The Clearing House Association filed a comment letter with the PCAOB on its concept release on auditor independence and audit rotation. TCH opposes the requirement for mandatory audit firm rotation for the following reasons: (i) a company’s Audit Committee is best suited to evaluate whether reappointment of the existing audit firm is appropriate; (ii) the potential downside risks of the concept release would be significant because mandatory rotation would inhibit the ability of audit firms to develop and maintain specialized industry expertise; (iii) there is no clear evidence that mandatory audit firm rotation would enhance auditor independence; (iv) the concept release would likely increase the duration and cost of audits significantly; and (v) many recent improvements that have been made to the audit process have had a positive impact on auditor independence.