
[Federal Register Volume 80, Number 122 (Thursday, June 25, 2015)]
[Notices]
[Pages 36601-36652]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-15571]



[[Page 36601]]

Vol. 80

Thursday,

No. 122

June 25, 2015

Part II





Securities and Exchange Commission





-----------------------------------------------------------------------





 Public Company Accounting Oversight Board; Notice of Filing of 
Proposed Rules to Implement the Reorganization of PCAOB Auditing 
Standards and Related Changes to PCAOB Rules and Attestation, Quality 
Control, and Ethics and Independence Standards; Notice

  Federal Register / Vol. 80 , No. 122 / Thursday, June 25, 2015 / 
Notices  

[[Page 36602]]


-----------------------------------------------------------------------

SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-75251; File No. PCAOB 2015-01]


Public Company Accounting Oversight Board; Notice of Filing of 
Proposed Rules to Implement the Reorganization of PCAOB Auditing 
Standards and Related Changes to PCAOB Rules and Attestation, Quality 
Control, and Ethics and Independence Standards

 June 19, 2015.
    Pursuant to Section 107(b) of the Sarbanes-Oxley Act of 2002 (the 
``Act''), notice is hereby given that on June 17, 2015, the Public 
Company Accounting Oversight Board (the ``Board'' or the ``PCAOB'') 
filed with the Securities and Exchange Commission (``SEC'' or 
``Commission'') the proposed rules described in items I and II below, 
which items have been prepared by the Board. The Commission is 
publishing this notice to solicit comments on the proposed rules from 
interested persons.

I. Board's Statement of the Terms of Substance of the Proposed Rules

    On March 31, 2015, the Board adopted amendments to implement the 
reorganization of PCAOB auditing standards and related changes to PCAOB 
rules and attestation, quality control, and ethics and independence 
standards (collectively referred to as, the ``amendments'' or the 
``proposed rules'').
    The text of the proposed rules is set out below.

Amendments to Rules of the Board

Rule 3101. Certain Terms Used in Auditing and Related Professional 
Practice Standards
    Rule 3101. Certain Terms Used in Auditing and Related Professional 
Practice Standards, is amended as follows:
    In paragraph (b), the phrase ``adopted in Rules 3200T, 3300T, 
3400T, 3500T, and 3600T'' is deleted.
Rule 3200T. Interim Auditing Standards
    Rule 3200T. Interim Auditing Standards, is amended as follows:
     The letter ``T'' is removed from the reference to Rule 
3200T.
     The word ``Interim'' is removed from the title of the 
rule.
     The text of the rule is replaced with the following:
    In connection with the preparation or issuance of any audit report, 
a registered public accounting firm and its associated persons shall 
comply with all applicable auditing standards adopted by the Board and 
approved by the SEC, including, to the extent not superseded or amended 
by the Board, AICPA Statements on Auditing Standards as in existence on 
April 16, 2003.

Amendments to PCAOB Standards

Auditing Standards and Interpretations
    Auditing Standard No. 1, References in Auditors' Reports to the 
Standards of the Public Company Accounting Oversight Board \1\
---------------------------------------------------------------------------

    \1\ The captions in this section refer to the numbers and titles 
of existing PCAOB auditing standards and interpretations.
---------------------------------------------------------------------------

    Auditing Standard No. 1, References in Auditors' Reports to the 
Standards of the Public Company Accounting Oversight Board, is 
superseded.
Auditing Standard No. 3, Audit Documentation
    Auditing Standard No. 3, Audit Documentation, as amended, is 
amended as follows:
    a. The section number ``Auditing Standard No. 3'' is replaced with 
``AS 1215.''
    b. In the references before paragraph 1, the phrase ``[supersedes 
SAS No. 96, Audit Documentation]'' is deleted.
    c. Paragraph numbers 1 through 21 are replaced with .01 through 
.21.
    d. In footnote 1 to paragraph 4, the reference to ``paragraph 12'' 
is replaced with ``paragraph .12.''
    e. In footnote 2 to paragraph 6, the reference to ``paragraphs 28-
33 of Auditing Standard No. 5'' is replaced with ``paragraphs .28-.33 
of AS 2201.''
    f. In paragraph 9:
     The parenthetic reference to ``paragraph 15'' is replaced 
with ``paragraph .15.''
     In the first bullet, the reference to ``paragraph 16'' is 
replaced with ``paragraph .16.''
     In the second bullet, the reference to ``AU sec. 390'' is 
replaced with ``AS 2901.''
    g. In footnote 2A to paragraph 12a:
     The reference to ``paragraphs 12-13 of Auditing Standard 
No. 12'' is replaced with ``paragraphs .12-.13 of AS 2110.''
     The reference to ``AU sec. 316'' is replaced with ``AS 
2401.''
    h. In footnote 2B to paragraph 12c, the reference to ``paragraphs 
10-23 of Auditing Standard No. 14'' is replaced with ``paragraphs 
.10-.23 of AS 2810.''
    i. In footnote 2C to paragraph 12f:
     The reference to ``paragraph 74 of Auditing Standard No. 
12, Identifying and Assessing Risks of Material Misstatement,'' is 
replaced with ``AS 2110.74.''
     The reference to ``paragraph 36 of Auditing Standard No. 
14, Evaluating Audit Results'' is replaced with ``AS 2810.36.''
    j. In the second sentence of paragraph 17, the reference to ``AU 
sec. 711, Filings Under Federal Securities Statutes'' is replaced with 
``AS 4101, Responsibilities Regarding Filings Under Federal Securities 
Statutes.''
    k. In the first sentence of paragraph 18, the reference to 
``paragraphs 4-13'' is replaced with ``paragraphs .04-.13.''
    l. In paragraph 19a, the reference to ``paragraphs 12 and 13'' is 
replaced with ``paragraphs .12 and .13.''
    m. In paragraph 19c, the reference to ``paragraph 8'' is replaced 
with ``paragraph .08.''
    n. In the last sentence of paragraph 19, the reference to ``AU sec. 
543, Part of Audit Performed by Other Independent Auditors,'' is 
replaced with ``AS 1205, Part of the Audit Performed by Other 
Independent Auditors.''
Auditing Standard No. 4, Reporting on Whether a Previously Reported 
Material Weakness Continues to Exist
    Auditing Standard No. 4, Reporting on Whether a Previously Reported 
Material Weakness Continues to Exist, as amended, is amended as 
follows:
    a. The section number ``Auditing Standard No. 4'' is replaced with 
``AS 6115.''
    b. Paragraph numbers 1 through 65 are replaced with .01 through 
.65.
    c. In Note 1 to paragraph 1, the reference to ``Auditing Standard 
No. 5'' is replaced with ``AS 2201.''
    d. In paragraph 2:
     In item (1), the reference to ``Auditing Standard No. 5, 
An Audit of Internal Control Over Financial Reporting That Is 
Integrated with An Audit of Financial Statements,'' is replaced with 
``AS 2201.''
     In item (2), the reference to ``Auditing Standard No. 5'' 
is replaced with ``AS 2201.''
     The parenthetic reference to ``paragraph 26'' is replaced 
with ``paragraph .26.''
     In the note, the reference to ``Auditing Standard No. 5, 
An Audit of Internal Control Over Financial Reporting That Is 
Integrated with An Audit of Financial Statements'' is replaced with 
``AS 2201.''
    e. In the last sentence of paragraph 4, the reference to ``Auditing 
Standard No. 5, An Audit of Internal Control Over Financial Reporting 
That Is Integrated with An Audit of Financial Statements,'' is replaced 
with ``AS 2201.''
    f. In paragraph 7e, the reference to ``paragraph 48'' is replaced 
with ``paragraph .48.''
    g. In paragraph 8, the reference to ``paragraph 7'' is replaced 
with ``paragraph .07.''

[[Page 36603]]

    h. In paragraph 9, the reference to ``Auditing Standard No. 5, An 
Audit of Internal Control Over Financial Reporting That Is Integrated 
with An Audit of Financial Statements'' is replaced with ``AS 2201.''
    i. In paragraph 10:
     In the first sentence, the reference to ``Paragraph 5 of 
Auditing Standard No. 5, An Audit of Internal Control Over Financial 
Reporting That Is Integrated with An Audit of Financial Statements,'' 
is replaced with ``AS 2201.05.''
     In the first sentence of the note, the reference to 
``Auditing Standard No. 5, An Audit of Internal Control Over Financial 
Reporting That Is Integrated with An Audit of Financial Statements,'' 
is replaced with ``AS 2201.''
    j. In paragraph 11, the reference to ``Auditing Standard No. 5, An 
Audit of Internal Control Over Financial Reporting That Is Integrated 
with An Audit of Financial Statements'' is replaced with ``AS 2201.''
    k. In footnote 2 to paragraph 13, the reference to ``paragraph 42 
of Auditing Standard No. 5, An Audit of Internal Control Over Financial 
Reporting That Is Integrated with An Audit of Financial Statements'' is 
replaced with ``AS 2201.42.''
    l. In the last sentence of the note to paragraph 17, the reference 
to ``Auditing Standard No. 5, An Audit of Internal Control Over 
Financial Reporting That Is Integrated with An Audit of Financial 
Statements'' is replaced with ``AS 2201.''
    m. In Note 2 to paragraph 18, the reference to ``Auditing Standard 
No. 5, An Audit of Internal Control Over Financial Reporting That Is 
Integrated with An Audit of Financial Statements'' is replaced with 
``AS 2201.''
    n. In the first sentence of paragraph 23, the reference to 
``paragraph 20 of Auditing Standard No. 5, An Audit of Internal Control 
Over Financial Reporting That Is Integrated with An Audit of Financial 
Statements'' is replaced with ``AS 2201.20.''
    o. In the last sentence of paragraph 24, the reference to 
``paragraph 9 of Auditing Standard No. 5, An Audit of Internal Control 
Over Financial Reporting That Is Integrated with An Audit of Financial 
Statements'' is replaced with ``AS 2201.09.''
    p. In paragraph 25:
     In the last sentence, the reference to ``Auditing Standard 
No. 5, An Audit of Internal Control Over Financial Reporting That Is 
Integrated with An Audit of Financial Statements,'' is replaced with 
``AS 2201.''
     In the note:
     Each reference to ``Auditing Standard No. 5, An Audit of 
Internal Control Over Financial Reporting That Is Integrated with An 
Audit of Financial Statements,'' is replaced with ``AS 2201.''
     In the second sentence, the reference to ``paragraphs 26a-
b and 27'' is replaced with ``paragraphs .26a-b and .27.''
     In the last sentence, the reference to ``paragraphs 26 and 
27'' is replaced with ``paragraphs .26 and .27.''
    q. In paragraph 26:
     In the first sentence, the reference to ``paragraph 5'' is 
replaced with ``paragraph .05.''
     In footnote 3, the reference to ``paragraph .02 of AU sec. 
315, Communications Between Predecessor and Successor Auditors'' is 
replaced with ``paragraph .02 of AS 2610, Initial Audits--
Communications Between Predecessor and Successor Auditors.''
    r. In the first sentence of paragraph 26a, the reference to 
``paragraphs 22-27 of Auditing Standard No. 5, An Audit of Internal 
Control Over Financial Reporting That Is Integrated with An Audit of 
Financial Statements'' is replaced with ``AS 2201.22-.27.''
    s. In paragraph 26b, the reference to ``paragraphs 34-38 of 
Auditing Standard No. 5, An Audit of Internal Control Over Financial 
Reporting That Is Integrated with An Audit of Financial Statements,'' 
is replaced with ``AS 2201.34-.38.''
    t. In the first sentence of paragraph 26c, the reference to ``AU 
sec. 315, Communications Between Predecessor and Successor Auditors'' 
is replaced with ``AS 2610.''
    u. In paragraph 27:
     In the first sentence, the reference to ``paragraph 26'' 
is replaced with ``paragraph .26.''
     In the last sentence, the reference to ``Auditing Standard 
No. 5, An Audit of Internal Control Over Financial Reporting That Is 
Integrated with An Audit of Financial Statements'' is replaced with 
``AS 2201.''
    v. In the last sentence of paragraph 28, the reference to 
``paragraph 7'' is replaced with ``paragraph .07.''
    w. In the last sentence of paragraph 31, the reference to 
``paragraphs 42-43 of Auditing Standard No. 5, An Audit of Internal 
Control Over Financial Reporting That Is Integrated with An Audit of 
Financial Statements'' is replaced with ``AS 2201.42-.43.''
    x. In paragraph 32:
     In the first sentence, the reference to ``paragraphs 44-45 
of Auditing Standard No. 5, An Audit of Internal Control Over Financial 
Reporting That Is Integrated with An Audit of Financial Statements'' is 
replaced with ``AS 2201.44-.45.''
     In the last sentence, the reference to ``paragraphs 50-54 
of Auditing Standard No. 5'' is replaced with ``AS 2201.50-.54.''
    y. In the third sentence of paragraph 33, the reference to 
``paragraphs 22-24 of Auditing Standard No. 5, An Audit of Internal 
Control Over Financial Reporting That Is Integrated with An Audit of 
Financial Statements'' is replaced with ``AS 2201.22-.24.''
    z. In paragraph 35, the reference to ``Auditing Standard No. 5, An 
Audit of Internal Control Over Financial Reporting That Is Integrated 
with An Audit of Financial Statements,'' is replaced with ``AS 2201.''
    aa. In the last sentence of paragraph 36, the reference to 
``paragraphs 16-19 of Auditing Standard No. 5, An Audit of Internal 
Control Over Financial Reporting That Is Integrated with An Audit of 
Financial Statements'' is replaced with ``AS 2201.16-.19.''
    bb. In the first sentence of paragraph 38, the reference to 
``Paragraphs 18-19 of Auditing Standard No. 5, An Audit of Internal 
Control Over Financial Reporting That Is Integrated with An Audit of 
Financial Statements,'' is replaced with ``AS 2201.18-.19.''
    cc. In the first sentence of paragraph 40, the reference to ``AU 
sec. 543, Part of Audit Performed by Other Independent Auditors'' is 
replaced with ``AS 1205, Part of the Audit Performed by Other 
Independent Auditors.''
    dd. In the first sentence of the note to paragraph 43, the 
reference to ``paragraph 51'' is replaced with ``paragraph .51.''
    ee. In the second sentence of paragraph 46, the reference to 
``paragraph 43'' is replaced with ``paragraph .43.''
    ff. In paragraph 47:
     In the first sentence, the reference to ``Auditing 
Standard No. 3'' is replaced with ``AS 1215.''
     In the second sentence, the reference to ``Paragraph 14 of 
Auditing Standard No. 3'' is replaced with ``AS 1215.14.''
     In the third sentence, the reference to ``paragraph 29'' 
is replaced with ``paragraph .29.''
     In the last sentence, the reference to ``Auditing Standard 
No. 3'' is replaced with ``AS 1215.''
    gg. In the first sentence of paragraph 48, the reference to 
``paragraph 7e'' is replaced with ``paragraph .07e.''
    hh. In paragraph 50, the reference to ``paragraph 48'' is replaced 
with ``paragraph .48.''
    ii. In the first sentence of the note to paragraph 51b, the 
reference to ``Auditing Standard No. 5, An Audit of Internal Control 
Over Financial Reporting That Is Integrated with An

[[Page 36604]]

Audit of Financial Statements'' is replaced with ``AS 2201.''
    jj. In the note to paragraph 51g, the reference to ``paragraph 31'' 
is replaced with ``paragraph .31.''
    kk. In the first sentence of the note to paragraph 51l, the 
reference to ``Auditing Standard No. 5, An Audit of Internal Control 
Over Financial Reporting That Is Integrated with An Audit of Financial 
Statements'' is replaced with ``AS 2201.''
    ll. In the note to paragraph 51o, the reference to ``Auditing 
Standard No. 5, An Audit of Internal Control Over Financial Reporting 
That Is Integrated with An Audit of Financial Statements'' is replaced 
with ``AS 2201.''
    mm. In the first sentence of paragraph 52, the reference to 
``Auditing Standard No. 5, An Audit of Internal Control Over Financial 
Reporting That Is Integrated with An Audit of Financial Statements,'' 
is replaced with ``AS 2201.''
    nn. In paragraph 53:
     In the first sentence, the reference to ``paragraph 3'' is 
replaced with ``paragraph .03.''
     In the last sentence, the reference to ``paragraph 51'' is 
replaced with ``paragraph .51.''
    oo. In paragraph 54a, the parenthetic reference to ``paragraph 56'' 
is replaced with ``paragraph .56.''
    pp. In paragraph 54b, the parenthetic reference to ``paragraphs 57 
and 58'' is replaced with ``paragraphs .57 and .58.''
    qq. In paragraph 54c, the parenthetic reference to ``paragraphs 59 
through 60'' is replaced with ``paragraphs .59 through .60.''
    rr. In the first sentence of paragraph 55, the reference to 
``paragraph 43'' is replaced with ``paragraph .43.''
    ss. In the third sentence of paragraph 57, the reference to 
``paragraph 44'' is replaced with ``paragraph .44.''
    tt. In the first sentence of paragraph 58, the reference to 
``paragraph 61'' is replaced with ``paragraph .61.''
    uu. In the first sentence of paragraph 59, the reference to 
``paragraph 48'' is replaced with ``paragraph .48.''
    vv. In the note to paragraph 60, each reference to ``paragraph 59'' 
is replaced with ``paragraph .59.''
    ww. In the first sentence of paragraph 62, the reference to 
``paragraph 55'' is replaced with ``paragraph .55.''
    xx. In paragraph 63, the reference to ``paragraphs 7 and 29-32 of 
AU sec. 722, Interim Financial Information'' is replaced with 
``paragraphs .07 and .29-.32 of AS 4105, Reviews of Interim Financial 
Information.''
    yy. In paragraph 64:
     In the second sentence, the reference to ``paragraph 56'' 
is replaced with ``paragraph .56.''
     In the last sentence, the reference to ``paragraphs 7 and 
29-32 of AU 722, Interim Financial Information'' is replaced with ``AS 
4105.07 and AS 4105.29-.32.''
    zz. In Appendix A, in the first sentence of the first paragraph, 
the reference to ``Paragraphs 51 through 60'' is replaced with 
``Paragraphs .51 through .60.''
Auditing Standard No. 5, An Audit of Internal Control Over Financial 
Reporting That Is Integrated with An Audit of Financial Statements
    Auditing Standard No. 5, An Audit of Internal Control Over 
Financial Reporting That Is Integrated with An Audit of Financial 
Statements, as amended, is amended as follows:
    a. The section number ``Auditing Standard No. 5'' is replaced with 
``AS 2201.''
    b. Paragraph numbers 1 through 98 are replaced with .01 through 
.98.
    c. In footnote 3 to paragraph 2, the reference to ``Paragraph A5'' 
is replaced with ``Paragraph .A5.''
    d. In footnote 5 to paragraph 3, the reference to ``AU sec. 230'' 
is replaced with ``AS 1015.''
    e. In paragraph 4:
     In the first sentence, the phrase ``The general 
standards'' is replaced with the phrase ``The standards, AS 1005, 
Independence, AS 1010, Training and Proficiency of the Independent 
Auditor, and AS 1015, Due Professional Care in the Performance of 
Work,.''
     Footnote 6 is deleted.
    f. In paragraph 14:
     In the second sentence:
     The reference to ``paragraph 22'' is replaced with 
``paragraph .22.''
     The reference to ``paragraph 39'' is replaced with 
``paragraph .39.''
     In footnote 10, the reference to ``Auditing Standard No. 
12'' is replaced with ``AS 2110.''
     In footnote 10A to the first bullet, the reference to ``AU 
sec. 316'' is replaced with ``AS 2401.''
    g. In paragraph 15, the reference to ``paragraphs 65-69 of Auditing 
Standard No. 12, Identifying and Assessing Risks of Material 
Misstatement'' is replaced with ``AS 2110.65-.69.''
    h. In the last sentence of paragraph 16, the reference to ``AU sec. 
322, The Auditor's Consideration of the Internal Audit Function in an 
Audit of Financial Statements'' is replaced with ``AS 2605, 
Consideration of the Internal Audit Function.''
    i. In the third sentence of paragraph 18, the reference to 
``paragraphs .09 through .11 of AU sec. 322'' is replaced with ``AS 
2605.09 through .11.''
    j. In footnote 11 to paragraph 20, the reference to ``Auditing 
Standard No. 11'' is replaced with ``AS 2105.''
    k. In footnote 12 to paragraph 28, the reference to ``Auditing 
Standard No. 15'' is replaced with ``AS 1105.''
    l. In footnote 13 to the note to paragraph 31:
     The first parenthetic reference to ``paragraph 14 of 
Auditing Standard No. 14'' is replaced with ``paragraph .14 of AS 
2810.''
     The second parenthetic reference to ``paragraph 61 and 
paragraph 5 of Auditing Standard No. 13'' is replaced with ``paragraph 
.61 and paragraph .05 of AS 2301.''
    m. In paragraph 35:
     The reference to ``paragraph 34'' is replaced with 
``paragraph .34.''
     The reference to ``AU sec. 322'' is replaced with ``AS 
2605.''
    n. In the second sentence of paragraph 36:
     The reference to ``paragraph 29'' is replaced with 
``paragraph .29.''
     The reference to ``Auditing Standard No. 12, Identifying 
and Assessing Risks of Material Misstatement'' is replaced with ``AS 
2110.''
    o. In the first sentence of paragraph 37, the reference to 
``paragraph 34'' is replaced with ``paragraph .34.''
    p. In paragraph 53, the parenthetic reference to ``paragraph B1'' 
is replaced with ``paragraph .B1.''
    q. In the last sentence of paragraph 57, the reference to 
``paragraphs 46 through 56'' is replaced with ``paragraphs .46 through 
.56.''
    r. In paragraph 58, the reference to ``paragraph 47'' is replaced 
with ``paragraph .47.''
    s. In the first sentence of paragraph 59, the reference to 
``paragraphs 47 and 58'' is replaced with ``paragraphs .47 and .58.''
    t. In the last sentence of paragraph 60, the reference to 
``paragraph B28'' is replaced with ``paragraph .B28.''
    u. In paragraph 73, the reference to ``paragraph C2'' is replaced 
with ``paragraph .C2.''
    v. In paragraph 74, the parenthetic reference to ``paragraphs C3 
through C7'' is replaced with ``paragraphs .C3 through .C7.''
    w. In paragraph 75g, the reference to ``paragraphs 78 and 80'' is 
replaced with ``paragraphs .78 and .80.''
    x. In paragraph 76, the reference to ``paragraph C3'' is replaced 
with ``paragraph .C3.''
    y. In paragraph 77, the reference to ``AU sec. 333'' is replaced 
with ``AS 2805.''
    z. In the last sentence of paragraph 84:
     The reference to ``AU sec. 316, Consideration of Fraud in 
a Financial

