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Deloitte comments on AICPA's proposed SSARS on materiality in a review of financial statements, adverse conclusions, and special purpose frameworks

Published on: Oct 01, 2019

Deloitte & Touche LLP has commented on the AICPA's proposed Statement on Standards for Accounting and Review Services, Materiality in a Review of Financial Statements, Adverse Conclusions, and Special Purpose Frameworks.

An excerpt from the comment letter is shown below:

D&T acknowledges that the proposed ED includes, among other revisions, various amendments to AR-C section 60, General Principles for Engagements Performed in Accordance With Statements on Standards for Accounting and Review Services (AR-C 60), and AR-C section 90, Reviews of Financial Statements (AR-C 90), aimed to converge with International Standard on Review Engagements (ISRE) 2400 (Revised), Engagements to Review Historical Financial Statements (ISRE 2400 (Revised)), to facilitate the accountant’s ability to perform and report on engagements in accordance with both sets of standards and to avoid unnecessary differences between the standards that may result in confusion.

While we support convergence and minimizing differences between AR-C 90 of the proposed ED and ISRE 2400 (Revised), we believe certain proposed amendments to AR-C 90 of the proposed ED may result in inconsistencies as it relates to the suite of professional standards pertaining to review engagements performed within the United States. D&T believes that having defined terms (or no definitions as the case may be) and performance requirements that are similarly aligned within our jurisdiction is important for the consistent execution of all review engagements of historical financial information. This will alleviate confusion for accountants when they are also performing review procedures in accordance with the Statement on Auditing Standard (SAS) No. 122, Statements on Auditing Standards: Clarification and Recodification, as amended, specifically AU-C section 930, Interim Financial Information (AU-C 930), and Statements on Standards for Attestation Engagements (SSAE) No, 18, Attestation Standards: Clarification and Recodification, specifically section 210, Review Engagements (AT-C 210).

For more information, see the full text of the comment letter which is available below.


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