GAO's September 13, 2010 letter commenting on PCAOB Rulemaking Docket Matter No. 028: PCAOB Release No. 2010-003, Proposed Auditing Standard Related To Confirmation and Related Amendments to PCAOB Standards

GAO appreciates the PCAOB's efforts to establish auditing standards on audit confirmations for registered companies and agree that confirmation procedures can be an important means of obtaining audit evidence. However, GAO has serious concerns about the proposed standard, specifically, (1) the proposed standard could lead to over-reliance on confirmation procedures as the presumptive requirement to perform confirmation procedures would cause auditors to spend time on confirmations when other audit procedures may be more appropriate, (2) the appendix identifies certain significant differences among the analogous standards but does not adequately explain the reasons for all significant differences, and (3) the drafting conventions and wording used in some sections of the proposed standard are unclear and will likely lead to confusion among users and inconsistency of practice. These concerns, along with other comments and suggestions for improving the clarity and other aspects of the standard, are discussed in this document.