Statement on the Adoption of the Reorganization of PCAOB Auditing Standards

Good Morning,

I would like to join my fellow Board members in thanking the staff of the Office of the Chief Auditor, Office of Information Technology and the Office of General Counsel, for their thoughtful and thorough work on this project. This was a project that required a lot of careful attention to detail but comes with little fanfare, and I appreciate the staff's diligence.

As Marty and his staff have clearly explained — and I won't repeat the details — this new organization is intended to provide standards in the order in which they usually apply to an audit. It is our hope that this framework will provide a more user-friendly and logical framework for all PCAOB Auditing Standards — including the interim AICPA standards adopted by the Board in 2003. I also believe that the tables which cross-reference our standards to those of the International Auditing and Assurance Standards Board and the Auditing Standards Board of the AICPA create a helpful resource for auditors who operate in multiple jurisdictions.

There are several important issues, however, that this project did not tackle. For example, this project did not involve redrafting the auditing standards or making substantive changes to any audit requirements. As the Board explained early on in its existence, we intend to review all of the interim standards adopted by the Board in 2003. We are currently working on several of these standards and will take up others as circumstances dictate and resources allow. As I noted two years ago when we proposed this reorganization, this work will take time. I am hopeful, however, that the ongoing review of our standard setting process and any efficiencies we may gain will help us complete this task.

This project also did not amend any of the auditing standards for references to generally accepted accounting principles ("GAAP") or other requirements not issued by the PCAOB that may have been superseded or eliminated since the standards were originally drafted. In some cases, these references would be relatively easy to eliminate or to replace with current citations; in others, updating the GAAP reference may require a substantive amendment to the auditing requirements. Because tackling that work would require resources that we believe currently are better spent on substantive standard setting projects, the Board has decided that, for now, we will address any necessary GAAP references on a case-by-case basis when we amend our standards as part of other projects. Nevertheless, I continue to urge the staff to consider when and how we might be able to complete this task more efficiently.

Finally, we are retaining the existing guidance on the interim auditing standards, including a variety of interpretations and guidance issued by the AICPA, though we are presenting them on our website separately from the standards themselves. What we have not yet done is organize guidance that the Board has issued during the past decade, including in its adopting releases and staff audit practice alerts, to make it more accessible to auditors. I hope that this work we can begin in 2015.

Again, I would like to thank our staff, as well as the staff of the SEC, for their thoughtful work and valuable insights.