December 10, 2014, letter commenting on the ASB Exposure Draft "An Audit of Internal Control Over Financial Reporting That Is Integrated With an Audit of Financial Statements"

This letter provides the U.S. Government Accountability Office's (GAO) comments on the ASB's proposed SAS, entitled "An Audit of Internal Control Over Financial Reporting That Is Integrated With an Audit of Financial Statements". We support ASB's efforts to apply clarity drafting conventions to extant Attestation Standards (AT) section 501, An Examination of an Entity's Internal Control Over Financial Reporting That Is Integrated With an Audit of Its Financial Statements. Because examinations performed under extant AT section 501 are required to be integrated with audits of financial statements, we also support ASB's decision to move the content of extant AT section 501 from the attestation standards into the auditing standards. We also encourage ASB to develop an attestation standard addressing examinations of internal control other than examinations of internal control over financial reporting that are integrated with audits of financial statements. We believe that developing such an attestation standard would be helpful to address examinations of internal control over operations, compliance, and other reporting, such as privacy or information security, as well as examinations of internal control over financial reporting that are not integrated with audits of financial statements (e.g., examinations of specific areas of internal control over financial reporting, such as monitoring controls, or examinations that do not satisfy the preconditions for an audit of internal control over financial reporting because the as of date specified in management's assertion about internal control over financial reporting does not correspond to the balance sheet date).