Appendix C

Remarks Regarding the Questions
Posed in the Proposing Release








Appendix C

Remarks Regarding the Questions
Posed in the Proposing Release

We have not been able to develop responses to all of the 400 questions raised in the Proposing Release within the comment period. Drawing on existing AICPA guidance, we have answered many of the questions, both in the Comment Letter and in Appendix B. For the AICPA to go beyond these responses would require the completion of a deliberative process of vetting and consultation with various committees of experts - a process which could not possibly be accomplished in the 75 days permitted for the comment period.

The volume of highly specific, rule-based questions further illustrates the need for a principles-based approach to auditor independence, supplemented by a pragmatic balancing of threats and safeguards. That can be accomplished through the development of a conceptual framework, which the ISB is in the process of formulating.