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A88403 1 (2005-08-26)

handle is hein.gao/gaobadvus0001 and id is 1 raw text is: 

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

         August 26, 2005


         Mr. John A. Fogarty, Chair
         Audit and Attest Standards
         American Institute of Certified Public Accountants
         1211 Avenue of the Americas
         New York, New York 10036

         Subject: Exposure Draft of Proposed Statements on Auditing Standards on Audit
         Risk, Dated June 15, 2005

         Dear Mr. Fogarty:

         This letter provides the U.S. Government Accountability Office's (GAO) comments on
         the Auditing Standards Board's (ASB) June 15, 2005, exposure draft of proposed
         Statements on Auditing Standards (SAS) on Audit Risk.

         We commend the ASB's efforts to strengthen standards in the area of the auditors'
         assessment of the risks of material misstatement in a financial statement audit.
         We especially support the new emphasis on the linkage between the auditors' risk
         assessment and the design and performance of audit procedures whose nature,
         timing, and extent are responsive to the assessed risks. We are especially pleased
         that the proposed standards encourage auditor evaluation and testing of internal
         control by eliminating the option of defaulting to maximum risk without
         documenting the basis for that conclusion. In addition, we are pleased that the
         proposed standards clearly use must and should terminology and would require
         auditors to (1) quantify materiality, (2) quantify tolerable misstatement at less than
         materiality, and (3) communicate known and likely misstatements to management
         and to those charged with governance. These changes should enhance audit quality.
         We also commend the AICPA for its commitment to developing a related audit guide
         and training materials.

         The Board has requested specific comments related to clarification of misstatements
         identified by the auditor and to evaluating audit findings. We have addressed these
         important issues in Enclosure 1 to this letter.

         Our detailed comments on the proposed standards and amendments are included in
         Enclosure 2 to this letter. We ask that you consider closely our comment on the level
         of assurance provided in an audit, which is discussed on pages 1-2 (Enclosure 2) and
         is related to the amendments to SAS 1, and our comment on the need for auditors to
         evaluate the fair presentation of an entity's financial statements, which is discussed
         on pages 12-13 (Enclosure 2) and is related to the proposed standard on Performing

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