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D04683 1 (2013-05-15)

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GO                   US. GOVERNMENT ACCOUNTABILITY OFFICE
441 G St. N.W.
Washington, DC 20548


May 15, 2013

Mr. James Gunn
IAASB Technical Director
International Auditing and Assurance Standards Board
545 Fifth Avenue, 14th Floor
New York, New York 10017

Subject: International Auditing and Assurance Standards Board January 2013 Consultation

Paper, A Framework for Audit Quality.

Dear Mr. Gunn,

This letter provides the U.S. Government Accountability Office's (GAO) comments on the
International Auditing and Assurance Standards Board (IAASB or Board) Consultation Paper
entitled A Framework forAudit Quality. We appreciate the IAASB's goal of developing a
comprehensive framework for audit quality, including the factors that contribute to the consistent
performance of quality audits.

We generally support the IAASB's efforts to raise awareness of the key elements of audit
quality, encourage stakeholders to explore ways to improve audit quality, and facilitate a greater
dialogue between the key stakeholders and users of the auditor's report. The document itself is
well organized by conceptual area, and the graphics on the heading of each page and
throughout the paper are well-conceived and helpful. However, we believe the value and
usefulness of the consultation paper would be enhanced if it addressed how this document is
expected to be used and its relationship with the other frameworks established by the IAASB.
We also suggest clarifying if and how the Framework is to be used by the IAASB to develop
future auditing standards.

The Board has asked respondents for comments on the specific matters discussed in the
Consultation Paper and we have provided responses to these questions below. Along with
these specific responses, we are providing additional comments for your consideration.


Request for Specific Comments

1. Does the Framework cover all of the areas of audit quality that commenters would expect? If
not, what else should be included?

We believe that the Framework covers the key areas of audit quality. We noted that it does not
fully consider issues common to governmental auditors and audits of public sector entities. For
example, and as described in greater detail below, engagement acceptance and continuance
decisions are not always possible for public sector organizations. The Framework is written
primarily for a corporate or commercial audience, and while it includes a section on
considerations specific to public sector audits, it does not fully address the issues that are often
involved with audits of public sector entities. We suggest merging considerations specific to

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