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A88702 1 (2005-08-02)

handle is hein.gao/gaobadvwq0001 and id is 1 raw text is: 


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


          August 2, 2005

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

          Subject: Proposed International Standard on Auditing (ISA) 600, The Audit of Group
          Financial Statements

          Dear Mr. Sylph:

          This letter provides the U.S. Government Accountability Office's (GAO) comments on
          the International Auditing and Assurance Standards Board's (JAASB) proposed ISA
          600, which was issued in March 2005.

          We have a serious concern about whether this proposed standard is viable in audits
          of large, complex, and diverse entities, whether in the public or private sector. We
          also have particular concerns about the implications for large public sector entities,
          such as national and state governments. The absence of alternatives could serve as a
          significant disincentive to large public entities that might otherwise want to adopt
          JAASB standards.

          We understand from discussions with JAASB staff that the JAASB's intent is to not
          allow reference to other auditors in the group auditors' report. We are very
          concerned that the proposed standard does not clearly articulate this important issue.
          More importantly, we strongly disagree with the JAASB's position on this matter,
          since we believe that the flexibility to refer to another auditor in the group auditors'
          report is essential to preserving transparency to the users of group financial
          statements, maximizing audit efficiency, and providing auditors and audited entities
          with practical options, especially when entities are large, complex, and diverse in
          nature, including national governments. Standards in the United States promulgated
          by the Government Accounting Standards Board and similarly by the Federal
          Accounting Standards Advisory Board define the criteria for components that are to
          be included in the financial statements of federal, state, or local government financial
          reporting entities. This has resulted in the frequent inclusion of components whose
          financial statements are audited due to legislative or other requirements by auditors
          other than the principal auditor engaged by the group financial reporting entity. Also,
          certain U.S. federal departments and agencies and a number of state and local
          governments require that the auditor proposing to perform audits of the group

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