[[Page 36605]]

Statement Audit'' is replaced with ``AS 2401.''
     The reference to ``AU sec. 317'' is replaced with ``AS 
2405.''
    aa. In paragraph 85e, the reference to ``paragraph A5'' is replaced 
with ``paragraph .A5.''
    bb. In paragraph 90:
     In the first sentence, the reference to ``Paragraphs 62 
through 70'' is replaced with ``Paragraphs .62 through .70.''
     In footnote 19, the reference to ``paragraph C3'' is 
replaced with ``paragraph .C3.''
    cc. In the first bullet of paragraph 91, the reference to 
``paragraph A7'' is replaced with ``paragraph .A7.''
    dd. In the first sentence of the note to paragraph 92, the 
reference to ``paragraphs 88 and 91'' is replaced with ``paragraphs .88 
and .91.''
    ee. In the last sentence of paragraph 93, the reference to 
``paragraph 75h'' is replaced with ``paragraph .75h.''
    ff. In the second sentence of paragraph 95, the reference to ``AU 
sec. 560'' is replaced with ``AS 2801.''
    gg. In paragraph 96:
     The parenthetic reference to ``paragraph C2'' is replaced 
with ``paragraph .C2.''
     In the last sentence, the reference to ``paragraph C13'' 
is replaced with ``paragraph .C13.''
    hh. In the last sentence of paragraph 98, the reference to ``AU 
sec. 561'' is replaced with ``AS 2905.''
    ii. In Appendix A, paragraph numbers A1 through A11 are replaced 
with .A1 through .A11.
    jj. In Appendix B, paragraph numbers B1 through B33 are replaced 
with .B1 through .B33.
    kk. In the first sentence of paragraph B5, the reference to 
``paragraph B2'' is replaced with ``paragraph .B2.''
    ll. In paragraph B13, the reference to ``paragraph 61'' is replaced 
with ``paragraph .61.''
    mm. In the fifth sentence of paragraph B16, the reference to ``AU 
sec. 722, Interim Financial Information'' is replaced with ``AS 4105, 
Reviews of Interim Financial Information.''
    nn. In paragraph B17:
     In the first sentence, the reference to ``AU sec. 324, 
Service Organizations,'' is replaced with ``AS 2601, Consideration of 
an Entity's Use of a Service Organization.''
     In the last sentence, the reference to ``AU sec. 324'' is 
replaced with ``AS 2601.''
    oo. In the first sentence of paragraph B18, the reference to ``AU 
sec. 324.03'' is replaced with ``AS 2601.03.''
    pp. In the first sentence of paragraph B19, the reference to ``AU 
sec. 324.07'' is replaced with ``AS 2601.07.''
    qq. In the first sentence of paragraph B20, the reference to ``AU 
sec. 324.12'' is replaced with ``AS 2601.12.''
    rr. In the note to paragraph B20a:
     In the first sentence, the parenthetic reference to ``AU 
sec. 324.24b'' is replaced with ``AS 2601.24b.''
     In the second sentence, the parenthetic reference to ``AU 
sec. 324.24a'' is replaced with ``AS 2601.24a.''
     In the last sentence, the reference to ``AU sec. 324'' is 
replaced with ``AS 2601.''
    ss. In the note to paragraph B21, the reference to ``AU sec. 
324.16'' is replaced with ``AS 2601.16.''
    tt. In the last sentence of paragraph B23, the reference to ``AU 
sec. 543, Part of Audit Performed by Other Independent Auditors'' is 
replaced with ``AS 1205, Part of the Audit Performed by Other 
Independent Auditors.''
    uu. In Appendix C, paragraph numbers C1 through C17 are replaced 
with .C1 through .C17.
    vv. In the last sentence of paragraph C2, the reference to 
``paragraph 91'' is replaced with ``paragraph .91.''
    ww. In paragraph C4, the parenthetic reference to ``paragraph 85'' 
is replaced with ``paragraph .85.''
    xx. In paragraph C5:
     In the first bullet, the reference to ``paragraph A7'' is 
replaced with ``paragraph .A7.''
     In the last sentence of the second bullet, the reference 
to ``paragraph 91'' is replaced with ``paragraph .91.''
    yy. In the note to paragraph C6, the reference to ``paragraph 89'' 
is replaced with ``paragraph .89.''
    zz. In the second sentence of paragraph C8, the reference to ``AU 
sec. 543, Part of Audit Performed by Other Independent Auditors'' is 
replaced with ``AS 1205, Part of the Audit Performed by Other 
Independent Auditors.''
    aaa. In the last sentence of paragraph C9, the reference to ``AU 
sec. 543'' is replaced with ``AS 1205.''
    bbb. In footnote 1 to paragraph C10, the reference to ``paragraph 
B15'' is replaced with ``paragraph .B15.''
    ccc. In paragraph C12, the reference to ``paragraph 72'' is 
replaced with ``paragraph .72.''
    ddd. In paragraph C14:
     In the last sentence, the reference to ``AU sec. 317'' is 
replaced with ``AS 2405.''
     In the first sentence of the note, the reference to 
``paragraph C12'' is replaced with ``paragraph .C12.''
    eee. In paragraph C15:
     In the first sentence, the reference to ``AU sec. 722, 
Interim Financial Information'' is replaced with ``AS 4105, Reviews of 
Interim Financial Information.''
     In the last sentence, the reference to ``AU sec. 722'' is 
replaced with ``AS 4105.''
    fff. In paragraph C16:
     In the first sentence, the reference to ``AU sec. 711, 
Filings Under Federal Securities Statutes'' is replaced with ``AS 4101, 
Responsibilities Regarding Filings Under Federal Securities Statutes.''
     In the second sentence, the reference to ``AU sec. 711'' 
is replaced with ``AS 4101.''
     In the last sentence, the reference to ``AU sec. 711.10'' 
is replaced with ``AS 4101.10.''
Auditing Standard No. 6, Evaluating Consistency of Financial Statements
    Auditing Standard No. 6, Evaluating Consistency of Financial 
Statements, as amended, is amended as follows:
    a. The section number ``Auditing Standard No. 6'' is replaced with 
``AS 2820.''
    b. In the references before paragraph 1, the phrase ``Supersedes AU 
secs. 420 and 9420'' is deleted.
    c. Paragraph numbers 1 through 11 are replaced with .01 through 
.11.
    d. In paragraph 8:
     In the second sentence, the reference to ``paragraph 7'' 
is replaced with ``paragraph .07.''
     Each reference to ``AU sec. 508'' is replaced with ``AS 
3101.''
     In the last sentence of the note, the reference to ``AU 
sec. 508'' is replaced with ``AS 3101.''
    e. In paragraph 9, the reference to ``AU sec. 508'' is replaced 
with ``AS 3101.''
    f. In the last sentence of paragraph 10:
     The reference to ``paragraph 31'' is replaced with 
``paragraph .31.''
     The reference to ``Auditing Standard No. 14'' is replaced 
with ``AS 2810.''
     The reference to ``AU sec. 508'' is replaced with ``AS 
3101.''
    g. In paragraph 11:
     In the fifth sentence, the reference to ``paragraphs 7 and 
8 and AU sec. 508'' is replaced with ``paragraphs .07 and .08 and AS 
3101.''
     In the last sentence, the reference to ``paragraphs 9 and 
10 and AU sec. 508'' is replaced with ``paragraphs .09 and .10 and AS 
3101.''
Auditing Standard No. 7, Engagement Quality Review
    Auditing Standard No. 7, Engagement Quality Review, as amended, is 
amended as follows:
    a. The section number ``Auditing Standard No. 7'' is replaced with 
``AS 1220.''
    b. In the references before paragraph 1, the phrase ``Supersedes 
SECPS

[[Page 36606]]

Requirements of Membership Sec.  1000.08(f).'' is deleted.
    c. Paragraph numbers 1 through 21 are replaced with .01 through 
.21.
    d. In paragraph 1, the phrase ``a review interim financial 
information'' is replaced with ``a review of interim financial 
information.''
    e. In the last sentence of footnote 1 to paragraph 2, the reference 
to ``AU section (``sec.'') 722, Interim Financial Information'' is 
replaced with ``AS 4105, Reviews of Interim Financial Information.''
    f. In the last sentence of paragraph 9, the reference to 
``paragraphs 10 and 11'' is replaced with ``paragraphs .10 and .11.''
    g. In footnote 4 to paragraph 10e, the reference to ``Paragraph 13 
of PCAOB Auditing Standard No. 3'' is replaced with ``Paragraph .13 of 
AS 1215.''
    h. In footnote 5 to paragraph 10g:
     The reference to ``AU sec. 550'' is replaced with ``AS 
2710.''
     The reference to ``AU sec. 711, Filings Under Federal 
Securities Statutes'' is replaced with ``AS 4101, Responsibilities 
Regarding Filings Under Federal Securities Statutes.''
    i. In the first sentence of paragraph 11, the reference to 
``paragraph 10'' is replaced with ``paragraph .10.''
    j. In footnote 6 to paragraph 12, the reference to ``AU sec. 230'' 
is replaced with ``AS 1015.''
    k. In the last sentence of paragraph 14, the reference to 
``paragraphs 15 and 16'' is replaced with ``paragraphs .15 and .16.''
    l. In paragraph 15c, the reference to ``paragraphs 10.d and 10.e'' 
are replaced with ``paragraphs .10d and .10e.''
    m. In footnote 8 to paragraph 15e:
     The reference to ``AU sec. 722.18f'' is replaced with ``AS 
4105.18f.''
     The reference to ``AU sec. 711'' is replaced with ``AS 
4101.''
    n. In paragraph 15f, the reference to ``paragraphs 10.h and 10.i'' 
are replaced with ``paragraphs .10h and .10i.''
    o. In paragraph 16, the reference to ``paragraph 15'' is replaced 
with ``paragraph .15.''
    p. In paragraph 21, the reference to ``PCAOB Auditing Standard No. 
3, Audit Documentation,'' is replaced with ``AS 1215.''
Auditing Standard No. 8, Audit Risk
    Auditing Standard No. 8, Audit Risk, is amended as follows:
    a. The section number ``Auditing Standard No. 8'' is replaced with 
``AS 1101.''
    b. Paragraph numbers 1 through 11 are replaced with .01 through 
.11.
    c. In the first sentence of footnote 1 to paragraph 1, the 
reference to ``Auditing Standard No. 5'' is replaced with ``AS 2201.''
    d. In paragraph 3:
     In footnote 2, the reference to ``Auditing Standard No. 
14'' is replaced with ``AS 2810.''
     In footnote 3:
     The reference to ``AU sec. 110'' is replaced with ``AS 
1001.''
     The reference to ``AU sec. 230'' is replaced with ``AS 
1015.''
    e. In paragraph 5:
     In the last sentence, the reference to ``Auditing Standard 
No. 12'' is replaced with ``AS 2110.''
     In footnote 4, the reference to ``Auditing Standard No. 
15'' is replaced with ``AS 1105.''
     In footnote 5, the reference to ``Paragraph 59 of Auditing 
Standard No. 12'' is replaced with ``AS 2110.59.''
    f. In paragraph 8:
     In footnote 6, the reference to ``Paragraph 59.a. of 
Auditing Standard No. 12'' is replaced with ``AS 2110.59a.''
     In footnote 7, the reference to ``Paragraphs 32-34 of 
Auditing Standard No. 13'' is replaced with ``Paragraphs .32-.34 of AS 
2301.''
    g. In footnote 8 to paragraph 11, the reference to ``Paragraph 37 
of Auditing Standard No. 13'' is replaced with ``AS 2301.37.''
Auditing Standard No. 9, Audit Planning
    Auditing Standard No. 9, Audit Planning, as amended, is amended as 
follows:
    a. The section number ``Auditing Standard No. 9'' is replaced with 
``AS 2101.''
    b. Paragraph numbers 1 through 19 are replaced with .01 through 
.19.
    c. In the second sentence of footnote 3 to paragraph 6a, the 
reference to ``AU sec. 161, The Relationship of Generally Accepted 
Auditing Standards to Quality Control Standards'' is replaced with ``AS 
1110, Relationship of Auditing Standards to Quality Control 
Standards.''
    d. In paragraph 6c, the reference to ``Auditing Standard No. 16'' 
is replaced with ``AS 1301.''
    e. In paragraph 7:
     In the second sentence, the reference to ``paragraphs 8-
10'' is replaced with ``paragraphs .08-.10.''
     In footnote 5, the reference to ``Auditing Standard No. 
11'' is replaced with ``AS 2105.''
    f. In the first sentence of footnote 7 to paragraph 9a, the 
reference to ``Auditing Standard No. 16, Communications with Audit 
Committees'' is replaced with ``AS 1301.''
    g. In footnote 8 to paragraph 9b, the reference to ``paragraph 6 of 
Auditing Standard No. 10'' is replaced with ``paragraph .06 of AS 
1201.''
    h. In paragraph 9c:
     The reference to ``paragraph 7'' is replaced with 
``paragraph .07.''
     In footnote 9, the reference to ``Paragraph 6'' is 
replaced with ``Paragraph .06.''
    i. In footnote 10 to paragraph 9d:
     The reference to ``AU sec. 230'' is replaced with ``AS 
1015.''
     The reference to ``paragraph 16'' is replaced with 
``paragraph .16.''
     The reference to ``paragraph 5.a.'' is replaced with 
``paragraph .05a.''
     The reference to ``Auditing Standard No. 13'' is replaced 
with ``AS 2301.''
    j. In footnote 11 to paragraph 10a, the reference to ``Auditing 
Standard No. 12'' is replaced with ``AS 2110.''
    k. In footnote 12 to paragraph 10b:
     The reference to ``Auditing Standard No. 13'' is replaced 
with ``AS 2301.''
     The reference to ``Auditing Standard No. 5'' is replaced 
with ``AS 2201.''
    l. In footnote 14 to paragraph 12a, the reference to ``AU sec. 
316'' is replaced with ``AS 2401.''
    m. In footnote 15 to paragraph 12b, the reference to ``Paragraph 10 
of Auditing Standard No. 11'' is replaced with ``AS 2105.10.''
    n. In the note to paragraph 12g:
     The reference to ``Auditing Standard No. 5'' is replaced 
with ``AS 2201.''
     In footnote 17, the reference to ``Paragraphs B10-B16 of 
Auditing Standard No. 5'' is replaced with ``AS 2201.B10-.B16.''
    o. In paragraph 13:
     In the first sentence:
     The reference to ``AU sec. 322, The Auditor's 
Consideration of the Internal Audit Function in an Audit of Financial 
Statements'' is replaced with ``AS 2605, Consideration of the Internal 
Audit Function.''
     The reference to ``Auditing Standard No. 5'' is replaced 
with ``AS 2201.''
     In the last sentence:
     The reference to ``AU sec. 322'' is replaced with ``AS 
2605.''
     The reference to ``Auditing Standard No. 5'' is replaced 
with ``AS 2201.''
    p. In paragraph 14:
     In the first sentence, the reference to ``AU sec. 543, 
Part of Audit Performed by Other Independent Auditors'' is replaced 
with ``AS 1205, Part of the Audit Performed by Other Independent 
Auditors.''
     In the last sentence, the reference to ``paragraphs 11-
13'' is replaced with ``paragraphs .11-.13.''

