Comments: PCAOB proposal on substantive analytical procedures

We support the Board’s proposal to modernize the accounting guidance on substantive analytical procedures, and to strengthen and clarify the existing requirements and elements of substantive analytical procedures. We believe the proposal’s overall objectives and the principles-based requirements will improve the quality of substantive analytical procedures performed by auditors. But, we ask the Board to clarify specific areas, which we believe could enhance the overall effectiveness of the proposal while avoiding practical application challenges.

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