EY Comment letters
10 March 2017
Responding to non-compliance with laws and regulations from the AICPA Professional Ethics Division
The Professional Ethics Division issued this exposure draft seeking comments on a proposal which provides guidance for members in public practice and in business when they encounter actual or suspected act of non-compliance with laws or regulations (NOCLAR) at a client or within the employing organization. Comments are due by 12 May 2017.
9 January 2017
Proposed revised and new interpretations applicable to members in business
The Professional Ethics Executive Committee exposed for comment, revisions to the “Knowing Misrepresentations in the Preparation of Financial Statements or Records” interpretation under the “Integrity and Objectivity Rule”, applicable to members in business. Comments are due by 17 April 2017.
15 December 2016
Client and attest client: Proposed revised definitions of client and attest client as well as related definitions, interpretations, and other guidance
The AICPA Professional Ethics Executive Committee is exposing for comment revisions to the definitions of “Client” and “Attest Client,” including the relocation of the government provision from the definition of “Client” to the “Simultaneous Employment or Association With an Attest Client” interpretation under the Independence Rule. Comments are due by 15 May 2017.
13 July 2016
Auditor involvement with exempt offering documents
The proposed SAS includes performance requirements when the auditor is involved with an exempt offering document. Involvement is determined by a two-benchmark model: (1)The auditor’s report on financial statements or the auditor’s review report on interim financial information is included or incorporated by reference in an exempt offering document, and (2) The auditor performs one or more specified activities with respect to the exempt offering document. Specified activities which trigger involvement are included in the proposed SAS. Although an auditor is not required to become involved in an exempt offering document unless the benchmarks defining involvement are met, auditors are not precluded from becoming voluntarily involved with an offering document in other circumstances. Comments are due by 13 October 2016.
6 July 2016
Amendment to Statement on Standards for Accounting and Review Services No. 21 Section 90, Review of financial statements
The AICPA Accounting and Review Services Committee (ARSC) issued an exposure draft that would amend the AICPA’s standard on reviews of financial statements. AR-C Section 90 includes requirements and guidance when supplementary information accompanies reviewed financial statements and the accountant’s review report thereon. ARSC determined that certain revisions are necessary to correct the requirements and guidance related to reporting on supplementary information. These revisions would be accomplished by amending paragraphs .05 and .80–.82 of AR-C Section 90, Review of Financial Statements, and the corresponding application paragraphs. Comments are due by 2 September 2016.
5 July 2016
The auditor's consideration of an entity's ability to continue as a going concern
This proposal would supersede SAS No. 126 and amend various sections of SAS No. 122. The ASB is pursuing a strategy to converge its standards with those of the IAASB and used International Standard on Auditing (ISA) 570 (Revised), Going Concern, as the base for the going concern proposal. The proposed SAS does not reflect any revisions to ISA 570 (Revised) related to the convergence with the IAASB’s auditor reporting standards. Those revisions will be considered during the ASB’s overall project on the auditor’s report. It includes proposed amendments to auditing standards addressing: audits of special-purpose frameworks and audits of single financial statements and specific elements, accounts, or items of a financial statement and interim financial information. Comments are due by 5 September 2016.
16 May 2016
The AICPA Professional Ethics Executive Committee (PEEC) is exposing for comment an independence interpretation that provides guidance to members on the provision of hosting services to clients. The PEEC believes hosting services involve situations where a client engages a member to have custody or control of data or records that the client uses to conduct its operations. As it is management’s responsibility to have custody and control over its assets, the PEEC believes providing hosting services creates threats to independence that are not at an acceptable level and cannot be reduced to an acceptable level by the application of safeguards; therefore, impairing independence. Comments are due by 18 July 2016.
8 December 2015
Compilation of prospective financial information, compilation of pro forma financial information, and Omnibus statement on standards for accounting and review services - 2016
The proposed SSARS Compilation of Prospective Financial Information provides the requirements and guidance with respect to compilations of prospective financial information. Requirements and guidance with respect to examinations and engagements to apply agreed-upon procedures to prospective financial information are retained in the clarified attestation standards. Those clarified standards have been finalized by the Auditing Standards Board and are expected to be issued in late December of 2015 or early January 2016. The proposed SSARS Compilation of Pro Forma Financial Information represents the clarity redraft of AR section 120, Compilation of Pro Forma Financial Information. The proposed SSARS Omnibus - 2016 represents revisions to AR-C sections 60, General Principles for Engagements Performed in Accordance With Statements on Standards for Accounting and Review Services; 70, Preparation of Financial Statements; 80, Compilation Engagements; and 90, Review of Financial Statements. Comments are due by 6 May 2016.
