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Progress in Meeting Rule 4003(g) Thresholds (current as of June 30, 2012) 

The Board is providing additional information here about the PCAOB’s progress in meeting the target thresholds that it announced in adopting Rule 4003(g), which permits the Board to defer, for up to three years, the first inspection of 49 non-U.S. firms that were otherwise required to be inspected in 2009. In adopting that rule, the Board stated that:

  • it intended to inspect at least four of those firms in 2009 and that the four firms would have combined issuer audit-client U.S. market capitalization equal to at least 35 percent of the aggregate U.S. market capitalization of the audit clients of all firms meeting the Rule 4003(g) criteria for deferral. 
  • for 2010, it intended to inspect at least eleven more firms, and that the firms inspected in 2009 and 2010 would have combined issuer audit-client U.S. market capitalization equal to at least 90 percent of the aggregate U.S. market capitalization of the audit clients of all firms meeting the Rule 4003(g) criteria for deferral. 
  • for 2011 it intended to inspect at least fourteen additional firms and that the firms inspected in 2009 through 2011 would have combined issuer audit-client U.S. market capitalization equal to at least 99.9 percent of the aggregate U.S. market capitalization of the audit clients of all firms meeting the Rule 4003(g) criteria for deferral; and
  • the Board would inspect the remaining firms in 2012.

As of June 30, 2012, the PCAOB had inspected six firms eligible for deferral pursuant to Rule 4003(g), including one firm inspected in the period from January 1, 2012 to June 30, 2012.  The combined market capitalization of the clients of those six inspected firms equaled 20 percent of the aggregate market capitalization of the audit clients of all firms meeting the Rule 4003(g) criteria for deferral.**

**A previous update had reported that as of December 31, 2011, the PCAOB had inspected six firms that met the Rule 4003(g) criteria for deferral.  It has since been determined that this count included the inspection of one firm that was not subject to, or deferred pursuant to, Rule 4003(g).  That firm had no audit clients with U.S. market capitalization (the inspection included a review of referred work in an audit in which the firm played a role) and, therefore, excluding that inspection from the count has no effect on the combined market capitalization figure reported here.