SYNOPSIS

This commentary reflects my experiences with the U.S. Securities and Exchange Commission (SEC) during the academic year 2000/2001 (Academic Fellow) and the two calendar years 2004–2005 (Deputy Chief Accountant [Professional Practice]). These comments reflect only my thoughts without citations in support of or contrary to those thoughts and resulting opinions. The topics covered in this commentary include: (1) early staff relations between the PCAOB and SEC in their respective roles of audit standard setter and oversight agency; (2) the PCAOB decision to act as the sole audit standard setter for registered public companies displacing the AICPA in this role; (3) the PCAOB's approach to “revising” the interim audit standards through Rule 3101, Certain Terms Used in Auditing and Related Professional Practice Standards; (4) Audit Standard 3 (AS3), Audit Documentation; and (5) Audit Standard 2 (AS2), An Audit of Internal Control over Financial Reporting Performed in Conjunction With an Audit of Financial Statements. I will also comment on several observations made by others concerning the competence of PCAOB staff and the PCAOB Board members to set audit standards and perform meaningful inspections. I conclude with a brief note on the international aspects of PCAOB actions during this period.

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