backOn October 30, 2024, the PCAOB published a supplement to its November 18, 2013, Staff Guidance Concerning the Remediation Process which describes, among other things, the factors that the Division of Registration and Inspections staff applies when considering its recommendations to the Board about firms’ remedial actions. The supplement follows a February 2023 PCAOB Spotlight in which the staff noted whether its remediation guidance needed updating.
The new supplement does not change or supersede the prior guidance but provides firms with additional guidance based on the staff’s experience with making recommendations to the PCAOB concerning firms’ remedial efforts since 2013. Specifically, the supplement encourages firms to consider: (1) starting the remediation process sooner to take advantage of the full remediation period; (2) planning ahead in order to get the benefit of Inspections staff feedback; (3) implementing actions early enough to be able to monitor their operation and include in the submission evidence that they are effective; (4) considering whether certain quality control criticisms persist due to the influence of non-technical factors, such as a firm’s culture; and (5) understanding the limits of acceptable supplemental submissions after the submission deadline.