[[Page 36607]]

     In footnote 18, the reference to ``paragraphs C8-C11 of 
Auditing Standard No. 5'' is replaced with ``AS 2201.C8-.C11.''
    q. In paragraph 18b, the reference to ``AU sec. 315, Communications 
Between Predecessor and Successor Auditors'' is replaced with ``AS 
2610, Initial Audits--Communications Between Predecessor and Successor 
Auditors.''
    r. In footnote 19 to paragraph 19, the reference to ``paragraph 3 
of Auditing Standard No. 6'' is replaced with ``paragraph .03 of AS 
2820.''
    s. In Appendix A, paragraph numbers A1 through A2 are replaced with 
.A1 through .A2.
Auditing Standard No. 10, Supervision of the Audit Engagement
    Auditing Standard No. 10, Supervision of the Audit Engagement, is 
amended as follows:
    a. The section number ``Auditing Standard No. 10'' is replaced with 
``AS 1201.''
    b. Paragraph numbers 1 through 6 are replaced with .01 through .06.
    c. In paragraph 3:
     In the last sentence, the reference to ``Paragraphs 5-6'' 
is replaced with ``Paragraphs .05-.06.''
     In footnote 2, the reference to ``AU sec. 336'' is 
replaced with ``AS 1210.''
     In footnote 3, the reference to ``AU sec. 543, Part of 
Audit Performed by Other Independent Auditors'' is replaced with ``AS 
1205, Part of the Audit Performed by Other Independent Auditors.''
     In footnote 4, the reference to ``AU sec. 322, The 
Auditor's Consideration of the Internal Audit Function in an Audit of 
Financial Statements'' is replaced with ``AS 2605, Consideration of the 
Internal Audit Function.''
     In footnote 5, the reference to ``Paragraphs 16-19 of 
Auditing Standard No. 5'' is replaced with ``Paragraphs .16-.19 of AS 
2201.''
     In footnote 6, the reference to ``AU sec. 230'' is 
replaced with ``AS 1015.''
    d. In paragraph 5a:
     In footnote 7 to paragraph 5a:
     The reference to ``AU sec. 230.06'' is replaced with ``AS 
1015.06.''
     The reference to ``paragraph 5 of Auditing Standard No. 
13'' is replaced with ``paragraph .05 of AS 2301.''
     In footnote 8 to item (3), the reference to ``Auditing 
Standard No. 12'' is replaced with ``AS 2110.''
    e. In footnote 9 to paragraph 5b:
     The reference to ``paragraph 15 of Auditing Standard No. 
9'' is replaced with ``paragraph .15 of AS 2101.''
     The reference to ``paragraph 74 of Auditing Standard No. 
12'' is replaced with ``AS 2110.74.''
     The reference to ``paragraphs 20-23 and 35-36 of Auditing 
Standard No. 14'' is replaced with ``paragraphs .20-.23 and .35-.36 of 
AS 2810.''
    f. In the note to paragraph 5, the reference to ``AU sec. 230'' is 
replaced with ``AS 1015.''
    g. In footnote 10 to item (3) of paragraph 5c:
     The reference to ``Auditing Standard No. 14'' is replaced 
with ``AS 2810.''
     The reference to ``Auditing Standard No. 3'' is replaced 
with ``AS 1215.''
    h. In footnote 11 to paragraph 6a, the reference to ``Paragraph 10 
of Auditing Standard No. 12'' is replaced with ``AS 2110.10.''
    i. In footnote 12 to paragraph 6d:
     The reference to ``paragraph 5.a. of Auditing Standard No. 
13'' is replaced with ``AS 2301.05a.''
     The reference to ``AU sec. 230.06'' is replaced with ``AS 
1015.06.''
    j. In the note to paragraph 6:
     The reference to ``paragraph 5 of Auditing Standard No. 
13, The Auditor's Responses to the Risks of Material Misstatement,'' is 
replaced with ``AS 2301.05.''
     In footnote 13, the reference to ``Paragraph 5.b. of 
Auditing Standard No. 13'' is replaced with ``AS 2301.05b.''
    k. In Appendix A, paragraph numbers A1 and A2 are replaced with .A1 
and .A2.
Auditing Standard No. 11, Consideration of Materiality in Planning and 
Performing an Audit
    Auditing Standard No. 11, Consideration of Materiality in Planning 
and Performing an Audit, is amended as follows:
    a. The section number ``Auditing Standard No. 11'' is replaced with 
``AS 2105.''
    b. Paragraph numbers 1 through 12 are replaced with .01 through 
.12.
    c. In footnote 1 to paragraph 1, the reference to ``Auditing 
Standard No. 14'' is replaced with ``AS 2810.''
    d. In paragraph 3:
     In the third sentence, the reference to ``Auditing 
Standard No. 14'' is replaced with ``AS 2810.''
     In footnote 4, the reference to ``Auditing Standard No. 
14'' is replaced with ``AS 2810.''
    e. In paragraph 4:
     The reference to ``Auditing Standard No. 5'' is replaced 
with ``AS 2201.''
     In footnote 5, the reference to ``Paragraph 20 of Auditing 
Standard No. 5'' is replaced with ``AS 2201.20.''
    f. In paragraph 12:
     In the note, the reference to ``Auditing Standard No. 14'' 
is replaced with ``AS 2810.''
     In footnote 6 to the note, the reference to ``Paragraph 17 
of Auditing Standard No. 14'' is replaced with ``AS 2810.17.''
Auditing Standard No. 12, Identifying and Assessing Risks of Material 
Misstatement
    Auditing Standard No. 12, Identifying and Assessing Risks of 
Material Misstatement, is amended as follows:
    a. The section number ``Auditing Standard No. 12'' is replaced with 
``AS 2110.''
    b. Paragraph numbers 1 through 74 are replaced with .01 through 
.74.
    c. In footnote 1 to paragraph 1, the reference to ``Paragraphs 5-8 
of Auditing Standard No. 8'' is replaced with ``Paragraphs .05-.08 of 
AS 1101.''
    d. In paragraph 2:
     In the first sentence, the reference to ``Paragraphs 4-
58'' is replaced with ``Paragraphs .04-.58.''
     In the last sentence, the reference to ``Paragraphs 59-
73'' is replaced with ``Paragraphs .59-.73.''
    e. In paragraph 4:
     In footnote 3:
     In the first sentence, the reference to ``AU sec. 316'' is 
replaced with ``AS 2401.''
     In the last sentence, the reference to ``Auditing Standard 
No. 18'' is replaced with ``AS 2410.''
     In footnote 4, the reference to ``Auditing Standard No. 
15'' is replaced with ``AS 1105.''
    f. In paragraph 5a, the parenthetic reference to ``paragraphs 7-
17'' is replaced with ``paragraphs .07-.17.''
    g. In paragraph 5b, the parenthetic reference to ``paragraphs 18-
40'' is replaced with ``paragraphs .18-.40.''
    h. In paragraph 5c, the parenthetic reference to ``paragraphs 41-
45'' is replaced with ``paragraphs .41-.45.''
    i. In paragraph 5d, the parenthetic reference to ``paragraphs 46-
48'' is replaced with ``paragraphs .46-.48.''
    j. In paragraph 5e, the parenthetic reference to ``paragraphs 49-
53'' is replaced with ``paragraphs .49-.53.''
    k. In paragraph 5f:
     The parenthetic reference to ``paragraphs 54-58'' is 
replaced with ``paragraphs .54-.58.''
     In footnote 5 to the note, the reference to ``Paragraph 11 
of Auditing Standard No. 15'' is replaced with ``AS 1105.11.''
    l. In footnote 7 to paragraph 9, the reference to ``AU sec. 317'' 
is replaced with ``AS 2405.''
    m. In paragraph 11:
     The reference to ``paragraph 7'' is replaced with 
``paragraph .07.''

[[Page 36608]]

     In the third bullet, the reference to ``paragraph 10A'' is 
replaced with ``paragraph .10A.''
    n. In footnote 7A to the fifth bullet in paragraph 13, the 
reference to ``AU secs. 316.66-.67A'' is replaced with ``AS 
2401.66-.67A.''
    o. In footnote 8 to paragraph 18, the reference to ``Paragraphs 21-
22'' is replaced with ``Paragraphs .21-.22.''
    p. In paragraph 19:
     In footnote 9, the reference to ``Paragraph 13 of Auditing 
Standard No. 5'' is replaced with ``Paragraph .13 of AS 2201.''
     In footnote 10 to the note, the reference to ``Paragraph 
10 of Auditing Standard No. 15'' is replaced with ``AS 1105.10.''
    q. In paragraph 20:
     In the last sentence of the first note, the reference to 
``paragraphs 37-38'' is replaced with ``paragraphs .37-.38.''
     In the last sentence of the second note, the reference to 
``paragraphs 37-38'' is replaced with ``paragraphs .37-.38.''
    r. In paragraph 22:
     In the third sentence, the reference to ``Auditing 
Standard No. 5'' is replaced with ``AS 2201.''
     In the last sentence, the reference to ``paragraphs 23-
36'' is replaced with ``paragraphs .23-.36.''
     In footnote 13, the reference to ``Paragraph 5 of Auditing 
Standard No. 5'' is replaced with ``AS 2201.05.''
    s. In the note to paragraph 24:
     In the first sentence, the reference to ``paragraph 23'' 
is replaced with ``paragraph .23.''
     In the last sentence, the reference to ``Auditing Standard 
No. 5'' is replaced with ``AS 2201.''
     In footnote 14, the reference to ``Paragraph 25 of 
Auditing Standard No. 5'' is replaced with ``AS 2201.25.''
    t. In paragraph 25:
     The reference to ``paragraphs 65-66'' is replaced with 
``paragraphs .65-.66.''
     In footnote 15, the reference to ``Paragraph A3 of 
Auditing Standard No. 5'' is replaced with ``AS 2201.A3.''
    u. In paragraph 32:
     The reference to ``paragraph 28.e.'' is replaced with 
``paragraph .28e.''
     In footnote 17, the reference to ``Paragraphs 12-13'' is 
replaced with ``Paragraphs .12-.13.''
    v. In paragraph 34:
     In the first sentence, the reference to ``paragraph 18'' 
is replaced with ``paragraph .18.''
     In footnote 18, the reference to ``paragraph B5'' is 
replaced with ``paragraph .B5.''
    w. In footnote 19 to paragraph 35, the reference to ``AU sec. 322, 
The Auditor's Consideration of the Internal Audit Function in an Audit 
of Financial Statements'' is replaced with ``AS 2605, Consideration of 
the Internal Audit Function.''
    x. In paragraph 37:
     In the first sentence, the reference to ``paragraph 20'' 
is replaced with ``paragraph .20.''
     In the first and last sentences of the note, the 
references to ``Auditing Standard No. 5'' are replaced with ``AS 
2201.''
     In footnote 20 to the note, the reference to ``paragraphs 
34-38 of Auditing Standard No. 5'' is replaced with ``AS 2201.34-.38.''
    y. In paragraph 39:
     In the first sentence, the reference to ``paragraph 18'' 
is replaced with ``paragraph .18.''
     In footnote 21, the reference to ``Paragraphs 16-35 of 
Auditing Standard No. 13'' is replaced with ``Paragraphs .16-.35 of AS 
2301.''
     In footnote 22, the reference to ``Paragraph B1 of 
Auditing Standard No. 5'' is replaced with ``AS 2201.B1.''
    z. In paragraph 40:
     In the first sentence, the reference to ``Auditing 
Standard No. 5'' is replaced with ``AS 2201.''
     In footnote 23, the reference to ``Paragraph 22 of 
Auditing Standard No. 5'' is replaced with ``AS 2201.22.''
     In footnote 24, the reference to ``paragraph 24 of 
Auditing Standard No. 5'' is replaced with ``AS 2201.24.''
    aa. In the last sentence of paragraph 41, the reference to 
``paragraph 59'' is replaced with ``paragraph .59.''
    bb. In paragraph 42, the reference to ``paragraph 8'' is replaced 
with ``paragraph .08.''
    cc. In paragraph 44, the reference to ``AU sec. 722, Interim 
Financial Information'' is replaced with ``AS 4105, Reviews of Interim 
Financial Information.''
    dd. In footnote 26 to paragraph 45, the reference to ``Paragraph 7 
of Auditing Standard No. 9'' is replaced with ``Paragraph .07 of AS 
2101.''
    ee. In the last sentence of paragraph 47, the reference to ``AU 
sec. 722'' is replaced with ``AS 4105.''
    ff. In paragraph 49:
     In footnote 28 to the first note to paragraph 49, the 
reference to ``Paragraphs 52-53'' is replaced with ``Paragraphs 
.52-.53.''
     In the second note, the reference to ``paragraph 67'' is 
replaced with ``paragraph .67.''
    gg. In footnote 29 to paragraph 51, the reference to ``paragraph 29 
of Auditing Standard No. 14'' is replaced with ``paragraph .29 of AS 
2810.''
    hh. In paragraph 53:
     In the first bullet, the reference to ``AU sec. 316'' is 
replaced with ``AS 2401.''
     In footnote 30 to the first bullet, the reference to ``AU 
sec. 316.13'' is replaced with ``AS 2401.13.''
     In the second bullet, the parenthetic reference to 
``Auditing Standard No. 14'' is replaced with ``AS 2810.''
     In footnote 31 to the third bullet, the reference to 
``Paragraphs 20-23 of Auditing Standard No. 14'' is replaced with ``AS 
2810.20-.23.''
    ii. In footnote 31A to Item a(8) of paragraph 56, the reference to 
``AU secs. 316.66-67A'' is replaced with ``AS 2401.66-.67A.''
    jj. In paragraph 59a:
     The parenthetic reference to ``paragraphs 4-58'' is 
replaced with ``paragraphs .04-.58.''
     In the note, the reference to ``paragraphs 65-69'' is 
replaced with ``paragraphs .65-.69.''
    kk. In footnote 32 to the note to paragraph 59d, the reference to 
``Paragraphs 16-35 of Auditing Standard No. 13'' is replaced with ``AS 
2301.16-.35.''
    ll. In paragraph 59e:
     The parenthetic reference to ``paragraphs 60-64'' is 
replaced with ``paragraphs .60-.64.''
     In footnote 33, the reference to ``Paragraph A10 of 
Auditing Standard No. 5'' is replaced with ``AS 2201.A10.''
     In footnote 34, the reference to ``Paragraph A9 of 
Auditing Standard No. 5'' is replaced with ``AS 2201.A9.''
    mm. In paragraph 59f, the parenthetic reference to ``paragraphs 70-
71'' is replaced with ``paragraphs .70-.71.''
    nn. In the first sentence of paragraph 60, the reference to 
``paragraph 59.e.'' is replaced with ``paragraph .59e.''
    oo. In footnote 35 to the note to paragraph 62:
     In the second sentence, the reference to ``paragraphs 11, 
14, and 25 of Auditing Standard No.14'' is replaced with ``AS 2810.11, 
.14, and .25.''
     In the last sentence:
     The reference to ``paragraph 61 of Auditing Standard No. 
5'' is replaced with ``AS 2201.61.''
     The reference to ``paragraph 5.c. of Auditing Standard No. 
13'' is replaced with ``AS 2301.5c.''
    pp. In paragraph 65:
     In the fourth sentence, the reference to ``AU sec. 
316.85'' is replaced with ``AS 2401.85.''
     In the first sentence of the note, the reference to ``AU 
sec. 316.85'' is replaced with ``AS 2401.85.''
    qq. In paragraph 67, the reference to ``paragraph 65'' is replaced 
with ``paragraph .65.''

[[Page 36609]]

    rr. In paragraph 71a, the reference to ``paragraph 60'' is replaced 
with ``paragraph .60.''
    ss. In paragraph 72:
     The reference to ``paragraphs 18-40'' is replaced with 
``paragraphs .18-.40.''
     In footnote 36, the reference to ``Auditing Standard No. 
13'' is replaced with ``AS 2301.''
    tt. In footnote 37 to paragraph 73:
     The phrase ``AU sec. 316.88 and'' is deleted.
     The reference to ``paragraph 14 of Auditing Standard No. 
5'' is replaced with ``AS 2201.14,'' and ``present'' is replaced with 
``presents.''
    uu. In paragraph 73A, the reference to ``paragraphs 18-40 and 72-
73'' is replaced with ``paragraphs .18-.40 and .72-.73.''
    vv. In footnote 38 to paragraph 74, the reference to ``paragraph 46 
of Auditing Standard No. 13'' is replaced with ``AS 2301.46.''
    ww. In Appendix A, paragraph numbers A1 through A5 are replaced 
with .A1 through .A5.
    xx. In Appendix B, paragraph numbers B1 through B6 are replaced 
with .B1 through .B6.
    yy. In paragraph B1:
     In footnote 1, the reference to ``AU sec. 324, Service 
Organizations'' is replaced with ``AS 2601, Consideration of an 
Entity's Use of a Service Organization.''
     In footnote 2, the reference to ``paragraphs 16-17 of 
Auditing Standard No. 9'' is replaced with ``paragraphs .16-.17 of AS 
2101.''
Auditing Standard No. 13, The Auditor's Responses to the Risks of 
Material Misstatement
    Auditing Standard No. 13, The Auditor's Responses to the Risks of 
Material Misstatement, is amended as follows:
    a. The section number ``Auditing Standard No. 13'' is replaced with 
``AS 2301.''
    b. Paragraph numbers 1 through 47 are replaced with .01 through 
.47.
    c. In paragraph 3, the reference to ``Auditing Standard No. 12'' is 
replaced with ``AS 2110.''
    d. In paragraph 4a, the reference to ``paragraphs 5-7'' is replaced 
with ``paragraphs .05-.07.''
    e. In paragraph 4b, the reference to ``paragraphs 8-46'' is 
replaced with ``paragraphs .08-.46.''
    f. In footnote 1 to paragraph 5a, the reference to ``AU sec. 230'' 
is replaced with ``AS 1015.''
    g. In paragraph 5b, the parenthetic reference to ``paragraphs 5-6 
of Auditing Standard No. 10'' is replaced with ``paragraphs .05-.06 of 
AS 1201.''
    h. In footnote 2 to item (5) of paragraph 5c, the reference to 
``paragraphs 61 and B13 of Auditing Standard No. 5'' is replaced with 
``paragraphs .61 and .B13 of AS 2201.''
    i. In footnote 3 to paragraph 5d:
     In the first sentence, the reference to ``Paragraphs 12-13 
of Auditing Standard No. 12'' is replaced with ``AS 2110.12-.13.''
     In the last sentence:
     The reference to ``AU sec. 316'' is replaced with ``AS 
2401.''
     The reference to ``AU sec. 411, The Meaning of Present 
Fairly in Conformity With Generally Accepted Accounting Principles'' is 
replaced with ``AS 2815, The Meaning of `Present Fairly in Conformity 
with Generally Accepted Accounting Principles.' ''
    j. In footnote 4 to paragraph 7, the reference to ``AU secs. 
230.07-.09'' is replaced with ``AS 1015.07-.09.''
    k. In footnote 5 to paragraph 7, the reference to ``AU secs. 
316.13'' is replaced with ``AS 2401.13.''
    l. In paragraph 9c:
     In footnote 7 to item (1), the reference to ``paragraph 
7.b. of Auditing Standard No. 8'' is replaced with ``paragraph .07b of 
AS 1101.''
     In the note to item (2), the reference to ``Auditing 
Standard No. 5'' is replaced with ``AS 2201.''
    m. In paragraph 10:
     In the last sentence:
     The reference to ``Paragraphs 16-35'' is replaced with 
``Paragraphs .16-.35.''
     The reference to ``paragraphs 36-46'' is replaced with 
``paragraphs .36-.46.''
     In the first sentence of the note, the reference to 
``Paragraphs 16-17'' is replaced with ``Paragraphs .16-.17.''
    n. In paragraph 11:
     In the note, the reference to ``Auditing Standard No. 12'' 
is replaced with ``AS 2110.''
     In footnote 10 to the note, the reference to ``paragraph 
71 of Auditing Standard No. 12'' is replaced with ``AS 2110.71.''
    o. In paragraph 11A:
     In the first sentence, the reference to ``Paragraph 71.g. 
of Auditing Standard No. 12'' is replaced with ``AS 2110.71g.''
     In the second sentence, the reference to ``AU sec. 
316.66-.67A'' is replaced with ``AS 2401.66-.67A.''
     In the last sentence, the reference to ``AU sec. 
316.66-.67A'' is replaced with ``AS 2401.66-.67A.''
    p. In paragraph 12:
     In the second note, the reference to ``Auditing Standard 
No. 5'' is replaced with ``AS 2201.''
     In footnote 11 to the second note, the reference to 
``Paragraphs 14-15 of Auditing Standard No. 5'' is replaced with ``AS 
2201.14-.15.''
    q. In the last sentence of paragraph 13, the reference to 
``paragraphs 16-17'' is replaced with ``paragraphs .16-.17.''
    r. In the note to paragraph 14, the reference to ``AU secs. 
316.54-.67'' is replaced with ``AS 2401.54-.67.''
    s. In paragraph 15, the reference to ``AU sec. 316'' is replaced 
with ``AS 2401.''
    t. In paragraph 15a, the parenthetic reference to ``AU secs. 
316.58-.62'' is replaced with ``AS 2401.58-.62.''
    u. In paragraph 15b, the parenthetic reference to ``AU secs. 
316.63-.65'' is replaced with ``AS 2401.63-.65.''
    v. In paragraph 15c, the parenthetic reference to ``AU secs. 
316.66-.67A'' is replaced with ``AS 2401.66-.67A.''
    w. In footnote 14 to paragraph 17:
     The reference to ``Paragraph 10 of Auditing Standard No. 
15'' is replaced with ``Paragraph .10 of AS 1105.''
     The reference to ``AU sec. 329'' is replaced with ``AS 
2305.''
    x. In footnote 15 to paragraph 20, the reference to ``Paragraphs 
37-38 of Auditing Standard No. 12'' is replaced with ``AS 
2110.37-.38.''
    y. In the note to paragraph 27, the reference to ``AU sec. 350'' is 
replaced with ``AS 2315.''
    z. In the last sentence of paragraph 28, the reference to 
``Paragraph 16'' is replaced with ``Paragraph .16.''
    aa. In the last sentence of footnote 16 to the ninth bullet of 
paragraph 31, the reference to ``paragraph B28 of Auditing Standard No. 
5'' is replaced with ``AS 2201.B28.''
    bb. In the note to paragraph 34:
     In the first sentence, the reference to ``Auditing 
Standard No. 5'' is replaced with ``AS 2201.''
     In the last sentence, the reference to ``AU sec. 325'' is 
replaced with ``AS 1305.''
    cc. In paragraph 35:
     Each reference to ``Auditing Standard No. 5'' is replaced 
with ``AS 2201.''
     In footnote 17, the reference to ``Paragraph B1 of 
Auditing Standard No. 5'' is replaced with ``AS 2201.B1.''
    dd. In paragraph 38:
     In footnote 18, the reference to ``Paragraph A5 of 
Auditing Standard No. 5'' is replaced with ``AS 2201.A5.''
     In footnote 19, the reference to ``AU sec. 328'' is 
replaced with ``AS 2502.''
    ee. In the note to paragraph 39, the reference to ``Auditing 
Standard No. 15'' is replaced with ``AS 1105.''
    ff. In paragraph 40, the reference to ``paragraph 9.b.'' is 
replaced with ``paragraph .09b.''
    gg. In the note to paragraph 41b, the reference to ``AU secs. 
316.58-.62'' is replaced with ``AS 2401.58-.62.''

