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A88279 1 (2009-05-29)

handle is hein.gao/gaobadvuc0001 and id is 1 raw text is: 


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T I   IAccountability * Integrity * Reliability
United States Government Accountability Office
Washington, DC 20548



         May 29, 2009

         Ms. Sherry 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) January 2009 Exposure Draft for a
         proposed Statement on Auditing Standards (SAS) entitled Consideration of Fraud in
         a Financial Statement Audit (Redrafted)

         This letter provides the U.S. Government Accountability Office's (GAO) comments on
         the ASB's proposed SAS on the auditor's consideration of fraud in a financial
         statement audit. Generally, we support the proposed statement and agree that the
         principles-based approach used in this standard will permit the flexibility needed in
         this critical area. Our responses to the questions raised in the related Explanatory
         Memorandum are noted below. In addition, we are providing comments on retaining
         a separate fraud risk standard and the need for additional guidance related to third
         party fraud.

         Responses to Questions on Application of the Clarity Conventions and
         Converging with International Standard on Auditing (ISA) No. 240

         (1) We believe that the objectives stated in the proposed SAS to be achieved by the
         auditor are appropriate.

         (2) We agree with the revisions made to the existing standard to converge with the
         ISA.

         (3) We agree with the differences between the proposed SAS and ISA 240.

         (4) We agree with the governmental considerations included in the proposed
         standard, and we recommend including additional special considerations for audits of
         governmental entities to provide further guidance on fraud risks that relate to
         government entities. In the attachment to this letter we propose wording for these
         additional considerations.

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