We are writing on behalf of the Board of Directors of the Association to comment on proposed changes to the composition and procedures of audit committees contemplated in the four Releases noted above. The diversity of publicly traded companies in American is a great strength of our economy. Considering the entire spectrum of thousands of public companies, there is no typical corporate board, just as there is no typical business. It is a bedrock principle of the Association that corporate boards and managers, working together in their separate spheres can effectively manage the affairs of each publicly traded company.
Corporate boards have broad discretion and solemn responsibilities.
Maintaining the board s flexibility in appointing and tasking audit committees is good corporate governance and promotes accurate financial reporting, one company at a time. Indeed many of the BRC s recommendations represent practices that some companies have already implemented to improve the quality of their financial reporting. The Association appreciates the BRC s contribution to the body of knowledge and the overall discourse on corporate governance and financial reporting. We would encourage all publicly traded companies to seriously consider each of the BRC recommendations. We think the key to a good audit committee is not more process or more rules.