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In our comment letter, we support the efforts by the AICPA’s Auditing Standards Board (ASB) to improve the usefulness of the auditor’s report for audits of non-issuers. We support the proposal to set requirements for auditors engaged to report on key audit matters (KAMs) rather than require the reporting of KAMs. However, we believe it would be preferable for the ASB to align the KAMs requirements with the Public Company Accounting Oversight Board (PCAOB) requirements for reporting on critical audit matters to promote comparability among auditor’s reports issued in the US.
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