PCAOB Revises Effective Date of Rules Requiring Reporting by Registered Firms

The PCAOB postponed the effective date for registered public accounting firms required to report under its new rules to Dec. 31, 2009, from the previous date of Oct. 12, in order to resolve technical issues related to deploying the board’s new Web-based system for processing and publishing filings on the new forms, according to a news release.

Forms 1 2, 3 and 4 must be filed electronically through that system. 

The postponement will not affect the timing of the first annual reports required from registered firms, which will still be due on June 30, 2010, for the 12-month period ending March 31, 2010.

Under the new rules, approved by the SEC on Aug. 13, 2009, certain events— ranging from administrative matters such as changes in a firm’s contact information to more substantive matters, including certain types of legal proceedings against a firm or its personnel—that occur on or after the Dec. 31 effective date must be reported by a registered firm in a special report on PCAOB Form 3 within 30 days after the event.

If certain events occurred between the time of a firm’s registration application and the Dec. 31 effective date, a firm must report those events in a special report on Form 3 within 30 days after the Dec. 31 effective date.

The rules also govern the filing of Form 4, an optional form that allows for 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. That form must be filed by Jan. 14, 2010.

The revised effective date does not affect the deadline for firms’ annual reports on Form 2. Beginning in 2010, 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. That date did not change, and the amount of the fee has not been determined.

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