Comment: Proposed SAS on group audits


In our comment letter in response to the Auditing Standards Board’s Proposed Statement on Auditing Standards (SAS), Special Considerations – Audits of Group Financial Statements (Including the Work of Component Auditors and Audits of Referred-To Auditors), we support the Board’s project to improve the group audits standard and to align this guidance with International Standards on Auditing, particularly as global audits become more prevalent.


But, we believe it is imperative for the Board to consider the new requirements recently adopted by the Public Company Accounting Oversight Board (PCAOB) on this topic before issuing a final standard. Operational challenges within our jurisdiction could arise if the proposed SAS diverges too far from the PCAOB requirements.


We also call for additional clarification in the new quality management standards with regard to applying quality management to a group audit, which you can read about by downloading our letter here.



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