US Chamber Submission for PCAOB Release No. 2022-009; PCAOB Rulemaking Docket Matter No. 028

The Center for Capital Markets Competitiveness (“CCMC”) appreciates the opportunity to comment on the Public Company Accounting Oversight Board (“PCAOB” or the “Board”) Exposure Draft on The Auditor’s Use of Confirmation and Other Proposed Amendments to PCAOB Standards (the “Exposure Draft” or “Proposal”). The PCAOB’s existing confirmation standard was promulgated by the American Institute of Certified Public Accountants (“AICPA”) before the Sarbanes-Oxley Act of 2002 (“SOX”). In 2009, the Board issued a concept release on confirmations and, in 2010, the Board proposed a standard on confirmations, which was not acted upon.The proposal is now part of an aggressive effort by the Board to overhaul standards in a condensed timeframe. For example, the PCAOB is engaged in actively working to update more than twenty-five standards within eight standard-setting projects and apparently “is just getting started.”