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A88556 1 (2007-10-31)

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 A                    0                                                  Comptroller General
M   M MAccountability * Integrity * Reliability                          of the United States
United States Government Accountability Office
Washington, DC 20548



      October 31, 2007


      International Federation of Accountants
      545 Fifth Avenue, 14th Floor
      New York, New York 10017

      Subject: International Auditing and Assurance Standards Board (JAASB) July 2007
      Exposure Draft: ISA 530, Audit Sampling

      This letter provides the U.S. Government Accountability Office's (GAO) comments on the
      JAASB's proposed revisions to ISA 530.

      GAO is committed to transforming and modernizing the accountability profession;
      accordingly, we support the IAASB's efforts to improve the clarity of its auditing
      standards. Overall, we support the proposed revisions to ISA 530. In particular, we
      believe that the proposed revisions to ISA 530 help clarify the auditor's responsibility to
      project and evaluate sample results.

      In our review of the proposed standard, we identified certain issues for which we have
      proposed suggestions. Specifically, we believe certain provisions of the draft standard
      are inconsistent with statistical principles and, therefore, require revision to help avoid
      having auditors reach inappropriate audit conclusions.

      Because statistical principles are too complex to explain in detail in an auditing standard,
      we encourage the JAASB to develop a sampling audit guide that would provide additional
      guidance on this complex topic. In addition to assisting users, such an audit guide would
      encourage greater consistency of practice. Alternatively, the standard could refer users
      to guides and textbooks developed by others, such as the American Institute of Certified
      Public Accountants (AICPA) guide on audit sampling.

      Our comments below offer suggestions for improving the following issues discussed in
      the proposed standard:

        * Anomalies
        * Sample design, size and selection of items for testing
        * Clarifying the role of random selection
        * Enhancing guidance on value weighted selection
        * Factors influencing sample size
        * Sample selection methods

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