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A88416 1 (2008-05-30)

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


          May 30, 2008

          International Auditing and Assurance Standards Board
          International Federation of Accountants
          545 Fifth Avenue, 14th Floor
          New York, New York 10017

          Subject: International Auditing and Assurance Standards Board (JAASB)
          December 2007, Exposure Draft: ISAE 3402, Assurance Reports on Controls at a
          Third Party Service Organization

          This letter provides the U.S. Government Accountability Office's (GAO) comments on
          the JAASB's proposed International Standard on Assurance Engagements (ISAE)
          3402. Overall, we support the proposed standard.

          The Board has asked respondents to answer specific questions and to comment on
          other matters in the exposure draft. We provide the requested answers and comments
          in this letter and recommend specific wording changes in the related attachment.



          Request for Specific Comments

          Question 1.

          The IAASB would welcome views on the proposal that the ISAE be written for
          application to assertion-based engagements. In particular, the IAASB would welcome
          any views on whether there are situations in which it would not be possible or
          practicable for management of the service organization to provide an assertion.

          Response/Comment:

          We support the JAASB's decision to write the proposed standard for application to an
          assertion-based engagement, where the service organization's management confirms,
          in a statement made available to users, certain information about the design and, for
          type B reports, the operating effectiveness, of the service organization's controls. An
          assertion-based engagement is preferable to a direct reporting engagement, in which
          all relevant information is included in the service auditor's assurance report and there
          is no management assertion. Also, including in the report management's
          acknowledgement of its responsibility for the design and, for type B reports, the
          operating effectiveness, of controls serves as an important accountability mechanism,
          clearly informing report users that management is responsible for controls.

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