A Regulatory Budget for the Public Company Accounting Oversight Board


The Public Company Accounting Standards Board (PCAOB) was created by the Sarbanes–Oxley Act (SOX) in 2002 in response to the Enron and WorldCom auditing scandals. The PCAOB regulates the $20 billion annual auditing industry, which itself provides assurance for the financial integrity of $27 trillion in outstanding global publicly traded equity. The PCAOB is uniquely a quasi-private entity overseen by the Securities and Exchange Commission (SEC), which approves its budget and must approve any changes in its rules. The PCAOB has undertaken initiatives to attenuate the cost–benefit calculus of its rules, most notably in a change from Auditing Standard 2 to Auditing Standard 5, to reduce the compliance costs of auditor attestation of internal controls required by § 404(b) of the SOX. This Article provides the SEC with a regulatory budget rubric, crafted on similar models implemented in the United Kingdom and Canada, to help the SEC fulfill its oversight function over the PCAOB by tracking a regulatory budget for the PCAOB.