SEC Approves PCAOB Reporting Rules

The SEC has approved PCAOB rules requiring registered public accounting firms to report certain events. The rules take effect Oct. 12. They implement a provision of the Sarbanes-Oxley Act of 2002 and are the first reporting obligations imposed on registered firms by the board.

Under the rules, certain events that occur on or after Oct. 12, 2009, must be reported on PCAOB Form 3 within 30 days after they occur. If certain events occurred between the time of a firm’s registration application and Oct. 12, the firm must report those events in a special report on Form 3 by Nov. 11. Qualifying events range from administrative matters such as changes in a firm’s contact information to more substantive matters, such as the institution of certain types of legal proceedings against a firm or its personnel.

Firms also must file annual reports on Form 2, with the first annual reports due June 30, 2010. Going forward, all firms that are registered with the board as of March 31 of a particular year must file an annual report covering the 12-month period ending March 31 by June 30 of that year. Annual reports should include information about audit reports issued, disciplinary histories of new personnel and certain information about fees billed to issuer audit clients for various categories of services, among other things.

All firms registered as of March 31 of a given year also must pay an annual fee by July 31 of that year. The amount of the fee has not been determined.

The rules also govern the filing of Form 4, an optional form that allows a firm to succeed to the registration status of a predecessor firm without a break in that registration status and without the need to file a new registration application on Form 1, in certain circumstances.

Forms 1, 2, 3 and 4 all must be filed electronically through the board’s Web-based system.

More information and links to detailed rules can be found on the board’s Web site at pcaob.org.