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Published 1 (2023-05-01)

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


May  1, 2023

Mr. Willie Botha
Technical Director
International Auditing and Assurance Standards Board
529 Fifth Avenue
New  York, NY 10017

GAO's  Response  to the International Auditing and Assurance Standards  Board's
Exposure  Draft Proposed  Part 10, Audits of Group Financial Statements of the Proposed
International Standards of Auditing for Audits of Financial Statements of Less Complex
Entities

This letter provides GAO's comments on the International Auditing and Assurance Standards
Board's (IAASB) Proposed Part 10, Audits of Group Financial Statements of the Proposed
International Standards of Auditing for Audits of Financial Statements of Less Complex Entities.
GAO  promulgates generally accepted government auditing standards, which provide
professional standards for auditors of government entities in the United States.

We  do not support the IAASB's efforts to make group audit part of a standard for the audit of
financial statements of less complex entities (LCE). We believe that group audit is inherently
complex and not appropriate for LCE financial statement audit. We believe that there is an
inherent risk of group audit for LCEs being applied to more complex entities. In addition, we find
that the qualitative characteristics are insufficient to identify appropriate circumstances for using
a group audit for an LCE financial statement audit. While we agree with the exclusion of
component  auditors in group audits of LCEs, we find that the exclusion of requirements and
application material for how to use component auditors in the limited circumstances allowed
problematic.

The IAASB  seeks comment  on three 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 would like
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


Page 1

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