Category: Exposure Draft

Comments to American Institute of Certified Public Accountants on Proposed Statement on Standards for Accounting and Review Services (SSARS) Applicability of AR-C Section 70 to Financial Statements Prepared as Part of a Consulting Services Engagement

Yigal Rechtman, Principal Drafter, New Jersey State Society of CPAs, December 2024 The Accounting and Auditing Standards Interest Group (A&ASIG) of the New Jersey Society of Certified Public Accountants (NJCPA) is pleased to offer its feedback and comments on the proposed statement on Standards for Accounting and Review Services applicability of AR-C section 70 to […]

Select Comment letter to PCAOB: Proposed Auditing Standard Designing and Performing Substantive Analytical Procedures Comment letter to PCAOB: Proposed Auditing Standard Designing and Performing Substantive Analytical Procedures

Principal Drafter, New York State Society of CPAs, August 2024 We appreciate the opportunity to comment on PCAOB Release No, 2024-006 Proposed Auditing Standard – Designing and Performing Substantive Analytical Procedures and Amendments to Other PCAOB Standards (the “Release”). We are generally supportive of the PCAOB’s efforts to create a framework that is scalable for […]

Responding to Security and Exchange Commission’s Exposure Draft on Cybersecurity Risk Management Rule for Broker-Dealers, Clearing Agencies, Major Security-Based Swap Participants, the Municipal Securities Rulemaking Board, National Securities Associations, National Securities Exchanges, Security-Based Swap Data Repositories, Security-Based Swap Dealers, and Transfer Agents

In response to the Proposed Rule on Cybersecurity Risk Management Rule for Broker-Dealers, Clearing Agencies, Major Security-Based Swap Participants, the Municipal Securities Rulemaking Board, National Securities Associations, National Securities Exchanges, Security-Based Swap Data Repositories, Security-Based Swap Dealers, and Transfer Agents, File Number S7-06-23 (the “Proposed Rule”) Rechtman CPA PLLC is pleased to provide our comments […]

Responding to Security and Exchange Commission Proposing Release: Amendments to PCAOB Auditing Standards related to a Company’s Noncompliance with Laws and Regulations And Other Related Amendments

Yigal Rechtman, Principal Author, New York State Society of CPAs, August 2023 The New York State Society of Certified Public Accountants (NYSSCPA), representing more than 19,000 CPAs in public practice, industry, government and education, welcomes the opportunity to comment on the above-captioned invitation to comment (ITC). The NYSSCPA’s Auditing Standards Committee deliberated the exposure draft […]

Respond to Security and Exchange Commission’s Exposure Draft on Cybersecurity Risk Management for Investment Advisers, Registered Investment Companies, and Business Development Companies

In response to the Proposed Rule on Cybersecurity Risk Management for Investment Advisers, Registered Investment Companies, and Business Development Companies, File Number S7-04-22 (the “Proposed Rule”) Rechtman CPA PLLC is pleased to provide our comments to the Securities and Exchange Commission in furtherance of creating an effective cybersecurity rule.. Full Article

Comment letter on NIST Special Publication 800-163 Revision 1 – Vetting the Security of Mobile Applications

Principal Drafter, New York State Society of CPAs, September 2018 We welcome the opportunity to comment on the National Institute of Standards and Technology’s (NIST) Draft NIST Special Publication 800-163 Revision 1 – Vetting the Security of Mobile Applications (the Exposure Draft or ED). The ED is both timely and appropriate. It includes many features, […]

Comments to New York State Department of Financial Services on Proposed New York Codes, Rules and Regulations

Principal drafter, November 2016 Overall, we support the New York State Department of Financial Services’ (DFS) promotion of establishing, enhancing and maintaining robust cybersecurity risk management practices. We agree with the NYSDFS’ assessment over the criticality of cybersecurity programs. While we support the objectives of the proposed regulation, we have concerns that it may result […]