[[Page 36610]]

    hh. In item (1) of paragraph 44a, the reference to ``paragraphs 32-
34'' is replaced with ``paragraphs .32-.34.''
    ii. In footnote 20 to paragraph 47, the reference to ``Paragraph 
.44 of AU sec. 350'' is replaced with ``AS 2315.44.''
    jj. In Appendix A, paragraph numbers A1 through A3 are replaced 
with .A1 through .A3.
Auditing Standard No. 14, Evaluating Audit Results
    Auditing Standard No. 14, Evaluating Audit Results, is amended as 
follows:
    a. The section number ``Auditing Standard No. 14'' is replaced with 
``AS 2810.''
    b. Paragraph numbers 1 through 37 are replaced with .01 through 
.37.
    c. In footnote 3 to paragraph 6b:
     The reference to ``Paragraphs 46-48 of Auditing Standard 
No. 12'' is replaced with ``Paragraphs .46-.48 of AS 2110.''
     The reference to ``AU sec. 329'' is replaced with ``AS 
2305.''
    d. In the note to paragraph 6, the reference to ``paragraph 36'' is 
replaced with ``paragraph .36.''
    e. In footnote 4 to paragraph 7, the reference to ``Paragraph 47 of 
Auditing Standard No. 12'' is replaced with ``AS 2110.47.''
    f. In the first sentence of paragraph 9, the reference to 
``paragraph 6.b.'' is replaced with ``paragraph .06b.''
    g. In the second sentence of the note to paragraph 10, the 
reference to ``Auditing Standard No. 11'' is replaced with ``AS 2105.''
    h. In paragraph 12:
     In the last sentence:
     The reference to ``paragraph 13'' is replaced with 
``paragraph .13.''
     The reference to ``AU sec. 350'' is replaced with ``AS 
2315.''
     In footnote 5, the reference to ``AU sec. 350.26'' is 
replaced with ``AS 2315.26.''
    i. In the last sentence of the note to paragraph 13, the reference 
to ``Paragraph 27'' is replaced with ``Paragraph .27.''
    j. In footnote 6 to paragraph 14b, the reference to ``Auditing 
Standard No. 11'' is replaced with ``AS 2105.''
    k. In paragraph 17:
     In footnote 7:
     In the first sentence, the reference to ``AU sec. 508'' is 
replaced with ``AS 3101.''
     In the last sentence, the reference to ``AU sec. 508.35'' 
is replaced with ``AS 3101.35.''
     In footnote 11 to the second note, the reference to ``AU 
sec. 317'' is replaced with ``AS 2405.''
     In the third note, the reference to ``Auditing Standard 
No. 11'' is replaced with ``AS 2105.''
     In footnote 12 to the third note, the reference to 
``Paragraphs 11-12 of Auditing Standard No. 11'' is replaced with ``AS 
2105.11-.12.''
    l. In paragraph 18, the reference to ``paragraph 17'' is replaced 
with ``paragraph .17.''
    m. In the last sentence of paragraph 19, the reference to 
``paragraph 36'' is replaced with ``paragraph .36.''
    n. In the last sentence of paragraph 20, the reference to ``AU sec. 
316'' is replaced with ``AS 2401.''
    o. In footnote 14 to paragraph 20, the reference to ``AU sec. 
316.05'' is replaced with ``AS 2401.05.''
    p. In paragraph 23, the reference to ``AU secs. 316.79-.82A, AU 
sec. 317'' is replaced with ``AS 2401.79-.82A, AS 2405.''
    q. In the note to paragraph 25a, the reference to ``paragraph 15'' 
is replaced with ``paragraph .15.''
    r. In footnote 15 to paragraph 25c, the reference to ``Paragraph 
5.d. of Auditing Standard No. 13'' is replaced with ``Paragraph .05d of 
AS 2301.''
    s. In footnote 16 to paragraph 25d, the reference to ``Paragraph 
27'' is replaced with ``Paragraph .27.''
    t. In the note to paragraph 27, the reference to ``AU secs. 
316.64-.65'' is replaced with ``AS 2401.64-.65.''
    u. In footnote 17 to paragraph 28:
     The first parenthetic reference to ``paragraph 9'' is 
replaced with ``paragraph .09.''
     The second parenthetic reference to ``paragraphs 20-23'' 
is replaced with ``paragraphs .20-.23.''
     The third parenthetic reference to ``paragraphs 24-27'' is 
replaced with ``paragraphs .24-.27.''
    v. In the note to paragraph 29, the parenthetic reference to 
``paragraphs 49-51 of Auditing Standard No. 12'' is replaced with ``AS 
2110.49-.51.''
    w. In the first note to paragraph 30:
     In the first sentence, the reference to ``AU sec. 411, The 
Meaning of Present Fairly in Conformity With Generally Accepted 
Accounting Principles'' is replaced with ``AS 2815, The Meaning of 
'Present Fairly in Conformity with Generally Accepted Accounting 
Principles.' ''
     In the last sentence, the reference to ``Auditing Standard 
No. 6'' is replaced with ``AS 2820.''
    x. In paragraph 31:
     In the note, the reference to ``AU sec. 508'' is replaced 
with ``AS 3101.''
     In footnote 18 to the note, the reference to ``AU secs. 
508.41-.44'' is replaced with ``AS 3101.41-.44.''
    y. In paragraph 32:
     The reference to ``Auditing Standard No. 8'' is replaced 
with ``AS 1101.''
     In footnote 19, the reference to ``Paragraph 3 of Auditing 
Standard No. 8'' is replaced with ``AS 1101.03.''
    z. In paragraph 34a, the parenthetic reference to ``paragraphs 14 
and 17-19'' is replaced with ``paragraphs .14 and .17-.19.''
    aa. In paragraph 34b, the parenthetic reference to ``paragraphs 20-
23 and 28-29'' is replaced with ``paragraphs .20-.23 and .28-.29.''
    bb. In paragraph 34c, the parenthetic reference to ``paragraph 36'' 
is replaced with ``paragraph .36.''
    cc. In footnote 20 to paragraph 34e, the reference to ``Paragraphs 
7-9 of Auditing Standard No. 15'' is replaced with ``Paragraphs .07-.09 
of AS 1105.''
    dd. In paragraph 35:
     In the last sentence, the reference to ``AU sec. 508'' is 
replaced with ``AS 3101.''
     In footnote 21, the reference to ``AU sec 508.22-.34'' is 
replaced with ``AS 3101.22-.34.''
    ee. In the note to paragraph 36:
     In the first sentence, the reference to ``Auditing 
Standard No. 12'' is replaced with ``AS 2110.''
     In footnote 22, the reference to ``Paragraph 74 of 
Auditing Standard No.12'' is replaced with ``AS 2110.74.''
     In the last sentence, the reference to ``Auditing Standard 
No. 13'' is replaced with ``AS 2301.''
     In footnote 23, the reference to ``Paragraphs 32-34 of 
Auditing Standard No. 13'' is replaced with ``AS 2301.32-.34.''
    ff. In paragraph 37:
     Each reference to ``Auditing Standard No. 5'' is replaced 
with ``AS 2201.''
     In footnote 24:
     The reference to ``Paragraphs 62-70 of Auditing Standard 
No. 5'' is replaced with ``AS 2201.62-.70.''
     The reference to ``paragraphs 71-73 of Auditing Standard 
No. 5'' is replaced with ``AS 2201.71-.73.''
    gg. In Appendix A, paragraph numbers A1 through A3 are replaced 
with .A1 through .A3.
    hh. In footnote 2 to paragraph A2, the reference to ``AU sec. 316'' 
is replaced with ``AS 2401.''
    ii. In footnote 3 to paragraph A3, the reference to ``Paragraph 
10'' is replaced with ``Paragraph .10.''
    jj. In Appendix B, paragraph numbers B1 through B2 are replaced 
with .B1 through .B2.
    kk. In paragraph B1:
     The reference to ``Paragraph 17'' is replaced with 
``Paragraph .17.''
     In footnote 1:
     In the first sentence, the reference to ``AU sec. 508'' is 
replaced with ``AS 3101.''

[[Page 36611]]

     In the last sentence, the reference to ``AU sec. 508.35'' 
is replaced with ``AS 3101.35.''
     In footnote 5 to the second note, the reference to ``AU 
sec. 317'' is replaced with ``AS 2405.''
    ll. In the last sentence of paragraph B2.o, the reference to 
``paragraph B2.l'' is replaced with ``paragraph .B2l.''
    mm. In Appendix C, paragraph number C1 is replaced with .C1.
    nn. In paragraph C1, the reference to ``paragraph 28'' is replaced 
with ``paragraph .28.''
    oo. In footnote 1 to item (2) of paragraph C1b, the reference to 
``Paragraph 9 of Auditing Standard No. 15'' is replaced with 
``Paragraph .09 of AS 1105.''
    pp. In the parenthetic reference of footnote 2 to item (1) of 
paragraph C1c:
     The reference to ``Auditing Standard No. 5'' is replaced 
with ``AS 2201.''
     The reference to ``AU sec. 508'' is replaced with ``AS 
3101.''
Auditing Standard No. 15, Audit Evidence
    Auditing Standard No. 15, Audit Evidence, is amended as follows:
    a. The section number ``Auditing Standard No. 15'' is replaced with 
``AS 1105.''
    b. Paragraph numbers 1 through 29 are replaced with .01 through 
.29.
    c. In footnote 1 to paragraph 3:
     In the first sentence, the reference to ``Auditing 
Standard No. 14'' is replaced with ``AS 2810.''
     In the second sentence, the reference to ``Auditing 
Standard No. 3'' is replaced with ``AS 1215.''
    d. In footnote 2 to the first bullet of paragraph 5, the reference 
to ``Paragraph A5 of Auditing Standard No. 12'' is replaced with 
``Paragraph .A5 of AS 2110.''
    e. In footnote 3 to paragraph 10:
     In the first sentence, the reference to ``AU sec. 336'' is 
replaced with ``AS 1210.''
     In the last sentence:
     The reference to ``AU sec. 324, Service Organizations'' is 
replaced with ``AS 2601, Consideration of an Entity's Use of a Service 
Organization.''
     The reference to ``Auditing Standard No. 5'' is replaced 
with ``AS 2201.''
    f. In footnote 5 to paragraph 12, the reference to ``paragraph 28 
of Auditing Standard No. 5'' is replaced with ``AS 2201.28.''
    g. In footnote 6 to paragraph 13a, the reference to ``Auditing 
Standard No.12'' is replaced with ``AS 2110.''
    h. In footnote 7 to paragraph 13b, the reference to ``Auditing 
Standard No. 13'' is replaced with ``AS 2301.''
    i. In the first sentence of paragraph 14, the reference to 
``Paragraphs 15-21'' is replaced with ``Paragraphs .15-.21.''
    j. In footnote 8 to paragraph 16, the reference to ``AU sec. 331, 
Inventories'' is replaced with ``AS 2510, Auditing Inventories.''
    k. In footnote 9 to paragraph 17, the reference to ``AU sec. 333'' 
is replaced with ``AS 2805.''
    l. In footnote 10 to paragraph 18, the reference to ``AU sec. 330'' 
is replaced with ``AS 2310.''
    m. In footnote 11 to paragraph 21, the reference to ``AU sec. 329'' 
is replaced with ``AS 2305.''
    n. In paragraph 27, the reference to ``paragraphs 25-26'' is 
replaced with ``paragraphs .25-.26.''
    o. In footnote 12 to paragraph 27, the reference to ``paragraphs 
12-13 and paragraphs 17-19 of Auditing Standard No. 14'' is replaced 
with ``AS 2810.12-.13 and AS 2810.17-.19.''
    p. In footnote 13 to paragraph 28, the reference to ``AU sec. 350'' 
is replaced with ``AS 2315.''
Auditing Standard No. 16, Communications with Audit Committees
    Auditing Standard No. 16, Communications with Audit Committees, is 
amended as follows:
    a. The section number ``Auditing Standard No. 16'' is replaced with 
``AS 1301.''
    b. Paragraph numbers 1 through 26 are replaced with .01 through 
.26.
    c. In the first sentence of footnote 5 to paragraph 8, the 
reference to ``paragraphs 5.f. and 54-57 of Auditing Standard No. 12'' 
is replaced with ``paragraphs .05f and .54-.57 of AS 2110.''
    d. In the first sentence of footnote 6 to paragraph 8, the 
reference to ``AU sec. 317'' is replaced with ``AS 2405.''
    e. In paragraph 9:
     In footnote 7, the reference to ``paragraphs 8-9 of 
Auditing Standard No. 9'' is replaced with ``paragraphs .08-.09 of AS 
2101.''
     In the first sentence of footnote 8, the reference to 
``Auditing Standard No. 12'' is replaced with ``AS 2110.''
    f. In footnote 9 to paragraph 10a, the reference to ``paragraph 16 
of Auditing Standard No. 9'' is replaced with ``AS 2101.16.''
    g. In footnote 10 to paragraph 10b, the reference to ``AU sec. 322, 
The Auditor's Consideration of the Internal Audit Function in an Audit 
of Financial Statements'' is replaced with ``AS 2605, Consideration of 
the Internal Audit Function.''
    h. In footnote 11 to paragraph 10c, the reference to ``paragraphs 
16-19 of Auditing Standard No. 5'' is replaced with ``paragraphs 
.16-.19 of AS 2201.''
    i. In footnote 12 to paragraph 10d, the reference to ``paragraphs 
8-14 of Auditing Standard No. 9'' is replaced with ``AS 2101.08-.14.''
    j. In footnote 13 to paragraph 10e, the reference to ``AU sec. 543, 
Part of Audit Performed by Other Independent Auditors'' is replaced 
with ``AS 1205, Part of the Audit Performed by Other Independent 
Auditors.''
    k. In footnote 14 to paragraph 11, the reference to ``paragraph 15 
of Auditing Standard No. 9'' is replaced with ``AS 2101.15.''
    l. In footnote 17 to item (1) of paragraph 12c, the reference to 
``AU sec. 342'' is replaced with ``AS 2501.''
    m. In footnote 20 to item (1) of paragraph 12d, the reference to 
``paragraph 71.g. of Auditing Standard No. 12'' is replaced with ``AS 
2110.71g.''
    n. In the first sentence of the note to paragraph 12, the reference 
to ``paragraph 12'' is replaced with ``paragraph .12.''
    o. In footnote 21 to item (1) of paragraph 13a, the reference to 
``paragraphs 24-27 of Auditing Standard No. 14'' is replaced with 
``paragraphs .24-.27 of AS 2810.''
    p. In footnote 22 to item (2) of paragraph 13a, the reference to 
``paragraph 27 of Auditing Standard No. 14'' is replaced with ``AS 
2810.27.''
    q. In footnote 23 to paragraph 13c, the reference to ``AU sec. 
342'' is replaced with ``AS 2501.''
    r. In footnote 24 to paragraph 13d, the reference to ``AU sec. 
316'' is replaced with ``AS 2401.''
    s. In footnote 25 to paragraph 13e:
     In the first sentence, the reference to ``paragraphs 30-31 
of Auditing Standard No. 14'' is replaced with ``AS 2810.30-.31.''
     In the last sentence:
     The reference to ``Auditing Standard No. 18'' is replaced 
with ``AS 2410.''
     The reference to ``AU sec. 341, The Auditor's 
Consideration of an Entity's Ability to Continue as a Going Concern'' 
is replaced with ``AS 2415, Consideration of an Entity's Ability to 
Continue as a Going Concern.''
    t. In footnote 27 to paragraph 14:
     In the first sentence, the reference to ``AU sec. 550'' is 
replaced with ``AS 2710.''
     In the last sentence:
     The reference to ``AU sec. 550'' is replaced with ``AS 
2710.''
     The reference to ``Auditing Standard No. 17'' is replaced 
with ``AS 2701.''
     The reference to ``AU sec. 558'' is replaced with ``AS 
2705.''