14 August 2015
Amendment to Statement on Auditing Standards No. 122 Section 700, Forming an opinion and reporting on financial statements
Auditors of entities whose audits are within the jurisdiction of the PCAOB are required to be registered with, and subject to inspection by, the PCAOB. In these situations, the AICPA Code of Professional Conduct requires members to conduct the audit of the financial statements in accordance with the standards of the PCAOB and does not also require an audit to be conducted in accordance with GAAS. Other situations exist in which an entity whose audits are not within the jurisdiction of the PCAOB desires to obtain an audit conducted under PCAOB auditing standards. In these situations, the AICPA Code of Professional Conduct requires members to also conduct the audit in accordance with GAAS, which results in the audit being conducted in accordance with multiple auditing standards. The financial statements and the auditor’s report may, in some circumstances, be filed with the SEC. This proposed amendment provides requirements and guidance for reporting on an audit conducted in accordance with both GAAS and the standards of the PCAOB. Comments are due by 30 September 2015.
15 June 2015
Trust services principles and criteria for security, availability, processing integrity, confidentiality, and privacy
The Assurance Services Executive Committee (ASEC) of the AICPA is revising the trust services principles and criteria to clarify, eliminate redundancy in, and update the criteria to reflect the changing technology and business environment. The criteria related to the security, availability, processing integrity, and confidentiality principles were revised in 2014 and are contained in paragraph .15 of TSP section 100. ASEC is seeking comments specifically on changes resulting from the restructuring of the trust services privacy principle, CC3.1, CC3.3, C1.7 and C1.8. Comments are due 15 August 2015.
16 April 2015
Affiliate proposed revised definition
The AICPA Professional Ethics Division is exposing for comment revisions to the definition of “Affiliate” [AICPA, Professional Standards, ET sec. 0.400.02]. The proposal provides guidance on how to treat multiemployer employee benefit plans under this definition. Comments are due 18 May 2015.
10 December 2014
Firm mergers and acquisitions
The proposal provides guidance to members in situations where independence with respect to an attest client may become impaired as a result of a firm merger or acquisition. Comments are due 15 May 2015.
18 September 2014
Reporting on an examination of controls at a service organization relevant to user entities’ internal control over financial reporting: clarification and recodification
The ASB has issued a third exposure draft resulting from the Attest Clarity Project. Among other things the proposed SSAE revises extant AT section 801, Reporting on Controls at a Service Organization (AICPA, Professional Standards), to conform it with chapters 1-4 of an updated version of the Proposed SSAE Attestation Standards: Clarification and Recodification, and address certain issues encountered in practice. Comments are due 18 December 2014.
10 September 2014
An audit of internal control over financial reporting that is integrated with an audit of financial statements
The ASB concluded that, because engagements performed under extant AT section 501, as well as related attestation interpretation No. 1, are required to be integrated with an audit of financial statements, it would be appropriate to move the content of extant AT section 501 from the attestation standards into GAAS. Extant AT section 501 is expected to be withdrawn when the proposed SAS is issued as a final standard. The ASB will consider developing an attestation standard addressing examinations of internal control other than internal control over financial reporting that is integrated with an audit of financial statements at a later date. Comments are due 10 December 2014.
16 June 2014
Breach of an independence interpretation
The AICPA’s Professional Ethics Executive Committee (PEEC) is restructuring the Institute’s ethics standards to improve the AICPA Code of Professional Conduct (Code) so that members and others can apply the rules and reach correct conclusions more easily and intuitively. The PEEC is exposing for comment proposed standards revisions which provide guidance to members in public practice concerning a breach of an independence interpretation. Comments are due 16 September 2014.
13 February 2014
Amendment to Statement on Auditing Standards No. 122, Statements on Auditing Standards: Clarification and Recodification, section 920, Letters for Underwriters and Certain Other Requesting Parties, as amended
This exposure draft amends AU-C Section 920, Letters for Underwriters and Certain Other Requesting Parties, to further clarify the standard, help auditors in implementation, and avoid unintended changes to previous practice. Comments are due 15 April 2014.
26 November 2013
Framework for performing and reporting on compilation and review engagements
This exposure draft would supersede paragraphs .01 - 04 and .09 - .51 of AR section 60, Framework for Performing and Reporting on Compilation and Review Engagements. Comments are due by 2 May 2014.
26 November 2013
Omnibus proposal - Proposed revised and new interpretations
The Professional Ethics Executive Committee is exposing for comment revised Interpretation No. 102-2, "Conflicts of interest for members in public practice," and new Interpretation No. 102-7, "Conflicts of interest for members in business," under Rule 102, Integrity and Objectivity which provide guidance to members in public practice and business concerning conflicts of interest. Comments are due by 27 January 2014.
10 September 2013
Proposed definition of those charged with governance
The Professional Ethics Executive Committee (PEEC) of the AICPA has issued an exposure draft of a new definition of the term “those charged with governance” under the AICPA Code of Professional Conduct (Code). Comments are due by Sunday, November 10, 2013.
