October 2, 2012 letter commenting on Proposed Revised Interpretations

This letter provides the U.S. Government Accountability Office's (GAO) comments on the AICPA Professional Ethics Executive Committee's (PEEC) proposed revisions to Interpretation No. 101-3, "Nonattest Services," under Rule 101, Independence. GAO is commenting on PEEC's proposed revisions to language in Interpretation No. 101-3 on the effect on independence of providing nonattest services, including financial statement preparation and cash-to-accrual conversion and internal audit assistance services. GAO is not commenting on the proposed new interpretations under Rules 501 and 502 or the proposed deletions of ethics rulings that are included in the exposure draft. As noted below, while GAO generally agrees with the proposed Interpretation No. 101-3, we have concerns related to the proposed language addressing special conditions under which independence would not be impaired, the proposed discussion of cumulative threats to independence, and the placement of the section on monitoring of internal control in the internal audit assistance section of the Interpretation.