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A88653 1 (2006-09-29)

handle is hein.gao/gaobadvwe0001 and id is 1 raw text is: 




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


          September 29, 2006



          Mr. John Fogarty, Chair
          Auditing Standards Board
          American Institute of Certified Public Accountants
          1211 Avenue of the Americas
          New York, NY 10036-8775

          Subject: Proposed Statement on Quality Control Standards-A Firm System of
          Quality Control

          This letter provides the U.S. Government Accountability Office's (GAO) comments on
          the Auditing Standards Board's (ASB) July 28, 2006, exposure draft of a proposed
          Statement on Quality Control Standards (SQCS) -A Firm System of Quality Control.

          GAO commends the Auditing Standards Board's efforts to strengthen the quality
          control standards and guidance and thereby enhance the quality of auditors'
          work. We believe that an audit organization's quality assurance function is a
          fundamental and critical determinant of audit quality. We disagree, however, with the
          proposed significant departures from international standards, whereby the specific
          requirement for periodic inspections is omitted and engagement quality reviews
          performed prior to the audit report issuance are considered as an option for
          monitoring. Our concerns are discussed in greater detail below.

          Our comments on the proposed quality control standard focus on the following areas:
             * Periodic inspections and other monitoring procedures
             * Competencies of practitioners-in-charge
             * Small audit organizations
             * Engagement quality control review

          Periodic inspections and other monitoring procedures

          Paragraph 90 of the proposed standard contains a significant departure from
          International Statement of Quality Control (ISQC) No. 1 in that it omits a specific
          requirement for periodic inspections of a selection of completed engagements from
          the procedures required in a system of quality control. The proposed standard then
          goes on to give audit organizations a choice among different types of monitoring
          procedures in paragraph 93 by requiring either engagement quality control reviews,
          post-issuance reviews of specific engagement documents, or inspection procedures.
          Engagement quality reviews, however, are conducted prior to issuance of the audit

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