Key takeaways

• Under the Exchange Act, the audit committee of a listed company or a company otherwise required to file SEC reports is directly responsible for oversight of the company’s auditor.
• The Public Company Accounting Oversight Board ("PCAOB") has published a release proposing four questions about PCAOB inspections that audit committees of SEC registrants may want to ask their audit firms – including advice for audit committees about audit firm responses that should be viewed with skepticism.
• According to the PCAOB, while some audit committees report that their audit firms provide helpful information about PCAOB inspections, other audit committees have told the PCAOB that "their auditors decline to discuss their PCAOB inspection results with them or downplay the results of any adverse findings that may be included in the report."