Statement on the Proposed 2026-2030 Strategic Plan

Remarks as prepared for delivery 

Thank you, Mr. Chairman.

Today, the PCAOB publishes its proposed 2026-2030 Strategic Plan for public comment. While some of the words are new, the PCAOB’s direction under Chairman Logothetis has been clear. We will listen more to our stakeholders, focus our inspections more on quality control systems, and re-focus our enforcement resources to significant violations that pose risks to investors, audit integrity, and U.S. capital markets. We will also modernize by making better use of technology and data, investing in our staff, and finding ways to deliver greater value at lower cost. These and other objectives make up our proposed plan.

I draw your attention in particular to Objective 3.2, Clarify Enforcement Principles and Priorities, and Strengthen SEC Coordination, which could have an outsized impact on investor protection. As I mentioned, in the next few years we intend to focus our enforcement resources on violations that present the most risk. We will need to work closely with the SEC on this objective, especially since the SEC reportedly is building its own capacity to investigate significant audit deficiencies, independence failures, and noncompliance with professional standards. We will need new administrative protocols with the SEC to support these efforts.

I believe the SEC’s different legal authorities give them advantages in enforcement cases over the PCAOB.  I have great respect for the PCAOB Enforcement staff, but the Sarbanes-Oxley Act of 2002, as amended, limits the PCAOB’s ability to get bad actors off the street quickly. Partly, this is because registered firms and associated persons can seek SEC review of “any disciplinary action of the Board,” which stays the Board’s decision until the Commission orders otherwise.¹ We know there will be cases where the SEC’s legal authority to act more nimbly will better protect investors, and where the PCAOB can best fulfill its mission by supporting the SEC. Needless to say, it will be critical that any protocols we develop under Objective 3.2 let nothing fall through the cracks.

In sum, I believe that the proposed 2026-2030 Strategic Plan keeps faith with our mission to protect investors by improving audit quality. I invite you to contribute your ideas on the plan’s goals and objectives.

I want to thank the Chairman and his staff for their leadership and collaboration on this proposed strategic plan, my fellow Board Members, and the PCAOB’s professional staff for their tireless work.

Back to you, Mr. Chairman.