Statement on Amendments to Conform PCAOB Rules and Forms to the Dodd-Frank Act and Make Certain Updates and Clarifications

Mr. Chairman, I support the conforming rule amendments before us today.

These amendments would revise the Board's rules to reflect the authority provided to the Board under the Dodd-Frank Act related to the audits of brokers and dealers. In addition, other changes are being made to our rules based on the Board's administrative experience.

The principal effect of the Dodd-Frank Act was to give the Board the same regulatory authority over auditors of brokers and dealers that it has over auditors of issuers. The Board has adopted other rules related to the audits of brokers and dealers, including its temporary inspection rule, which has been in effect for several years, and the newly adopted attestation standards related to reports filed by brokers and dealers pursuant to Rule 17a-5 of the Securities Exchange Act of 1934. I support updating our rules to capture the Board's expanded authority.

I believe the amendments before us are not controversial. I would note, however, that while the Board initially proposed that auditors of brokers and dealers be prohibited from providing tax services to individuals in a financial reporting oversight role in brokers and dealers, the Board has opted not to adopt that prohibition at this time, with an understanding that we are committed to review this decision as we gather and analyze information about the independence issues involved. The Board feels it needs more data to analyze the impact on both the audit and broker-dealer community that would be affected. However, if under the Board's interim inspection program the provision of such tax services is viewed as impairing the independence of the auditors of brokers and dealers, I would support the imposition of a prohibition.

I want to join my fellow board members in thanking Nancy Doty and Vincent Meehan from our Office of General Counsel for their hard work on this project. I would also like to thank the staff members from our other Divisions and Offices that contributed to these amendments and the staff at the SEC for their suggestions and feedback on this project.

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