Member firms may elect, or non-SEC issuers may request, that an audit of a non-SEC issuer's financial statements be performed in accordance with PCAOB standards. Under this circumstance, when the firm will be voluntarily performing or legally required to perform the audit in accordance with PCAOB standards and the audit report will not be included in an SEC filing, the member firm can elect to either perform the audit in accordance with all PCAOB auditing and related professional practice standards or solely in accordance with PCAOB auditing standards. In both circumstances, the member firm must also comply with GAAS. The AICPA has conveniently organized all AICPA Statements on Auditing Standards (SASs), relevant PCAOB rules and standards, and AICPA Statements on Standards for Attestation Engagements (SSAEs) with all conforming amendments to give you the most up-to-date guidance. Purchase Codification of Auditing Standards.

It is important to note that if the non-SEC issuer is a subsidiary, division, or segment of an SEC issuer whose report is being relied upon by the principal auditor of the SEC issuer and filed with the SEC, then the guidance above to choose whether to perform the audit in accordance with all of the PCAOB standards or solely in accordance with the PCAOB auditing standards, does not apply. In this situation, since the non-SEC issuer's audit report will be relied upon by the principal auditor of an SEC issuer and included in an SEC filing, the member firm must perform the audit in accordance with all of the auditing and related professional practice standards of the PCAOB and all applicable SEC rules.

Refer to the CAQ Guidance for Firms Issuing Audit Reports for Non-Issuers that are Filed with the SEC for additional information and a roadmap to PCAOB Standards.

Additional auditing guidance:

• CAQ's 10/4/07 Webcast - PCAOB Insights on Internal Control: A Discussion on Auditing Standard No. 5 - Available on CD-ROM!  Purchase online or call 1-888-777-7077 and ask for product number 780116HS 
  
  
• U.S. Treasury Secretary Announces Charter of Advisory Committee on Strengthening the Auditing Profession (May 2007) 
  
  
• CPAs Exempt from Privacy Notification Requirement of the Gramm-Leach-Bliley Act (September 2006)
  
  
• CAQ SEC Disclosure Checklist Resource Page
  
  
• CAQ Resource Page on Employee Benefit Plan Audits and Form 11-K Latest Industry Developments
  
  
•  CAQ Audit & Control Technology Store Resource Page
  
  
• Alternative Investments – Audit Considerations: A Practice Aid for Auditors (July 2006) – Due to the increased risk of misstatement inherent with alternative investments, the AICPA's Alternative Investments Task Force has issued this practice aid for auditors to assist in auditing alternative investments.
  
  
•  PCAOB Staff Q&As: Adjustments to Financial Statements Audited by a Predecessor Auditor
  
  
• Investment Companies Expert Panel Issues Revised N-SAR Letter – An illustration of the independent registered public accounting firm's report on a registered investment company's internal control.
  
  
• New AICPA Technical Practice Aid—Impact of Natural Disasters on Audit Work
  
  
• Applicability of SSARS to Reviews of Nonissuers Who Are Owned By or Controlled By an Issuer – View CAQ Summary of SSARS Interpretation
  
  
• Reporting Considerations for Non-Accelerated Filer Audit Reports
  
  
• GAO Issues Guidance for Audits Subject to Both Governmental Auditing Standards (or Yellow Book) and PCAOB Auditing Standards
  
  
• Big 4 Issued Two Investor Resource Guides on SOX 404 to assist investors—individual and institutional, small and large in understanding the new internal control reporting. Firms are encouraged to distribute these two guides to their clients:
  
  

o        Internal Control Over Financial Reporting: An Investor Resource (PDF)

o        Perspectives on Internal Control Reporting: A Resource for Market Participants (PDF)

·         Federal Financial Institutions Examination Council (FFIEC) issues an Interagency Advisory on the Unsafe and Unsound Use of Limitation of Liability Provisions in External Engagement Letters

·         Reference to PCAOB Standards in an Audit Report on a Nonissuer (Interpretation 18 to SAS 58)

·         PCAOB FAQs on Audits of Nonissuers

·         Professional Issues Task Force (PITF) Practice Alerts

·         SEC Regulations Committee Highlights

·         Enterprise Risk Management—Integrated Framework Published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)

·         Center for Audit Quality Issues FAQs on Insured Depository Institutions Subject to FDICIA