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D17893 1 (2017-10-16)

handle is hein.gao/gaobadtww0001 and id is 1 raw text is: GU.S. GOVERNMENT ACCOUNTABILITY OFFICE 441 G St. N.W. Washington, DC 20548 October 16, 2017 Mr. Samuel L. Burke, Chair AICPA Professional Ethics Executive Committee American Institute of Certified Public Accountants 1211 Avenue of the Americas New York, New York 10036-8775 GAO's Response to the American Institute of Certified Public Accountants Professional Ethics Division's July 2017 Exposure Draft, Proposed Interpretation and Other Guidance: State and Local Government Entities (Formerly Entities Included in State and Local Government Financial Statements) Dear Mr. Burke: This letter provides GAO's comments on the American Institute of Certified Public Accountants (AICPA) Professional Ethics Division's exposure draft entitled Proposed Interpretation and Other Guidance: State and Local Government Entities (Formerly Entities Included in State and Local Government Financial Statements). GAO promulgates generally accepted government auditing standards (GAGAS), which provide professional standards for auditors of government entities in the United States. We appreciate the AICPA's efforts to obtain a wide range of perspectives on important matters relating to professional ethics in the accountability community. The AICPA Professional Ethics Executive Committee (PEEC) asked for responses to seven specific questions. Our responses follow. Specific Comments 1. Are there any situations in which you believe the framework proposed will not reach the appropriate answer for the general fund? If so, please explain the situation and why you believe the appropriate answer would not be reached. We support PEEC's efforts to address auditor independence through enhanced application of a threats and safeguards approach. This approach is consistent with the GAGAS Conceptual Framework Approach to Independence. We do not envision any situations where the proposed framework will not reach an appropriate answer for the general fund. 2. Paragraph .03 of the proposed revised interpretation notes that when an interpretation of the Independence Rule (ET sec. 1.200.001) is applied in a state or local government environment and the interpretation uses terminologythat is not applicable in this environment, the member should use their professional judgement to deternine if there is an equivalent termand provides an example of one such situation in which PEEC believes this could occur. Are there any other Page 1

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