FSA's Comments on the Proposed Registration System of Public Accounting Firms by the U.S. Public Company Accounting Oversight Board under the Sarbanes-Oxley Act of 2002

March 28, 2003
Financial Services Agency (FSA)

1. The Financial Services Agency (''FSA'') sent a comment letter on March 28 regarding the Proposal of Registration System for Public Accounting Firms (''Proposal'') by the Public Company Accounting Oversight Board (''PCAOB'') (*) of the United States under the Sarbanes-Oxley Act of 2002.

   (*)  The PCAOB is a new oversight body of public accounting firms.

2. The Proposal requires foreign public accounting firms including Japanese audit firms to be registered with the PCAOB if a foreign public accounting firm prepares or furnishes audit reports with respect to foreign corporations including Japanese corporations listed in the United States or plays a substantial role in the preparation and furnishing of such reports for such corporations.

3. Oversight of Japanese audit firms should be conducted by the Japanese auditor oversight bodies under the Japanese CPA Law. From this viewpoint, the FSA has had constructive dialogues with the SEC on this issue as well as other issues related to the Sarbanes-Oxley Act of 2002.

4. As part of these dialogues, the FSA has decided to send the comment letter regarding the Proposal and request the PCAOB to provide an appropriate exemption from the registration requirement to Japanese audit firms.

   In relation to the Proposal, the PCAOB will hold a public roundtable to discuss issues relating to the registration and oversight of non-U.S. public accounting firms on March 31 in Washington, D.C., and the FSA will attend the roundtable.

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• (Reference 1) Comment letter to the PCAOB(PDF:62K)
• (Reference 2) Comments on the PCAOB's Proposal (to be circulated at the roundtable)(PDF:133K)