ASB issues auditing interpretation on dual reporting

It applies to audits performed beyond PCAOB oversight.

The AICPA Auditing Standards Board (ASB) recently issued an interpretation to help auditors comply with reporting requirements under both AU-C Section 700 and PCAOB Auditing Standard No. 3101.

Auditing Interpretation No. 4, "Reporting on Audits Conducted in Accordance With Auditing Standards Generally Accepted in the United States of America and the Standards of the PCAOB," has been determined to be consistent with generally accepted auditing standards, but should not be construed to be an interpretation of PCAOB standards.

The interpretation provides guidance for complying with AU-C Section 700, Forming an Opinion and Reporting on Financial Statements, in the context of AS No. 3101, The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion.

Interpretation No. 4 applies in situations when an auditor may be required by law or regulation — or voluntarily agrees — to perform an audit engagement in accordance with PCAOB standards for a company whose audit is not subject to PCAOB oversight.

For example, SEC rules permit audits under PCAOB standards in connection with offerings under Regulation A and Regulation Crowdfunding. In these situations, certain elements of the auditor's report required under the final standard, such as the use of "registered public accounting firm" in the title or the statement regarding independence requirements, may not apply.

The interpretation includes answers to common questions CPAs may ask in these situations and includes examples of reports prepared according to the guidance in the interpretation.

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