(d) We do not recommend a separate standard for component auditors as we believe the current model can, with appropriate revision, address the concerns raised in the post-implementation review. We believe the standards should be revised to address more clearly and distinctly when the audit is of a group, when the audit involves other auditors, and when the auditor is making reference to the report of a component auditor (if that notion is adopted.) GA2. Acceptance and Continuance of the Group Audit Engagement (a) Paragraphs 204–217 set out matters relating to acceptance and continuance of the group audit engagement. (i) Which of the possible actions outlined in paragraphs 215–217 would be most meaningful in addressing issues related to acceptance and continuance procedures? (ii) Why do you believe actions are necessary? (iii) Are there other relevant issues that we should consider, or actions that would be more effective than those described? If you would not support a particular action, please explain why. (iv) Please also describe any potential consequences of possible actions that you believe we need to consider further. (b) Specifically: (i) Are access issues as described in paragraph 207(a) still frequently being experienced in practice? If yes, please provide details and, where possible, explain how these are being addressed today. (ii) Do you agree that ISA 600 can or should be strengthened in relation to addressing access issues as part of acceptance and continuance? (iii) Would expanding the understanding required for acceptance and continuance, as described in paragraph 215 (b), be achievable in the case of a new audit engagement? In practice, issues of access can be distinguished between access necessary for auditor involvement, supervision and review, and issues of access to complete documentation. With regard to the former, in the age of technology, the meaning of access may be different. We recommend focusing on what is necessary to obtain sufficient appropriate audit evidence while performing appropriate supervisory and review procedures. Additional application material on the extent of involvement necessary to be able to serve as engagement partner would be helpful. Access to issues that relate to documentation may be more difficult to resolve. Jurisdictions may not allow foreign auditors the same degree of access available to management or to native auditors. Foreign auditors may have access to the evidence, but be limited in what they are
(d) We do not recommend a separate standard for component auditors as we believe the current model can, with appropriate revision, address the concerns raised in the post-implementation review. We believe the standards should be revised to address more clearly and distinctly when the audit is of a group, when the audit involves other auditors, and when the auditor is making reference to the report of a component auditor (if that notion is adopted.) GA2. Acceptance and Continuance of the Group Audit Engagement (a) Paragraphs 204–217 set out matters relating to acceptance and continuance of the group audit engagement. (i) Which of the possible actions outlined in paragraphs 215–217 would be most meaningful in addressing issues related to acceptance and continuance procedures? (ii) Why do you believe actions are necessary? (iii) Are there other relevant issues that we should consider, or actions that would be more effective than those described? If you would not support a particular action, please explain why. (iv) Please also describe any potential consequences of possible actions that you believe we need to consider further. (b) Specifically: (i) Are access issues as described in paragraph 207(a) still frequently being experienced in practice? If yes, please provide details and, where possible, explain how these are being addressed today. (ii) Do you agree that ISA 600 can or should be strengthened in relation to addressing access issues as part of acceptance and continuance? (iii) Would expanding the understanding required for acceptance and continuance, as described in paragraph 215 (b), be achievable in the case of a new audit engagement? In practice, issues of access can be distinguished between access necessary for auditor involvement, supervision and review, and issues of access to complete documentation. With regard to the former, in the age of technology, the meaning of access may be different. We recommend focusing on what is necessary to obtain sufficient appropriate audit evidence while performing appropriate supervisory and review procedures. Additional application material on the extent of involvement necessary to be able to serve as engagement partner would be helpful. Access to issues that relate to documentation may be more difficult to resolve. Jurisdictions may not allow foreign auditors the same degree of access available to management or to native auditors. Foreign auditors may have access to the evidence, but be limited in what they are
AICPAASBCommentLetter-EnhancingAuditQuality-May2016.docx