Statement on Consideration of Adopting Rules on Reporting by Registered Public Accounting Firms and on Succeeding to a Predecessor Firm's Registration Status

A motion has been made and seconded, so the question before the Board is whether to adopt the rules and form as presented to us today by staff.

As Michael Stevenson just outlined, the Board will consider a recommendation to adopt rules that, in certain circumstances, would allow a public accounting firm to succeed to the registration status of a predecessor firm.

Before moving forward, I would like to thank Michael Stevenson and Sarah Williams for their hard work on this project. As with our annual and special reporting rules adopted in June, this has been a particularly challenging project.

In a nutshell, the recommendation pertains to rules that, if adopted, would allow, in certain circumstances, a public accounting firm to succeed to the registration status of a predecessor firm, for example for the firm that survives a merger or other change in a registered firm’s legal form. As Michael noted, the rules would provide flexibility that is important given the serious implications of a firm operating without registration.

This recommendation makes good sense and I support it. I will now turn to my fellow Board Members for any discussion.