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A92216 1 (2010-11-01)

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       Acountabiity  I Integrity * Reliability
United States Government Accountability Office
Washington, DC 20548





         November 1, 2010


         International Auditing and Assurance Standards Board
         545 Fifth Avenue, 14th Floor
         New York, New York 10017 USA

         Subject: International Auditing and Assurance Standards Board (JAASB) July 2010
         Exposure Draft on Proposed International Standards on Auditing (ISA) 315 (Revised),
         Identifying and Assessing the Risks of Material Misstatement through
         Understanding the Entity and Its Environment and ISA 610 (Revised), Using the
         Work of Internal Auditors.

         This letter provides the U.S. Government Accountability Office's (GAO) comments on
         the JAASB's proposed revisions to the ISAs on identifying and assessing the risk of
         material misstatement and using the work of internal auditors. We agree with the
         changes made by the Board and we support the proposed standards.

         ISA 315
         We believe that the proposed revisions to ISA 315 will help clarify the auditor's
         responsibility with regard to identifying and assessing risks of material misstatements
         through understanding the entity and its environment. We especially support the
         JAASB's position of requiring that the auditor inquire of appropriate individuals
         within the internal audit function as part of the risk assessment process. This will
         further inform the external auditor's understanding of the entity and its environment,
         which forms the basis of the risk assessment. Also, it encourages effective
         communication between the internal auditors and the external auditors which
         supports an environment in which internal auditors can bring significant matters that
         may affect the work of the external auditor to the external auditor's attention.


         While we support the revisions to ISA 315, we suggest including a section in ISA 315
         that addresses special considerations for the audit of public sector entities. This
         consideration for governmental entities would be referenced to paragraph 6(a) of ISA
         315 and would provide important guidance on the broader audit objectives in audits
         of government entities that use the work of internal auditors. We suggest wording
         this government consideration as follows:

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