August 27, 2007
NASBA’s comments to the Public Company Accounting Oversight Board (Board) on the Proposed Ethics and Independence Rule 3526, Communicating with Audit Committees Concerning Independence, Proposed Amendment to Rule 3523, Tax Services for Persons in Financial Reporting Oversight Roles and Implementation Schedule for Rule 3523 (Proposal). The National Association of State Boards of Accountancy’s (NASBA) goal is to increase the effectiveness of State Boards of Accountancy.
The Board is proposing to amend Rule 3523 to exclude the portion of the audit period that precedes the professional engagement period from the scope of Rule 3523. The Committee believes that an enterprise should have the widest possible selection of registered public accounting firms (registered firms) if and when the enterprise decides to change auditors. The Committee also believes that independence of the registered firm selected will not be impaired if the Board adopts its proposal to amend Rule 3523. The Committee supports the Board’s proposal.
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