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A88357 1 (2003-09-03)

handle is hein.gao/gaobadvup0001 and id is 1 raw text is: 

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         G    A     0Comptroller General
       Ac- ntablilty - Integrity * Reliability                      of the United States
United States General Accounting Office
Washington, DC 20548




         September 3, 2003

         Office of the Secretary
         Public Company Accounting Oversight Board
         1666 K Street, NW
         Washington, DC 20006-2803

         Subject: Proposed Rules on Inspections of Registered Public Accounting Firms

         This letter provides the U.S. General Accounting Office's (GAO) comments on the
         Public Company Accounting Oversight Board's (PCAOB) July 28, 2003, proposed
         rules on accounting firm inspections, as mandated by the Sarbanes-Oxley Act of 2002.

         GAO supports improved transparency and accountability in the accounting
         profession, and we believe that the proposed inspection rules will help in this
         endeavor. In finalizing the rules on inspections, we urge the PCAOB to consider the
         important issue of coordination with the profession's self-regulatory peer review
         program in order to avoid duplication and to minimize the burden on CPA firms that
         are required to undergo both a PCAOB inspection and a peer review.

         GAO envisions a system of coordination in which peer reviewers would place
         appropriate reliance on a firm's PCAOB inspection report such that peer reviewers
         could use this information to possibly reduce the scope of their peer review, as
         appropriate. In order to make such a system possible, peer reviewers would need
         specific information and access to documentation on the scope of the inspections or
         information from the PCAOB on the specific level of assurance and reliance that can
         be placed on the inspection reports for purposes of planning the scope of the peer
         review engagement.

         Coordination of effort between PCAOB inspections and peer reviews is particularly
         important because many CPA firms are subject to the peer review requirements of
         GovernmentAuditing Standards promulgated by the GAO under the statutory
         authority awarded to the Comptroller General of the United States. For example, the
         following laws and regulations require peer reviews as applicable under Government
         Auditing Standards:

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