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A88693 1 (2005-05-09)

handle is hein.gao/gaobadvwl0001 and id is 1 raw text is: im Accountability * Integrity * Reliability United States Government Accountability Office Washington, DC 20548 May 9, 2005 Ms. Sherry Boothe Audit and Attest Standards American Institute of Certified Public Accountants 1211 Avenue of the Americas New York, New York 10036 Subject: Proposed statement on auditing standards Defining Professional Requirements in Statements on Auditing Standards dated March 2, 2005 This letter provides the U.S. Government Accountability Office's (GAO) comments on the Auditing Standards Board's (ASB) exposure draft of a proposed statement on auditing standards Defining Professional Requirements in Statements on Auditing Standards and a related proposed statement on standards for attestation engagements dated March 2, 2005. We appreciate the opportunity to have participated as a member of the task force that prepared this exposure draft and are pleased to contribute further to the deliberative process by providing comments on the exposure draft. GAO supports improved transparency and accountability in the accounting and auditing profession and commends the ASB on its efforts to improve the clarity of its auditing standards. We also commend the ASB for striving to achieve consistency with the standards of the Public Company Accounting Oversight Board (PCAOB) and the International Federation of Accountants (IFAC) in areas where consistency is appropriate. Following are our comments on the exposure draft. Paragraph references are to the proposed statement on auditing standards (SAS); however, given the interrelationship of these proposed statements, our comments are applicable to both proposals. Categories of Professional Requirements - Paragraph 4 We agree with the categories of requirements identified and defined by specific terms in the exposure draft to describe the degree of responsibility that the standards impose on auditors. We strongly support the requirement for documenting a departure from an applicable presumptive requirement. We agree that these departures should be rare, and that the documentation be required to include not only why the auditor decided to depart from the presumptive requirement, but also how the alternative procedures performed in the circumstances were sufficient to achieve the objectives of the presumptive requirement. We also agree with the language in the last sentence of paragraph 2 that states that Auditors have a responsibility to consider the entire text of a relevant SAS in carrying out their work

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