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D05224 1 (2013-07-15)

handle is hein.gao/gaobadppu0001 and id is 1 raw text is: GAOU.S. GOVERNMENT ACCOUNTABILITY OFFICE 441 G St. N.W. Washington, DC 20548 July 15, 2013 Ms. Sherry Hazel Audit and Attest Standards American Institute of Certified Public Accountants 1211 Avenue of the Americas New York, New York 10036-8775 Subject: AICPA Auditing Standards Board (ASB) April 2013 Exposure Draft for a Proposed Statement on Auditing Standards (SAS), Entitled Using the Work of Internal Auditors This letter provides the U.S. Government Accountability Office's (GAO) comments on the ASB's proposed SAS. We support the ASB's efforts to redraft SAS No. 65 to apply clarity drafting conventions and to converge with the International Standards on Auditing (ISAs). We believe that the divergences from the ISA 610 (Revised 2013), Using the Work of Internal Auditors, proposed in the Exposure Draft are necessary and appropriate. Although we acknowledge the ASB's commitment to harmonize its standards to the analogous standards of the International Auditing and Assurance Standards Board (IAASB), we concur with the ASB that the use of the work of internal auditors represents a current and accepted practice in the United States that does not appear to have detracted from overall audit quality, and we agree with the ASB's use of terms or phrases that are more commonly used in the United States. The ASB is seeking comments on changes resulting from applying the clarity drafting conventions and converging with the ISA, and their effect on the content of the proposed SAS. Our specific comments which were requested by the ASB, follow. Requests for Specific Comments 1. Are the objectives to be achieved by the auditor, stated in the proposed SAS, appropriate? We agree with the objectives to be achieved by the auditor in the proposed SAS, and we believe that they are appropriate for cases in which the external auditor expects to use the work of internal auditors to modify the nature or timing, or reduce the extent, of audit procedures performed by the external auditor. We also note that using the work of internal auditors represents current practice in the United States. 2. Are the revisions from the existing standards to converge with ISA 610 (Revised 2013) appropriate? and 3. Are the differences between the proposed SAS and ISA 610 (Revised 2013) identified in the exhibit, and other language changes, appropriate? We broadly agree with the revisions made to the standards to converge with ISA 610 (Revised 2013), and believe that the differences between the ASB's proposed SAS and

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