The Public Company Accounting Oversight Board (PCAOB) on Tuesday issued its draft five-year strategic plan for public comment.
“The people we serve are top of mind in everything we do at the PCAOB, and we look forward to hearing from the public as we move forward with our ambitious plan to protect investors,” said PCAOB Chair Erica Williams in a press release.
Comments are due by Sept. 15.
The draft plan includes the PCAOB’s organizational priorities of investor protection, engagement, and adaptability, along with these four main goals:
Modernizing standards: The PCAOB’s near-term agenda includes a review of existing standards that might be outdated and adoption of new or amended ones to respond to areas of emerging risk, along with changes in financial reporting and the auditing profession. This goal includes adopting standards that improve audit quality and are clear and enforceable, so the board can ensure compliance through its inspections.
The objective is for standards to be scalable for different sizes of public companies and audit firms. Gary Gensler, chair of the Securities and Exchange Commission (SEC), last month called for the PCAOB to act quickly in this area, because it has historically been too slow in updating standards.
As part of this goal, the board intends to evaluate the need for updates to standards to address the greater use of technology by public companies and auditors. The PCAOB has received criticism for not having modernized auditing standards to keep pace with changes by both preparers and auditors in the use of data analytics and emerging technologies and to address the related risks.
Enhancing inspections: The draft plan states the PCAOB’s inspection process for public accounting firms is one of the board’s most important tools for protecting investors. This goal includes performing quality inspections of firms’ compliance with laws, rules, and standards; increasing the transparency, timeliness, and usefulness of inspection reports; and publishing guidance based on inspection observations of both deficiencies and good practices to improve audit quality.
The PCAOB further intends to place greater focus on firms’ efforts to remediate quality control criticisms and defects in their systems on a timely basis, along with publishing information about firms that have not remediated issues to the board’s satisfaction.
Strengthening enforcement: “Assertive enforcement and meaningful sanctions for those who violate the rules also deter wrongdoing,” the draft plan reads. Williams made clear in public remarks last month the PCAOB “means business” when it comes to “those who break the rules.”
To accomplish this goal, proposed activities include more assertive and rigorous enforcement actions for violations of standards, whether intentional or negligent; more significant penalties, suspensions, and other forms of relief; collaboration with other regulators, including the SEC and international counterparts, and concurrent enforcement actions against auditors and audit firms; and increased transparency about settled audit enforcement actions by naming names and providing penalty amounts to the public.
Improving organizational effectiveness: To achieve its mission and strategic objectives, the PCAOB intends to invest in its people, including employee retention and recruitment, and increase staff engagement through professional development, flexible work arrangements, and diversity and inclusion efforts. The organization also intends to improve its internal processes to “become more agile.”
The other aspect of this goal relates to enhancing stakeholder engagement. The board intends to “make external engagement an institutional capability and a program through which the PCAOB seeks and receives feedback from stakeholders and shares it story.” Stakeholders include investors, investor advocates, audit firms and auditors, audit committees, financial statement preparers, academics, Congress, and other regulators.
Historically, the PCAOB has not been known for communicating with financial statement preparers but instead has been focused more on their auditors and audit committees.
The board wants to maintain ongoing dialogue with these stakeholders and seek input for its standard-setting. It has established advisory groups and hired an investor advocate and an associate director of stakeholder relations. It intends to create an investor education program and provide more user-friendly information for investors.
In the past, the PCAOB has been criticized for its lack of innovation and for an inspection program that did not provide timely and useful feedback to audit firms to improve audit quality. After years of instability, the board has four of five new board members in place, including a new chairperson. The SEC has made clear the PCAOB’s strategy and activities are being closely watched.
Worth monitoring is whether the PCAOB receives significant comments on its draft plan and if the new board will achieve its overall vision of promoting “high-quality auditing through forward-looking, responsive, and innovative oversight.”