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A88275 1 (2009-08-31)

handle is hein.gao/gaobadvty0001 and id is 1 raw text is: ~G A 0 Acountabiity I Integrity * Reliability United States Government Accountability Office Washington, DC 20548 August 31, 2009 Ms. Sharon Hazel Audit and Attest Standards American Institute of Certified Public Accountants 1211 Avenue of the Americas New York, New York 10036-8775 Subject: AICPA Auditing Standards Board (ASB) June 2009 Exposure Draft of Proposed Statement on Quality Control Standards (SQCS) entitled A Firm's System of Quality Control (Redrafted) This letter provides the U.S. Government Accountability Office's (GAO) comments on the ASB's proposed SQCS on quality control. We commend the ASB for converging its quality control standard with the International Auditing and Assurance Standards Board's (JAASB) International Standard on Quality Control (ISQC) No. 1 Quality Control for Firms that Perform Audits and Reviews of Financial Statements, and Other Assurance and Related Services Engagements. Overall, we support the proposed statement and believe it appropriately addresses a firm's responsibilities for its system of quality control. Our comments and suggestions for improving the standard are noted below. Comments on Engagement Quality Control Review In its request for comments on the proposed SQCS and the related Statement on Auditing Standards (SAS) Quality Control for an Audit of Financial Statements, the ASB has requested comment on whether additional requirements relating to engagement quality control review should be included in the proposed standard, specifically additional requirements relating to engagement quality control review from Public Company Accounting Oversight Board (PCAOB) Auditing Standard No. 7 - Engagement Quality Review. We do not support adding requirements from the PCAOB standard to the proposed SQCS or SAS except as noted below in our response to question 2. PCAOB's AS No. 7 contains specific requirements and processes for an engagement quality review that may be appropriate for audits of issuers. The proposed SQCS provides an appropriate level of flexibility for audits of non- issuers.

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