June 20, Mr. Michael Glynn Technical Manager Audit and Attest Standards AICPA 1211 Avenue of the Americas New York, NY 10036

Similar documents
Electronically:

Re: AICPA Professional Ethics Division Exposure Draft Proposed Interpretations, Responding to Non-Compliance with Laws and Regulations, March 10, 2017

EXPOSURE DRAFT PROPOSED STATEMENT ON STANDARDS FOR ACCOUNTING AND REVIEW SERVICES STANDARDS FOR ACCOUNTING AND REVIEW SERVICES DECEMBER 11, 2003

Foundation for Accounting Education, Inc. Board of Trustees Meeting. Minutes of: Thursday, September 17, 2015, 2:00 to 5:40 p.m.

COVER TO BE SET BY AICPA

Re: Revisions to Statement on Standards for Attestation Engagements No. 18, Attestation Standards: Clarification and Recodification

May 2007 Board of Directors Minutes

Uniform Accountancy Act

Texas State Board of Public Accountancy May 12, 2016

CMA CENTURY MEDIATION ASSOCIATES, INC. Panel of Arbitrators & Mediators New York State

NOTICE OF PENDENCY AND SETTLEMENT OF DERIVATIVE ACTIONS AND OF SETTLEMENT HEARING TO ALL HOLDERS OF BARNES & NOBLE, INC. STOCK ON SEPTEMBER 11, 2007

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

AUDIT COMMITTEE CHARTER of the Audit Committee of Puma Biotechnology, Inc.

Brown & Brown, Inc. AUDIT COMMITTEE CHARTER

U.S. District Court District of South Carolina (Columbia) CIVIL DOCKET FOR CASE #: 3:00-cv JFA

CARA OPERATIONS LIMITED AUDIT COMMITTEE CHARTER

MINUTES, North Carolina Veterinary Medical Board Raleigh, North Carolina, August 27 & 28, 2008

Proceedings of the Semiannual Meeting

Thursday 17-Mar Courtroom II - 2nd Floor

Case MFW Doc Filed 11/19/18 Page 1 of 5 UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE

STATE OF NORTH CAROLINA

Case MFW Doc Filed 10/22/18 Page 1 of 4 UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE

FEDERAL HOME LOAN BANK OF BOSTON CHARTER OF THE AUDIT COMMITTEE

May 14, Ms. Ann Marsh Associate Accountant Rate Setting Unit NYS Education Department Albany, New York, By

Tel: Fax:

NORTH CAROLINA GENERAL ASSEMBLY 2009 SESSION 23 rd Edition SENATE COMMITTEE ASSIGNMENTS BY MEMBER

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA

437 Russell Senate Office Building 124 Russell Senate Office Building. Washington, DC Washington, DC 20510

AUDIT COMMITTEE CHARTER of the Audit Committee of New Oriental Education & Technology Group Inc.

St. Gregory the Great School Home / School Association. Constitution and By-Laws

STATE OF NORTH CAROLINA

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

New Federal Ministry and Shadow Ministry 41 st Australian Parliament

EXPRESS SCRIPTS HOLDING COMPANY AUDIT COMMITTEE CHARTER. Adopted December 14, 2011, as amended as of September 7, 2016

Missouri Society of Certified Public Accountants Peer Review Annual Report on Oversight Date Issued December 12, 2014

STATE OF NORTH CAROLINA

AUDIT COMMITTEE CHARTER of the Audit Committee of ACCURAY INCORPORATED. (As amended and restated by the Board of Directors effective July 1, 2016)

UNITED CONTINENTAL HOLDINGS, INC. Audit Committee Charter

ASB Meeting March 8, 2019

REPORT OF THE 2017 NOMINATIONS COMMITTEE

Omnibus Statement on Auditing Standards 2018 Issues

AUDIT COMMITTEE CHARTER As Amended and Restated by the Board of Directors November 7, 2013

SENATE CALENDAR. No. 3. Wednesday, January 16, 2019 SENATE CONVENES at 2:30 PM. Order of Business ROLL CALL INVOCATION AND PLEDGE OF ALLEGIANCE

CAUSE NO

FINANCIAL STATEMENT AUDIT REPORT OF MADISON COUNTY PARTNERSHIP

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No.

THE HARTFORD FINANCIAL SERVICES GROUP, INC. AUDIT COMMITTEE CHARTER

The Ward M. Canaday Center for Special Collections The University of Toledo

rbk Doc#62 Filed 09/08/17 Entered 09/08/17 06:57:51 Main Document Pg 1 of 9

Introduction to Political Science

Re: Exposure Draft Proposed International Standards on Related Services 4400 (Revised) Agreed-Upon Procedures Engagement

MINUTES. Texas State Board of Public Accountancy July 26, 2001

MINUTES. Texas State Board of Public Accountancy November 20, 2014

U.S. District Court Eastern District of New York (Central Islip) CIVIL DOCKET FOR CASE #: 2:04-cv ADS-AKT

University of Hawai i System Revisions to the Charter of the Committee on Independent Audit to conform to HRS 304A-321

