ASA Urges PCAOB to Address Outstanding Questions Before Finalizing Broker-Dealer Auditor Inspection Program

WASHINGTON – The American Securities Association (ASA) today submitted a comment letter to the Public Company Accounting Oversight Board (PCAOB or the Board) on the Board's Draft 2026-2030 Strategic Plan Goals and Objectives.. The letter focuses on Objective 2.4, which would establish a permanent inspection program for broker-dealer auditors.

"Investors are best served by an inspection program that is proportionate to actual risk," said ASA Chief Legal Officer Jessica Giroux. "A small firm that never touches a customer's money shouldn't be reviewed the same way as a firm that holds their assets. We're asking the Board to define those limits before the rules are locked in, and to work with the SEC and FINRA so firms aren't juggling overlapping demands from multiple regulators."

ASA's letter urges the Board to:

• Define the risk factors, including custody of customer assets and business line complexity, that will govern inspection scope, frequency, and depth

• Publish a cost-benefit analysis before finalizing the program, given the disproportionate impact of fixed compliance costs on smaller audit practices

• Consult with the SEC and FINRA and obtain their concurrence on scope, timing, and information-sharing protocols before adopting or materially revising the program

• Engage directly with trade associations representing affected firms and auditors, separate from the general strategic plan comment process

• Open a further, program-specific comment period and provide a phase-in period before any final program takes effect
  

ASA's letter notes that the Board has operated an interim inspection program under authority granted by the 2010 Dodd-Frank Act, and asks that any move to a permanent program be preceded by additional public input given the open questions the Draft Plan raises. To read the full letter, click here.

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The American Securities Association (ASA) represents the retail and institutional capital markets interests of regional financial services firms who provide Main Street businesses with access to capital and advise hardworking Americans how to create and preserve wealth. ASA’s mission is to promote trust and confidence among investors, facilitate capital formation, and support efficient and competitively balanced capital markets. This mission advances financial independence, stimulates job creation, and increases prosperity. The ASA has a geographically diverse membership of almost one hundred members that spans the Heartland, Southwest, Southeast, Atlantic, and Pacific Northwest regions of the United States.