Advocacy.

• Position: Fei News

FEI's Committee on Corporate Reporting (CCR) has issued a written comment to the Public Company Accounting Oversight Board (PCAOB) on its proposal, An Audit of Internal Control Over Financial Reporting Performed in Conjunction with an Audit of Financial Statements, that takes issue with a perceived level of duplicative testing.

While generally supportive of the proposal, CCR argues that "the standard, as currently drafted, creates a situation where the costs far outweigh the benefits of implementation. Given the limited level of reliance that the external auditor can place on the work of others, the resultant level of duplicative testing will cause numerous interruptions to the operations of our businesses.

"These interruptions alone are very costly; however, when coupled with the cost of internal and external resources to support management's assertion and the fees associated with the increased work to be performed by the external auditor, the costs are far beyond the benefits attained," the letter adds. "Most CCR companies will see an increase of 30 percent to 50 percent in audit fees as a direct result of the required audit of internal control over financial reporting."

The committee also contends that "that the standard does not allow the auditor to exercise sufficient judgment. The proposed standard is very prescriptive, causing auditors to perform the same level of testing at companies with strong control structures as would be performed at those with weak control structures."

In situations where the control environment is very strong, CCR argues, "the level of detail testing of the controls over routine data processing should be minimal." And, as the rule relates to rotating tests of controls, the committee believes the rule "does not allow...