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



July 25, 2017


Mr. Ken Siong
Technical Director
International Ethics Standards Board for Accountants
529 Fifth Avenue, 6th Floor
New York, NY 10017

GAO's Response to the International Ethics Standards Board for Accountants' May 2017
Exposure Draft, Proposed Application Material Relating to Professional Skepticism and
Professional Judgment

Dear Mr. Siong:

This letter provides GAO's response to the exposure draft, Proposed Application Material
Relating to (a) Professional Skepticism - Linkage with the Fundamental Principles; and (b)
Professional Judgment - Emphasis on Understanding Facts and Circumstances. GAO
promulgates generally accepted government auditing standards (GAGAS) in the United States.
GAGAS provides a framework for conducting high-quality audits of government awards with
competence, integrity, objectivity, and independence. Our comments reflect the importance we
place on reinforcing the values promoted in both the International Ethics Standards Board for
Accountants (I ESBA) Code of Ethics for Professional Accountants (code) and GAGAS.

We support IESBA's efforts to promote the application of professional skepticism in audits,
reviews, and other assurance engagements by supplementing the code's existing references to
professional skepticism. We believe that professional skepticism is a specific term applicable to
professional accountants who perform audits, reviews, and other assurance engagements. The
term has a slightly different meaning and connotes a different level of responsibility for
professional accountants in business who should practice professional skepticism, but to a
different extent. In our view, the meaning of the term and its importance to auditing and
assurance engagements will be diminished and it will ultimately be interpreted differently if the
concept is applied to all professional accountants.

Specific Comments

Proposed Application Material Relating to Professional Skepticism (para. 120. 13 A 1)

1. Do respondents agree that the proposed application material enhances the
   understandability of the conceptual framework in section 120 of the proposed
   restructured code?

   We support I ESBA's efforts to explain how compliance with the fundamental principles
   supports the exercise of professional skepticism in the context of audits, reviews, and other
   assurance engagements. However, we suggest that the application material be placed in
   section 110, The Fundamental Principles, of the code rather than in section 120, The


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