DISCUSSION OF: Economic Analysis of Proposed PCAOB Standards: Finding a Path Forward

Abstract

SYNOPSIS For organizing my discussant response, I use the “input-process-output-outcomes” framework, where the PCAOB is part of the standard-setting infrastructure (input), the processes are its standard-setting activities, the standards eventually developed and approved by the SEC (the output), and assessing the outcome(s) refers to evaluating how well the PCAOB is achieving its mission and vision. From this perspective, Nolder and Palmrose's (2018) critique of the PCAOB's standard-setting pace as being “glacial” can only be regarded an “operational criticism.” In fact, viewed in light of the recently released Monitoring Group's (2017) Consultation paper, the PCAOB actually appears to be ahead of the IAASB as a much more independent and active standard-setter. Expanding the PCAOB's “economic analysis” to incorporate behavioral disciplines could certainly make the rationale more grounded and stronger, but will likely further slow down the pace of standard-setting—a result that goes against the authors' preference. Beyond just behavioral approaches, I consider the even broader perspective of “political economy” in this context and highlight the relevance of Ashby's Law of Requisite Variety (Ashby 1956) as an overarching framework. Toward the end, I support certain arguments made by Nolder and Palmrose (2018), and in particular commend their suggestion that the PCAOB develop a conceptual framework for standard-setting going forward.