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7 tips to have an influence on future standards

StandardsStandards are amended, and new ones are issued. But did you know that it is possible to express your opinion—and even make a difference—in the standard-setting process? If you’ve never done so before, here are some tips based on my own experience.

Your opinions are welcome! Standard setters actively solicit comments – not only from those who are directly impacted by the exposure draft but also from any other interested parties. They do read and carefully consider all comments submitted.

The explanatory memorandum is a helpful guide. With any exposure draft, you’ll want to understand the key issues and what they mean. Exposure drafts generally come with explanatory memoranda that offer a quick introduction to the proposed standard. It can tell you, among other things, the key issues addressed and changes proposed. Many explanatory memoranda include questions to consider when drafting your response.

 

You don’t have to answer all of the questions from the memorandum. It’s fine to address only the ones that are meaningful to you and ignore those that don’t pertain to your practice or area of expertise. Your comment letter may be short and focus exclusively on a narrow matter relevant to you.

State your mind in your letter. At the beginning of your response, say whether you support the exposure draft and highlight the main areas of focus for your letter. When you’re addressing issues covered in the questions noted in the explanatory memorandum, frame your comments as answers to those questions. That can make it easier to organize your thoughts, and it helps the standard setters to judge overall opinions with respect to the specific questions posed. You can also highlight areas of concern not addressed in the memorandum, as well as provide editorial comments relating to the exposure draft where you believe further clarification is needed.

Offer ideas for improvement. If you don’t agree with some or all of the exposure draft, try to be constructive in your criticism. If possible, suggest solutions, including specific wording. Feel free to offer examples of how the proposal could affect your own practice, clients or company, including any unintended consequences that the standard setter may not have considered. 

Express all views, including the positive! Positive comments either relating to the exposure draft as a whole, or to key aspects being addressed therein, are important to share as well. This feedback can help standard setters better evaluate support for the proposal. If you think the proposal will improve the quality of auditing in practice, don’t be silent – share your insights with the standard setter!

Get in touch if you need to. It’s often possible to reach out to technical staff at the standard setter—whose names may be listed in the exposure draft—for help with questions. Standard setters’ sites also often include meeting materials or discussions of how and why the project was developed, as well as access to comment letters already received on the proposal. In addition, the TIC Alert, published by the AICPA Technical Issues Committee, offers details on standards in development that will have an impact on private companies. The alert typically includes comment deadlines for exposure drafts. 

Standard setters welcome the opinions and ideas of their constituents, which means that your comments can make a difference, helping to shape the rules we follow and the way we practice...

The AICPA Auditing Standards Board has released a set of exposure drafts aimed at enhancing the relevance and usefulness of the auditor’s report. Please consider commenting on these proposals. Send all feedback to Sherry Hazel at Sherry.Hazel@aicpa-cima.com by May 15.

Sally Ann Bailey, Senior Manager, National Office—Audit and Assurance Services, Deloitte & Touche LLP.  Sally Ann is responsible for analyzing and drafting certain of Deloitte’s responses to various standard setting exposure drafts, both in the U.S. and globally. She consults and advises engagement teams on the application of appropriate professional standards. Sally Ann is also involved in developing Deloitte methodology and implementation guidance.

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