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A88654 1 (2005-05-02)

handle is hein.gao/gaobadvwf0001 and id is 1 raw text is: 

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


         May 2, 2005


         Mr. James M. Sylph
         Technical Director
         International Auditing and Assurance Standards Board
         545 Fifth Avenue, 14' Floor
         New York, NY 10017

         Subject: Proposed Revisions to International Standard on Auditing No. 320-
                 Materiality in the Identification and Evaluation of Misstatements

         This letter provides the U.S. Government Accountability Office's (GAO) comments on
         the International Auditing and Assurance Standards Board (JAASB) December 2004,
         proposed revisions to International Standard on Auditing (ISA) No. 320 - Materiality
         in the Identification and Evaluation of Misstatements.

         GAO actively coordinates with accountability organizations around the world,
         and actively participates in the International Organization of Supreme Audit
         Institutions (INTOSAI), the professional organization of the national audit offices of
         184 countries. Through our international work, we strive to strengthen professional
         standards, promote best practices, provide technical assistance, leverage resources,
         and develop strategic working relationships that allow us to extend our institutional
         knowledge and experience around the world.

         We commend the JAASB for its work to establish high quality auditing and assurance
         standards and to improve the uniformity of practice by professional accountants
         throughout the world. Overall, we support the JAASB's proposed revisions to ISA
         320. We especially support the increased recognition of the need for greater
         consideration of not only size but also an entity's nature and circumstances when
         determining materiality and evaluating misstatements. We believe that the proposed
         standard could be enhanced in several areas that would strengthen audits in both the
         public and private sectors. Our specific comments are included in the comment letter
         of the INTOSAI Working Group on Financial Audit Guidelines dated April 22, 2005.
         The INTOSAI Working Group comment letter includes several suggested
         enhancements and, most notably, it includes proposed public sector guidance to
         include in the proposed standard. We believe that the changes proposed by the
         INTOSAI Working Group would strengthen audits in both the public and private
         sectors. A copy of the INTOSAI Working Group comment letter is enclosed.

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