Case 1:13-cv WMS Document 138 Filed 11/26/13 Page 1 of 2 STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL

The new committee assignments include: STANDING COMMITTEES. Committee on Budget and Finance (7 Voting Members) O. Temple Sloan (Chair)

Norwegian Cruise Line Holdings Ltd. Audit Committee Charter

Thursday 01-Sep Courtroom II - 2nd Floor

United States Senator:

FAIRFAX FINANCIAL HOLDINGS LIMITED AUDIT COMMITTEE CHARTER

OPINIONS. The Supreme Court of the State of Colorado 2 East 14 th Avenue Denver, Colorado CO 32

US District Court for the Southern District of New York

THE GENERAL ASSEMBLY OF PENNSYLVANIA HOUSE BILL

COOK COUNTY BAR ASSOCIATION 2014 APPELLATE COURT JUDICIAL RATINGS COOK COUNTY BAR ASSOCIATION 2014 CIRCUIT COURT

U.S. District Court Eastern District of Missouri (LIVE) (St. Louis) CIVIL DOCKET FOR CASE #: 4:11-cv AGF

Introduction to Political Science

TANGER FACTORY OUTLET CENTERS, INC. AUDIT COMMITTEE OF THE BOARD OF DIRECTORS CHARTER (adopted with amendments through October 28, 2013)

Thursday 30-May Courtroom 1-2nd Floor

STATE OF NORTH CAROLINA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION

Accountants Liability. An accountant may be liable under common law due to negligence or fraud.

UNIFORM ACCOUNTANCY ACT STANDARDS FOR REGULATION. Eighth Edition January 2018

Sandra Day O Connor College of Law Judicial Clerkship Table Career Services

CONTINUED /S/ SFW 7/3/18

Money Spent by General Electric to Influence Decisions and Secure Future Federal Contracts 1997 through 2004

PSCI 370: Comparative Representation and Accountability Spring 2011 Zeynep Somer-Topcu Office: 301A Calhoun Hall

FEDERAL PUBLIC DEFENDER District of Arizona 850 Adams Street, Suite 201 PHOENIX, ARIZONA 85007

SPECIAL MEETING OF THE BOARD OF DIRECTORS OF THE CONNECTICUT MUNICIPAL ELECTRIC ENERGY COOPERATIVE. February 26, 2018

NOTICE OF CLASS ACTION SETTLEMENT

Aptiv PLC. Audit Committee Charter

NEVADA STATE BOARD OF ACCOUNTANCY Minutes September 21, 2016

Office of the Public Defender

REPUBLICAN PARTY Cumulative Report Official CORYELL COUNTY, TEXAS PRIMARY ELECTION OFFICIAL BALLOT March 02, 2010

PERFORMED UNDER CONTRACT WITH THE NORTH CAROLINA OFFICE OF STATE AUDITOR RALPH CAMPBELL, JR.

PROFESSIONAL ETHICS COMMITTEE PROCEDURES MANUAL

STATE OF NORTH CAROLINA

: No. 852 Disciplinary Docket No. 3. : Nos. 148 DB 2003 & 174 DB : Attorney Registration No : (Allegheny County) ORDER

Registered Voters Cards Cast % Num. Report Precinct Num. Reporting %

Commonwealth of Massachusetts. Division of Labor Relations

U.S. District Court Western District of Tennessee (Memphis) CIVIL DOCKET FOR CASE #: 2:10-cv SHM-dkv

Thursday 09-Aug Courtroom 1-2nd Floor

Arkin Kaplan Rice LLP v Kaplan 2013 NY Slip Op 31780(U) August 1, 2013 Sup Ct, New York County Docket Number: /2012 Judge: O.

LOUISIANA BOARD OF DRUG AND DEVICE DISTRIBUTORS (FORMERLY LOUISIANA BOARD OF WHOLESALE DRUG DISTRIBUTORS) STATE OF LOUISIANA

STATE OF NORTH CAROLINA

Case 1:07-cv SHS Document 165 Filed 12/07/12 Page 1 of 2

STATE OF NORTH CAROLINA

ACTION MEMORANDUM May 3, 2002

U.S. District Court Eastern District of Missouri (LIVE) (St. Louis) CIVIL DOCKET FOR CASE #: 4:11-cv AGF

Transcription:

Mr. Michael Glynn Technical Manager Audit and Attest Standards AICPA 1211 Avenue of the Americas New York, NY 10036 By email: mglynn@aicpa.org Re: Exposure Draft of Proposed Statement on Standards for Accounting and Review Services Omnibus Statement on Standards for Accounting and Review Services -- 2005 Dear Mr. Glynn: The New York State Society of Certified Public Accountants, the oldest state accounting association, represents approximately 30,000 CPAs that will implement the provisions proposed in the captioned exposure draft. NYSSCPA thanks AICPA for the opportunity to comment on its exposure draft. The NYSSCPA Accounting and Review Services Committee deliberated the exposure draft and prepared the attached comments. If you would like additional discussion with the committee, please contact Joseph A. Maffia, chair of the committee, at (212) 980-2470, or Robert Colson, NYSSCPA staff, at (212) 719-8350. Attachment Sincerely, Stephen F. Langowski President

