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A88705 1 (2005-08-10)

handle is hein.gao/gaobadvws0001 and id is 1 raw text is: 


   I

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


          August 10, 2005

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

          Subject: Proposed International Standard on Auditing (ISA) 705, Modifications to the
          Opinion in the Auditor's Report and proposed ISA 706, Emphasis of Matter
          Paragraphs and Other Matters Paragraphs in the Independent Auditor's Report

          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 ISAs
          705 and 706 issued in March 2005.

          We support the IAASB's effort to enhance the guidance for issuing modifications to
          the auditor's opinion and for including emphasis of matter paragraphs and other
          matters paragraphs in the auditor's report. We also support its efforts to assure
          consistency of the proposed standards with ISA 700, The Independent Auditor's
          Report on a Complete Set of General Puipose Financial Statements. However, we
          have concerns with certain matters in the proposed standards that we discuss below.

          Proposed ISA 705 - Modifications to the Opinion

          While we agree with the IAASB's intent to provide additional guidance on
          circumstances that may result in a modification to the auditor's opinion and the type
          of opinion appropriate in the circumstances, we believe that:

          1) The guidance does not adequately discuss the need for auditors to consider the
             fair presentation of the financial statements when they determine the type of
             opinion to issue. ISA 700.15 discusses extremely rare circumstances when
             applying the financial reporting framework results in misleading financial
             statements and states that in those circumstances auditors should consider the
             need to modify the auditors' report. We recommend adding a reference to ISA
             700.15 or a discussion similar to ISA 700.15 to the section titled Circumstances
             Resulting in a Modification to the Auditor's Opinion in order to improve the
             clarity and completeness of the proposed standard and to assure consistency with
             ISA 700.

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