Statement in Support of the Proposed Auditing Standard – General Responsibilities of the Auditor in Conducting an Audit and Proposed Amendments to the PCAOB Standards

Remarks as prepared for delivery

Thank you, Chair Williams. Today, the PCAOB is releasing a new proposed auditing standard, AS 1000, General Responsibilities in Conducting an Audit and Proposed Amendments to the PCAOB Standards, which replaces five AICPA standards that the PCAOB adopted on an interim basis in 2003. One of the priorities of this Board is to update the interim standards. Many of the principles are still relevant and therefore may not require substantial changes. Nonetheless, this process of updating interim standards adopted 20 years ago allows us to collect timely input from our stakeholders. Most importantly the process instills trust in the PCAOB standards, as well as audits conducted using our standards.

This proposed standard adds a new requirement to accelerate the archival deadline of audit documentation from a maximum of 45 days to 14 days. I am especially interested in reading comment letters from small/medium registered firms and emerging growth companies (EGCs) responding to the list of questions, and in particular, questions on whether the proposed amendment to accelerate uniformly for all firms, regardless of size, the documentation completion date is appropriate. I am also interested in reading any comments on: (1) our assumptions that the use of electronic workpapers enables auditors to assemble a final set of audit documentation in less time; and (2) the significance of the perceived benefits to investors.

The proposed release represents an incremental step forward in the PCAOB’s standard setting agenda. But we still have much work ahead of us, particularly in leveraging data and technology to further the public interest mission of the PCAOB. I cannot emphasize enough that the PCAOB, as a standard-setter, must have a bold vision – a vision that is forward-looking and focused on adapting our auditing standards to fit not only current uses of technology but also future uses of emerging technologies to increase audit quality and investor protection. Recent turbulence affecting our financial institutions and our financial markets bolster my view that the PCAOB must strive to “look around corners” by making better use of the data we collect and unlocking its value. 

I support the release of the proposed AS 1000 standard for public comment, and I thank the team that worked on this initiative, including Barbara Vanich, Jessica Watts, Dominika Taraszkiewicz, Hunter Jones, Ekaterina Dizna, Akiko Upchurch, Michael Gurbutt, John Cook and Dylan Rassier. I’d also like to thank the Division of Registration and Inspections and the Office of General Counsel for their respective contributions to this proposed standard.  

Thank you.