May 31, 2019
PCAOB Rule 3526, Communication with Audit Committees Concerning Independence provides, among other things, that a registered public accounting firm must, at least annually with respect to each of its audit clients:
(1) describe in writing to the audit committee all relationships between the audit firm and the audit client that, as of the date of the communication, may reasonably be thought to bear on independence;
(2) discuss with the audit committee the potential effects of those relationships on the independence of the audit firm; and
(3) affirm to the audit committee in writing that, as of the date of the communication, the firm is independent in compliance with PCAOB Rule 3520, Auditor Independence.
Inspection observations have identified situations that raise questions about how firms are executing against the provisions of PCAOB Rule 3526 in circumstances in which there has been a relationship that caused a firm not to be independent under PCAOB Rule 3520. Staff considerations include observations from PCAOB oversight activities, relevant research, and outreach.