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A88761 1 (2009-12-22)

handle is hein.gao/gaobadvwx0001 and id is 1 raw text is: 


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       A countabiIlty  I integrity I Reiability
United States Government Accountability Office
Washington, DC 20548





         December 22, 2009

         Ms. Sherry Hazel
         Audit and Attest Standards
         American Institute of Certified Public Accountants
         1211 Avenue of the Americas
         New York, New York 10036-8775

         Subject: AICPA Auditing Standards Board (ASB) September 2009 Exposure Draft for
         a proposed SAS, Engagements to Report on Summary Financial Statements.

         This letter provides the U.S. Government Accountability Office's (GAO) comments on
         the ASB's proposed SAS on summary financial statements. Overall we support the
         proposed SAS.

         Availability of Audited Financial Statements
         The ASB is seeking specific comments on the requirement for the audited financial
         statements to be readily available. Specifically, the proposed SAS requires the auditor
         to obtain management's agreement that it acknowledges and understands its
         responsibility to make the audited financial statements, from which the summary
         financial statements have been derived, readily available to the intended users of the
         summary financial statements.

         We believe that the term 'readily available' is too restrictive and that the ISA 810
         wording on the availability of audited financial statements is more appropriate. ISA
         810 states that the audited financial statements need to be available to the intended
         users of the summary financial statements without undue difficulty. We suggest using
         wording similar to paragraph 6 (b) ii and iii and paragraph A8 of ISA 810, as follows:

               6. Before accepting an engagement to report on summary financial statements,
               the auditor      : (Ref: Para. A2)
                      (a) Determine whether the applied criteria are acceptable; (Ref:
                      Para.vA3-A7)
                      (b) Obtain the agreement of management that it acknowledges and
                      understands its responsibility:
                            i. For the preparation of the summary financial statements, in
                            accordance with the applied criteria;

                            ii. To make the audited financial statements available to the
                            intended users of the summary financial statements without

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