News
April 26, 2013

PCAOB Issues Policy Statement Regarding Credit for "Extraordinary Cooperation"

Arnold & Porter Advisory

On April 24, 2013, the Public Company Accounting Oversight Board (PCAOB or Board) issued a Policy Statement Regarding Credit for Extraordinary Cooperation in Connection with Board Investigations (Policy Statement). The Policy Statement provides guidance concerning how the PCAOB may consider the effect of "extraordinary cooperation" in determining the disciplinary outcome of an investigation. Extraordinary cooperation includes self-reporting, remedial or corrective action, or substantial assistance in an investigation. If the Board determines that the subject of an investigation has provided "extraordinary cooperation" in a manner consistent with the Policy Statement, it may impose reduced charges or sanctions, include language in settlement documents noting the cooperation and its positive effect on settlement terms, or, in "exceptional" cases, bring no disciplinary action at all.

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