May 29, 2009, letter commenting on the AICPA Auditing Standards Board January 2009 Exposure Draft for a proposed Statement on Auditing Standards entitled "Consideration of Fraud in a Financial Statement Audit (Redrafted)"

This letter provides the U.S. Government Accountability Office's (GAO) comments on the American Institute of Certified Public Accountants (AICPA) Auditing Standards Board's (ASB) proposed Statement on Auditing Standards (SAS) on the auditor's consideration of fraud in a financial statement audit. Generally, we support the proposed statement and agree that the principles-based approach used in this standard will permit the flexibility needed in this critical area. Our responses to the questions raised in the related Explanatory Memorandum are noted below. In addition, we are providing comments on retaining a separate fraud risk standard and the need for additional guidance related to third party fraud.