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Published 1 (2020-02-28)

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G      A     O        U.S. GOVERNMENT ACCOUNTABILITY OFFICE
441 G St. N.W.
Washington, DC 20548


February 28, 2020

Mr. Brian S. Lynch
Ms. Toni Lee-Andrews
American Institute of Certified Public Accountants
1345 Avenue of the Americas
New York, NY 10019

GAO's Response to the American Institute of Certified Public Accountants Professional
Ethics Division November 15, 2019 Consultation Paper, Strategy and Work Plan

This letter provides GAO's response to the American Institute of Certified Public Accountants
(AICPA) Professional Ethics Division's consultation paper, Strategy and Work Plan. GAO
promulgates generally accepted government auditing standards (commonly referred to as
GAGAS), which provide professional standards for auditors of government entities in the United
States. These standards include ethical principles for auditors in the government environment.

As the supreme audit institution for the United States as well as an auditing standard-setting
organization, GAO is committed to supporting the public interest and the interest of the public
sector auditing community.

Response to Request for Comments

We identified certain proposed new standard-setting projects and new member enrichment
projects as matters of particular interest to GAO and provide the following responses to AICPA's
Professional Ethics Executive Committee's (PEEC) request for input:

1. Business relationships

    a) What business relationships do firms have with either nonattest or attest clients?

We are aware that many audit organizations provide professional services, such as
bookkeeping; financial statement preparation; internal audit assistance; internal control
evaluation; information technology services; appraisal, valuation, and actuarial services; and
various management consulting services to their nonattest and attest clients.

    b) What additional guidance related to business relationships, if any, would be
       helpful to address in the code?

The existing code in section 1.265 focuses on business relationships between audit
organizations and clients that pertain to cooperative arrangements and joint closely held
investments. We believe that expanding the code to identify common nonattest services that
audit organizations provide would enhance and clarify the concept of business relationships to
reflect current practice in the audit industry, which now includes an extensive array of vendor-
type or outsourced management services that audit organizations provide to their clients.

In addition, we believe that more guidance would be helpful to address business relationships in
which auditors are engaged to both provide a nonattest service, such as preparing an entity's


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