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Deloitte comments on AICPA's proposed revisions to SSAE 18

Published on: Oct 12, 2018

Deloitte & Touche LLP comments on the Auditing Standards Board of the American Institute of Certified Public Accountants (AICPA) on its proposed Statement on Standards for Attestation Engagements (SSAE), Revisions to Statement on Standards for Attestation Engagements No. 18, Attestation Standards: Clarification and Recodification.

An excerpt from the comment letter is shown below:

In responding, we thoughtfully considered the reasoning for the amendments, as outlined in the Explanatory Memorandum, as well as the appended dissents. Our response has also been informed by the views expressed by the members of the ASB at the numerous meetings where this topic has been robustly discussed and debated. D&T recognizes and supports the opportunity to explore and develop quality professional standards intended to nurture and support potential new market opportunities; however, we do not believe that this should be done at the expense of diluting the clarified attestation standards that were recently deliberated by the ASB and issued only two years ago. It is our overarching perspective that the underlying principles of those clarified attestation standards would be undermined by the ED, such that the proposed SSAE would no longer explicitly support existing attestation engagements as we know them.

We acknowledge the issues outlined by the ASB members in the dissents, and we believe that the concerns raised in these dissents are valid and worthy of further deliberation. Accordingly, we respectfully request that the ASB consider these dissents as part of its ongoing deliberations. While the dissenting members expressed views highlighting a variety of differing perspectives, when read and considered together, it appears that there is significant concern that the ASB may not have fundamentally considered all the practical implications and long-term ramifications of the amendments set forth in the proposed SSAE.

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