30 July 2013
Trust services principles and criteria
The proposal, The trust services principles and criteria for security, availability, processing integrity, confidentiality, and privacy, is intended to increase the clarity of the criteria, eliminate redundancy amongst the criteria and update the criteria based on the changing technology and business environment. The comment deadline for this exposure draft is 30 September 2013.
24 July 2013
Attestation standards: Clarification and recodification
This proposed Statement on Standards for Attestation (SSAE) would supersede AT sections 20, Defining Professional Requirements in Statements on Standards for Attestation Engagements; 50, SSAE Hierarchy; 101, Attest Engagements; and 201, Agreed-Upon Procedures Engagements (AICPA, Professional Standards). It represents the redrafting of those AT sections to apply the Auditing Standards Board’s (ASB’s) clarity drafting conventions. To assist respondents in identifying changes and in responding to this request to comment on the proposed SSAE, the Audit and Attest Standards staff has prepared a matrix document, which identifies the disposition of the requirements in extant AT sections 20, 50, 101, and 201 within the proposed SSAE. The ASB is seeking comments specifically on changes resulting from applying the clarity drafting conventions and their effect on the content of the proposed SSAE. Comments are due by 24 October 2013.
19 November 2012
Review of Financial Statements
As part of its Clarity Project, the Accounting and Review Services Committee (ARSC) has separated the review standards into two separate proposed standards. The proposed SSARS Review of Financial Statements addresses those areas that are applicable to a basic review engagement, and the proposed SSARS Review of Financial Statements -- Special Considerations addresses those areas that are less frequently encountered. The proposed SSARSs would supersede paragraphs 1.07-.08 and 3.01-.73 of SSARS No. 19, Compilation and Review Engagements. The comment period for the exposure draft of the proposed SSARSs ends on April 26.
8 November 2012
Financial Reporting Framework for Small-and Medium-Sized Entities
The Framework is an other comprehensive basis of accounting (also known as a special purpose framework) that, when finalized, will offer small- and medium-sized entities a reliable, relevant, and simplified financial reporting solution that addresses marketplace demands. Comments are due by January 30, 2013.
21 December 2010
Alert as to the intended use of the auditor's written communication
This proposal addresses the auditor’s responsibility to include an alert as to the intended use of the auditor’s report.
6 September 2016
Comment Letter - ASB’s going concern proposal
In our comment letter, we support the issuance of the Proposed Statement on Auditing Standards, The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern, to promote consistency between the auditing standards and ASU 2014-15, Presentation of Financial Statements – Going Concern, which will require management to evaluate whether there is substantial doubt about an entity’s ability to continue as a going concern. However, we disagree with the proposed requirement for the auditor to make inquiries of management about its knowledge of conditions or events beyond the period of management’s evaluation that raise substantial doubt about the entity’s ability to continue as a going concern.
29 September 2015
Comment Letter - AICPA proposed statement on forming an opinion and reporting on financial statements
In our comment letter, we support the proposed Statement on Auditing Standards. We believe the amendments will improve consistency in reporting when an audit is conducted in accordance with both GAAS and the standards of the PCAOB and the audit is not within the jurisdiction of the PCAOB.
22 January 2015
Comment Letter - AICPA’s proposed statement on standards for attestation agreements
In our comment letter on the Proposed Statement on Standards for Attestation Engagements, Reporting on an Examination of Controls at a Service Organization Relevant to User Entities’ Internal Control Over Financial Reporting: Clarification and Recodification, we supported clarifying the standards in accordance with the clarity drafting conventions used in the proposed general attestation standard.
10 December 2014
Comment letter - AICPA's Proposed Statement on Auditing Standard, An Audit of Internal Control Over Financial Reporting That Is Integrated With An Audit of Financial Statements
In our comment letter, we agree with the Auditing Standards Board’s proposal to move the content of AT section 501, An Examination of an Entity’s Internal Control Over Financial Reporting That Is Integrated With An Audit Of Its Financial Statements, from the attestation standards into generally accepted auditing standards. Further, we support the development of an attestation standard to address examinations of internal control that aren’t integrated with audits of financial statements.
23 June 2014
Comment Letter - AICPA’s proposed statement on standards for attestation engagements
In our comment letter on the Proposed Statement on Standards for Attestation Engagements, Subject-Matter Specific Attestation Standards: Clarification and Recodification, we supported clarifying the standards in accordance with the clarity drafting conventions used in the proposed general attestation standard.
29 November 2013
Comment Letter - Statement on standards for attestation engagements
In our comment letter, we supported the AICPA’s objective of addressing concerns about the clarity, length and complexity of the attestation standards. Additionally, we commented on several ways to increase consistency between examinations and audit engagements.