As a result of their registration with the PCAOB, are auditors of non-public broker-dealers now subject to different independence requirements than applied before the expiration of the exemption?
No. Auditors of non-public broker-dealers must continue to comply with Exchange Act Rule 17a-5(f)(3), which states that the auditor “shall be independent in accordance with the provisions of 210.2-01(b) and (c) of this chapter.” As noted previously by the staff, however, auditors of non-public broker-dealers are not subject to the partner rotation requirements or compensation requirements of 210.201(c).
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