PCAOB seeks comment on proposed quality control amendments

The PCAOB issued for public comment a supplemental release regarding narrow, targeted proposed amendments to QC 1000, A Firm’s System of Quality Control, and related amendments to PCAOB forms and the QC reporting rule.

The comment deadline is July 9.

The amendments, according to a news release, are intended to improve coherence, where appropriate, with other quality management standards and potentially reduce compliance costs without compromising the PCAOB’s statutory mission to protect investors and further the public interest in the preparation of informative, accurate, and independent audit reports.

“As we evaluate potential refinements to QC 1000, our goal is to produce a rigorous, clear, and consistent framework while ensuring that implementation is scalable, efficient, cost-effective, and contributes to audit quality,” PCAOB Chair Demetrios Logothetis said in the release. “QC 1000 is a foundational standard for protecting investors and improving audit quality, and the PCAOB is committed to getting this right.”

The proposed amendments to QC 1000 would:

• Rescind the “design-only” requirement so that QC 1000 imposes requirements only on firms that are required to comply with applicable professional and legal requirements with respect to any “engagement”;

• Provide increased flexibility in filling certain specified roles in the QC system, including permitting roles to be assigned to nonfirm personnel and divided among multiple individuals;

• Rescind the requirement for the firms with the largest PCAOB audit practices to have an external QC function;

• Narrow and simplify communication requirements relating to metrics that the firm communicates about its audit practice, firm personnel, or its engagements;

• With respect to identified engagement deficiencies, require evaluation of whether similar engagement deficiencies exist only if the identified deficiency could result in (1) a failure to obtain sufficient appropriate audit evidence to support the conclusion reached on an engagement or (2) an inappropriate overall conclusion on the subject matter of an engagement;

• Revise the definition of QC deficiency to make clear that, when firms have implemented more than one quality response to address the same quality risk, they can take those other quality responses (e.g., compensating responses) into account when determining whether a QC deficiency exists;

• Allow firms to select the date as of which they annually evaluate the effectiveness of their QC system, rather than requiring firms to evaluate as of Sept. 30;

• Revise the QC system evaluation conclusions to align more closely with the conclusions in other quality management standards, while retaining a structured process, including specified factors for consideration to guide the evaluation; and

• Simplify the requirements for retention of QC system documentation and abbreviate the retention period from seven to five years.

QC 1000 is scheduled to take effect on Dec. 15. The PCAOB has not extended that effective date in connection with this proposal.

— To comment on this article or to suggest an idea for another article, contact Kevin Brewer at Kevin.Brewer@aicpa-cima.com.