PwC supports the enhanced guidance in the clarity redraft, but identifies possible improvements.
PwC submitted a comment letter supporting the Auditing Standards Board’s proposed Statement on Standards for Attestation Engagements, Attestation Standards: Clarification and Recodification (the proposed SSAE). The proposed SSAE represents phase one of a project to redraft the attestation standards, a key feature of which is restructuring the standards into a framework consisting of guidance common to all attestation engagements, on which are layered the requirements and guidance specific to each of the three types of attestation services: examinations, reviews and agreed-upon procedures. Phase two of the project will address subject-matter specific engagements.
PwC believes the new structure may initially pose navigational challenges to practitioners since a practitioner performing an examination of prospective financial statements, for example, will need to consult three “chapters,” as they are called in the proposed SSAE: common concepts, examinations and financial forecasts and projections. As a result, PwC would not object to eliminating the concepts common to all attestation engagements chapter and repeating its content in the chapters for examinations, reviews and agreed-upon procedures.
PwC supports the significant enhancements in the proposed SSAE, particularly for examinations and reviews, with relevant content from the clarified auditing standards, but also provides comments to improve the consistency and clarity of the guidance.