Request for Comments on the Review of Independence Provisions for Auditors

June 14, 2010

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Request for Comments on the Review of Independence Provisions for Auditors

Letter Summary:

The CAC support convergence of regulatory and accounting standards, but to the higher standard. We believe that requiring rotation every 7 years with a 2 year “time out” is effectively no standard at all. We strongly encourage the CICA to reconsider convergence to rules that provide less protect to investors.

Overview of the Council’s Comments:

The CAC does support a one-time temporary extension of the terms for audit partners and reviewers that would normally end in the years 2010 to 2011 (2 years extension) to facilitate the transition to IFRS for public companies. The CAC also support the express application of independence rules to mutual funds that might not automatically be considered to be “publicly accountable”.