Letter to the PCAOB on the Request for Public Comment re: Strategic Plan Goals and Objectives

To Whom It May Concern:

The American Bankers Association (ABA) welcomes the opportunity to comment on the Public Company Accounting Oversight Board's (PCAOB) Request for Public Comment on the Draft 2026–2030 Strategic Plan Goals and Objectives (PCAOB Release No. 2026-006) (the Request). The Request seeks input on the PCAOB's proposed strategic direction, which includes goals to modernize standard setting and implementation, modernize inspections and registration, sharpen enforcement focus, deepen stakeholder engagement and communications, modernize oversight through technology and data, and strengthen organizational effectiveness and stewardship.

Executive Summary

• The PCAOB should also emphasize proportionality: ABA supports the PCAOB's effort to update its strategic plan around modernization, clarity, technology and stakeholder engagement. To be effective, however, the final plan should make proportionality, scalability and cost-benefit discipline explicit across the PCAOB’s objectives. Proportionality is particularly important for community banks because disproportionate audit and oversight expectations can increase costs, reduce auditor availability and divert limited resources from serving customers and local communities without commensurate investor-protection benefits. For banks, which already operate under extensive prudential supervision, examinations and regulatory reporting, PCAOB oversight should recognize how that framework affects audit risk assessment and avoid expectations that effectively duplicate existing regulatory requirements or layer on procedures that do not improve audit quality.

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