Audit Committee Disclosure: SEC Issues Concept Release Seeking Comment on Possible Revisions to Audit Committee Disclosure Requirements

Sullivan & Cromwell LLP - July 9, 2015

On July 1, 2015, the SEC issued a concept release seeking public comment regarding audit committee reporting requirements, including certain potential changes to disclosure requirements regarding the audit committee’s oversight of the independent auditor.  In the release, the SEC notes that there have been significant changes to the role and responsibilities of audit committees since the current disclosure requirements were adopted in 1999, and states that it is soliciting comment in response to recent public discussion regarding potential strengthening of audit committee disclosure, and in light of initiatives by the PCAOB and regulatory authorities in other jurisdictions.

The release invites comment on specific audit committee disclosure requirements in three primary areas:  the audit committee’s oversight of the auditor, the audit committee’s process for selecting or retaining the auditor and the audit committee’s consideration of the qualifications of the audit firm and the members of the auditor engagement team.  The SEC also seeks responses to general questions regarding existing audit committee disclosure requirements.

Comments must be received on or before September 8, 2015.