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TCH Comments on PCAOB Revisions to Auditor’s Report

The Clearing House Association submitted a comment letter to the PCAOB regarding their Rulemaking Docket Matter No. 34, a proposal to revise the Auditor’s Report. TCH does not support the revisions, which propose to add a discussion of critical audit matters (CAM) and a requirement for the auditor to evaluate other information in the Auditor’s report. TCH believes that the discussion of CAMs may create confusion as such information has historically come from management rather than originating with the auditors. Similarly, TCH believes that the addition of the evaluation of other information is unnecessary due to existing management certification requirements, and also will be challenging for auditors to develop and perform audit procedures on forward-looking information.