[[Page 36612]]

     The reference to ``AU sec. 711, Filings Under Federal 
Securities Statutes'' is replaced with ``AS 4101, Responsibilities 
Regarding Filings Under Federal Securities Statutes.''
    u. In footnote 28 to paragraph 17:
     In the first sentence, the reference to ``AU sec. 341'' is 
replaced with ``AS 2415.''
     In the last sentence, the reference to ``AU secs. 341.03a-
c'' is replaced with ``AS 2415.03a-c.''
    v. In footnote 29 of paragraph 17a:
     The reference to ``AU sec. 341.06'' is replaced with ``AS 
2415.06.''
     The reference to ``AU sec 341.07'' is replaced with ``AS 
2415.07.''
    w. In footnote 30 to paragraph 17b, the reference to ``AU sec. 
341.08'' is replaced with ``AS 2415.08.''
    x. In footnote 31 to paragraph 17c:
     In the first sentence, the reference to ``AU sec. 341.12'' 
is replaced with ``AS 2415.12.''
     In the last sentence, the reference to ``AU sec. 341.03c'' 
is replaced with ``AS 2415.03c.''
    y. In footnote 32 to item (1) of paragraph 17c, the reference to 
``AU sec. 341.10'' is replaced with ``AS 2415.10.''
    z. In footnote 33 to item (2) of paragraph 17c, the reference to 
``AU sec. 341.12-.16'' is replaced with ``AS 2415.12-.16.''
    aa. In footnote 34 to paragraph 18, the reference to ``paragraph 20 
of Auditing Standard No. 14'' is replaced with ``paragraph .20 of AS 
2810.''
    bb. In footnote 36 to paragraph 18, the reference to ``Auditing 
Standard No. 14'' is replaced with ``AS 2810.''
    cc. In footnote 37 to paragraph 19, the reference to ``paragraph 10 
of Auditing Standard No. 14'' is replaced with ``AS 2810.10.''
    dd. In footnote 39 to the note to paragraph 23, the reference to 
``AU sec. 508'' is replaced with ``AS 3101.''
    ee. In footnote 40 to paragraph 24:
     The reference to ``AU sec. 316.79-.81'' is replaced with 
``AS 2401.79-.81.''
     The reference to ``AU sec. 317.17'' is replaced with ``AS 
2405.17.''
    ff. In paragraph 25:
     Footnote 41 is deleted.
     In footnote 42, the reference to ``Auditing Standard No. 
3'' is replaced with ``AS 1215.''
     In the note, the reference to ``paragraphs 12 or 18'' is 
replaced with ``paragraphs .12 or .18.''
    gg. In Appendix A, paragraph numbers A1 through A4 are replaced 
with .A1 through .A4.
    hh. Appendix B of Auditing Standard No. 16 is replaced with the 
following: This appendix identifies other PCAOB rules and standards 
related to the audit that require communication of specific matters 
between the auditor and the audit committee.
     AS 6115, Reporting on Whether a Previously Reported 
Material Weakness Continues to Exist, paragraphs .60, .62, and .64
     AS 2201, An Audit of Internal Control Over Financial 
Reporting That Is Integrated with An Audit of Financial Statements, 
paragraphs .78-.81, .91, .C7, and .C14
     AS 2110, Identifying and Assessing Risks of Material 
Misstatement, paragraphs .05f and .54-.57
     AS 2410, Related Parties, paragraphs .07 and .19
     Attestation Standard No. 1, Examination Engagements 
Regarding Compliance Reports of Brokers and Dealers, paragraphs 34 and 
35
     Attestation Standard No. 2, Review Engagements Regarding 
Exemption Reports of Brokers and Dealers, paragraph 15
     PCAOB Rule 3524, Audit Committee Pre-approval of Certain 
Tax Services
     PCAOB Rule 3525, Audit Committee Pre-approval of Non-audit 
Services Related to Internal Control Over Financial Reporting
     PCAOB Rule 3526, Communication with Audit Committees 
Concerning Independence
     AS 2401, Consideration of Fraud in a Financial Statement 
Audit, paragraphs .79-.81
     AS 2405, Illegal Acts by Clients, paragraphs .08, .17, and 
.20
     AS 1305, Communications About Control Deficiencies in an 
Audit of Financial Statements, paragraphs .04-.07 and .09
     AS 2502, Auditing Fair Value Measurements and Disclosures, 
paragraph .50
     AS 2805, Management Representations, paragraph .05
     AS 2710, Other Information in Documents Containing Audited 
Financial Statements, paragraphs .04 and .06
     AS 4101, Responsibilities Regarding Filings Under Federal 
Securities Statutes, paragraph .13
     AS 4105, Reviews of Interim Financial Information, 
paragraphs .08-.09, .30-.31, and .33-.36
    ii. In Appendix C, paragraph numbers C1 through C2 are replaced 
with .C1 through .C2.
    jj. In footnote 2 to item 2b of paragraph C1b, the reference to 
``AU sec. 325'' is replaced with ``AS 1305.''
    kk. In footnote 3 to item (b) of paragraph C2, the reference to 
``AU sec. 722, Interim Financial Information'' is replaced with ``AS 
4105, Reviews of Interim Financial Information.''
Auditing Standard No. 17, Auditing Supplemental Information 
Accompanying Audited Financial Statements
    Auditing Standard No. 17, Auditing Supplemental Information 
Accompanying Audited Financial Statements, is amended as follows:
    a. The section number ``Auditing Standard No. 17'' is replaced with 
``AS 2701.''
    b. Paragraph numbers 1 through 15 are replaced with .01 through 
.15.
    c. In footnote 3 to the note to paragraph 3b, the reference to 
``Auditing Standard No. 11'' is replaced with ``AS 2105.''
    d. In footnote 6 to paragraph 7, the reference to ``paragraph 10 of 
Auditing Standard No. 14'' is replaced with ``paragraph .10 of AS 
2810.''
    e. In footnote 7 to the note to paragraph 8, the reference to 
``paragraph 17 of Auditing Standard No. 14'' is replaced with ``AS 
2810.17.''
    f. In footnote 8 to paragraph 12b:
     In the first sentence, the reference to ``AU sec. 561'' is 
replaced with ``AS 2905.''
     In the second sentence, the reference to ``AU sec. 561'' 
is replaced with ``AS 2905.''
    g. In Appendix A, paragraph numbers A1 and A2 are replaced with .A1 
and .A2.
Auditing Standard No. 18, Related Parties
    Auditing Standard No. 18, Related Parties, is amended as follows:
    a. The section number ``Auditing Standard No. 18'' is replaced with 
``AS 2410.''
    b. Paragraph numbers 1 through 19 are replaced with .01 through 
.19.
    c. In footnote 2 to paragraph 2:
     In the first sentence, the reference to ``paragraphs 30-31 
of Auditing Standard No. 14'' is replaced with ``paragraphs .30-.31 of 
AS 2810.''
     In the last sentence, the reference to ``AU sec. 411, The 
Meaning of Present Fairly in Conformity With Generally Accepted 
Accounting Principles'' is replaced with ``AS 2815, The Meaning of 
`Present Fairly in Conformity with Generally Accepted Accounting 
Principles.' ''
    d. In paragraph 3:
     In the first sentence, the reference to ``Auditing 
Standard No. 12'' is replaced with ``AS 2110.''
     In item a, the parenthetic reference to ``paragraph 4'' is 
replaced with ``paragraph .04.''
     In item b, the parenthetic reference to ``paragraphs 5-7'' 
is replaced with ``paragraphs .05-.07.''

[[Page 36613]]

     In item c, the parenthetic reference to ``paragraphs 8-9'' 
is replaced with ``paragraphs .08-.09.''
     In the second note:
     The reference to ``paragraphs 4-9'' is replaced with 
``paragraphs .04-.09.''
     The reference to ``Auditing Standard No. 12'' is replaced 
with ``AS 2110.''
    e. In footnote 3 to paragraph 4:
     In the first sentence, the reference to ``paragraph 18 of 
Auditing Standard No. 12'' is replaced with ``AS 2110.18.''
     In the last sentence, the reference to ``paragraph 20 of 
Auditing Standard No. 12'' is replaced with ``AS 2110.20.''
    f. In footnote 4 to paragraph 5:
     In the first sentence, the reference to ``AU sec. 333'' is 
replaced with ``AS 2805.''
     In the last sentence, the reference to ``paragraph 5'' is 
replaced with ``paragraph .05.''
    g. In paragraph 6, the reference to ``paragraph 5'' is replaced 
with ``paragraph .05.''
    h. In footnote 7 to paragraph 7, the reference to ``Auditing 
Standard No. 16'' is replaced with ``AS 1301.''
    i. In footnote 8 to paragraph 8:
     In the first sentence, the reference to ``paragraph 49 of 
Auditing Standard No. 12'' is replaced with ``AS 2110.49.''
     In the last sentence, the reference to ``paragraph 5 of 
Auditing Standard No. 10'' is replaced with ``paragraph .05 of AS 
1201.''
    j. In footnote 9 to paragraph 9, the reference to ``AU sec. 543, 
Part of Audit Performed by Other Independent Auditors'' is replaced 
with ``AS 1205, Part of the Audit Performed by Other Independent 
Auditors.''
    k. In paragraph 10:
     In footnote 10, the reference to ``paragraph 59 of 
Auditing Standard No. 12'' is replaced with ``AS 2110.59.''
     In the note:
     The reference to ``paragraphs 4-9'' is replaced with 
``paragraphs .04-.09.''
     The reference to ``Auditing Standard No. 12'' is replaced 
with ``AS 2110.''
    l. In paragraph 11:
     In footnote 11, the reference to ``paragraph 3 of Auditing 
Standard No. 13'' is replaced with ``paragraph .03 of AS 2301.''
     In footnote 12:
     The reference to ``Auditing Standard No. 13'' is replaced 
with ``AS 2301.''
     The reference to ``paragraph 17 of Auditing Standard No. 
15'' is replaced with ``paragraph .17 of AS 1105.''
     In the note:
     In the first sentence, the reference to ``AU sec. 316'' is 
replaced with ``AS 2401.''
     In the last sentence, the reference to ``AU sec. 316.67'' 
is replaced with ``AS 2401.67.''
    m. In the last sentence of the note to paragraph 12, the reference 
to ``paragraph 12'' is replaced with ``paragraph .12.''
    n. In footnote 16 to paragraph 15, the reference to ``paragraph 29 
of Auditing Standard No .15'' is replaced with ``AS 1105.29.''
    o. In paragraph 16:
     In footnote 17 to item b, the reference to ``AU sec. 
333.04'' is replaced with ``AS 2805.04.''
     In item e, the reference to ``paragraph 12'' is replaced 
with ``paragraph .12.''
     In item f:
     In footnote 18 to item ii, the reference to ``paragraph 74 
of Auditing Standard No. 12'' is replaced with ``AS 2110.74.''
     In the last sentence of item iii:
     The reference to ``AU secs. 316.79-.82'' is replaced with 
``AS 2401.79-.82.''
     The reference to ``AU sec. 317'' is replaced with ``AS 
2405.''
    p. In footnote 19 to paragraph 17, the reference to ``paragraphs 
30-31 of Auditing Standard No. 14'' is replaced with ``AS 
2810.30-.31.''
    q. In footnote 20 to paragraph 18:
     In the first sentence, the reference to ``paragraph .06.l. 
of AU sec. 333'' is replaced with ``AS 2805.06l.''
     In the last sentence, the reference to ``AU sec. 508'' is 
replaced with ``AS 3101.''
    r. In footnote 21 to paragraph 19, the reference to ``Auditing 
Standard No. 16'' is replaced with ``AS 1301.''
    s. In Appendix A, paragraph numbers A1 through A3 are replaced with 
.A1 through .A3.
    t. In paragraph A1:
     In the second sentence, the reference to ``paragraph A2.'' 
is replaced with ``paragraph .A2.''
     In the third sentence, the reference to ``paragraph A3.'' 
is replaced with ``paragraph .A3.''
AU sec. 110, ``Responsibilities and Functions of the Independent 
Auditor''
    SAS No. 1, ``Codification of Auditing Standards and Procedures,'' 
section 110, ``Responsibilities and Functions of the Independent 
Auditor'' (AU sec. 110, ``Responsibilities and Functions of the 
Independent Auditor''), as amended, is amended as follows:
    a. The section number ``AU Section 110'' is replaced with ``AS 
1001.''
    b. In the third sentence of paragraph .01, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    c. In paragraph 02:
     In footnote 1:
     In the first sentence, the reference to ``Auditing 
Standard No. 11'' is replaced with ``AS 2105.''
     In the second sentence, the reference to ``section 317'' 
is replaced with ``AS 2405.''
     In footnote 2, the phrase ``section 230, Due Professional 
Care in the Performance of Work, paragraphs .10 through .13'' is 
replaced with ``paragraphs .10 through .13 of AS 1015, Due Professional 
Care in the Performance of Work.''
    d. In the first sentence of paragraph .05, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    e. Paragraph .10 is deleted.
    f. Paragraph .11 and its following note is added:
    The auditor should be aware of and consider auditing 
interpretations applicable to his or her audit. If the auditor does not 
apply the auditing guidance included in an applicable auditing 
interpretation, the auditor should be prepared to explain how he or she 
complied with the provisions of the auditing standard addressed by such 
auditing guidance.
    Note: The term ``auditing interpretations,'' as used in this 
paragraph, refers to the publications entitled ``Auditing 
Interpretation'' issued by the American Institute of Certified Public 
Accountants' Auditing Standards Board as in existence on April 16, 
2003, and in effect.
AU sec. 150, ``Generally Accepted Auditing Standards''
    SAS No. 95, ``Generally Accepted Auditing Standards'' (AU sec. 150, 
``Generally Accepted Auditing Standards''), as amended, is rescinded.
AU sec. 161, ``The Relationship of Generally Accepted Auditing 
Standards to Quality Control Standards''
    SAS No. 25, ``The Relationship of Generally Accepted Auditing 
Standards to Quality Control Standards,'' (AU sec. 161, ``The 
Relationship of Generally Accepted Auditing Standards to Quality 
Control Standards''), as amended, is amended as follows:
    a. The section number ``AU Section 161'' is replaced with ``AS 
1110.''
    b. The title ``The Relationship of Generally Accepted Auditing 
Standards to Quality Control Standards'' is replaced with 
``Relationship of Auditing Standards to Quality Control Standards.''
    c. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 4)'' is deleted.
    d. In paragraph .01:

[[Page 36614]]

     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     The last sentence is deleted.
    e. In the second sentence of paragraph .02, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    f. In paragraph .03:
     In the first sentence, the phrase ``Generally accepted 
auditing standards'' is replaced with ``Auditing standards.''
     In the second sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``auditing standards.''
     In the last sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the auditing standards.''
AU sec. 201, ``Nature of the General Standards''
    SAS No. 1, ``Codification of Auditing Standards and Procedures'' 
(AU sec. 201, ``Nature of the General Standards''), is rescinded.
AU sec. 210, ``Training and Proficiency of the Independent Auditor''
    SAS No. 1, ``Codification of Auditing Standards and Procedures'' 
section 210 ``Training and Proficiency of the Independent Auditor'' (AU 
sec. 210, ``Training and Proficiency of the Independent Auditor''), as 
amended, is amended as follows:
    a. The section number ``AU Section 210'' is replaced with ``AS 
1010.''
    b. In paragraph .01, the introductory phrase ``The first general 
standard is:'' is deleted.
    c. In paragraph .02, the phrase ``This standard'' is replaced with 
the phrase ``The statement in the preceding paragraph.''
AU sec. 220, ``Independence''
    SAS No. 1, ``Codification of Auditing Standards and Procedures'' 
section 220 ``Independence'' (AU sec. 220, ``Independence''), as 
amended, is amended as follows:
    a. The section number ``AU Section 220'' is replaced with ``AS 
1005.''
    b. In paragraph .01, the introductory phrase ``The second general 
standard is:'' is deleted.
    c. In the first sentence of paragraph .02, the phrase ``This 
standard'' is replaced with the phrase ``The statement in the preceding 
paragraph.''
    d. In paragraph .05, the phrase ``that differ from the AICPA 
requirements in certain respects'' is deleted.
AU sec. 230, ``Due Professional Care in the Performance of Work''
    SAS No. 1, ``Codification of Auditing Standards and Procedures'' 
section 230 ``Due Professional Care in the Performance of Work'' (AU 
sec. 230, ``Due Professional Care in the Performance of Work''), as 
amended, is amended as follows:
    a. The section number ``AU Section 230'' is replaced with ``AS 
1015.''
    b. Footnote * to the title of the standard is deleted.
    c. In paragraph .01:
     The introductory phrase ``The third general standard is:'' 
is deleted.
     Footnote 1 is deleted.
    d. In the first sentence of paragraph .02, the phrase ``This 
standard'' is replaced with ``The statement in the preceding 
paragraph.''
    e. In footnote 4 to paragraph .06, the reference to ``Auditing 
Standard No. 10'' is replaced with ``AS 1201.''
    f. In footnote 5 to paragraph .11, the reference to ``section 342'' 
is replaced with ``AS 2501.''
    g. In paragraph .12:
     In the fifth sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     In the sixth sentence, the parenthetic reference to 
``paragraph 9 of Auditing Standard No. 15'' is replaced with 
``paragraph .09 of AS 1105.''
AU sec. 315, ``Communications Between Predecessor and Successor 
Auditors''
    SAS No. 84, ``Communications Between Predecessor and Successor 
Auditors'' (AU sec. 315, ``Communications Between Predecessor and 
Successor Auditors''), as amended, is amended as follows:
    a. The section number ``AU Section 315'' is replaced with ``AS 
2610.''
    b. The title ``Communications Between Predecessor and Successor 
Auditors'' is replaced with ``Initial Audits--Communications Between 
Predecessor and Successor Auditors.''
    c. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 7)'' is deleted.
    d. In last sentence of paragraph .01, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    e. In paragraph .09:
     The sentence ``The successor auditor may wish to consider 
other reasonable inquiries.'' is moved to the end of the paragraph, 
after the fifth bullet.
     In footnote 5 to the third bullet:
     The reference to ``section 316'' is replaced with ``AS 
2401.''
     The reference to ``section 317'' is replaced with ``AS 
2405.''
     The reference to ``section 325'' is replaced with ``AS 
1305.''
     In footnote 5A to the last bullet, the reference to 
``Paragraph .66 of AU sec. 316, Consideration of Fraud in a Financial 
Statement Audit,'' is replaced with ``AS 2401.66.''
    f. In the last sentence of footnote 8 to paragraph .12, the 
reference to ``section 543, Part of Audit Performed by Other 
Independent Auditors, paragraph 10a'' is replaced with ``paragraph .10a 
of AS 1205, Part of the Audit Performed by Other Independent 
Auditors.''
    g. In paragraph .16:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     In the second sentence, the reference to ``section 543, 
Part of Audit Performed by Other Independent Auditors'' is replaced 
with ``AS 1205.''
     In the last sentence:
     The reference to ``AU sec. 336'' is replaced with ``AS 
1210.''
     The reference to ``AU sec. 322, The Auditor's 
Consideration of the Internal Audit Function in an Audit of Financial 
Statements,'' is replaced with ``AS 2605, Consideration of the Internal 
Audit Function.''
     The reference to ``paragraphs 16-19 of PCAOB Auditing 
Standard No. 5'' is replaced with ``paragraphs .16-.19 of AS 2201.''
    h. In the first sentence of paragraph .20, the reference to 
``section 331, Inventories'' is replaced with ``AS 2510, Auditing 
Inventories.''
    i. In paragraph .21:
     In the last sentence, the reference to ``section 561'' is 
replaced with ``AS 2905.''
     In footnote 9, the reference to ``section 508, Reports on 
Audited Financial Statements, paragraphs .70 through .74'' is replaced 
with ``paragraphs .70 through .74 of AS 3101, Reports on Audited 
Financial Statements.''
    j. Under item 1 of paragraph 25:
     In the first sentence of the illustrative letter's first 
paragraph, the phrase ``auditing standards generally accepted in the 
United States of America'' is replaced with ``the standards of the 
Public Company Accounting Oversight Board (United States).''
     In the first bullet, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     In item (2) of the illustrative paragraph, the phrase 
``generally accepted auditing standards'' is

