The Clearing House Association, along with multiple other trade associations, filed a comment letter with the PCAOB opposing the requirement for mandatory audit firm rotation for the following reasons: (i) PCAOB’s failure to present supporting evidence for mandatory audit firm rotation, (ii) the potential harm to overall corporate governance by reducing audit quality, diminishing the role of the audit committees and increasing the incidence of undetected fraud, and (iii) the increase in costs and disruption to U.S. capital markets.