The American Institute of Certified Public Accountants (AICPA) sets ethical standards for the accounting profession and US auditing standards for audits of private companies, non-profit organizations and federal, state and local governments.

    Proposed rules
    EY Comment letters

    Proposed rules

    28 November 2017

    Auditor reporting
    The call for changes to the auditor reporting model in the United States and other jurisdictions around the world resulted from a desire by users of financial statements and the auditor’s report for more information about significant aspects of the audit. The proposal makes amendments to heighten auditor focus on disclosures throughout the performance of an audit of financial statements. It is focused on the form and content of the auditor’s report and does not change the existing requirements for performing an audit in accordance with GAAS. Comments are due by 15 May 2018.

    28 November 2017

    Omnibus statement on auditing standards - 2018
    The proposal would amend SAS No. 122, Statements on Auditing Standards: Clarification and Recodification and SAS No. 130, An Audit of Internal Control Over Financial Reporting That Is Integrated With an Audit of Financial Statements. Comments are due by 15 May 2018.

    28 November 2017

    The auditor’s responsibilities relating to other information included in annual reports
    The ASB believes that the proposed SAS will benefit users of audited financial statements and other information by improving audit quality by bringing greater consistency regarding auditors’ consideration of other information and reducing diversity in practice with respect to documents that are considered to be with-in the scope of the proposed SAS; increasing the value of the audit, without changing its scope, in a cost-beneficial manner, through enhancing the auditor’s responsibility with respect to the other information; and narrowing potential or existing expectation gaps through requiring auditors to articulate in their re-ports their responsibilities under the proposed SAS, and the outcome of their work relative to the other information. Comments are due by 15 May 2018.

    20 October 2017

    Leases interpretation
    The Professional Ethics Executive Committee reviewed the FASB updated standard for leases and the related independence requirements of other standard setters and regulators. The proposed revision addresses all leases between covered members and attest clients except automobile leases with lending institution attest clients. Comments are due by 15 January 2018.

    14 September 2017

    Omnibus statement on standards for accounting and review services - 2018
    The Accounting and Review Services Committee (ARSC) determined that SSARSs should include requirements and guidance when an accountant is engaged to perform a compilation or review of financial statements prepared in accordance with a financial reporting framework generally accepted in another country or in accordance with both SSARSs and another set of compilation or review standards. ARSC also determined that revisions should be made to AR-C section 90 to substantially harmonize the requirements with respect to the accountant’s consideration of an entity’s ability to continue as a going concern with those in AU-C section 930, resulting from the issuance of SAS No. 132 and to include a specific written representation regarding disclosure of all information relevant to the use of the going concern assumption in the financial statements. Comments are due by 14 December 2017.

    1 September 2017

    Selected procedures
    This proposal, issued by the AICPA Accounting and Review Services Committee (ARSC), would result in flexibility provided to practitioners in performing and reporting on a procedures and findings service. Under the proposal practitioners would be permitted to perform procedures and report in a procedures and findings format beyond what's currently provided by AT-C Section 215, Agreed-Upon Procedures Engagements. The proposal is a joint effort of ARSC and the AICPA Auditing Standards Board, and its effective date will not be earlier than for reports dated on or after May 1, 2019. Comments are due by 1 December 2017.

    24 July 2017

    Proposed revision of description criteria for a description of a service organization’s system in a SOC 2® report
    The AICPA is in the process of revising AICPA Guide Reporting on an Examination of Controls at a Service Organization Relevant to Security, Availability, Processing Integrity, Confidentiality, or Privacy (SOC 2®). That guide has been developed to assist service auditors engaged to examine and report on a service organization’s controls relevant to security, availability, processing integrity, confidentiality, or privacy, which is known as a SOC 2 examination. The description criteria for a description of a service organization’s system are currently presented in paragraphs 1.26 and 1.27 of the guide. With the forthcoming revision of the guide, however, description criteria will no longer be presented within the body of the guide. Instead, description criteria for use in a SOC 2 examination will be published as a stand-alone document. Comments are due by 7 September 2017.

    14 July 2017

    Long association of senior personnel with an attest client
    In developing the proposed interpretation, the Professional Ethics Executive Committee (PEEC) of the AICPA considered the new ethics standard Long Association of Personnel with an Audit Client of the IESBA Code of Ethics for Professional Accountants (IESBA code). The PEEC believes that though many of the proposed requirements are consistent with that of the new IESBA standard, certain differences are necessary to enhance the clarity of the proposed interpretation and make it relevant to AICPA members in the United States. Certain provisions of the IESBA standard were not included in the AICPA proposal because the SEC already addresses provisions such as partner rotation for registered companies. The proposal addresses familiarity threats due to long association with an attest client. Comments are due by 15 September 2017.

    7 July 2017

    State and local government entities
    The Professional Ethics Executive Committee of the AICPA proposed this interpretation as a conforming revision to the definition of a financial statement attest client and revision to “The Plan Is an Attest Client or Is Sponsored by an Attest Client” interpretation. Comments are due by 16 October 2017.

