COMMENTS ON PCAOB PROPOSED AUDITING STANDARD An Audit of Internal Control over Financial Reporting Performed in Conjunction with an Audit of Financial Statements

After public comment, the Public Company Accounting Oversight Board (the "Board" or "PCAOB") has adopted Auditing Standard No. 2, An Audit of Internal Control Over Financial Reporting Performed in Conjunction With an Audit of Financial Statements. This standard is the standard on attestation engagements referred to in Section 404(b) as well as Section 103(a)(2)(A) of the Sarbanes-Oxley Act of 2002 (the "Sarbanes-Oxley Act" or "the Act"). The Board will submit this standard to the Securities and Exchange Commission ("Commission" or "SEC") for approval pursuant to Section 107 of the Sarbanes-Oxley Act of 2002 (the "Act"). This standard will not take effect unless approved by the Commission.