Audit, Attest, and Quality Control – ASB Comment Letters

The Auditing Standards Board (ASB) has issued the following consultation papers and comment letters to communicate its views and positions on audit, attest, and quality control matters. 

• October 4, 2022, ASB comment letter:  The IAASB’s Exposure Draft — Narrow Scope Amendments to ISA 700 (Revised), Forming an Opinion and Reporting on Financial Statements, and ISA 260 (Revised), Communication with Those Charged With Governance, as a Result of the Revisions to the IESBA Code that Require a Firm to Publicly Disclose When a Firm Has Applied the Independence Requirements for Public Interest Entities (PIEs)
• January 31, 2022, ASB comment letter: Proposed International Standard on Auditing (ISA) for Audits of Financial Statements of Less Complex Entities (ISA for LCE)
• September 23, 2021, ASB comment letter:  IASB’s March 2021 Request for Information – Third Agenda Consultation (RFI)
• January 29, 2021, ASB comment letter: IAASB's Discussion Paper - Fraud and Going Concern in an Audit of Financial Statements: Exploring the Differences Between Public Perceptions About the Role of the Auditor and the Auditor's Responsibilities in a Financial Statement Audit
• September 26, 2020, ASB comment letter: Proposed International Standard on Auditing 600 (Revised), Special, Considerations-Audits of Group Financial Statements (Including the Work of Component Auditors) and Proposed Conforming and Consequential Amendments to Other ISAs
• September 12, 2019, ASB comment letter:  IAASB’s Discussion Paper: Audits of Less Complex Entities: Exploring Possible Options to Address the Challenges in Applying the ISAs
• July 1, 2019, ASB comment letter: The IAASB's Exposure Drafts for Quality Management at the Firm and Engagement Level, Including Engagement Quality Reviews
• March 15, 2019, ASB comment letter: Proposed International Standard on Related Services (ISRS) 4400 (Revised), Agreed-Upon Procedures Engagements (ED-4400)
• October 31, 2018, ASB comment letter: Proposed International Standard on Auditing (ISA) 315 (Revised), Identifying and Assessing the Risks of Material Misstatement (ED-315)
• July 31, 2017, ASB comment letter: Proposed International Standard on Auditing 540 (Revised), Auditing Accounting Estimates and Related Disclosures
• May 16, 2016, ASB comment letter: Invitation to Comment – Enhancing Audit Quality in the Public Interest—A Focus on Professional Skepticism, Quality Control and Group Audits
• November 2, 2015, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 810 (Revised), “Engagements to Report on Summary Financial Statements”
• October 16, 2015, ASB comment letter on Exposure Draft: Responding to Non-Compliance or Suspected Non-Compliance with Laws and Regulations
• April 22, 2015, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 800 (Revised), “Special Considerations–Audits of Financial Statements Prepared in Accordance with Special Purpose Frameworks” and Proposed ISA 805 (Revised), “Special Considerations–Audits of Single Financial Statements and Specific Elements, Accounts or Items of a Financial Statement”
• September 11, 2014, ASB comment letter on Exposure Draft: Addressing Disclosures in the Audit of Financial Statements
• July 18, 2014, ASB comment letter on Exposure Draft:  Proposed International Standard on Auditing 720 (Revised), “The Auditor’s Responsibilities Relating to Other Information”
• November 21, 2013, ASB comment letter on Exposure Draft: Reporting on Audited Financial Statements: Proposed New and Revised International Standards on Auditing (ISAs)
• May 15, 2013, ASB comment letter on Consultation Paper: A Framework for Audit Quality
• March 20, 2013, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 720 (Revised), “The Auditor’s Responsibilities Relating to Other Information in Documents Containing or Accompanying Audited Financial Statements and the Auditor’s Report Thereon”
• October 8, 2012, ASB comment letter on Invitation to Comment: Improving the Auditor's Report
• September 16, 2011, ASB comment letter on Consultation Paper: Enhancing the Value of Auditor Reporting: Exploring Options for Change
• August 31, 2011, ASB comment letter on Exposure Draft: Proposed International Standard on Assurance Engagements 3000 (Revised), “Assurance Engagements Other Than Audits or Reviews of Historical Financial Information”
• June 20, 2011, ASB comment letter on Exposure Draft: Proposed International Standard on Assurance Engagements 3410, “Assurance Engagements on Greenhouse Gas Statements”
• June 1, 2011, ASB comment letter on Discussion Paper: The Evolving Nature of Financial Reporting: Disclosure and Its Audit Implications
• April 4, 2011, ASB comment letter on Exposure Draft: Proposed IAASB Strategy and Work Program for 2012–2014
• February 26, 2010, ASB comment letter on Consultation Paper: Assurance on a Greenhouse Gas Statement
• May 20, 2008, ASB comment letter on Exposure Draft: Proposed Revised and Redrafted International Standard on Auditing 402, “Audit Considerations Relating to an Entity Using a Third Party Service Organization”
