The Digital Chamber (TDC) has submitted feedback on the Public Company Accounting Oversight Board’s (PCAOB) Proposed Rule 2400, specifically addressing the implications for Proof of Reserves (PoR) in the blockchain sector.

PoR is a pivotal transparency tool within the cryptocurrency industry, providing a verification method for the reserves held by platforms and issuers. We support the use of PoR and similar attestations to ensure the integrity of digital asset holdings, enhancing consumer and investor trust. The PCAOB’s proposal aims to extend its oversight to include audits and attestations like PoR that are beyond its traditional regulatory scope. Our comments argue this expansion is unsupported by the PCAOB’s statutory authority and lacks concrete evidence of investor harm or confusion that the rule purportedly addresses. Instead, PoR has been instrumental in promoting transparency and accountability, particularly highlighted during the failures of several large cryptocurrency platforms.

We urge the PCAOB to use a more measured approach that involves further study and dialogue, which could lead to more informed and effective regulations that foster innovation while protecting investors.