The American Institute of Certified Public Accountants (AICPA) sets ethical standards for the accounting profession and US auditing standards for audits of private companies, non-profit organizations and federal, state and local governments.

    Proposed rules
    EY Comment letters

    Proposed rules

    11 January 2019

    Proposed interpretation state and local government client affiliates (formerly Entities included in state and local government financial statements)
    On 7 July 2017, the Professional Ethics Executive Committee (PEEC) exposed for comment revisions to the interpretation “State and Local Government Entities” (ET sec. 1.224.020). These revisions are referred to in this explanation as the initial exposure draft. Based upon feedback received and further discussion of the issues, PEEC made a number of changes to the initial exposure draft. As such, PEEC is issuing this new exposure draft (second exposure draft) and seeks feedback on only the changes from the initial exposure draft. PEEC believes the revisions represent substantive changes to what was proposed in the initial exposure draft. Comments are due by 11 March 2019.

    20 December 2018

    Description criteria for a description of an entity’s production, manufacturing, or distribution system in a SOC for supply chain report
    Because entity management is ultimately responsible for designing, implementing, and operating the entity’s system and the controls within that system, it is also responsible for preparing, and presenting in the SOC for Supply Chain report, the description of the entity’s system. Entity management uses description criteria when preparing the description, and the practitioner uses it when evaluating whether the description is in accordance with the description criteria. This document presents the description criteria for use when preparing the description of the entity’s system; it does not present the trust services control criteria against which the effectiveness of system controls is measured and evaluated. Comments are due by 28 February 2019.

    11 July 2018

    Revisions to SSAEs No. 18, Attestation standards: Clarification and recodification
    This proposed Standards for Attestation Engagements (SSAEs) would supersede AT-C section 105, Concepts Common to All Attestation Engagements; AT-C section 205, Examination Engagements; AT-C section 210, Review Engagements; and AT-C section 215, Agreed-Upon Procedures Engagements. Comments are due 11 October 2018.

    20 June 2018

    Disclosing client information in connection with a quality review
    The proposal requires that members performing quality reviews not use to their advantage or disclose any information obtained in the course of the review. Furthermore, members obtaining such reviews should be satisfied that the disclosure requirements of Treas. Reg. 7216 are met at a minimum and apply additional safeguards as the member determines necessary. The requirements of Treas. Reg. 7216 regarding disclosures of information in connection with quality reviews are not less restrictive than the requirements of the AICPA “Confidential Client Information Rule” (ET sec. 1.700.001) and are considered adequate safeguards against prohibited disclosures. Similar to other reviews of a member’s practice, if threats are still not at an acceptable level, the member should take additional precautions, such as entering into a confidentiality agreement or de-identifying the information. Comments are due by 20 August 2018.

    15 March 2018

    Information system services
    The Professional Ethics Executive Committee (PEEC) is exposing for comment a revision to the "Information Systems Design, Implementation, or Integration" interpretation. In May 2015, PEEC began a project to determine what changes were necessary to the "Nonattest Services" subtopic (ET sec. 1.295) of the “Independence Rule” (ET sec. 1.200.001) considering the current information technology service offerings of members. With the assistance of current information technology experts, PEEC reviewed its "Information Systems Design, Implementation, or Integration" interpretation and is proposing certain clarifications that will allow for a better understanding of where significant threats to independence exist. Comments are due by 15 June 2018.

    28 November 2017

    Auditor reporting
    The call for changes to the auditor reporting model in the United States and other jurisdictions around the world resulted from a desire by users of financial statements and the auditor’s report for more information about significant aspects of the audit. The proposal makes amendments to heighten auditor focus on disclosures throughout the performance of an audit of financial statements. It is focused on the form and content of the auditor’s report and does not change the existing requirements for performing an audit in accordance with GAAS. Comments are due by 15 May 2018.

    28 November 2017

    Omnibus statement on auditing standards - 2018
    The proposal would amend SAS No. 122, Statements on Auditing Standards: Clarification and Recodification and SAS No. 130, An Audit of Internal Control Over Financial Reporting That Is Integrated With an Audit of Financial Statements. Comments are due by 15 May 2018.

    28 November 2017

    The auditor’s responsibilities relating to other information included in annual reports
    The ASB believes that the proposed SAS will benefit users of audited financial statements and other information by improving audit quality by bringing greater consistency regarding auditors’ consideration of other information and reducing diversity in practice with respect to documents that are considered to be with-in the scope of the proposed SAS; increasing the value of the audit, without changing its scope, in a cost-beneficial manner, through enhancing the auditor’s responsibility with respect to the other information; and narrowing potential or existing expectation gaps through requiring auditors to articulate in their re-ports their responsibilities under the proposed SAS, and the outcome of their work relative to the other information. Comments are due by 15 May 2018.

    20 October 2017

    Leases interpretation
    The Professional Ethics Executive Committee reviewed the FASB updated standard for leases and the related independence requirements of other standard setters and regulators. The proposed revision addresses all leases between covered members and attest clients except automobile leases with lending institution attest clients. Comments are due by 15 January 2018.

