Konig & Meyer Pro microphone boom stand- 210-2

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not obtained while a covered person in the firm) is consistent with the current provision in Rule 2–01(c)(1)(ii)(A)( the improved financial reporting quality under the proposed amendments also would benefit audit clients as the higher quality of financial reporting could potentially reduce information asymmetry between auditors and their investors, improve firms' liquidity and decrease cost of capital. [ 74]

We do not anticipate significant incremental costs associated with the proposed amendments to the ICC definition for registered investment companies, unregistered funds, investment advisers or sponsors, or auditors as well as investment company investors. The proposed amendments may require additional effort from audit firms and registered investment companies, unregistered funds, and investment advisers or sponsors that are under audit to become familiar with the application of the proposed ICC definition. This may potentially lead to an initial increase in compliance costs. However, the proposed amendments would improve the clarity of the ICC definition and therefore likely would decrease overall compliance costs after affected parties adjust to the new definition. The proposed materiality test is already part of the Commission's auditor independence rules [ 83] Alternatively, it could result in a delay of a merger or acquisition while the auditor and its audit client attempt to resolve the potential independence matters to the possible detriment of the audit client and investors. [ 53]

We anticipate the proposed amendments would benefit audit firms and audit clients in several ways. First, the proposal is likely to reduce compliance costs for both audit firms and their clients by updating certain aspects of the auditor independence requirements that may be unduly burdensome. The proposed amendments may reduce the emphasis in our rules on relationships and services that are less likely to threaten auditor objectivity and impartiality. As a result, the proposed amendments likely would allow auditors and audit clients to focus their resources and attention on those relationships and services that are more likely to pose threats to auditor objectivity and impartiality. In turn, compliance costs likely would decrease for both auditors and audit clients. The RFA directs us to consider alternatives that would accomplish our stated objectives while minimizing any significant adverse impacts on small entities. In connection with the proposed amendments, we considered certain types of alternatives, including: management functions) that auditors must give up where an independence impairing relationship or service exists with a sister entity that is not material to the controlling entity. These cost savings could be especially pronounced for entities with complex organizational structures ( In 2000, the Commission adopted a comprehensive framework of rules governing auditor independence, laying out governing principles and describing certain specific financial, employment, business, and non-audit service relationships that would cause an auditor not to be independent of its audit client. The 2000 amendments set forth the standard for analysis to determine whether an auditor is

For example, an audit firm could have an existing audit relationship with an issuer that acquires another company for which the audit firm was not the auditor but provided services or had relationships that would be prohibited under Rule 2–01. Through no action of the audit firm, the acquisition would cause what had been announcement that a definite agreement has been reached. However, some mergers and acquisitions take a long time to be completed and a substantial portion of such transactions never reach completion. As a result, an alternative window of six months following announcement of the merger or acquisition may unnecessarily increase compliance burdens and associated costs ( we would expect those relationships and services would be easily known by the auditor as such services and relationships might be thought to reasonably bear on an auditor's independence due to the nature, extent, relative importance, or other aspects of the service or relationship.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] Moreover, we believe obtaining a student loan as a covered person poses a higher risk to the auditor's objectivity and impartiality because loans obtained while a covered person are likely more recent and thus may have a larger balance than loans obtained when such person was not a covered person. Additionally, a covered person obtaining a student loan from an audit client creates, at a minimum, an independence appearance issue that is not present when a non-covered person obtained a similar student loan from such audit client. In addition, the proposed exception would not encompass student loans obtained for a covered person's immediate family members. We are concerned that the amount of student loan borrowings could be significant when considering student loans obtained for multiple immediate family members and thus could impact an auditor's objectivity and impartiality. We are therefore limiting the exclusion to student loans obtained for the covered person's educational expenses. Considered together, we believe these proposed limitations appropriately balance the benefits of the proposed exception with its potential impact on the auditor's objectivity and impartiality. Request for Comment The device is suitable for applications ranging from home multimedia entertainment to small office and home office (SOHO) settings. Enhance the Safety of your Data with a Next-Generation File System Superior storage technology and optimised snapshot technology are the cornerstones of the Btrfs file system, which is what TerraMaster's F2-210 2-Bay NAS unit relies on for advanced data protection, prevention of data corruption, and minimal maintenance expenses. Use of this file system promotes high data integrity, all the while promoting flexiblity and efficiency in the areas of data protection and data recovery. Rule 2–01 is designed to ensure that auditors are qualified and independent of their audit clients both in fact and in appearance.” [ 9] Based on the passage of time, these transition and grandfathering provisions are no longer necessary. We propose deleting the current Rule 2–01(e) and reserving it for the proposed amendments discussed in Section II.D.

Is it appropriate for auditors to assess whether or not sister investment companies are material to the controlling entity even when a sister fund's investment adviser may not be material to the controlling entity? Should we include a reference to paragraph (f)(14)(i)(C) within paragraph (f)(14)(i)(D), as proposed? iii. Investment Companies That Share an Investment Adviser or Sponsor Included Within the ICC Definition Send paper comments to Vanessa A. Countryman, Secretary, Securities and Exchange Commission, 100 F Street NE, Washington, DC 20549–1090. In this section, we discuss the anticipated economic benefits and costs of the proposed amendments. We first analyze the overall economic effects of the proposed amendments. We then discuss the potential costs and benefits of specific proposed amendments. 1. Overall Potential Benefits and Costs We believe that the proposed amendments would not duplicate, overlap or conflict with other Federal rules. F. Significant Alternatives

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The potential expansion of auditor choices as a result of the proposed amendments could also allow audit clients to align audit expertise better with the audit engagement, which may lead to an improvement in audit quality and financial statement quality. [ 72] GYS is a family run company with its main factory in France. The Multi pearl range is manufactured in France. Authority: 15 U.S.C. 77f, 77g, 77h, 77j, 77s, 77z–2, 77z–3, 77aa(25), 77aa(26), 77nn(25), 77nn(26), 78c, 78j–1, 78 l, We note that a determination under the proposed amendments that sister entities are not material to the controlling entity, by itself, does not conclude the independence analysis under Rule 2–01. This is because, as explained above, auditors and audit clients must consider “all relevant facts and circumstances” when assessing independence pursuant to the general standard in Rule 2–01(b). Currently, the term “audit and professional engagement period” is defined differently for domestic first time filers and FPI first time filers. [ 85]

Be in compliance with the applicable independence standards related to the services or relationships when the services or relationships originated and throughout the period in which the applicable independence standards apply; we do not expect a significant learning curve in applying the test or significant incremental compliance costs for auditors.We believe that the root cause of auditor independence issues arising from mergers and acquisitions, however, generally differs from that arising from IPOs. In situations involving mergers and acquisitions, a pre-existing auditor-client relationship between the auditor and the merged company or the company being acquired is less likely, as compared to an IPO, and the timing of the transaction is generally shorter and more uncertain. As such, these transactions can give rise to auditor independence violations that are inadvertent and often difficult to contemplate in advance. [ 51]