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A94946 1 (2011-06-03)

handle is hein.gao/gaobadvxu0001 and id is 1 raw text is: i A~contabi ity I Integrity Reliability United States Government Accountability Office Washington, DC 20548 June 3, 2011 Ms. Lisa A. Snyder, Director Professional Ethics Division American Institute of Certified Public Accountants New York, New York 10036-8775 Subject: AICPA Professional Ethics Executive Committee (PEEC) April 2011 Exposure Draft of a proposed pronouncement entitled Omnibus Proposal AICPA Professional Ethics Division - Interpretations and Definition. This letter provides the U.S. Government Accountability Office's (GAO) comments on the PEEC's Omnibus Proposal. The exposure draft (ED) contains proposals that will apply to members in business and industry, in addition to members in public practice, and requests specific comment on the two questions listed on page 14 of the ED. Our responses to these questions, along with other comments, are provided below. We support the PEEC's initiatives to achieve international convergence of ethics standards, but have concerns regarding certain terms used in the Omnibus Proposal. For these reasons, our comments will be primarily oriented to the proposed new definition of the term members in business and industry and the population to which this term applies under ET Section 92, Definitions. We also have comments on the use of the conceptual framework terms threats and safeguards in the proposed new Interpretation No. 501-10, Financial Interests, under Rule 501, Acts Discreditable. GAO's Comments to Specific Questions Proposed New Definition, Member in Business and Industry, Under ET Section 92, Definitions (1) Does the proposed definition appropriately capture all members in business and industry? Should there be additional wording added to include any other examples of members in business and industry? We believe the proposed definition of members in business and industry does not clearly distinguish between the members who would and those who would not be included in the definition and, accordingly, could lead to an inconsistent understanding of the term and application of the requirements. The proposed

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