[[Page 36615]]

replaced with ``the standards of the PCAOB.''
AU sec. 316, ``Consideration of Fraud in a Financial Statement Audit''
    SAS No. 99, ``Consideration of Fraud in a Financial Statement 
Audit'' (AU sec. 316, ``Consideration of Fraud in a Financial Statement 
Audit''), as amended, is amended as follows:
    a. The section number ``AU Section 316'' is replaced with ``AS 
2401.''
    b. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 82)'' is deleted.
    c. In paragraph .01:
     In the first sentence, the reference to ``Section 110, 
Responsibilities and Functions of the Independent Auditor, paragraph 
.02'' is replaced with ``Paragraph .02 of AS 1001, Responsibilities and 
Functions of the Independent Auditor,.''
     In the note, the reference to ``paragraphs 14-15 of PCAOB 
Auditing Standard No. 5'' is replaced with ``paragraphs .14-.15 of AS 
2201.''
     In the first sentence of footnote 1, the reference to 
``section 317'' is replaced with ``AS 2405.''
    d. In paragraph .01A:
     In the first sentence, the reference to ``Auditing 
Standard No. 12'' is replaced with ``AS 2110.''
     In the second sentence, the reference to ``Auditing 
Standard No. 13'' is replaced with ``AS 2301.''
     In the last sentence, the reference to ``Auditing Standard 
No. 14'' is replaced with ``AS 2810.''
    e. In the second sentence of paragraph .04, the reference to 
``section 110.03'' is replaced with ``AS 1001.03.''
    f. In the fifth sentence of paragraph .09, the term ``GAAS'' is 
replaced with ``the standards of the PCAOB.''
    g. In footnote 7 to paragraph .12, the reference to ``section 230, 
Due Professional Care in the Performance of Work, paragraphs .10 
through .13'' is replaced with ``paragraphs .10 through .13 of AS 1015, 
Due Professional Care in the Performance of Work.''
    h. In the second sentence of paragraph .13, the phrase ``section 
230, Due Professional Care in the Performance of Work, paragraphs .07 
through .09'' is replaced with ``AS 1015.07 through .09.''
    i. In paragraph .52:
     In the first sentence, the reference to ``Paragraph 8 of 
Auditing Standard No. 13, The Auditor's Responses to the Risks of 
Material Misstatement,'' is replaced with ``AS 2301.08.''
     In the last sentence, the reference to ``Paragraph 12 of 
Auditing Standard No. 13'' is replaced with ``AS 2301.12.''
     In the note, the reference to ``Paragraph 71.b. of 
Auditing Standard No. 12, Identifying and Assessing Risks of Material 
Misstatement,'' is replaced with ``AS 2110.71b.''
    j. In paragraph .53:
     In footnote 20 to the fourth bullet, the reference to ``AU 
sec. 329'' is replaced with ``AS 2305.''
     In the fifth bullet, the parenthetic reference to 
``paragraph 54 of Auditing Standard No. 12, Identifying and Assessing 
Risks of Material Misstatement'' is replaced with ``AS 2110.54.''
    k. In paragraph .54:
     In footnote 21 to the second sub-bullet of the first 
bullet, the reference to ``AU sec. 330'' is replaced with ``AS 2310.''
     In footnote 22 to the second bullet, the reference to ``AU 
sec. 336'' is replaced with ``AS 1210.''
     In the third bullet:
     In the fourth sentence, the reference to ``section 342'' 
replaced with ``AS 2501.''
     In the fifth sentence, the parenthetic reference to 
``section 342.09 through .14'' is replaced with ``AS 2501.09 through 
.14.''
    l. In the second sentence of paragraph .56, the reference to 
``paragraphs 8 through 15 of Auditing Standard No. 13, The Auditor's 
Responses to the Risks of Material Misstatement,'' is replaced with 
``AS 2301.08 through .15.''
    m. In footnote 23 to item 1 of paragraph .58, the reference to 
``paragraphs 28 through 32 of Auditing Standard No. 12, Identifying and 
Assessing Risks of Material Misstatement'' is replaced with ``AS 
2110.28 through .32.''
    n. In the last sentence of the fifth bullet of paragraph .61, the 
reference to ``paragraphs 11 through 14 of Auditing Standard No. 9'' is 
replaced with ``paragraphs .11 through .14 of AS 2101.''
    o. In the last sentence of paragraph .63, the reference to 
``Paragraphs 24 through 27 of Auditing Standard No. 14, Evaluating 
Audit Results'' is replaced with ``AS 2810.24 through .27.''
    p. In footnote 24 to paragraph .63, the reference to ``section 342, 
Auditing Accounting Estimates, paragraphs .02 and .16,'' is replaced 
with ``AS 2501.02 and .16.''
    q. In paragraph .66:
     In the first note, the reference to ``Auditing Standard 
No. 12, Identifying and Assessing Risks of Material Misstatement'' is 
replaced with ``AS 2110.''
     In the second note:
     In the second sentence, the reference to ``paragraphs 14-
16 of Auditing Standard No. 18'' is replaced with ``paragraphs .14-.16 
of AS 2410.''
     In the last sentence, the reference to ``Auditing Standard 
No. 18, Related Parties,'' is replaced with ``AS 2410.''
    r. In the note to paragraph .66A, the reference to ``Paragraph 11A 
of Auditing Standard No. 13'' is replaced with ``AS 2301.11A.''
    s. In paragraph 67:
     In the note, the reference to ``Paragraphs 20-23 of 
Auditing Standard No. 14, Evaluating Audit Results,'' is replaced with 
``AS 2810.20-.23.''
     In the second sentence of footnote 25A to the third 
bullet, the reference to ``Auditing Standard No. 18, Related Parties,'' 
is replaced with ``AS 2410.''
    t. In paragraph 67A:
     In the note, the reference to ``AU sec. 550'' is replaced 
with ``AS 2710.''
     In footnote 25B, the reference to ``paragraphs 30-31 of 
Auditing Standard No. 14'' is replaced with ``AS 2810.30-.31.''
    u. In paragraph .80:
     In the second sentence, the parenthetic reference to 
``section 325, `Communications About Control Deficiencies in An Audit 
of Financial Statements,' paragraph 4'' is replaced with ``paragraph 
.04 of AS 1305, Communications About Control Deficiencies in an Audit 
of Financial Statements.''
     In the third sentence, the parenthetic reference to 
``paragraphs 72-73 of Auditing Standard No. 12, Identifying and 
Assessing Risks of Material Misstatement'' is replaced with ``AS 
2110.72-.73.''
    v. In the second sentence of paragraph .81, the parenthetic 
reference to ``paragraphs 12-13 of Auditing Standard No. 16'' is 
replaced with ``paragraphs .12-.13 of AS 1301.''
    w. In paragraph .82:
     In item a, the reference to ``AU sec. 315, Communications 
Between Predecessor and Successor Auditors'' is replaced with ``AS 
2610, Initial Audits--Communications Between Predecessor and Successor 
Auditors.''
     In footnote 40, the reference to ``Section 315'' is 
replaced with ``AS 2610.''
    x. In paragraph .83:
     In the first bullet, the parenthetic reference to 
``paragraphs 52 and 53 of Auditing Standard No. 12, Identifying and 
Assessing Risks of Material Misstatement'' is replaced with ``AS 
2110.52 and .53.''
     In the second bullet, the parenthetic reference to 
``paragraph 47, paragraphs 56 through 58, and paragraphs 65 through 69 
of Auditing Standard No. 12, Identifying and Assessing Risks of 
Material Misstatement'' is replaced with ``AS 2110.47, AS 2110.56 
through .58, and AS 2110.65 through .69.''

[[Page 36616]]

     In the third bullet:
     The first parenthetic reference to ``(paragraphs 59 
through 69 of Auditing Standard No. 12, Identifying and Assessing Risks 
of Material Misstatement)'' is replaced with ``(AS 2110.59 through 
.69.).''
     The second parenthetic reference to ``(paragraphs 5 
through 15 of Auditing Standard No. 13, The Auditor's Response to the 
Risks of Material Misstatement)'' is replaced with ``(AS 2301.05 
through .15.).''
     In the fourth bullet, the parenthetic reference to 
``paragraph 68 of Auditing Standard No. 12, Identifying and Assessing 
Risks of Material Misstatement'' is replaced with ``AS 2110.68.''
     In the fifth bullet, the parenthetic reference to 
``paragraph 15 of Auditing Standard No. 13, The Auditor's Responses to 
the Risks of Material Misstatements'' is replaced with ``AS 2301.15.''
     In the sixth bullet, the parenthetic reference to 
``paragraphs 5 through 9 of Auditing Standard No. 14, Evaluating Audit 
Results'' is replaced with ``AS 2810.05 through .09.''
    y. In the first sentence of item A.1 of paragraph .85, the 
reference to ``paragraphs 65 through 69 of Auditing Standard No. 12, 
Identifying and Assessing Risks of Material Misstatement'' is replaced 
with ``AS 2110.65 through .69.''
    z. Paragraphs .86 through .88 are deleted.
    aa. Footnotes 5 and 6 to paragraph .86 are deleted.
    bb. Footnote 8 to paragraph .87 is deleted.
    cc. Footnotes 1 through 11 to paragraph .88 are deleted.
AU sec. 317, ``Illegal Acts by Clients''
    SAS No. 54, ``Illegal Acts by Clients'' (AU sec. 317, ``Illegal 
Acts by Clients''), as amended, is amended as follows:
    a. The section number ``AU Section 317'' is replaced with ``AS 
2405.''
    b. In the references before paragraph .01, the phrase ``(Supersedes 
section 328)'' is deleted.
    c. In the first sentence of paragraph .01, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    d. In the last sentence of paragraph .05, the reference to 
``section 110'' is replaced with ``AS 1001.''
    e. In the last sentence of paragraph .07, the phrase ``generally 
accepted auditing standards'' is replaced with ``PCAOB auditing 
standards.''
    f. In paragraph .08:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``PCAOB auditing standards.''
     The parenthetic reference to ``section 333'' is replaced 
with ``AS 2805.''
    g. In footnote 2 to paragraph .21, the reference to ``section 508'' 
is replaced with ``AS 3101.''
    h. In the subtitle before paragraph .22, the phrase ``in Accordance 
With Generally Accepted Auditing Standards'' is deleted.
    i. In paragraph .23b:
     The reference to ``section 315, Communications Between 
Predecessor and Successor Auditors'' is replaced with ``AS 2610, 
Initial Audits--Communications Between Predecessor and Successor 
Auditors.''
     In footnote 5, the reference to ``section 315'' is 
replaced with ``AS 2610.''
AU sec. 9317, ``Illegal Acts by Clients: Auditing Interpretations of 
Section 317''
    AU sec. 9317, ``Illegal Acts by Clients: Auditing Interpretations 
of Section 317,'' is amended as follows:
    a. The section number ``AU Section 9317'' is replaced with ``AI 
13.''
    b. The title ``Illegal Acts by Clients: Auditing Interpretations of 
Section 317'' is replaced with ``Illegal Acts by Clients: Auditing 
Interpretations of AS 2405.''
    c. In paragraph .01:
     In the first sentence, the phrase ``The second standard of 
field work requires'' is replaced with ``The auditing standards 
require.''
     In the last sentence:
     The reference to ``section 317'' is replaced with ``AS 
2405, Illegal Acts by Clients.''
     The phrase ``the second standard of field work'' is 
replaced with ``AS 2110, Identifying and Assessing Risks of Material 
Misstatement.''
    d. In paragraph .03, the reference to ``section 317'' is replaced 
with ``AS 2405.''
    e. In paragraph .05, the parenthetic reference to ``section 
317.22'' is replaced with ``AS 2405.22.''
AU sec. 322, ``The Auditor's Consideration of the Internal Audit 
Function in an Audit of Financial Statements''
    SAS No. 54, ``The Auditor's Consideration of the Internal Audit 
Function in an Audit of Financial Statements'' (AU sec. 322, ``The 
Auditor's Consideration of the Internal Audit Function in an Audit of 
Financial Statements''), as amended, is amended as follows:
    a. The section number ``AU Section 322'' is replaced with ``AS 
2605.''
    b. The title ``The Auditor's Consideration of the Internal Audit 
Function in an Audit of Financial Statements'' is replaced with 
``Consideration of the Internal Audit Function.''
    c. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 9)'' is deleted.
    d. In the last sentence of paragraph .01, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    e. In the note to paragraph .01, the reference to ``paragraphs 16-
19 of PCAOB Auditing Standard No. 5'' is replaced with ``paragraphs 
.16-.19 of AS 2201.''
    f. In paragraph .02:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     In footnote 2, the phrase ``the AICPA Code of Professional 
Conduct'' is replaced with ``PCAOB Rule 3520, Auditor Independence.''
    g. In footnote 3 to paragraph .04, the reference to ``Auditing 
Standard No. 12'' is replaced with ``AS 2110.''
    h. In footnote 5 to paragraph .18, the reference to ``paragraph 8 
of Auditing Standard No. 15'' is replaced with ``paragraph .08 of AS 
1105.''
    i. In footnote 6 to paragraph .19, the reference to ``section 543, 
Part of Audit Performed by Other Independent Auditors'' is replaced 
with ``AS 1205, Part of the Audit Performed by Other Independent 
Auditors.''
    j. In the note to paragraph .22, the reference to ``paragraphs 18-
19 of PCAOB Auditing Standard No. 5, An Audit of Internal Control Over 
Financial Reporting That Is Integrated with An Audit of Financial 
Statements'' is replaced with ``AS 2201.18-.19.''
    k. In footnote 8 to paragraph .27, the reference to ``Auditing 
Standard No. 10'' is replaced with ``AS 1201.''
    l. In the appendix, the title ``The Auditor's Consideration of the 
Internal Audit Function in an Audit of Financial Statements'' is 
replaced with ``Consideration of the Internal Audit Function.''
AU sec. 324, ``Service Organizations''
    SAS No. 70, ``Service Organizations'' (AU sec. 324, ``Service 
Organizations''), as amended, is amended as follows:
    a. The section number ``AU Section 324'' is replaced with ``AS 
2601.''
    b. The title ``Service Organizations'' is replaced with 
``Consideration of an Entity's Use of a Service Organization.''
    c. Footnote * to the title of the standard is deleted.
    d. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 44)'' is deleted.

[[Page 36617]]

    e. In the note to paragraph .01, the reference to ``paragraphs B17-
B27 of Appendix B, Special Topics, of PCAOB Auditing Standard No. 5'' 
is replaced with ``paragraphs .B17-.B27 of Appendix B, Special Topics, 
of AS 2201.''
    f. In paragraph .07:
     In the first sentence, the reference to ``Auditing 
Standard No. 12'' is replaced with ``AS 2110.''
     In the third bullet, the second sentence is deleted.
    g. In the first sentence of paragraph .16, the reference to 
``paragraph 18 and paragraphs 29 through 31 of Auditing Standard No. 
13'' is replaced with ``paragraph .18 and paragraphs .29 through .31 of 
AS 2301.''
    h. In the last sentence of paragraph .18, the reference to 
``section 543, Part of Audit Performed by Other Independent Auditors, 
paragraph .10a'' is replaced with ``paragraph .10a of AS 1205, Part of 
the Audit Performed by Other Independent Auditors.''
    i. In the first sentence of paragraph 19, the reference to 
``section 543.12'' is replaced with ``AS 1205.12.''
    j. In the last sentence of paragraph .20, the reference to 
``section 325'' is replaced with ``AS 1305.''
    k. In the second sentence of paragraph .22:
     The phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     The phrase ``general standards and with the relevant 
fieldwork and reporting standards'' is replaced with ``relevant PCAOB 
auditing standards.''
    l. In the second sentence of paragraph .23:
     The reference to ``Auditing Standard No. 14'' is replaced 
with ``AS 2810.''
     The reference to ``section 317'' is replaced with ``AS 
2405.''
    m. In paragraph .38, in the last sentence of the first paragraph of 
the sample report on controls placed in operation at a service 
organization, the phrase ``standards established by the American 
Institute of Certified Public Accountants'' is replaced with ``the 
standards of the Public Company Accounting Oversight Board (United 
States).''
    n. In the last sentence of paragraph .41, the reference to 
``Section 350'' is replaced with ``AS 2315.''
    o. In paragraph .54, in the last sentence of the first paragraph of 
the sample report on controls placed in operation at a service 
organization and tests of operating effectiveness, the phrase 
``standards established by the American Institute of Certified Public 
Accountants'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
AU sec. 9324, ``Service Organizations: Auditing Interpretations of 
Section 324''
    AU sec. 9324, ``Service Organizations: Auditing Interpretations of 
Section 324,'' as amended, is amended as follows:
    a. The section number ``AU Section 9324'' is replaced with ``AI 
18.''
    b. The title ``Service Organizations: Auditing Interpretations of 
Section 324'' is replaced with ``Consideration of an Entity's Use of a 
Service Organization: Auditing Interpretations of AS 2601.''
    c. In paragraph .01:
     In the first sentence, the reference to ``section 324, 
Service Organizations'' is replaced with ``AS 2601, Consideration of an 
Entity's Use of a Service Organization.''
     In the second sentence, the reference to ``Section 
324.44f'' is replaced with ``AS 2601.44f.''
    d. In the first sentence of paragraph .02, the reference to 
``section 324.44f'' is replaced with ``AS 2601.44f.''
    e. In paragraph .05:
     In the third sentence, the reference to ``Paragraphs .06 
through .17 of section 324, Service Organizations,'' is replaced with 
``AS 2601.06 through .17.''
     In the fourth sentence, the reference to ``section 
324.06-.17'' is replaced with ``AS 2601.06-.17.''
     In the last sentence, the reference to ``section 324.06'' 
is replaced with ``AS 2601.06.''
    f. In the second sentence of paragraph .07, the reference to 
``Section 324.11-.16'' is replaced with ``AS 2601.11-.16.''
    g. Following paragraph .16, in the Sample Scope Paragraph of a 
Service Auditor's Report Using the Carve-Out Method:
     The heading ``Independent Service Auditor's Report'' above 
the example report is replaced with ``Service Auditor's Report of 
Independent Registered Public Accounting Firm.''
     In the last sentence of the report, the phrase ``standards 
established by the American Institute of Certified Public Accountants'' 
is replaced with ``the standards of the Public Company Accounting 
Oversight Board (United States).''
     In the bracketed sentence, the reference to ``section 
324.38 and .54'' is replaced with ``AS 2601.38 and .54.''
    h. In the first sentence of paragraph .17, the reference to 
``section 324.12'' is replaced with ``AS 2601.12.''
    i. Following paragraph .18, in the Sample Service Auditor's Report 
Using the Inclusive Method:
     The heading ``Independent Service Auditor's Report'' above 
the example report is replaced with ``Service Auditor's Report of 
Independent Registered Public Accounting Firm.''
     In the last sentence of the first paragraph of the report, 
the phrase ``standards established by the American Institute of 
Certified Public Accountants'' is replaced with ``the standards of the 
Public Company Accounting Oversight Board (United States).''
    j. In paragraph .35, each reference to ``Section 324.32'' or 
``section 324.32'' is replaced with ``AS 2601.32.''
    k. In paragraph .36:
     Each reference to ``Section 324.32'' or ``section 324.32'' 
is replaced with ``AS 2601.32.''
     Footnote 2 is deleted.
    l. In the first sentence of paragraph .37, the reference to 
``section 550'' is replaced with ``AS 2710.''
    m. In paragraph .38:
     In the first sentence, the reference to ``Section 324.29g 
and .44l'' is replaced with ``AS 2601.29g and .44l.''
     In the second sentence, the reference to ``Section 
324.44l'' is replaced with ``AS 2601.44l.''
     In the third sentence, the reference to ``section 324.38 
and .54'' is replaced with ``AS 2601.38 and .54.''
     In the fourth sentence, the reference to ``section 
324.54'' is replaced with ``AS 2601.54.''
    n. In the first sentence of paragraph .39, the reference to 
``section 324.38 and .54'' is replaced with ``AS 2601.38 and .54.''
    o. In the first sentence of paragraph .40, the reference to 
``section 324.38 and .54'' is replaced with ``AS 2601.38 and .54.''
AU sec. 325, ``Communications About Control Deficiencies in an Audit of 
Financial Statements''
    AU sec. 325, ``Communications About Control Deficiencies in an 
Audit of Financial Statements,'' as amended, is amended as follows:
    a. The section number ``AU Section 325'' is replaced with ``AS 
1305.''
    b. Paragraph numbers 1 through 9 are replaced with .01 through .09.
    c. The directions before paragraph 1 are replaced with the 
following:
    Note: For an integrated audit of financial statements and internal 
control over financial reporting, see paragraphs .78-.84 of AS 2201, An 
Audit of Internal Control Over Financial Reporting That Is Integrated 
with An Audit of Financial Statements.
    Note: The following paragraphs apply in an audit of financial 
statements only:
    d. In the second note to paragraph 3, the reference to ``paragraphs 
62-70 of

[[Page 36618]]

