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Konig & Meyer Pro microphone boom stand- 210-2

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For example, proposed paragraph (f)(14)(i)(B) includes the investment adviser or sponsor of an investment company under audit. As the language in neither proposed paragraph (f)(14)(i)(B) nor proposed paragraph (F) includes a materiality requirement, under proposed paragraph (f)(14)(i)(F), an auditor would need to consider as part of its independence analysis, sister investment companies that have the same investment adviser or sponsor as the investment company under audit, regardless of whether such sister investment companies are material to the shared investment adviser or sponsor. Consistent with current paragraph (f)(14)(i)(C), we continue to believe that the nature of the relationship between an investment adviser or sponsor and the investment companies it advises is such that once an investment adviser or sponsor is included within the proposed ICC definition, the investment companies it advises should be included as well. Request for Comment

not obtained while a covered person in the firm) is consistent with the current provision in Rule 2–01(c)(1)(ii)(A)( Furthermore, the proposed amendment might positively influence audit quality and financial reporting quality through improved auditor-client alignment. [ 79]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] Currently, under Rule 2–01(c)(1)(ii)(A) (the “Loan Provision”), an accountant is not independent if the accounting firm, any covered person in the firm, or any of his or her immediate family members has any loans (including any margin loan) to or from an audit client, or certain other entities or persons related to the audit client. [ 34] We propose a technical amendment to convert the current Preliminary Note to Rule 2–01 into introductory text to Rule 2–01, as this is consistent with current

We believe that the proposed amendments would not duplicate, overlap or conflict with other Federal rules. F. Significant Alternatives We are proposing to except student loans obtained for a covered person's educational expenses that were not obtained while the covered person in the firm was a covered person. Should we adopt this new exception as proposed? Should we limit the proposed exception to student loans not obtained while the covered person in the firm was a covered person and to student loans obtained only for the individual's educational expenses ( We request comment on all aspects of our economic analysis, including the potential costs and benefits of the proposed amendments and alternatives thereto, and whether the rules, if adopted, would promote efficiency, competition, and capital formation or have an impact on investor protection. Commenters are requested to provide empirical data, estimation methodologies, and other factual support for their views, in particular, on costs and benefits estimates. IV. Paperwork Reduction Act A reduction in compliance costs also may be realized because of the potential larger pool of eligible auditors due to the proposed amendments. With a larger pool of eligible auditors, audit clients could potentially avoid costs associated with searching for an independent auditor and related costs resulting from switching from one audit firm toThe proposed amendment also would help avoid the costs that audit clients could incur to switch auditors. Additionally, the proposed amendment could reduce instances of lost revenues from non-audit services ( We request comment on whether our conclusion that the proposed amendments would not impose any new collections of information is correct. Controls: CH1-4 Gain, 2 Band EQ, Effect Send, MIC/Line Switch, CH5-6 Gain, Master 16 Digital Effect Section with Level, Master 2 Band EQ, Master Volume, Phantom Power. We understand from the staff's independence consultation experience that in certain instances an independence violation can arise as a result of a corporate event, such as a merger or acquisition, where the services or relationships that are the basis for the violation were not prohibited by applicable independence standards before the consummation of such corporate event. [ 49]

with the four largest audit firms auditing about 46 percent of all registrants. More specifically, the four largest audit firms audit about 75 percent of accelerated and large accelerated filers. [ 71] The proposed amendments to Rule 2–01 aim to reduce or remove certain practical challenges associated with the auditor independence analysis by focusing the analysis on those relationships and services that are more likely to pose a threat to an auditor's objectivity and impartiality. The proposed amendments are expected to expand the pool of eligible auditors and covered persons to undertake audit engagements without impairing auditors' independence. As a result, audit clients should have more options and audit costs may decrease. The potential expansion of eligible auditing service providers may also lead to better alignment between the audit client's needs and the auditor's expertise. The improved alignment between auditor specialties and audit clients could enable auditors to perform auditing services more efficiently and effectively, thus potentially reducing audit fees and increasing audit quality over the long term. Specifically, where an audit client is looking to potentially change auditors, an audit client would be able to select from a broader group of auditors to perform audit services related to the audit client's IPO even if the auditor had provided prohibited services or had prohibited relationships in the second or third year prior to filing the IPO. However, the audit industry is already highly concentrated, especially with respect to IPOs, [ 88] We recognize that adding an evaluation of materiality as proposed may result in additional work to be done by audit firms with ongoing monitoring responsibilities for the purposes of compliance with the

As discussed above, the primary reason for, and objective of, the proposed amendments is to update certain provisions within the Commission's auditor independence rules to more effectively focus the analysis on those relationships or services that are more likely to pose threats to an auditor's objectivity and impartiality. Specifically, the proposed amendments would:

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