    14 September 2017

    Omnibus statement on standards for accounting and review services - 2018
    The Accounting and Review Services Committee (ARSC) determined that SSARSs should include requirements and guidance when an accountant is engaged to perform a compilation or review of financial statements prepared in accordance with a financial reporting framework generally accepted in another country or in accordance with both SSARSs and another set of compilation or review standards. ARSC also determined that revisions should be made to AR-C section 90 to substantially harmonize the requirements with respect to the accountant’s consideration of an entity’s ability to continue as a going concern with those in AU-C section 930, resulting from the issuance of SAS No. 132 and to include a specific written representation regarding disclosure of all information relevant to the use of the going concern assumption in the financial statements. Comments are due by 14 December 2017.

    1 September 2017

    Selected procedures
    This proposal, issued by the AICPA Accounting and Review Services Committee (ARSC), would result in flexibility provided to practitioners in performing and reporting on a procedures and findings service. Under the proposal practitioners would be permitted to perform procedures and report in a procedures and findings format beyond what's currently provided by AT-C Section 215, Agreed-Upon Procedures Engagements. The proposal is a joint effort of ARSC and the AICPA Auditing Standards Board, and its effective date will not be earlier than for reports dated on or after May 1, 2019. Comments are due by 1 December 2017.

    24 July 2017

    Proposed revision of description criteria for a description of a service organization’s system in a SOC 2® report
    The AICPA is in the process of revising AICPA Guide Reporting on an Examination of Controls at a Service Organization Relevant to Security, Availability, Processing Integrity, Confidentiality, or Privacy (SOC 2®). That guide has been developed to assist service auditors engaged to examine and report on a service organization’s controls relevant to security, availability, processing integrity, confidentiality, or privacy, which is known as a SOC 2 examination. The description criteria for a description of a service organization’s system are currently presented in paragraphs 1.26 and 1.27 of the guide. With the forthcoming revision of the guide, however, description criteria will no longer be presented within the body of the guide. Instead, description criteria for use in a SOC 2 examination will be published as a stand-alone document. Comments are due by 7 September 2017.

    14 July 2017

    Long association of senior personnel with an attest client
    In developing the proposed interpretation, the Professional Ethics Executive Committee (PEEC) of the AICPA considered the new ethics standard Long Association of Personnel with an Audit Client of the IESBA Code of Ethics for Professional Accountants (IESBA code). The PEEC believes that though many of the proposed requirements are consistent with that of the new IESBA standard, certain differences are necessary to enhance the clarity of the proposed interpretation and make it relevant to AICPA members in the United States. Certain provisions of the IESBA standard were not included in the AICPA proposal because the SEC already addresses provisions such as partner rotation for registered companies. The proposal addresses familiarity threats due to long association with an attest client. Comments are due by 15 September 2017.

    7 July 2017

    State and local government entities
    The Professional Ethics Executive Committee of the AICPA proposed this interpretation as a conforming revision to the definition of a financial statement attest client and revision to “The Plan Is an Attest Client or Is Sponsored by an Attest Client” interpretation. Comments are due by 16 October 2017.

    20 April 2017

    Forming an opinion and reporting on financial statements of employee benefit plans subject to ERISA
    The Auditing Standards Board of the AICPA proposed this Statement on Auditing Standards (SAS) for financial statement audits of employee benefit plans that are subject to the Employee Retirement Income Security Act (ERISA) in an effort to improve the quality of these audits and the relevance of the auditor’s report. This proposed SAS includes the form and content of the auditor’s report for an unmodified opinion, a new form of opinion when an ERISA-permitted audit scope limitation exists and reporting requirements on findings from procedures performed on specific plan provisions relating to the financial statements (either included in the auditor’s report on the ERISA plan financial statements or issued as a separate report). This proposed SAS would apply to audits of single employer, multiple employer, and multiemployer plans subject to ERISA. Comments are due by 21 August 2017.

    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.

    EY Comment letters

    11 October 2018

    Comment Letter - AICPA’s proposed changes to standards on agreed-upon procedures and other attestation engagements
    In our comment letter, we support expanding the instances in which a practitioner could perform and report on procedures. But we believe the AICPA should accomplish this objective by creating a new type of engagement similar to the selected procedures engagement the AICPA proposed in September 2017 rather than eliminating requirements for agreed-upon procedures engagements. We also do not support aligning the AICPA attestation standards with the International Standard on Assurance Engagements 3000 (Revised). Instead, we believe the Accounting Standards Board should conduct a post-implementation review of its clarified attestation standards that went into effect in May 2017.

    15 May 2018

    Comment Letter - ASB proposed auditor reporting standard
    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.

    15 May 2018

    Comment Letter - ASB proposed omnibus statement on auditing standards to minimize certain differences with PCAOB standards
    In our comment letter, we support the ASB’s efforts to minimize unnecessary differences between its auditing standards and those of the PCAOB for related parties and communications with those charged with governance. Overall, we believe the proposed amendments would clarify the auditor’s responsibilities and enhance audit quality.

    15 May 2018

    Comment Letter - ASB proposed standard on the auditor’s responsibilities relating to other information included in annual reports
    In our comment letter, we do not support the ASB’s proposal on the auditor’s responsibility for other information in annual reports. However, we recommended ways the ASB could make the standard more operable and promote consistent application if it decides to move forward with the proposal.

    1 December 2017

    Comment Letter - AICPA’s proposed new attestation service
    In our comment letter, we support the AICPA’s proposal to create a new type of attestation service called a selected procedures engagement that would provide more opportunities for companies to enhance the value of reports they provide to customers, employees, suppliers and other stakeholders. However, we believe any final standard should include additional requirements and application guidance to protect report users.

    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.