PwC submitted a comment letter on the ASB’s proposed Statement on Standards for Attestation Engagements, Reporting on an Examination of Controls at a Service Organization Relevant to User Entities’ Internal Control Over Financial Reporting: Clarification and Recodification (the proposed SSAE). The ASB has revised the existing standard, to (1) remove requirements and application guidance that is repetitive with chapter 1, “Concepts Common to All Attestation Engagements” and chapter 2, “Examination Engagements” of the July 24, 2013 Exposure Draft Attestation Standards: Clarification and Recodification, with the exception of a repetition of the basic report elements for examination engagements; (2) align it with certain application guidance included in the AICPA guide, Service Organizations: Reporting on Controls at a Service Organization Relevant to User Entities’ Internal Control Over Financial Reporting; and (3) address certain issues encountered in practice. We support the proposed SSAE overall, but offer some suggestions for improvement in finalizing the proposed SSAE in certain areas including, among others, information that is not covered by the service auditor’s report, management’s refusal to provide a written assertion, and the service auditor’s responsibilities with respect to obtaining evidence regarding the design of controls includes implementation.
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