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


March 16, 2020

Office of the Secretary
Public Company Accounting Oversight Board
1666 K Street, NW
Washington, D.C. 20006-2803

PCAOB Release No. 2019-003, Concept Release: Potential Approach to Revisions to
PCA OB Quality Control Standards (December 17, 2019)

This letter provides GAO's comments on the Public Company Accounting Oversight Board's
(PCAOB) concept release regarding revising the PCAOB's quality control standards. GAO
promulgates generally accepted government auditing standards, which provide professional
standards for auditors of government entities in the United States.

We support the PCAOB's efforts to improve its quality control standards and the concept
release's approach of using the International Auditing and Assurance Standards Board's
International Standard on Quality Management (ISQM) 1 as a basis for the PCAOB's quality
standard. We understand that the PCAOB will need to make changes to ISQM 1 because of the
legal and regulatory environment in which firms that use PCAOB standards operate. However,
we believe that the PCAOB should not be overly prescriptive with the requirements in its future
quality control standard and should focus on making the requirements as principle based as
possible. We believe that the PCAOB addressing emerging issues, such as the use of network
firms and cybersecurity, could improve firms' quality. Finally, we believe that identified changes
would significantly improve the PCAOB's standards.

The PCAOB seeks comment on 58 specific questions. Our responses to the questions follow in
the enclosure to this letter.

Thank you for the opportunity to comment. If you have questions about this letter or wish to
discuss any of our responses, please feel free to contact me at (202) 512-3133 or
dalkinj@gao.gov.







James R. Dalkin
Director
Financial Management and Assurance

Enclosure


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