    20 April 2017

    Forming an opinion and reporting on financial statements of employee benefit plans subject to ERISA
    The Auditing Standards Board of the AICPA proposed this Statement on Auditing Standards (SAS) for financial statement audits of employee benefit plans that are subject to the Employee Retirement Income Security Act (ERISA) in an effort to improve the quality of these audits and the relevance of the auditor’s report. This proposed SAS includes the form and content of the auditor’s report for an unmodified opinion, a new form of opinion when an ERISA-permitted audit scope limitation exists and reporting requirements on findings from procedures performed on specific plan provisions relating to the financial statements (either included in the auditor’s report on the ERISA plan financial statements or issued as a separate report). This proposed SAS would apply to audits of single employer, multiple employer, and multiemployer plans subject to ERISA. Comments are due by 21 August 2017.

    10 March 2017

    Responding to non-compliance with laws and regulations from the AICPA Professional Ethics Division
    The Professional Ethics Division issued this exposure draft seeking comments on a proposal which provides guidance for members in public practice and in business when they encounter actual or suspected act of non-compliance with laws or regulations (NOCLAR) at a client or within the employing organization. Comments are due by 12 May 2017.

    9 January 2017

    Proposed revised and new interpretations applicable to members in business
    The Professional Ethics Executive Committee exposed for comment, revisions to the “Knowing Misrepresentations in the Preparation of Financial Statements or Records” interpretation under the “Integrity and Objectivity Rule”, applicable to members in business. Comments are due by 17 April 2017.

    15 December 2016

    Client and attest client: Proposed revised definitions of client and attest client as well as related definitions, interpretations, and other guidance
    The AICPA Professional Ethics Executive Committee is exposing for comment revisions to the definitions of “Client” and “Attest Client,” including the relocation of the government provision from the definition of “Client” to the “Simultaneous Employment or Association With an Attest Client” interpretation under the Independence Rule. Comments are due by 15 May 2017.

    13 July 2016

    Auditor involvement with exempt offering documents
    The proposed SAS includes performance requirements when the auditor is involved with an exempt offering document. Involvement is determined by a two-benchmark model: (1)The auditor’s report on financial statements or the auditor’s review report on interim financial information is included or incorporated by reference in an exempt offering document, and (2) The auditor performs one or more specified activities with respect to the exempt offering document. Specified activities which trigger involvement are included in the proposed SAS. Although an auditor is not required to become involved in an exempt offering document unless the benchmarks defining involvement are met, auditors are not precluded from becoming voluntarily involved with an offering document in other circumstances. Comments are due by 13 October 2016.

    6 July 2016

    Amendment to Statement on Standards for Accounting and Review Services No. 21 Section 90, Review of financial statements
    The AICPA Accounting and Review Services Committee (ARSC) issued an exposure draft that would amend the AICPA’s standard on reviews of financial statements. AR-C Section 90 includes requirements and guidance when supplementary information accompanies reviewed financial statements and the accountant’s review report thereon. ARSC determined that certain revisions are necessary to correct the requirements and guidance related to reporting on supplementary information. These revisions would be accomplished by amending paragraphs .05 and .80–.82 of AR-C Section 90, Review of Financial Statements, and the corresponding application paragraphs. Comments are due by 2 September 2016.

    5 July 2016

    The auditor's consideration of an entity's ability to continue as a going concern
    This proposal would supersede SAS No. 126 and amend various sections of SAS No. 122. The ASB is pursuing a strategy to converge its standards with those of the IAASB and used International Standard on Auditing (ISA) 570 (Revised), Going Concern, as the base for the going concern proposal. The proposed SAS does not reflect any revisions to ISA 570 (Revised) related to the convergence with the IAASB’s auditor reporting standards. Those revisions will be considered during the ASB’s overall project on the auditor’s report. It includes proposed amendments to auditing standards addressing: audits of special-purpose frameworks and audits of single financial statements and specific elements, accounts, or items of a financial statement and interim financial information. Comments are due by 5 September 2016.

    16 May 2016

    Hosting services
    The AICPA Professional Ethics Executive Committee (PEEC) is exposing for comment an independence interpretation that provides guidance to members on the provision of hosting services to clients. The PEEC believes hosting services involve situations where a client engages a member to have custody or control of data or records that the client uses to conduct its operations. As it is management’s responsibility to have custody and control over its assets, the PEEC believes providing hosting services creates threats to independence that are not at an acceptable level and cannot be reduced to an acceptable level by the application of safeguards; therefore, impairing independence. Comments are due by 18 July 2016.

    EY Comment letters

    1 December 2017

    Comment Letter - AICPA’s proposed new attestation service
    In our comment letter, we support the AICPA’s proposal to create a new type of attestation service called a selected procedures engagement that would provide more opportunities for companies to enhance the value of reports they provide to customers, employees, suppliers and other stakeholders. However, we believe any final standard should include additional requirements and application guidance to protect report users.

    6 September 2016

    Comment Letter - ASB’s going concern proposal
    In our comment letter, we support the issuance of the Proposed Statement on Auditing Standards, The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern, to promote consistency between the auditing standards and ASU 2014-15, Presentation of Financial Statements – Going Concern, which will require management to evaluate whether there is substantial doubt about an entity’s ability to continue as a going concern. However, we disagree with the proposed requirement for the auditor to make inquiries of management about its knowledge of conditions or events beyond the period of management’s evaluation that raise substantial doubt about the entity’s ability to continue as a going concern.