The proposed amendments to except certain student and consumer loans that are less likely to raise threats to auditors' objectivity or impartiality may alleviate some compliance burdens. For instance, audit firms would no longer have to monitor such student and consumer loans as part of their compliance program. The proposed amendments would permit certain covered persons (including audit partners and staff) to be considered independent notwithstanding the existence of certain lending relationships, such as student loans or consumer loans. The potential expansion of qualified audit partners and staff may allow audit firms to more readily identify audit partners and staff for a given audit engagement and improve matching between partner and staff experience with audit engagements. The improved alignment between partner and staff experience and audit engagements can increase audit efficiency and reduce audit costs. Such efficiency gains may transfer to audit clients in the form of reduced audit fees and audit delays. We understand that it is more common today for companies to enter into multi-company arrangements in delivering products or services and that audit firms may contribute to such multi-company arrangements, such as through intellectual property or access to data using common technology platforms. Do these arrangements present instances where an auditor's objectivity and impartiality would not be impaired even after considering the proposed amendments discussed in this release? If so, what further amendments should be considered to appropriately focus on relationships where it is more likely an auditor's objectivity and impartiality would be impaired? This proposed amendment might also expand the pool of eligible auditors for domestic first time filers. The potential increase in the number of eligible auditors for these filers could foster competition among eligible auditors and thus reduce the cost of audit services. [ 87] However, the auditor market is highly concentrated, and such cost savings are likely to be limited. The expanded pool of qualified auditors also might improve matching between auditor expertise and audit task, thereby improving audit efficiency and reducing audit costs. [ 78]

We propose to add student loans obtained from a financial institution under its normal lending procedures, terms, and requirements for a covered person's educational expenses provided the loan was obtained by the individual prior to becoming a covered person in the firm as defined under Rule 2–01(f)(11). The limitation on the student loan exclusion ( Compliance with the proposed amendments would require the use of professional skills, including accounting and legal skills. The proposed amendments are discussed in detail in Section II above. We discuss the economic impact, including the estimated costs, of the proposed amendments in Section III (Economic Analysis) above. E. Duplicative, Overlapping, or Conflicting Federal Rules we believe the proposed amendments provide a useful update to the ICC definition that was adopted in 2000. Specifically, we believe the proposed amendments provide clarity for unregistered funds, their investment advisers or sponsors, and their auditors. In addition to this clarity, defining investment company to include unregistered funds would promote consistency in the application of Rule 2–01 to registered investment companies and unregistered funds so that these two types of audit clients, which share some similar characteristics, would not be subject to

Reduce 210/2 to lowest terms

Recognizing that not all creditor or debtor relationships threaten an auditor's objectivity and impartiality, the Commission included in Rule 2–01(c)(1)(ii)(A) a list of loans that are excepted from the prohibition. Under the current rule, the following loans from a financial institution under its normal lending procedures, terms, and requirements are excepted from the prohibition: The clarification, consolidation or simplification of compliance and reporting requirements under the rule for small entities; We are proposing to align the common control prong of the proposed ICC definition (proposed Rule 2–01(f)(14)(i)(D)) with the proposed common control prong for operating companies (proposed Rule 2–01(f)(4)(i)(B)), for the same reasons we discuss in Section II.A.1.a. As a result, proposed paragraph (f)(14)(i)(D)( Connect to a euro connecting TIG torch to make use of the machines automatic shielding gas system with adjustable post gas and downslope.

The proposed amendments are likely to benefit investors indirectly. First, the potentially expanded auditor choices under the proposed amendment might improve audit quality through better matching between auditor expertise and audit engagement, thus potentially enhancing financial reporting quality. [ 80] The proposed amendments deemphasize relationships and services that are unlikely to threaten auditor objectivity and impartiality, thus allowing auditors and audit clients to focus on those relationships and services that are more likely to threaten the auditor's objectivity and impartiality. To the extent that the proposed amendments do so, the quality of financial reporting is likely to improve, and the amount of audit client audit committee attention to independence questions when objectivity and impartiality is not at issue will be reduced, thus allowing the board to focus on its other responsibilities. Furthermore, we expect that improved identification of threats to auditor independence would increase investor confidence about the quality and accuracy of the information reported. Reduced uncertainty about the quality and accuracy of financial reporting should attract capital and thus reduce cost of capital, facilitate capital formation and improve overall market efficiency. [ 97] audit committee and underwriters) in place at first time filers, and auditors are subject to heightened litigation risk around IPOs. [ 90] c. Proposed Amendments to Loans or Debtor-Creditor Relationships Should we make the miscellaneous updates described above? Are there other conforming amendments we should make in light of these updates? III. Economic Analysis A. Introduction iv) limiting the mortgage exclusion to mortgage loans “not obtained while the covered person in the firm was a covered person,” and provides a familiar principle for compliance purposes.

Pair Factors of 210

independent. Under this analysis, pursuant to Rule 2–01(b), the “Commission will not recognize an accountant as independent, with respect to an audit client, if the accountant is not, or a reasonable investor with knowledge of all relevant facts and circumstances would conclude that the accountant is not, capable of exercising objective and impartial judgment on all issues encompassed within the accountant's engagement.” Rule 2–01(b) further states that the “Commission will consider all relevant circumstances, including all relationships between the accountant and the audit client,” in determining whether an auditor is independent. Rule 2–01(c) then sets forth a nonexclusive list of particular circumstances that the Commission considers to be inconsistent with the independence standard in Rule 2–01(b), including certain financial, employment, business, and non-audit service relationships between an accountant and its audit client. [ 5] Currently, certain aspects of Rule 2–01 require auditor independence compliance during the audit and professional engagement period, which may include periods before, during, and after merger and acquisition transactions. As a result, certain merger and acquisition transactions could give rise to inadvertent violations of auditor independence requirements. For example, an auditor may provide management functions to a target firm and auditing services to an acquirer prior to the occurrence of an acquisition. As a result, the acquisition may result in an auditor independence violation that had not existed prior to the acquisition. In this scenario, the auditor's objectivity and impartiality is likely not impaired. [ 96] The proposed amendments would not impose any reporting, recordkeeping, or disclosure requirements. The proposed amendments would impose new compliance requirements with respect to Rule 2–01.

In the private equity and investment company context, where there potentially is a significant volume of acquisitions and dispositions of unrelated portfolio companies, [ 16] i) With respect to the proposed amendment adding a merger and acquisition transition framework, there would be a new compliance burden only if the auditor and its client seek to avail themselves of the framework. As such, any additional compliance effort would be offset in any circumstance where relationships and services prohibited under the current rule would be deemed not to impair independence under the proposed amendments. On August 17, 2018, the Commission updated a number of rules as part of its disclosure effectiveness initiative. [ 56]

Examples of Long Division Calculations

We estimate, as June 30, 2019, that there are approximately 470 investment advisers that would be subject to the proposed amendments that may be considered small entities. [ 110]