Although the PCAOB expressed its desire for comment from the public regarding MAFR, it openly asserted its opinion that MAFR could increase auditor accountability.
THE THEORETICAL BENEFITS, AND THE UNDENIABLE COSTS, OF MAFR
Though a variety of arguments have been posed in favor of MAFR over the years, three arguments, in particular, warrant further discussion: (1) the "fresh eyes/fresh look" argument; (104) (2) the "auditor coziness" argument; (105) and, (3) the "watchdog" argument.
The Cohen Commission report, though it did not endorse MAFR, recognized that one of the main arguments cited in favor of MAFR is that it would usher in "a fresh viewpoint" to review the public company.
129) A similar "watchdog" type argument is discussed in relation to MAFR, when commentators suggest that indicia of auditor independence increase when accountants fear being criticized by another auditor for doing allegedly erroneous or fraudulent work.
A 2006 study found that auditors are more likely to report a material misstatement against the client's wishes when audit rotation is pending than when the auditor relationship is ongoing and not constrained by MAFR.
There are three general arguments posed by the AICPA and Center for Audit Quality (CAQ), an independent advisory group against implementation of MAFR.
136) This concern over a missing causal link or understanding of the "root cause" is echoed by the CAQ, which spoke out against MAFR in its public comment letter to the PCAOB.
138) The AICPA, likely expressing the view of many in the industry, argues that MAFR is not at present the solution to the obstacles preventing optimum auditor "independence, objectivity and professional skepticism.
While we are wholly committed to improving audit quality, we do not see any evidence that MAFR would result in direct and measurable improvements in audit quality, and we believe that such a mandate would have far-reaching, costly, and unintended consequences, not only for auditors and audit firms, but for public companies, audit committees, and investors.
Other nations have implemented MAFR schemes, among them Italy, India, Brazil, Singapore, and Spain.
Spain repealed MAFR less than a decade after its implementation.