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A88356 1 (2008-08-12)

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== Accountability * Integrity * Reliability
United States Government Accountability Office
Washington, DC 20548


         August 12, 2008

         Ms. Sharon Macey
         Audit and Attest Standards
         American Institute of Certified Public Accountants
         1211 Avenue of the Americas
         New York, NY 10036-8775

         Subject: AICPA Auditing Standards Board (ASB) June 2008, Exposure Draft:
         Proposed Statement on Standards for Attestation Engagements, An Examination of
         an Entity's Internal Control Over Financial Reporting That Is Integrated With an
         Audit of Its Financial Statements (Supersedes AT Section 501, Reporting on an
         Entity's Internal Control Over Financial Reporting).

         This letter provides the U.S. Government Accountability Office's (GAO) comments on
         the ASB's proposed revisions to AT Section 501. We have major concerns about the
         provisions of the proposed standard that would prohibit auditors from issuing an
         adverse opinion any time they encounter restrictions on the scope of an engagement,
         regardless of the nature or extent of the restrictions. Our concerns on this issue
         along with other comments and suggestions are summarized below.


         Scope Limitations

         Proposed AT 501 would require auditors to withdraw from an engagement or
         disclaim an opinion any time there are restrictions on the scope of an engagement,
         even when the auditors have identified one or more material weaknesses. We believe
         that the standard should allow flexibility for auditors to issue an adverse opinion
         when they have sufficient evidence to conclude that an entity's system of internal
         control is not effective. The existence of a material weakness provides such
         evidence.

         To incorporate flexibility into the proposed standard, we recommend revising
         paragraph 118 as follows:

             Paragraph 118: The auditor can express an unqualified or adverse opinion
             on the entity's internal control only if the auditor has obtained sufficient
             appropriate evidence to support such an opinion. , ble t3  f  th
             rfc Ift in               e rc     -nees. ff        If the auditor is
             unable to obtain sufficient aDoroDriate evidence to suport such an opinion
             due to restrictions on the scope of the engagement, the auditor should
             withdraw from the engagement or disclaim an opinion. If the auditor has

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