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A88635 1 (2009-12-15)

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United States Government Accountability Office
Washington, DC 20548

         December 15, 2009


         Ms. Sherry Hazel
         Audit and Attest Standards
         American Institute of Certified Public Accountants (AICPA)
         1211 Avenue of the Americas
         New York, New York 10036-8775

         Subject: AICPA Auditing Standards Board (ASB) September 2009 Exposure Draft of
         proposed Statement on Auditing Standards (SAS) Audits of Group Financial
         Statements (Including the Work of Component Auditors).

         This letter provides the U.S. Government Accountability Office's (GAO) comments on
         the ASB's proposed statement on auditing standards. GAO supports the proposed
         SAS and believes that it will help improve the quality of group audits. We believe that
         the option for a group auditor to refer to component auditors in the group auditor's
         report is necessary to help preserve transparency, maximize audit efficiency for the
         group auditor, and potentially reduce situations in which the group auditor must
         qualify or disclaim an audit opinion, as noted in our comments below Our responses
         to the questions in the Board's Issues for Consideration and Specific Comments are
         provided in this letter. Editorial changes and other comments are included in the
         attachment to this letter.

         Issues for Consideration
         The Board asks respondents specifically to consider the following questions:

         1. Should auditors be permitted to make reference to the audit of a
         component auditor in the auditor's report on the group financial statements?

         We strongly support the option to allow the auditor to make reference to the audit of
         a component auditor in the auditor's report on group financial statements. When
         done in accordance with the requirements of this SAS, the option of making reference
         to other auditors (divided responsibility) can improve audit efficiency for the group
         auditor without sacrificing effectiveness. It also preserves transparency by explaining
         in the group auditor's report the portions of the audit performed by the component
         auditor.
         Although this represents a difference from international standards, we believe this
         difference is necessary. In some situations, the group auditor's making reference to
         the audit of the component auditor is the only practical and/or feasible option for
         completing the audit. For example, a component of a government entity may be
         required by law or regulation to have its financial statements audited by auditors
         other than the group auditor, or management of the group may not have the authority

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