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Paul Gillis has become much more negative about a PCAOB China deal on audit inspections. He thinks there are signs that the process of deregistering Chinese audit firms is starting, which would lead to the delisting of Chinese companies from US exchanges. This is a reversal from his posts a few months ago. The 12/31 deadline is coming up and US and Chinese regulators have started last ditch effort to avert a stalemate. He did mention in another post that the deregistering process would be a lengthy process. This may all be moot if YONG gets taken private sooner than later. Even if it is later, I don't think a delisting from the NASDAQ would impact the buyout.

Chinese regulators had meetings in Washington last week with the PCAOB and SEC. They must not have gone very well.

The SEC yesterday charged the Big Four and BDO in China with violations of U.S. securities laws and the Sarbanes-Oxley Act for failing to provide audit working papers for U.S. listed companies. This follows the earlier charges against Deloitte for the same issue, and the Court action against Deloitte for failure to produce the working papers for Longtop Financial Technologies.

The Big Four issued statements pointing blame at diplomatic failure.

I believe that this marks the beginning of the process to deregister Chinese accounting firms from the PCAOB and to ban them from practice before the SEC. Unless resolved, this will likely lead to the delisting of U.S. listed Chinese companies. Multinational companies in China may also face issues since PCAOB rules require an auditor playing a substantial role in the audit of an MNC be registered with the PCAOB. There are situations where the China Big Four are playing a substantial role in the audit of U.S. MNCs that have substantial operations in China. They may need to resolve this by dividing the work among several firms so that no single firm plays a substantial role.

I expect the next action we see is the PCAOB releasing a proposed rule that will revoke the registration of any accounting firm it cannot inspect. I expect that we see this in the next few weeks. The proposed PCAOB rule would be sent out for public comment, which should be vociferous. Any rule has to be approved by the SEC.
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