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D09635 1 (2015-02-04)

handle is hein.gao/gaobadqye0001 and id is 1 raw text is: G A U.S. GOVERNMENT ACCOUNTABILITY OFFICE 441 G St. N.W. Washington, DC 20548 February 4, 2015 Mr. Ken Siong Technical Director International Ethics Standards Board for Accountants 529 Fifth Avenue, 6th Floor New York, NY 10017 International Ethics Standards Board for Accountant's November 2014 Consultation Paper, Entitled Improving the Structure of the Code of Ethics for Professional Accountants Dear Mr. Siong: This letter provides the U.S. Government Accountability Office's (GAO) comments on the International Ethics Standards Board for Accountant's (IESBA) Consultation Paper entitled Improving the Structure of the Code of Ethics for Professional Accountants (the Code). GAO promulgates generally accepted government auditing standards, which provide professional standards for auditors of government entities in the United States. We support IESBA's efforts to improve the usability of the Code. IESBA is seeking responses to the following questions. Our selected responses and additional comments on changes made by IESBA in restructuring the Code follow. We are also recommending that the Code include clarifications of responsibility for the government sector and that I ESBA consider the impact of the Code on government entities. GAO's Responses to Specific Questions Posed by IESBA o. Do you believe that the approach outlined in this Consultation Paper, as reflected in the Illustrative Examples, would be likely to achieve IESBA's objective of making the Code more understandable? If not, why not and what other approaches might be taken? We support the approach outlined in the Consultation Paper. The proposed format is consistent with our view that ethical principles should always be construed as requirements, with explanatory material provided strictly as support for those requirements. In our view, placing the explanatory material section directly after the requirements section increases ease in navigating the Code. We caution against placing the explanatory material too far from the related requirement, as we have found that users of clarified standards tend to place more emphasis on explanatory material that is located close to the related requirement rather than several pages away. Explanatory material that follows the related requirement within a page or two can help minimize problems resulting from insufficient attention to explanatory material. We will consider IESBA's approach outlined in this Consultation Paper for our revision of the U.S. Government Auditing Standards.

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