• May 15, 2008, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 265, “Communicating Deficiencies in Internal Control and Related Conforming Amendments to Other ISAs”
• April 15, 2008, ASB comment letter on Exposure Draft: Proposed Redrafted International Standard on Auditing (ISA) 710 (Redrafted), “Comparative Information— Corresponding Figures and Comparative Financial Statements”
• April 15, 2008, ASB comment letter on Exposure Draft: Proposed Redrafted International Standard on Auditing (ISA) 210, “Agreeing the Terms of Audit Engagements” and Related Conforming Amendments to Other ISAs
• March 31, 2008, ASB comment letter on Exposure Draft: Proposed Redrafted International Standard on Auditing (ISA) 520 (Redrafted), “Analytical Procedures”
• March 31, 2008, ASB comment letter on Exposure Draft: Proposed Redrafted International Standard on Auditing (ISA) 501 (Redrafted), “Audit Evidence Regarding Specific Financial Statement Account Balances and Disclosures”
• February 15, 2008, ASB comment letter on Exposure Draft: Proposed Revised and Redrafted International Standard on Auditing (ISA) 620, “Using the Work of an Auditor’s Expert”
• February 15, 2008, ASB comment letter on Exposure Draft: Proposed Redrafted International Standard on Auditing (ISA) 505 (Redrafted), “External Confirmations”
• December 31, 2007, ASB comment letter on Exposure Draft: Proposed Redrafted International Quality Control Standard 1, "Quality Control for Firms that Perform Audits and Reviews of Financial Statements, and Other Assurance and Related Services Engagements," and Proposed International Standard on Auditing (ISA) 220 (Redrafted), “Quality Control for an Audit of Financial Statements”
• November 30, 2007, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 805 (Revised), "Engagements to Report on Summary Financial Statements”
• November 30, 2007, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 706 (Revised), "Emphasis of Matter Paragraphs and Other Matter(s) Paragraphs in the Independent Auditor’s Report”
• October 31, 2007, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 530, "Audit Sampling”
• October 31, 2007, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 510, “Initial Audit Engagements—Opening Balances”
• September 15, 2007, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 500 (Redrafted), “Considering the Relevance and Reliability of Audit Evidence”
• September 13, 2007, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 500 (Redrafted), “Considering the Relevance and Reliability of Audit Evidence”
• September 13, 2007, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 200 (Redrafted), “Overall Objective of the Independent Auditor, and the Conduct of an Audit in Accordance with International Standards on Auditing”
• July 31, 2007, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 250 (Redrafted), “The Auditor’s Responsibilities Relating to Laws and Regulations in an Audit of Financial Statements”
• May 30, 2007, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 570, “Going Concern”
• April 30, 2007, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 580, “Written Representations”
• March 31, 2007, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 560, “Subsequent Events”
• May 1, 2006, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 550 (Revised), “Related Parties”
• July 31, 2005, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 260, “The Auditor’s Communication with Those Charged With Governance”
• May 25, 2005, ASB comment letter on Recommendations on the Use of Specialists
• May 17, 2005, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 540, “Auditing Accounting Estimates and Related Disclosures (Excluding Those Involving Fair Value Measurements and Disclosures)”
• February 8, 2005, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 230 (Revised), “Audit Documentation," Amendment to ISA 330, "The Auditor’s Procedures in Response to Assessed Risks," Amendment to ISQC 1, "Quality Control for Firms that Perform Audits and Reviews of Historical Financial Information and Other Assurance and Related Services Engagements.
• January 14, 2005, ASB comment letter on Exposure Draft: Proposed Policy Statement, “Clarifying Professional Requirements in International Standards Issued by the IAASB” and Consultation Paper: Improving the Clarity and Structure of IAASB Standards and Related Considerations for Practice Statements
• April 8, 2004, ASB comment letter on Exposure Draft: Proposed International Standard on Auditing (ISA) 700, “The Independent Auditor’s Report on a Complete Set of General Purpose Financial Statements” ISA 200, “Objective and General Principles Governing an Audit of Financial Statements” Amendment to ISA 210, “Terms of Audit Engagements” and Conforming Amendments

Letters from the Center for Audit Quality (CAQ) to other organizations (including the Public Company Accounting Oversight Board and Securities and Exchange Commission) are available on the CAQ's website.