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A93450 1 (2011-03-07)

handle is hein.gao/gaobadvxo0001 and id is 1 raw text is: 

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       Accountability , Integrity - Reliability
United States Government Accountability Office
Washington, DC 20548






         March 7, 2011


         Technical Manager
         International Accounting Education Standards Board
         International Federation of Accountants
         277 Wellington Street West, 4th Floor
         Toronto, Ontario M5V 3H2 CANADA

         Subject: International Education Standard (IES) 7, Continuing Professional
         Development: A Program of Lifelong Learning and Continuing Development of
         Professional Competence, December 2010

         This letter provides the U.S. Government Accountability Office's (GAO) comments on
         the International Accounting Education Standards Board's (IAESB) proposed
         revisions to the IES on continuing professional development (CPD). Overall, we agree
         with the changes made by the Board and we support the proposed standard. CPD
         requirements are an integral component of a professional accountant's competence
         and contribute to the profession's objective of providing high quality services to meet
         the needs of the public (including clients and employers).

         Our responses to the questions on the changes resulting from applying the clarity
         drafting conventions are detailed below.


         Comments from applying the clarity conventions
         (1) We believe that the objectives to be achieved by the member body as stated in the
         proposed IES are appropriate. However, we suggest rewording the opening sentence
         of the objective to improve consistency with the new clarity drafting conventions and
         with wording used in standards issued by other IFAC standard setting boards such as
         the International Auditing and Assurance Standards Board. The IES should contain a
         clear statement of the objectives to be achieved by the member body. Our suggested
         rewording would clarify that the member body is the one responsible for achieving
         the objective. We suggest the following wording for the first sentence of paragraph 7:
               The objective of

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