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Deloitte comments on AICPA's proposed criteria for evaluating the integrity of a set of data

Published on: Oct 12, 2018

Deloitte & Touche LLP comments on the Assurance Services Executive Committee (ASEC) of the American Institute of Certified Public Accountants (AICPA) proposed "Criteria for Evaluating the Integrity of a Set of Data."

An excerpt from the comment letter is shown below:


1. Are any of the criteria or implementation guidance unnecessary or otherwise not relevant? Please provide a list.

DI3 – D&T believes that criterion DI3 is unnecessary. If the description addresses each of the other criteria, we believe that would satisfy the accuracy and completeness of the description.

DI6 – D&T believes that criterion DI6 is unnecessary. As noted previously, if the description addresses each of the other criteria listed, we believe that would satisfy the consistency of the data with the description.

2. Are there any missing criteria or implementation guidance? Please provide a list.

We recommend adding a comprehensive example of a description. While we do not note any missing criteria, we believe a comprehensive example would assist the user of the proposed description criteria in preparing an accurate and complete description.

3. Do you have any concerns about the measurability of any of the criteria or implementation guidance? Please provide a list.

DCI2f – D&T concurs with the statement in the exposure draft that “[m]any types of data have characteristics that are uncertain at the time of measurement and will only be determined at a later time.” Consequently, D&T believes that uncertainty inherent in each data element and in thepopulation of those elements may be difficult to measure, depending on the facts and circumstances of the set of data. However, we believe that appropriate implementation guidance has been provided to allow for the practitioner to evaluate the integrity of the set of data when applying the description criteria.


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