PwC submitted a comment letter on the ASB’s proposed Statement on Auditing Standards, An Audit of Internal Control Over Financial Reporting That Is Integrated With an Audit of Financial Statements (the proposed SAS). We support moving the content of extant AT 501, An Examination of an Entity’s Internal Control Over Financial Reporting That Is Integrated With an Audit of Its Financial Statements, into generally accepted auditing standards. We also support the ASB’s approach in drafting a separate stand-alone SAS instead of addressing an integrated audit in each relevant existing AU-C section.
We agree with the approach the ASB has adopted relating to the presumption that management uses the 2013 Internal Control—integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (2013 COSO Framework) to evaluate the five components of internal control by assessing the principles in the 2013 framework, while continuing to allow the auditor to adapt and apply the proposed SAS when management applies a different internal control framework such as the U.S. Government Accountability Office’s Standards for Internal Control in the Federal Government. We do offer some suggestions for improvement in finalizing the proposed SAS, including in the areas of definitions, using the work of others, and subsequent events.