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D07954 1 (2014-07-17)

handle is hein.gao/gaobadqkz0001 and id is 1 raw text is: 




GAO U.S. GOVERNMENT ACCOUNTABILITY OFFICE
441 G St. N.W.
Washington, DC 20548



July 17, 2014


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 April 2014 Exposure
Draft, Proposed International Standard on Auditing (ISA) 720 (Revised), The Auditor's
Responsibilities Relating to Other Information and Proposed Consequential and
Conforming Amendments to Other ISAs

This letter provides the U.S. Government Accountability Office's (GAO) comments on the
International Auditing and Assurance Standards Board's (IAASB) revised exposure draft on the
auditor's responsibilities relating to other information.

We welcome the enhancements made to the November 2012 exposure draft, including those
that addressed certain issues relating to GAO's comments raised in our March 14, 2013, letter.
However, we would like the IAASB to further consider the points outlined in our comments
below. GAO's comments on the specific matters requested by the board follow the General
Comments section.

General Comments

Other Information Obtained Prior to the Date of the Auditor's Report

Since the proposed standard would require reporting only when the other information is
received prior to the date of the auditor's report, inconsistencies may develop in reporting on
other information, potentially resulting in less clarity to the multiple stakeholders.

The reporting requirement in the proposed paragraph 21 is applicable: When the auditor has
obtained the final version of all or part of the other information prior to the date of the auditor's
report. Paragraph A47 indicates that When the auditor has not obtained the final version of the
other information prior to the date of the auditor's report, this ISA does not require the auditor to
include a section in the auditor's report addressing other information.

As in practice it is common to receive final other information around, but not necessarily before,
the audit report date, the proposed standard may result in audit reports with no mention of the
auditor's responsibilities relating to other information because of the timing of receipt of other
information. Users may see some audit reports with a section describing the auditor's
responsibilities as to other information, and at the same time see other audit reports, consistent
with paragraph A47, with no mention of the auditor's responsibilities relating to other
information. The proposed reporting, which would be required in some cases and discretionary
in others, would not appear to address adequately the IAASB's goal of greater clarity and
enhanced consistency around the world regarding the auditor's responsibilities relating to other
information.


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