Thank you, Chair Gensler, and thank you to the staff for your presentation. The second item on today’s agenda is a new auditing standard on the general responsibilities of the auditor in conducting an audit.
AS 1000 is intended to set the foundational standards that apply to audits, including reasonable assurance, due professional care, professional skepticism, independence, competence, and professional judgment.[1] Given that these “foundational” standards had been adopted on an interim basis shortly after the PCAOB’s creation over two decades ago, a set of final standards is long overdue.
Commenters raised several concerns about the proposal for AS 1000, including whether the new standard imposed a new legal duty on auditors[2] and whether statements in the proposal relating to the auditor’s judgment concerning fair presentation expanded an auditor’s responsibilities or created conflicts.[3] The PCAOB appears to have addressed these concerns, as noted by some Board members when approving the standard[4] and by market participants that submitted letters to the Commission in support of the standard.[5]
Because of the PCAOB’s efforts to address commenters’ concerns, as well as market participants’ general approval for AS 1000, I support the new standard. I thank the PCAOB’s members and staff and the Commission staff, especially those from the Office of the Chief Accountant and the Office of the General Counsel.
[1] See General Responsibilities of the Auditor in Conducting an Audit and Amendments to PCAOB Standards, PCAOB Release No. 2024-004 (May 13, 2024) at p.11, available at https://assets.pcaobus.org/pcaob-dev/docs/default-source/rulemaking/docket-049/2024-004-as1000.pdf?sfvrsn=3ba6358a_2.
[2] Id. at p.18.
[3] Id. at p.51.
[4] See Statement by Erica Y. Williams (May 13, 2024), available at https://pcaobus.org/news-events/speeches/speech-detail/chair-williams--statement-on-new-standard-on-general-responsibilities-of-the-auditor, and Statement by Christina Ho (May 13, 2024), available at https://pcaobus.org/news-events/speeches/speech-detail/statement-on-the-as-1000-adoption--refreshed-general-auditor-responsibilities.
[5] See Letter from Center for Audit Quality (July 2, 2024), available at https://www.sec.gov/comments/pcaob-2024-01/pcaob202401-487751-1391794.pdf, and Letter from Deloitte & Touche LLP (June 28, 2024), available at https://www.sec.gov/comments/pcaob-2024-01/pcaob202401-486031-1389134.pdf.