November 20, 2012, letter commenting on AICPA Professional Ethics Executive Committee's September 2012 exposure Draft entitled "Omnibus Proposal ~ AICPA Professional Ethics Division ~ Interpretations and Definitions."

This letter provides the U.S. Government Accountability Office's (GAO) comments on the AICPA Professional Ethics Executive Committee's (the PEEC) proposed revisions to the definitions of practice of public accounting (paragraph .29 of ET section 92, Definitions [AICPA, Professional Standards]) and professional services (paragraph .30 of ET section 92) and the related conforming changes in the AICPA Code of Professional Conduct (the Code). As noted below, while GAO generally agrees with the proposed revisions to definitions, we believe that the revision process provides an opportunity for the PEEC to consider additional changes that would enhance the ability of auditors in government to apply the Code's rules and standards. We are suggesting that the PEEC take this opportunity to revise the definition of client (ET 92.03); add explanatory language to the definition of firm (ET 92.10); and revise the list of safeguards implemented by the firm (ET 100-01.26).