PCAOB Auditing Standard No. 5, An Audit of Internal Control Over 
Financial Reporting That Is Integrated with An Audit of Financial 
Statements'' is replaced with ``AS 2201.62-.70.''
    e. In the last sentence of paragraph 4, the reference to 
``paragraphs 2 and 3'' is replaced with ``paragraphs .02 and .03.''
    f. In the last sentence of paragraph 9:
     The reference to ``AU sec. 325'' is replaced with ``AS 
1305.''
     The reference to ``paragraph 2'' is replaced with 
``paragraph .02.''
AU sec. 9325, ``Communication of Internal Control Related Matters Noted 
in an Audit: Auditing Interpretations of Section 325''
    AU sec. 9325, ``Communication of Internal Control Related Matters 
Noted in an Audit: Auditing Interpretations of Section 325,'' as 
amended, is amended as follows:
    a. The section number ``AU Section 9325'' is replaced with ``AI 
12.''
    b. The title ``Communication of Internal Control Related Matters 
Noted in an Audit: Auditing Interpretations of Section 325'' is 
replaced with ``Communications About Control Deficiencies in an Audit 
of Financial Statements: Auditing Interpretations of AS 1305.''
    c. In the note before paragraph .01:
     In the first sentence:
     The reference to ``AU sec. 325'' is replaced with ``AS 
1305, Communications About Control Deficiencies in an Audit of 
Financial Statements.''
     The reference to ``paragraph 2'' is replaced with 
``paragraph .02.''
     In the last sentence, the reference to ``paragraph A7 of 
Appendix A, Definitions, of PCAOB Auditing Standard No. 5'' is replaced 
with ``paragraph .A7 of Appendix A, Definitions, of AS 2201.''
    d. In the first sentence of paragraph .01, the reference to 
``Section 325'' is replaced with ``AS 1305.''
    e. In the second sentence of paragraph .02, the reference to 
``Section 325'' is replaced with ``AS 1305.''
    f. In the first sentence of paragraph .03, the reference to 
``Section 325'' is replaced with ``AS 1305.''
    g. In the example report below paragraph .04, in the second 
sentence, the phrase ``standards established by the American Institute 
of Certified Public Accountants'' is replaced with ``the standards of 
the Public Company Accounting Oversight Board (United States).''
AU sec. 9326, ``Evidential Matter: Auditing Interpretations of Section 
326''
    AU sec. 9326, ``Evidential Matter: Auditing Interpretations of 
Section 326,'' as amended, is amended as follows:
    a. The section number ``AU Section 9326'' is replaced with ``AI 
28.''
    b. The title ``Evidential Matter: Auditing Interpretations of 
Section 326'' is replaced with ``Evidential Matter Relating to Income 
Tax Accruals: Auditing Interpretations.''
    c. In paragraph .10:
     In the first sentence, the phrase ``third standard of 
field work requires'' is replaced with ``auditing standards require.''
     In the second sentence, the reference to ``Paragraph 35 of 
Auditing Standard No. 14'' is replaced with ``Paragraph .35 of AS 
2810.''
     In the third sentence, the reference to ``Section 508, 
Reports on Audited Financial Statements, paragraph .24'' is replaced 
with ``Paragraph .24 of AS 3101, Reports on Audited Financial 
Statements.''
     In the fourth sentence, the reference to ``section 333 on 
Management Representations'' is replaced with ``AS 2805, Management 
Representations.''
     In the fifth sentence:
     The reference to ``Section 333.06'' is replaced with ``AS 
2805.06.''
     The reference to ``section 333.08'' is replaced with ``AS 
2805.08.''
     In the last sentence, the reference to ``section 333.13'' 
is replaced with ``AS 2805.13.''
    d. In the first sentence of paragraph .12, the phrase ``Section 
339, Audit Documentation, states that audit documentation is the 
principal record'' is replaced with ``Audit documentation is the 
written record.''
    e. In paragraph .16, the reference to ``section 336'' is replaced 
with ``AS 1210.''
    f. In the first sentence of paragraph .18, the reference to 
``Section 336.01'' is replaced with ``AS 1210.01.''
    g. In the first sentence of paragraph .19, the reference to 
``section 337'' is replaced with ``AS 2505.''
AU sec. 328, ``Auditing Fair Value Measurements and Disclosures''
    SAS No. No. 101, ``Auditing Fair Value Measurements and 
Disclosures'' (AU sec. 328, ``Auditing Fair Value Measurements and 
Disclosures''), as amended, is amended as follows:
    a. The section number ``AU Section 328'' is replaced with ``AS 
2502.''
    b. In paragraph .06 each reference to ``Section 342'' or ``section 
342'' is replaced with ``AS 2501.''
    c. In footnote 3 to paragraph .07, the reference to ``section 332'' 
is replaced with ``AS 2503.''
    d. In the first sentence of paragraph .11, the reference to 
``Auditing Standard No. 12'' is replaced with ``AS 2110.''
    e. In the last sentence of the fifth bullet of paragraph .12, the 
reference to ``section 324, Service Organizations'' is replaced with 
``AS 2601, Consideration of an Entity's Use of a Service 
Organization.''
    f. In the first sentence of paragraph .14, the reference to 
``Paragraph A5, second note of Auditing Standard No. 5'' is replaced 
with ``Paragraph .A5, second note of AS 2201.''
    g. In the last sentence of paragraph .20, the reference to 
``section 336'' is replaced with ``AS 1210.''
    h. In paragraph .22, the reference to ``Section 336'' or ``section 
336'' is replaced with ``AS 1210.''
    i. In footnote 6 to paragraph .40, the reference to ``section 329, 
Analytical Procedures'' is replaced with ``AS 2305, Substantive 
Analytical Procedures.''
    j. In footnote 7 to paragraph .41, the reference to ``section 560'' 
is replaced with ``AS 2801.''
    k. In footnote 8 to paragraph .43, the reference to ``paragraph 31 
of Auditing Standard No. 14'' is replaced with ``paragraph .31 of AS 
2810.''
    l. In the last sentence of paragraph .47, the parenthetic reference 
to ``paragraphs 12 through 18 and 24 through 27 of Auditing Standard 
No. 14, Evaluating Audit Results'' is replaced with ``AS 2810.12 
through .18 and AS 2810.24 through .27.''
    m. In the first sentence of paragraph .48:
     The reference to ``Section 333'' is replaced with ``AS 
2805.''
     The reference to ``generally accepted auditing standards'' 
is replaced with ``the standards of the PCAOB.''
    n. In paragraph .50, the reference to ``Paragraphs 12-13 of 
Auditing Standard No. 16'' is replaced with ``Paragraphs .12-.13 of AS 
1301.''
AU sec. 329, ``Substantive Analytical Procedures''
    SAS No. 56, ``Analytical Procedures'' (AU sec. 329, ``Substantive 
Analytical Procedures''), as amended, is amended as follows:
    a. The section number ``AU Section 329'' is replaced with ``AS 
2305.''
    b. In the references before paragraph .01, the phrase ``(Supersedes 
section 318)'' is deleted.
    c. In paragraph .01:
     In the first note, the reference to ``Auditing Standard 
No. 12'' is replaced with ``AS 2110.''
     In the second note, the reference to ``Auditing Standard 
No. 14'' is replaced with ``AS 2810.''
    d. In the last sentence of paragraph .09, the parenthetic reference 
to ``paragraph 11 of Auditing Standard No.

[[Page 36619]]

13'' is replaced with ``paragraph .11 of AS 2301.''
    e. In footnote 1 to paragraph .09, the reference to ``Auditing 
Standard No. 15'' is replaced with ``AS 1105.''
    f. In the last sentence of paragraph .21, the parenthetic reference 
to ``Auditing Standard No. 14, Evaluating Audit Results'' is replaced 
with ``AS 2810.''
AU sec. 330, ``The Confirmation Process''
    SAS No. 67, ``The Confirmation Process'' (AU sec. 330, ``The 
Confirmation Process''), as amended, is amended as follows:
    a. The section number ``AU Section 330'' is replaced with ``AS 
2310.''
    b. In the references before paragraph .01, the phrase ``(Supersedes 
section 331.03-.08)'' is deleted.
    c. In paragraph .01:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     In the last bullet:
     In the first sentence, the reference to ``section 331, 
Inventories, paragraphs .03-.08'' is replaced with ``paragraphs .03-.08 
of AS 2510, Auditing Inventories.''
     Each reference to ``section 331.01'' is replaced with ``AS 
2510.01.''
    d. In paragraph .02:
     In the second sentence:
     The reference to ``section 350'' is replaced with ``AS 
2315.''
     The reference to ``Auditing Standard No. 13'' is replaced 
with ``AS 2301.''
     In the last sentence, the reference to ``Auditing Standard 
No. 13, The Auditor's Responses to the Risks of Material Misstatement'' 
is replaced with ``AS 2301.''
    e. In paragraph .03:
     The reference to ``section 336'' is replaced with ``AS 
1210.''
     The reference to ``section 337'' is replaced with ``AS 
2505.''
    f. In the first sentence of paragraph .05, the reference to 
``Auditing Standard No. 8'' is replaced with ``AS 1101.''
    g. In the last sentence of paragraph .06, the reference to 
``paragraph 8 of Auditing Standard No. 15'' is replaced with 
``paragraph .08 of AS 1105.''
    h. In the last sentence of paragraph .11, the reference to 
``Auditing Standard No. 15, Audit Evidence,'' is replaced with ``AS 
1105.''
    i. In paragraph .15, the parenthetic reference to ``section 230'' 
is replaced with ``AS 1015.''
    j. In footnote 2 to paragraph .27, the reference to ``Auditing 
Standard No. 18'' is replaced with ``AS 2410.''
    k. In the last sentence of footnote 3 to paragraph .28, the 
reference to ``Section 322, The Auditor's Consideration of the Internal 
Audit Function in an Audit of Financial Statements'' is replaced with 
``AS 2605, Consideration of the Internal Audit Function.''
AU sec. 331, ``Inventories''
    SAS No. 1, ``Codification of Auditing Standards and Procedures'' 
section 331 ``Inventories'' (AU sec. 331, ``Inventories''), as amended, 
is amended as follows:
    a. The section number ``AU Section 331'' is replaced with ``AS 
2510.''
    b. The title ``Inventories'' is replaced with ``Auditing 
Inventories.''
    c. Footnote * to the title of the standard is deleted.
    d. Footnote 3 to the subtitle before paragraph .14, ``Inventories 
Held in Public Warehouses,'' is deleted.
    e. In paragraph .15, the reference to ``sections 508.24 and 
508.67'' is replaced with ``paragraphs .24 and .67 of AS 3101, Reports 
on Audited Financial Statements.''
AU sec. 332, ``Auditing Derivative Instruments, Hedging Activities, and 
Investments in Securities''
    SAS No. 92, ``Auditing Derivative Instruments, Hedging Activities, 
and Investments in Securities'' (AU sec. 332, ``Auditing Derivative 
Instruments, Hedging Activities, and Investments in Securities''), as 
amended, is amended as follows:
    a. The section number ``AU Section 332'' is replaced with ``AS 
2503.''
    b. Footnote 1 to the title of the standard is deleted.
    c. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 81)'' is deleted.
    d. In paragraph .01:
     In the last sentence, the reference to ``paragraphs 11 and 
12 of Auditing Standard No. 15'' is replaced with ``paragraphs .11 and 
.12 of AS 1105.''
     In footnote 3, the reference to ``section 623, Special 
Reports, paragraph .04'' is replaced with ``paragraph .04 of AS 3305, 
Special Reports.''
    e. In paragraph .06:
     In the first sentence, the reference to ``Auditing 
Standard No. 9'' is replaced with ``AS 2101.''
     In the second sentence, the reference to ``Auditing 
Standard No. 10'' is replaced with ``AS 1201.''
     In the last sentence, the reference to ``AU sec. 336'' is 
replaced with ``AS 1210.''
    f. In the last sentence of paragraph .07, the reference to 
``section 322, The Auditor's Consideration of the Internal Audit 
Function in an Audit of Financial Statements'' is replaced with ``AS 
2605, Consideration of the Internal Audit Function.''
    g. In the first sentence of paragraph .09, the reference to 
``Auditing Standard No. 12'' is replaced with ``AS 2110.''
    h. Footnote 6 to paragraph .10 is deleted.
    i. In paragraph .11:
     In the fourth sentence, the reference to ``Paragraphs 28 
through 32 and B1 through B6 of Auditing Standard No. 12, Identifying 
and Assessing Risks of Material Misstatement'' is replaced with ``AS 
2110.28 through .32 and AS 2110.B1 through .B6.''
     In the last sentence, the reference to ``section 324, 
Service Organizations'' is replaced with ``AS 2601, Consideration of an 
Entity's Use of a Service Organization.''
     In the note, the reference to ``paragraph 39 of PCAOB 
Auditing Standard No. 5'' is replaced with ``paragraph .39 of AS 
2201.''
    j. In footnote 8 to the fifth bullet of paragraph .14, the 
reference to ``Section 324'' is replaced with ``AS 2601.''
    k. In the last sentence of paragraph .15, the reference to 
``Auditing Standard No. 12, Identifying and Assessing Risks of Material 
Misstatement'' is replaced with ``AS 2110.''
    l. In paragraph .16a, the reference to ``section 324'' is replaced 
with ``AS 2601.''
    m. Footnote 10 to paragraph .18 is deleted.
    n. In paragraph .21:
     In the first sentence of footnote 11 to the second bullet, 
the reference to ``Section 330'' is replaced with ``AS 2310, The 
Confirmation Process.''
     In footnote 12 to the last bullet, the reference to 
``Section 329'' is replaced with ``AS 2305, Substantive Analytical 
Procedures.''
    o. In footnote 13 to the second bullet of paragraph .22, the 
reference to ``Section 330.17'' is replaced with ``AS 2310.17.''
    p. In footnote 15 to paragraph .32, the reference to ``section 508, 
Reports on Audited Financial Statements, paragraphs .16-.18'' is 
replaced with ``paragraphs .16-.18 of AS 3101, Reports on Audited 
Financial Statements.''
    q. In paragraph .33:
     In the third sentence, the reference to ``section 560, 
Subsequent Events, paragraphs .05-.06)'' is replaced with ``paragraphs 
.05-.06 of AS 2801, Subsequent Events.''
     In the last sentence, the reference to ``section 560.03'' 
is replaced with ``AS 2801.03.''
    r. In paragraph .35:
     In the sixth sentence, the reference to ``section 342'' is 
replaced with ``AS 2501.''

[[Page 36620]]

     In the last sentence, the reference to ``paragraphs 24 
through 27 of Auditing Standard No. 14'' is replaced with ``paragraphs 
.24 through .27 of AS 2810.''
    s. In paragraph .39:
     Each reference to ``Section 336'' is replaced with ``AS 
1210.''
     Each reference to ``Section 324'' is replaced with ``AS 
2601.''
    t. In paragraph .43a, the reference to ``section 342'' is replaced 
with ``AS 2501.''
    u. In paragraph .43b, the reference to ``section 336'' is replaced 
with ``AS 1210.''
    v. In the third sentence of paragraph .49, the reference to 
``section 411, The Meaning of Present Fairly in Conformity with 
Generally Accepted Accounting Principles, paragraph .04'' is replaced 
with ``paragraph .04 of AS 2815, The Meaning of `Present Fairly in 
Conformity with Generally Accepted Accounting Principles.' ''
    w. In paragraph .51, the parenthetic reference to ``paragraph 31 of 
Auditing Standard No. 14, Evaluating Audit Results'' is replaced with 
``AS 2810.31.''
    x. In paragraph .58:
     In the first sentence, the reference to ``Section 333'' is 
replaced with ``AS 2805.''
     In footnote 20, the reference to ``section 333.17'' is 
replaced with ``AS 2805.17.''
AU sec. 333, ``Management Representations''
    SAS No. 85, ``Management Representations'' (AU sec. 333, 
``Management Representations''), as amended, is amended as follows:
    a. The section number ``AU Section 333'' is replaced with ``AS 
2805.''
    b. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 19)'' is deleted.
    c. In paragraph .01, the phrase ``generally accepted auditing 
standards'' is replaced with ``the standards of the PCAOB.''
    d. In footnote 1 to paragraph .02, the reference to ``Section 230'' 
is replaced with ``AS 1015.''
    e. In the third sentence of paragraph .03, the reference to 
``Auditing Standard No. 18'' is replaced with ``AS 2410.''
    f. In the note to paragraph .05, the reference to ``paragraphs 75-
77 of PCAOB Auditing Standard No. 5'' is replaced with ``paragraphs 
.75-.77 of AS 2201.''
    g. In paragraph .06g:
     In footnote 4, the reference to ``Auditing Standard No. 
14'' is replaced with ``AS 2810.''
     In the first sentence of footnote 6, the reference to 
``Paragraph 11 of Auditing Standard No. 14, Evaluating Audit Results'' 
is replaced with ``AS 2810.11.''
     In footnote 7:
     In the first sentence:
     The reference to ``section 317, Illegal Acts by Clients, 
paragraph .17'' is replaced with ``paragraph .17 of AS 2405, Illegal 
Acts by Clients.''
     The reference to ``section 316, Consideration of Fraud in 
a Financial Statement Audit, paragraphs .79 through .82'' is replaced 
with ``paragraphs .79 through .82 of AS 2401, Consideration of Fraud in 
a Financial Statement Audit.''
     In the last sentence:
     The reference to ``section 317'' is replaced with ``AS 
2405.''
     The reference to ``section 316'' is replaced with 
``2401.''
    h. In footnote 9 to paragraph .06l, the reference to ``paragraph 18 
of Auditing Standard No. 18, Related Parties'' is replaced with ``AS 
2410.18.''
    i. In footnote 10 to paragraph .06o, the reference to ``section 
317'' is replaced with ``AS 2405.''
    j. In footnote 11 to paragraph .06p:
     In the first sentence, the reference to ``section 337, 
Inquiry of a Client's Lawyer Concerning Litigation, Claims, and 
Assessments, paragraph .05d'' is replaced with ``paragraph .05d of AS 
2505, Inquiry of a Client's Lawyer Concerning Litigation, Claims, and 
Assessments.''
     The parenthetic reference to ``section 9337.15-.17'' is 
replaced with ``paragraphs .15-.17 of AI 17, Inquiry of a Client's 
Lawyer Concerning Litigation, Claims, and Assessments: Auditing 
Interpretations of AS 2505.''
    k. In footnote 12 to paragraph .06q, the reference to ``section 
337.05b'' is replaced with ``AS 2505.05b.''
    l. In footnote 13 to paragraph .06t:
     The reference to ``section 560, Subsequent Events, 
paragraph .12'' is replaced with ``paragraph .12 of AS 2801, Subsequent 
Events.''
     The reference to ``section 711, Filings Under Federal 
Securities Statutes, paragraph .10'' is replaced with ``paragraph .10 
of AS 4101, Responsibilities Regarding Filings Under Federal Securities 
Statutes.''
     The reference to ``section 634, Letters for Underwriters 
and Certain Other Requesting Parties, paragraph .45, footnote 29'' is 
replaced with ``paragraph .45, footnote 31 of AS 6101, Letters for 
Underwriters and Certain Other Requesting Parties.''
    m. Footnote 14 to paragraph .07 is deleted.
    n. In the fourth sentence of paragraph .09, the bracketed reference 
to ``section 530, Dating of the Independent Auditor's Report, paragraph 
.05'' is replaced with ``paragraph .05 of AS 3110, Dating of the 
Independent Auditor's Report.''
    o. In footnote 15 to paragraph .12, the reference to ``section 508, 
Reports on Audited Financial Statements, paragraph .71'' is replaced 
with ``paragraph .71 of AS 3101, Reports on Audited Financial 
Statements.''
    p. In footnote 16 to paragraph .12, the reference to ``section 
711.10'' is replaced with ``AS 4101.10.''
    q. In footnote 18 to paragraph .13, the reference to ``section 
508.22-.34'' is replaced with ``AS 3101.22-.34.''
    r. In the second sentence of item 4 of paragraph .16:
     The reference to ``section 316'' is replaced with ``AS 
2401.''
     The reference to ``Auditing Standard No. 18'' is replaced 
with ``AS 2410.''
    s. The second sentence in item 1 of paragraph .17 is deleted.
AU sec. 9333, ``Management Representations: Auditing Interpretations of 
Section 333''
    AU sec. 9333, ``Management Representations: Auditing 
Interpretations of Section 333,'' is amended as follows:
    a. The section number ``AU Section 9333'' is replaced with ``AI 
21.''
    b. The title ``Management Representations: Auditing Interpretations 
of Section 333'' is replaced with ``Management Representations: 
Auditing Interpretations of AS 2805.''
    c. In the first sentence of paragraph .01, the reference to 
``Section 333'' is replaced with ``AS 2805.''
    d. In paragraph .02, each reference to ``Section 317'' or ``section 
317'' is replaced with ``AS 2405.''
    e. In the second sentence of paragraph .03, the reference to 
``Section 333'' is replaced with ``AS 2805.''
AU sec. 336, ``Using the Work of a Specialist''
    SAS No. 73, ``Using the Work of a Specialist'' (AU sec. 336, 
``Using the Work of a Specialist''), as amended, is amended as follows:
    a. The section number ``AU Section 336'' is replaced with ``AS 
1210.''
    b. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 11)'' is deleted.
    c. In paragraph .01:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     In footnote 1, the reference to ``Auditing Standard No. 
10'' is replaced with ``AS 1201.''

