Question 111.05 indicates that companies must disclose if its principal accountant issued an audit report on the financial statements within the last two years that questioned the company's ability to continue as a going concern. No surprise there.

At the same time, according to question 111.06, companies do not need to disclose if the accountant issued a report on the registrant's internal control over financial reporting in the last two fiscal years containing an explanatory paragraph, adverse opinion, or disclaimer of opinion. On the other hand, companies do need to disclose if the report contains "an adverse opinion with respect to the effectiveness of internal control over financial reporting."

As the CD&I's highlight, it confirms that changing auditors is a significant event, both in practical terms -- that is, moving information and processes from the old to the new teams -- and in managing disclosures about the transition. Having a good understanding of the requirements early on in the process is critical.

"You should not be reading it for the first time when you're exchanging dismissal and engagement letters," Wild notes.