Response to Exposure Draft: Proposed revisions related to engagements subject to the Statements on Standards for Attestation Engagements, Dated June 5, 2025

I considered the eight questions that were proposed by the Exposure Draft and decided that the best value would be to respond to questions (1), (2) and (4) together because which in effect deal with the definition of the period covered by an attest engagement. I combined the answers to these questions by expanding the definition to include a reference to all known and reasonably knowable facts and circumstances at a period or a point in time.

While the change from the financial-statement focus (for attest engagements) to a attest-report focus is reasonable, the U.S. Generally Accepted Accounting Principles has a built-in mechanism for handling subsequent events. Moving away from U.S. GAAP may cause the practitioners to lose this mechanism, so it must be added to the definition of the term “period covered by the attest engagement”, even if such a period is a single day, or “as of” a date.

I also responded to question (5) in connection with the definition of “Attest” versus “Audit”.
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