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A88369 1 (2003-11-06)

handle is hein.gao/gaobadvur0001 and id is 1 raw text is: ib & -, G A 0 Comptroller General . Accountability * Integrity * Reliability of the United States United States General Accounting Office Washington, DC 20548 November 6, 2003 Office of the Secretary Public Company Accounting Oversight Board 1666 K Street, NW Washington, DC 20006 Subject: PCAOB Rulemaking Docket Matter No. 009-Proposed Rule Regarding Certain Terms Used in Auditing and Related Professional Practice Standards This letter provides the U.S. General Accounting Office's (GAO) comments on the Public Company Accounting Oversight Board's (PCAOB) October 7, 2003, proposed rule explaining the terminology it will use in auditing and related professional practice standards to describe the requirements of those standards for registered public accounting firms. GAO supports improved transparency and increased accountability in the accounting and auditing professions, and we support the PCAOB's efforts in this endeavor. We commend the PCAOB for promoting clear, concise, and definitive language to distinguish the differing levels of professional requirements in its auditing standards. Following are our comments on this PCAOB proposed rule. Clarify and Expand Documentation Requirement GAO especially supports the requirement in proposed Rule 3101(a)(2) that documented evidence be prepared during the audit to justify deviations from presumptively mandatory requirements. Audit documentation should demonstrate compliance with professional standards and justify reasons for any deviation from the standards. This requirement also is consistent with the concepts discussed at the September 29, 2003, PCAOB Roundtable on Audit Documentation and with the requirements of Government Auditing Standards.' The section-by-section analysis of proposed Rule 3101(a)(2) in Appendix 2 clearly spells out, Such evidence must be memorialized at the time of the audit, not after- the-fact, and must be made a part of the audit workpapers. We support this concept. The proposed rule itself is not as explicit on this matter. Therefore, we suggest 'U.S. General Accounting Office, Government Auditing Standards, GAO-03-673G (Washington, D.C.: June 2003).

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