NYSSCPA 2005-2006 Board of Directors Stephen F. Langowski, President Thomas E. Riley, President-elect Raymond M. Nowicki, Secretary Neville Grusd, Treasurer Victor S. Rich, Susan R. Schoenfeld, Stephen P. Valenti, Louis Grumet, ex officio William Aiken Deborah L. Bailey-Browne Thomas P. Casey Ann B. Cohen Michelle A. Cohen Debbie A. Cutler Anthony G. Duffy Robert L. Ecker Mark Ellis David Evangelista Joseph M. Falbo, Jr. Dr. Myrna L. Fischman Daniel M. Fordham Phillip E. Goldstein Raymond P. Jones John J. Kearney Raymond P. Jones Don A. Kiamie Nancy A. Kirby John J. Lauchert Howard B. Lorch Beatrix G. McKane David J. Moynihan Ian M. Nelson Richard E. Piluso Robert T. Quarte C. Daniel Stubbs, Jr. Anthony J. Tanzi Edward J. Torres Robert N. Waxman Philip G. Westcott Ellen L. Williams Richard Zerah NYSSCPA 2005-2006 Accounting and Review Services Committee Joseph A. Maffia, Chair Alan Director Walter Orenstein Michael J. Aroyo Audrey J. Dussard John Sacco Harvey G. Beringer Julie Galaska Kenneth Smith Roseanne G. Bowen Stacy M. Glasser Ira M. Talbi Joseph G. Boyce Jay Goldberg George Weiss John J. Buchheit Khalil Issa Lawrence A. Wolff Bridget Burnell Zev Landau Daniel J. Cannon Melvyn M. Ockner NYSSCPA 2005-2006 Accounting & Auditing Oversight Committee Paul D. Warner, Chair Joseph A. Maffia Warren Ruppel George I. Victor, Vice Chair Robert S. Manzella Ira M. Talbi Elliot L. Hendler Mitchell J. Mertz Elizabeth K. Venuti Joel Lanz Mark Mycio Paul J. Wendell Michele M. Levine Eric J. Rogers Margaret A. Wood Thomas O. Linder NYSSCPA Staff Robert H. Colson

The New York State Society of Certified Public Accountants Comments on Exposure Draft: Proposed Statement on Standards for Accounting and Review Services (SSARS), Omnibus Statement on Standards for Accounting and Review Services 2005. Principal Drafters Ira M. Talbi Joseph A. Maffia Michael J. Aroyo

THE NEW YORK STATE SOCIETY OF CERTIFIED PUBLIC ACCOUNTANTS ACCOUNTING AND REVIEW SERVICES COMMITTEE S COMMENTS ON PROPOSED STATEMENT ON STANDARDS FOR ACCOUNTING AND REVIEW SERVICES: OMNIBUS 2005 General Comments The Committee appreciates the opportunity to comment on the proposed amendments to SSARS 1 and SSARS 2. Most of the proposed changes conform SSARS to existing auditing literature. Except as noted in the specific comments, the proposed changes improve guidance for accounting and review engagements. Comment 1. Page 5 - Third bullet point: Specific Comments The SSARS committee should consider replacing updating with updated. The past tense flows better, and it implies a completed action rather than an action in process. Comment 2. Page 6 Paragraph 1.05 Indications of Fraud and illegal acts : The proposed new language provides a clear requirement when to report fraud but fails to adequately define indications of fraud and indications of illegal acts. Not only will these terms be interpreted subjectively, but also to fulfill the requirements of the proposed statement will require information gained outside of a SSARS engagement to determine whether such indications exists, such as a study of internal control, an assessment of control, inherent, and fraud risks, or a forensic study. It would be preferable for the standard to require simply the report of indications of fraud and indications of illegal acts that come to the accountant s attention during the performance of the professional engagement rather than to require judgments about the significance of the indications of fraud risk factors or illegal acts. Comment 3. Page 7 Paragraph 1.07 Modifications in Conformity with GAAP : The proposed changes imply that additional inquiries and analytical procedures must be undertaken only when an accountant has found indications of fraud or illegal acts in compiling GAAP financial statements. Because OCBOA financial statements are frequently compiled, we suggest wording as follows: the review procedures performed, there are no material modifications that should be made to the statements in order for them to be in conformity with GAAP or OCBOA.

Comment 4. Page 7, Paragraph 1.08b. Successor accountant: The proposed changes suggest that the predecessor accountant can communicate knowledge of fraud or an illegal act to the successor accountant without the client s permission. We suggest the following amendment to the proposed wording: b. To a successor accountant when the successor decides to communicate with the predecessor accountant and when the predecessor is permitted in accordance with SSARS No. 4. Comment 5. Page 10, Paragraph 5.34 Updating Representation Letter : See the first specific comment regarding updated rather than updating representation letters. The proposed changes raise the requirements for representation letters in review procedures to a level higher than the current audit literature, which does not require updating a stale representation letter. Although consistency with the audit literature is preferable, if an updated representation letter is required then a more specific time period would be preferable, such as six months, to a significant period of time, which is too open-ended.