This letter provides the U.S. Government Accountability Office's (GAO) comments on the ASB's proposed SAS. Our views are consistent with our December 15, 2009 communication to the ASB on their September 2009 Exposure Draft of proposed Statement on Auditing Standards Audits of Group Financial Statements (Including the Work of Component Auditors.); GAO generally supports the proposed SAS and we believe that the primary effect will be to improve the quality of group audits.