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Deloitte comments on AICPA's proposal on auditor reporting

Published on: Oct 16, 2019

Deloitte & Touche LLP comments on the Auditing Standards Board of the American Institute of Certified Public Accountants (AICPA) on its proposed Statement on Auditing Standards (SAS) related to amendments to AU-C Sections 800, 805, and 810 to incorporate auditor reporting changes from SAS No. 134, Auditor Reporting and Amendments, Including Amendments Addressing Disclosures in the Audit of Financial Statements.

An excerpt from the comment letter is shown below:

We support the issuance of the proposed SAS in order to incorporate auditor reporting changes from SAS No. 134 as well as SAS No. 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA, and SAS No. 137, The Auditor’s Responsibilities Relating to Other Information Included in Annual Reports.

The proposed SAS indicated that if issued it will be effective for audits of financial statements for periods ending on or after December 15, 2020 and that early implementation is not permitted. We believe that this effective date allows sufficient time for auditors to adequately prepare for the implementation of the proposed SAS.


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