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




June 2, 2015

Mr. James Brackens
Vice President, Ethics and Practice Quality
American Institute of Certified Public Accountants
1211 Avenue of the Americas
New York, NY 10036

American Institute of Certified Public Accountants' December 2014 Concept Paper,
Entitled Evolving the CPA Profession's Peer Review Program for the Future

Dear Mr. Brackens:

This letter provides the U.S. Government Accountability Office's (GAO) comments on the
American Institute of Certified Public Accountants' (AICPA) concept paper entitled Evolving the
CPA Profession's Peer Review Program for the Future. GAO promulgates generally accepted
government auditing standards (GAGAS), which provide professional standards for auditors of
government entities in the United States.

We understand that the concept paper relates to the larger project described in last year's
AICPA discussion paper entitled Enhancing Audit Quality- Plans and Perspectives for the U.S.
CPA Profession. We support the AICPA's efforts to improve audit quality and the peer review
process. Our comments, provided below, address the following areas:

* Root cause analysis of audit quality issues
* Effect of the initiative on the timing of external peer reviews
* Consideration of governmental and other specialized audits
* Integrating information from disparate systems

Root Cause Analysis of Audit Quality Issues

While we agree that the AICPA should consider a multi-phased approach that leverages
technology to help make practice monitoring more effective and transparent, we believe that any
discussion of the peer review program's future must include consideration of the specific audit
quality problems that make the enhancing audit quality (EAQ) project so important. As we
indicated in our November 2014 comment letter on the EAQ discussion paper, in our view the
AICPA should consider performing a root cause analysis of audit quality issues before allocating
resources to the proposed initiatives. This step is fundamental to all considerations of EAQ,
including consideration of the future of the peer review program. It would also help the AICPA
tailor its peer review program to more effectively resolve the causes of audit problems in the
near term.

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