Today, I announced my intention to conclude my tenure at the PCAOB. I am grateful to the Commission for this appointment and to the nearly 800 talented and dedicated staff of the PCAOB who work to oversee the audits of public companies and broker-dealers.
During my tenure on the Board, I have called for increased transparency and public accountability at the PCAOB in order to enhance investor trust and confidence in the capital markets.
My policy priorities included:
- Renewing the PCAOB’s Investor Advisory Group (IAG), a forum to obtain the views and advice of investor protection experts, with mandated regular public meetings;
- Publishing the calendars and meetings by Board Members with third parties, including audit firms;
- Mandating notice and comment by the Board prior to the adoption of auditing standards or other rulemaking (similar to the obligations under the Administrative Procedure Act for federal agencies);
- Establishing a mechanism for investors and the public to petition the PCAOB to change standards or rules and the posting of comment letters received on the petition (similar to the obligations under the Administrative Procedure Act for federal agencies);
- Publishing Board Members’ votes, to the extent permitted under the statute, taken at official meetings (similar to the obligations for Federal Agencies);
- Establishing an Office of Investor Advocate and annually reporting to the SEC and Congress on how the PCOAB addressed the needs and perspectives of investors (similar to the statutory obligations for the SEC);
- Increasing the timeliness and relevancy of information provided to investors and the public in PCAOB inspection reports and PCAOB enforcement actions;
- Increasing the quality and usefulness of the information provided to investors and the public with respect to the remediation of audit firm quality control deficiencies identified by the PCAOB inspections staff;
- Expanding the academic fellowship program at the PCAOB to provide increased access to non-public data to researchers in order to provide the public with greater insight into matters relating to audit quality; and
- Ensuring that audit committees receive from audit firms the information necessary to facilitate timely and appropriate oversight of the audit process, including information to evaluate an audit firm’s independence.
Likewise, I advocated for the PCAOB to commit to the reevaluation of an auditor’s responsibilities and obligations with regard to quality of information disclosed by public companies outside of the financial statements (sometimes referred to as “other information”), including environmental, social and governance (ESG), sustainability and non-GAAP disclosures and for the need for the PCAOB to develop structures that would allow for real time feedback to audit firms, particularly with respect to the quality and sufficiency of auditors’ disclosure of critical audit matters.
With respect to the audit profession, I called on audit firms to proactively increase their interaction with the investor community and to address and respond to investors’ expectations, including the need to address the profession’s continued relevancy to the capital markets and to adopt structural protections to drive continuous improvement in audit quality.
Finally, I benefited at the PCAOB from a skilled and dedicated staff committed to the investor protection mission. I made it a priority to help strengthen this culture, and I strongly supported efforts towards diversity and inclusion, advocating for the establishment of an Office of Minority and Women Inclusion, which is statutorily mandated for many financial regulators.