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Overview
In our comment letter, we express our support for the proposal's objective to promote consistency in practice, clarify definitions, and enhance the quality of audits for financial statements of non-issuers by aligning more closely with PCAOB requirements for external confirmation. However, we recommend that "direct access" be recognized as an alternative method for obtaining relevant and reliable information, rather than being included in the definition of external confirmation. Additionally, we suggest removing the proposed exceptions to the proposed presumptive requirement to use external confirmation procedures for cash and cash equivalents held by third parties, in line with the PCAOB's approach.