Audit Considerations Relating to an Entity Using a Service Organization

February 17, 2009 Auditing Standards Board American Institute of Certified Public Accountants Audit – Tax – Advisory 1211 Avenue of the Americas Grant Thornton LLP New York, NY 10036-8775 175 W Jackson Boulevard, 20th Floor Chicago, IL 60604-2687 T 312.856.0200 F 312 565 4719 www.GrantThornton.com Dear Board Members and Staff: We appreciate the opportunity to comment on the proposed Statement on Auditing Standards (SAS), Audit Considerations Relating to an Entity Using a Service Organization (Redrafted), and proposed Statement on Standards for Attestation Engagements (SSAE), Reporting on Controls at a Service Organization, approved for exposure by the Auditing Standards Board of the American Institute of Certified Public Accountants. We support the Board’s issuance of the proposals, particularly separating them within the audit and attestation standards, and respectfully submit our comments and recommendations. Overall, we are very pleased with the proposals and commend the Board on this significant undertaking to clarify extant AU section 324, Service Organizations, and converge it with the standards of the International Auditing and Assurance Standards Board (IAASB). Objectives and requirements We believe the objectives to be achieved by the auditor, the related requirements, and the revisions to converge with proposed International Standard on Auditing (ISA) 402 (Revised and Redrafted), Audit Considerations Relating ...