In this letter to the PCAOB, the CAQ requests the PCAOB take action to defer the effective date of paragraph .10A of PCAOB Auditing Standard 1105, Audit Evidence (AS 1105) and determine whether questions and concerns with respect to paragraph .10A can be best addressed through written implementation guidance or standard-setting action.
Specifically, the CAQ is requesting a deferral of the effective date because, absent written interpretive guidance or amendments to further clarify the objective of AS 1105.10A, the requirement lacks sufficient clarity for successful implementation and could be interpreted in a way that would incur significant unnecessary costs without commensurate benefit. Deferring the effective date of AS 1105.10A would allow the PCAOB to issue written implementation guidance to address unanswered questions about how the requirements are expected to be applied or re-propose the requirements in AS 1105.10A for a targeted amendment.
Read the full comment letter here.