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D09459 1 (2014-12-18)

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





December 18, 2014

Ms. Sharon Macey
Audit and Attest Standards
American Institute of Certified Public Accountants
1211 Avenue of the Americas
New York, NY 10036-8775

AICPA Proposed Statement on Standards for Attestation Engagements: Reporting on
an Examination of Controls at a Service Organization Relevant to User Entities'
Internal Control Over Financial Reporting: Clarification and Recodification

Dear Ms. Macey:

This letter provides the U.S. Government Accountability Office's comments on the American
Institute of Certified Public Accountants' (AICPA) exposure draft on examining controls at
service organizations.

We support the AICPA's efforts to clarify the attestation standards regarding examining
controls at service organizations. We are providing comments on the application of the
definition of fraud to service organization audits, proposed language relating to intentional
acts, and on enhancing practitioners' consideration of fraud during a service organization
audit.

Definition of Fraud

As we considered how the definition of fraud proposed in Concepts Common to All
Attestation Engagements would apply to an examination of controls at a service
organization, we observed that the definition may not sufficiently clarify the parties to which
it applies. The exposure draft of Concepts Common to All Attestation Engagements defines
fraud as an intentional act involving the use of deception that results in a misstatement on
the subject matter or the assertion. We understand that this chapter is still in draft form. We
believe that the clarified attestation standards as a whole would benefit from a definition that
indicates whether fraud includes fraud committed by third parties. Such an indication would
provide valuable assistance to practitioners, including service auditors, as they plan and
perform procedures related to fraud. We encourage the AICPA to consider revising the
definition accordingly.

Intentional Acts and Fraud

Given the proposed requirements relating to the practitioner's consideration of fraud in the
proposed chapter Examination Engagements, we believe that the AICPA should consider
whether intentional acts as discussed in the Examination of Controls at a Service
Organization exposure draft should be referred to as fraud. According to paragraph 8.A39,
the risks and control objectives related to service organization controls encompass


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