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A88311 1 (2009-02-17)

handle is hein.gao/gaobadvul0001 and id is 1 raw text is: A 0 .,!! = Accountability * Integrity Reliability United States Government Accountability Office Washington, DC 20548 February 17, 2009 Ms. Sharon Macey 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) November 2008 Exposure Draft of Proposed Statement on Standards for Attestation Engagements (SSAE) entitled Reporting on Controls at a Service Organization This letter provides the U.S. Government Accountability Office's (GAO) comments on the ASB's proposed SSAE on audit considerations relating to reporting on controls at a service organization. Generally, we support the proposed statement and the related proposed Statement on Auditing Standards. We believe that addressing the needs of service and user auditors and their respective clients separately adds much-needed clarity in this area of practice. The Board is seeking comments on the effect of applying the clarity drafting conventions to the proposed SSAE and of converging it with the proposed new International Standard on Assurance Engagements, ISAE 3402, Assurance Reports on Controls at a Third Party Service Organization. We provide the requested comments in this letter and recommend specific wording changes, along with other minor editorial changes, in the related attachment. Request for Specific Comments (1) Comments on the objectives stated in the proposed SSAE to be achieved by the service auditor. We believe that the objectives stated in the proposed SSAE to be achieved by the service auditor are appropriate. (2) Comments on the revisions made to the existing standard to converge with the ISAE 3402 exposure draft. Except as noted, we agree with the revisions made to the existing standard to converge with the ISAE exposure draft. We do not believe that it is relevant or necessary for service auditors to report deviations if, on the basis of tests performed, the service auditor concludes that the related control objective was achieved, as the

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