ACTION REQUESTED
[15823]
March 28, 2003
TO: ACCOUNTING/TREASURERS COMMITTEE No. 15-03
CLOSED-END INVESTMENT COMPANY COMMITTEE No. 22-03
SEC RULES COMMITTEE No. 31-03
UNIT INVESTMENT TRUST COMMITTEE No. 10-03
RE: ICI DRAFT LETTER ON PCAOB ACCOUNTING SUPPORT FEE PROPOSAL
The Institute has drafted a comment letter regarding the Public Company Accounting
Oversight Board’s proposal to establish annual accounting support fees to cover the funding
costs of the Board’s operations, as required by the Sarbanes-Oxley Act of 2002. The draft letter
is attached, and it is summarized below.
Comments on the Board’s proposal are due by Friday, April 4, 2003. If you have
comments on the letter, please provide them to Greg Smith by Wednesday, April 2, 2003. Greg
can be reached by phone at (202) 326-5851, by fax at (202) 326-8314, or by email at
smith@ici.org.
The Institute’s draft letter supports the Board’s proposal, which would allocate the cost
of funding the Board’s operations into two classes of issuers – publicly-traded companies and
investment companies. The letter specifically supports the proposal to assess a lower fee on
investment companies than on operating companies in recognition of the investment company
structure and the relatively less-complex nature of investment company audits (as compared to
operating company audits). The letter also supports the proposal to assess investment
companies fees at a rate of ten percent of that assessed publicly-traded companies. The letter
explains that the relative amount of audit fees paid by issuers is an appropriate indicator of the
complexity and risk associated with an audit, and provides a sound basis for estimating the
amount of time and resources the Board will likely devote to different classes of issuers.
Barry E. Simmons
Associate Counsel
Attachment (in .pdf format)