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New Year. New Congress. Our Work Continues in 2019!


As we ring in a new year, I thought today would be a good day to send a legislative and regulatory update on our efforts to obtain common sense relief for small firms from the PCAOB audit requirement. Just in case you thought we were done fighting for this relief, I want to assure you that we are NOT giving up!

So, here is our update:


As 2018 came to a close, we worked as hard as we could to get our PCAOB exemption bills to the floors of both chambers. Unfortunately, we ran out of runway with that Congress. So now we have a new year and a new Congress, which means that we will have to reintroduce our bills in this new Congress and start the Hearing/Markup/Vote process over again.

While that may seem daunting, I know it was daunting to me for a moment, we have remained actively engaged with both sides of the aisle throughout December and both are encouraging us to reintroduce our bills. The tremendous work you have done over the past year has effectively introduced and raised awareness on this highly technical issue with legislators and their staff, and staff has suggested that we are well positioned to continue our advocacy and potentially deliver our bill to the President's desk.

Our education and advocacy efforts will need to continue, especially with the 100+ newly elected legislators, many of whom are still trying to staff up in DC. Once we know who the new Legislative Directors are in these offices, we will get to work. In light of the large number, we are contemplating working with a couple of the Associations in DC to host one or two events where we can introduce/educate legislative staff on not only our issue, but also a few others that matter to small and mid-sized firms.


In the House, it is our assumption that in the Chairwoman Waters-led House Financial Services Committee we will have to compromise on bill language, to what extent I am not sure, but we know the D's were unhappy with our definition of "small firm" (we used FINRA's definition of 150 or less registered reps) so we should expect further discussion on that point and potentially others. We will be speaking with Representatives Hill, Gonzalez and Beyer in the next two weeks to ask for their continued support and sponsorship of our House bill (which, by the way, will have a new number once reintroduced).


In the Senate, we have Senator Cotton's ongoing commitment to small businesses and our bill. We hope to speak with Senator Jones in the next week to ask for his continued support and co-sponsorship of our Senate bill (which, again, will have a new number once reintroduced).


On the regulatory front, we hope to set meetings with both the SEC and PCAOB in Q1 of 2019. It is important that we maintain our dialog with the SEC and establish a dialog with the PCAOB, so we are working on both the legislative and regulatory fronts at the same time.


I know we had all hoped for the equivalent of a legislative miracle, which would have been passing a bill within 6 months of having it introduced in both chambers, but people who do this for a living keep telling me what we accomplished in 2018 was nothing short of remarkable. Since they know more than we do, I'm going to believe what they are telling me -- and I remain incredibly proud of our collective achievements last year. It is AMAZING what we can do when we come together -- we can move mountains!!!

2019 is our year to finish what we started!

Here's To 2019!

Wishing you a happy, healthy, and prosperous 2019!

All the best,


Paige W. Pierce

Paige Pierce Consulting

SVP, Larimer Capital Corp

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Paige Pierce