DHG's Comment Letter Response to the AICPA's Proposed Changes to the Standards for Attestation Engagements

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Dixon Hughes Goodman LLP (DHG) welcomes the opportunity to comment on the Auditing Standards Board’s (ASB) Proposed Statement on Standards for Attestation Engagements - Revisions to Statement on Standards for Attestation Engagements No. 18, Attestation Standards: Clarification and Recodification (Attestation Proposal). Headquartered in Charlotte, North Carolina, DHG ranks among the top 20 public accounting firms in the nation, with more than 2,000 professionals and staff in 13 states, and is a member of Praxity, a global alliance of independent firms.

DHG is supportive of the ASB’s efforts in advancing the attestation standards to provide more flexibility to practitioners in meeting new market demands, particularly as it relates to amending AT-C Section 215, “Agreed-Upon Procedures” (AT-C 215) to allow for flexibility in the development of procedures and general use reports, while requiring the restriction of an agreed-upon procedures (AUP) report in certain circumstances. We believe there is a need for a service that allows for the performance of procedures and reporting of findings in a report that is general use and, consequently, does not specifically require the agreement of all users to the procedures. However, we do have concerns about the potential unintended consequences some of the proposed amendments could have on users’ understanding of the attestation services offerings, in particular, understanding of the services and procedures performed under an AUP engagement, and what evidence was obtained to support the procedures and findings included in these reports.

An AUP engagement has been a beneficial professional service offering for years, and any advancements to these engagements should be grounded within the foundational framework of extant AT-C 215. We acknowledge the challenges in developing any new service offering and have provided recommendations that are intended to enhance users’ understanding of the services offered and to assist practitioners and engaging parties in considering how to design and conduct AUP engagements.

Our responses are framed by our experience serving numerous private companies, middle-market public issuers, and non-issuer brokers and dealers, and include our concerns regarding the potential implications the Attestation Proposal could have for medium to larger-sized accounting firms.

Click below to read the full response letter.