[[Page 36621]]

    d. In the second sentence of paragraph .02, the reference to 
``section 337'' is replaced with ``AS 2505.''
    e. In paragraph .04:
     The reference to ``section 623'' is replaced with ``AS 
3305.''
     In footnote 3, the reference to ``section 623, Special 
Reports'' is replaced with ``AS 3305.''
    f. In the last sentence of paragraph .05, the reference to 
``Auditing Standard No. 10, Supervision of the Audit Engagement'' is 
replaced with ``AS 1201.''
    g. In footnote 4 to paragraph .07c, the parenthetic sentence is 
deleted.
    h. In the last sentence of paragraph .13, the parenthetic reference 
to ``section 508, Reports on Audited Financial Statements, paragraphs 
.22 and .23'' is replaced with ``paragraphs .22 and .23 of AS 3101, 
Reports on Audited Financial Statements.''
    i. In the last sentence of paragraph .14, the parenthetic reference 
to ``section 508.35, .36, and .41'' is replaced with ``AS 3101.35, .36, 
and .41.''
AU sec. 9336, ``Using the Work of a Specialist: Auditing 
Interpretations of Section 336''
    AU sec. 9336, ``Using the Work of a Specialist: Auditing 
Interpretations of Section 336,'' as amended, is amended as follows:
    a. The section number ``AU Section 9336'' is replaced with ``AI 
11.''
    b. The title ``Using the Work of a Specialist: Auditing 
Interpretations of Section 336'' is replaced with ``Using the Work of a 
Specialist: Auditing Interpretations of AS 1210.''
    c. In the first sentence of paragraph .04, the reference to 
``Section 336, Using the Work of a Specialist, paragraph .06'' is 
replaced with ``Paragraph .06 of AS 1210, Using the Work of a 
Specialist.''
    d. In the second sentence of paragraph .11, the reference to 
``Section 336.13'' is replaced with ``AS 1210.13.''
    e. In the fourth sentence of paragraph .15, the reference to 
``Paragraph 6 of Auditing Standard No. 15'' is replaced with 
``Paragraph .06 of AS 1105.''
    f. In the second sentence of paragraph .17, the reference to 
``section 336.09'' is replaced with ``AS 1210.09.''
    g. In paragraph .21:
     In footnote 14, the reference to ``section 336.13'' is 
replaced with ``AS 1210.13.''
     In the third sentence, the reference to ``section 508, 
Reports on Audited Financial Statements, paragraphs .35 through .60'' 
is replaced with ``paragraphs .35 through .60 of AS 3101, Reports on 
Audited Financial Statements.''
     In the last sentence, the reference to ``section 
508.22-.26 and 508.61-.63.'' is replaced with ``AS 3101.22-.26 and AS 
3101.61-.63.''
AU sec. 337, ``Inquiry of a Client's Lawyer Concerning Litigation, 
Claims, and Assessments''
    SAS No. 12, ``Inquiry of a Client's Lawyer Concerning Litigation, 
Claims, and Assessments'' (AU sec. 336, ``Inquiry of a Client's Lawyer 
Concerning Litigation, Claims, and Assessments''), as amended, is 
amended as follows:
    a. The section number ``AU Section 337'' is replaced with ``AS 
2505.''
    b. Footnote 1 to the title of the standard is deleted.
    c. In paragraph .01, the phrase ``generally accepted auditing 
standards'' is replaced with ``the standards of the PCAOB.''
    d. In footnote 2 to paragraph .03:
     The first sentence is deleted.
     In the last sentence, the term ``SAS'' is replaced with 
``auditing standard.''
    e. In footnote 4 to the subtitle before paragraph .08 (``Inquiry of 
a Client's Lawyer''), the parenthetic reference to ``section 337A'' is 
replaced with ``AS 2505A.''
    f. In footnote 6 to the subtitle before paragraph .12 
(``Limitations on the Scope of a Lawyer's Response''), the parenthetic 
reference to ``section 337C'' is replaced with ``AS 2505C.''
    g. In the first sentence of paragraph .13, the parenthetic 
reference to ``section 508.22 and .23'' is replaced with ``paragraphs 
.22 and .23 of AS 3101, Reports on Audited Financial Statements.''
    h. In the last sentence of paragraph .14, the reference to 
``section 508.45 through .49'' is replaced with ``AS 3101.45 through 
.49.''
    i. The section number ``AU Section 337A'' is replaced with ``AS 
2505A.''
    j. In AU Section 337A, the paragraph number ``.01'' is deleted.
    k. Exhibit I, AU sec. 337B and related footnotes are deleted.
    l. The section number ``AU Section 337C'' is replaced with ``AS 
2505C.''
AU sec. 9337, ``Inquiry of a Client's Lawyer Concerning Litigation, 
Claims, and Assessments: Auditing Interpretation of Section 337''
    AU sec. 9337, ``Inquiry of a Client's Lawyer Concerning Litigation, 
Claims, and Assessments: Auditing Interpretation of Section 337,'' as 
amended, is amended as follows:
    a. The section number ``AU Section 9337'' is replaced with ``AI 
17.''
    b. The title ``Inquiry of a Client's Lawyer Concerning Litigation, 
Claims, and Assessments: Auditing Interpretations of Section 337'' is 
replaced with ``Inquiry of a Client's Lawyer Concerning Litigation, 
Claims, and Assessments: Auditing Interpretation of AS 2505.''
    c. In the first sentence of paragraph .01, the reference to 
``section 337'' is replaced with ``AS 2505.''
    d. In the first sentence of paragraph .04, the reference to 
``[section 337A] to section 337, Inquiry of a Client's Lawyer 
Concerning Litigation, Claims, and Assessments,'' is replaced with 
``[AS 2505A] to AS 2505.''
    e. In the first sentence of paragraph .05, the reference to 
``Section 560.10 through .12 indicates'' is replaced with ``Paragraphs 
.10 through .12 of AS 2801, Subsequent Events, indicate.''
    f. In the first sentence of paragraph .06, the reference to 
``[section 337A] to section 337, Inquiry of a Client's Lawyer 
Concerning Litigation, Claims, and Assessments,'' is replaced with 
``[AS 2505A] to AS 2505.''
    g. In the first sentence of paragraph .07, the reference to 
``[section 337A] to section 337'' is replaced with ``[AS 2505A] to AS 
2505.''
    h. In the first sentence of paragraph .08, the reference to 
``Section 337, Inquiry of a Client's Lawyer Concerning Litigation, 
Claims, and Assessments, paragraph .05c,'' is replaced with ``AS 
2505.05c.''
    i. In the second sentence of paragraph .09:
     The parenthetic reference to ``section 337.13'' is 
replaced with ``AS 2505.13.''
     The reference to ``section 337.05c'' is replaced with ``AS 
2505.05c.''
    j. In the first sentence of paragraph .10, the reference to 
``[section 337A] of section 337, Inquiry of a Client's Lawyer 
Concerning Litigation, Claims, and Assessments,'' is replaced with 
``[AS 2505A] of AS 2505.''
    k. In paragraph .11:
     In the first sentence, the reference to ``Section 
337.09,'' is replaced with ``AS 2505.09.''
     In the second sentence, the reference to ``section 337'' 
is replaced with ``AS 2505.''
    l. In the last sentence of footnote 1 to paragraph .13:
     The reference to ``section 337'' is replaced with ``AS 
2505.''
     The bracketed reference to ``section 337C'' is replaced 
with ``AS 2505C.''
    m. In footnote 2 to paragraph .14, the parenthetic reference to 
``sections 9337.01-.05'' is replaced with ``paragraphs .01-.05.''
    n. In the first sentence of paragraph .15, the reference to 
``Section 337.06'' is replaced with ``AS 2505.06.''
    o. In paragraph .16:

[[Page 36622]]

     In the first sentence, the reference to ``Section 337'' is 
replaced with ``AS 2505.''
     In the second sentence:
     The reference to ``section 337.05 and .07'' is replaced 
with ``AS 2505.05 and .07.''
     The reference to ``section 333, Management 
Representations, paragraph .06m and n'' is replaced with ``paragraphs 
.06o and p of AS 2805, Management Representations.''
    p. In the first sentence of paragraph .18, the reference to 
``Section 337, Inquiry of a Client's Lawyer Concerning Litigation, 
Claims, and Assessments, paragraph .09d(2),'' is replaced with ``AS 
2505.09d(2).''
    q. In paragraph .19:
     In the first sentence, the reference to ``[section 337C] 
to section 337'' is replaced with ``[AS 2505C] to AS 2505.''
     In the second sentence, the bracketed reference to 
``section 337C'' is replaced with ``AS 2505C.''
    r. In the first sentence of paragraph .22:
     The reference to ``section 337.14'' is replaced with ``AS 
2505.14.''
     The bracketed reference to ``section 337C'' is replaced 
with ``AS 2505C.''
    s. In the last sentence of paragraph .23, the reference to 
``section 508.45 through .49'' is replaced with ``paragraphs .45 
through .49 of AS 3101, Reports on Audited Financial Statements,.''
    t. In the first sentence of paragraph .24, the reference to 
``Section 337.06'' is replaced with ``AS 2505.06.''
    u. In the first sentence of paragraph .25, the reference to 
``Section 337.08'' is replaced with ``AS 2505.08.''
    v. In footnote 4 to paragraph .26, the reference to ``section 
337.08'' is replaced with ``AS 2505.08.''
    w. In paragraph .32:
     In the third sentence, the bracketed reference to 
``section 337C'' is replaced with ``AS 2505C.''
     In footnote 5, each bracketed reference to ``section 
337C'' is replaced with ``AS 2505C.''
AU sec. 341, ``The Auditor's Consideration of an Entity's Ability to 
Continue as a Going Concern''
    SAS No. 59, ``The Auditor's Consideration of an Entity's Ability to 
Continue as Going Concern'' (AU sec. 341, ``The Auditor's Consideration 
of an Entity's Ability to Continue as a Going Concern''), as amended, 
is amended as follows:
    a. The section number ``AU Section 341'' is replaced with ``AS 
2415.''
    b. The title ``The Auditor's Consideration of an Entity's Ability 
to Continue as a Going Concern'' is replaced with ``Consideration of an 
Entity's Ability to Continue as a Going Concern.''
    c. In the references before paragraph .01, the phrase ``(Supersedes 
section 340)'' is deleted.
    d. In paragraph .01:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     In the last sentence of footnote 1, the parenthetic 
reference to ``section 9508.33-.38'' is replaced with ``AI 23.33-.38.''
    e. In the last sentence of paragraph .02, the reference to 
``Auditing Standard No. 15'' is replaced with ``AS 1105.''
    f. In the first sentence of footnote 3 to the fifth bullet of 
paragraph .10, the phrase ``generally accepted auditing standards'' is 
replaced with ``PCAOB auditing standards.''
    g. In the last sentence of footnote 4 to paragraph .12, the 
parenthetic reference to ``section 508'' is replaced with ``AS 3101.''
    h. In the last sentence of paragraph .14, the reference to 
``section 508, Reports on Audited Financial Statements'' is replaced 
with ``AS 3101.''
    i. In the last sentence of paragraph .15, the reference to 
``section 508'' is replaced with ``AS 3101.''
    j. In the first sentence of paragraph .17A, the reference to 
``Paragraph 17 of Auditing Standard No. 16'' is replaced with 
``Paragraph .17 of AS 1301.''
AU sec. 9341, ``The Auditor's Consideration of an Entity's Ability to 
Continue as a Going Concern: Auditing Interpretations of Section 341''
    AU sec. 9341, ``The Auditor's Consideration of an Entity's Ability 
to Continue as a Going Concern: Auditing Interpretations of Section 
341,'' as amended, is amended as follows:
    a. The section number ``AU Section 9341'' is replaced with ``AI 
15.''
    b. The title ``The Auditor's Consideration of an Entity's Ability 
to Continue as a Going Concern: Auditing Interpretations of Section 
341'' is replaced with ``Consideration of an Entity's Ability to 
Continue as a Going Concern: Auditing Interpretations of AS 2415.''
    c. In paragraph .02:
     In footnote 2, the reference to ``Section 530, Dating of 
the Independent Auditor's Report, paragraph .05'' is replaced with 
``Paragraph .05 of AS 3110, Dating of the Independent Auditor's 
Report.''
     In the second bullet, the reference to ``section 560, 
Subsequent Events, paragraph .12'' is replaced with ``paragraph .12 of 
AS 2801, Subsequent Events.''
     In the third bullet, the reference to ``section 341, The 
Auditor's Consideration of an Entity's Ability to Continue as a Going 
Concern, paragraphs .06 through .11,'' is replaced with ``paragraphs 
.06 through .11 of AS 2415, Consideration of an Entity's Ability to 
Continue as a Going Concern.''
AU sec. 342, ``Auditing Accounting Estimates''
    SAS No. 57, ``Auditing Accounting Estimates'' (AU sec. 342, 
``Auditing Accounting Estimates''), as amended, is amended as follows:
    a. The section number ``AU Section 342'' is replaced with ``AS 
2501.''
    b. In the first sentence of paragraph .01, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    c. In paragraph .07c:
     In footnote 2, the reference to ``Section 411, The Meaning 
of Present Fairly in Conformity With Generally Accepted Accounting 
Principles'' is replaced with ``AS 2815, The Meaning of `Present Fairly 
in Conformity with Generally Accepted Accounting Principles.' ''
     In footnote 3, the reference to ``paragraph 31 of Auditing 
Standard No. 14'' is replaced with ``paragraph .31 of AS 2810.''
    d. In paragraph .08b:
     In item 1, the parenthetic reference to ``Auditing 
Standard No. 12'' is replaced with ``AS 2110.''
     In item 3, the parenthetic reference to ``section 337'' is 
replaced with ``AS 2505.''
    e. In paragraph .11h, the parenthetic reference to ``section 336'' 
is replaced with ``AS 1210.''
    f. In paragraph .14, the reference to ``Paragraphs 24 through 27 of 
Auditing Standard No. 14, Evaluating Audit Results,'' is replaced with 
``AS 2810.24 through .27.''
AU sec. 9342, ``Auditing Accounting Estimates: Auditing Interpretations 
of Section 342''
    AU sec. 9342, ``Auditing Accounting Estimates: Auditing 
Interpretations of Section 342,'' as amended, is amended as follows:
    a. The section number ``AU Section 9342'' is replaced with ``AI 
16.''
    b. The title ``Auditing Accounting Estimates: Auditing 
Interpretations of Section 342'' is replaced with ``Auditing Accounting 
Estimates: Auditing Interpretations of AS 2501.''
    c. In the first sentence of paragraph .06--the example paragraph--
the phrase

[[Page 36623]]

``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board.''
    d. In the last sentence of paragraph .07, the reference to 
``Auditing Standard No. 17'' is replaced with ``AS 2701.''
    e. In the last sentence of paragraph .09, the reference to 
``section 550'' is replaced with ``AS 2710.''
    f. In the second flowchart of paragraph .10, ``Auditing Guidance 
for Fair Value Information: Required and Voluntary Information'':
     The reference to ``paragraph 10 of Auditing Standard No. 
17, Auditing Supplemental Information Accompanying Audited Financial 
Statements,'' is replaced with ``AS 2701.10.''
     The reference to ``section 550'' is replaced with ``AS 
2710.''
     The reference to ``interpretation 11 of section 623, 
`Reporting on Current-Value Financial Statements That Supplement 
Historical Cost Financial Statements in a General-Use Presentation of 
Real Estate Entities' '' is replaced with ``AI 24, Special Reports: 
Auditing Interpretations of AS 3305, interpretation 11, `Reporting on 
Current-Value Financial Statements That Supplement Historical Cost 
Financial Statements in a General-Use Presentation of Real Estate 
Entities.' ''
AU sec. 350, ``Audit Sampling''
    SAS No. 39, ``Audit Sampling'' (AU sec. 350, ``Audit Sampling''), 
as amended, is amended as follows:
    a. The section number ``AU Section 350'' is replaced with ``AS 
2315.''
    b. In the references before paragraph .01, the phrase ``(Supersedes 
Statement of Auditing Standards No. 1, sections 320A, and 320B.)'' is 
deleted.
    c. In the last sentence of footnote 2 to paragraph .02, the 
reference to ``Auditing Standard No. 14'' is replaced with ``AS 2810.''
    d. In the note to paragraph .06:
     The reference to ``Auditing Standard No. 15'' is replaced 
with ``AS 1105.''
     The reference to ``Auditing Standard No. 14, Evaluating 
Audit Results,'' is replaced with ``AS 2810.''
    e. In the first sentence of paragraph .07, the phrase ``referred to 
in the third standard of field work'' is deleted.
    f. In the note to paragraph .09, the reference to ``Auditing 
Standard No. 8'' is replaced with ``AS 1101.''
    g. In the last sentence of paragraph .11, the parenthetic reference 
to ``section 161, The Relationship of Generally Accepted Auditing 
Standards to Quality Control Standards'' is replaced with ``AS 1110, 
Relationship of Auditing Standards to Quality Control Standards.''
    h. In paragraph .15, the reference to ``Auditing Standard No. 9'' 
is replaced with ``AS 2101.''
    i. In the first sentence of paragraph .18A, the reference to 
``Paragraphs 8-9 of Auditing Standard No. 11'' is replaced with 
``Paragraphs .08-.09 of AS 2105.''
    j. The first sentence in paragraph .19 is deleted.
    k. In footnote 6 to paragraph .26, the reference to ``Paragraphs 10 
through 23 of Auditing Standard No. 14, Evaluating Audit Results,'' is 
replaced with ``AS 2810.10 through .23.''
    l. In the last sentence of paragraph .39, the reference to 
``Paragraphs 44 through 46 of Auditing Standard No. 13'' is replaced 
with ``Paragraphs .44 through .46 of AS 2301.''
    m. In the note to paragraph .44, the reference to ``Paragraph 47 of 
Auditing Standard No. 13, The Auditor's Responses to the Risks of 
Material Misstatement'' is replaced with ``AS 2301.47.''
AU sec. 390, ``Consideration of Omitted Procedures After the Report 
Date''
    SAS No. 46, ``Consideration of Omitted Procedures After the Report 
Date'' (AU sec. 390, ``Consideration of Omitted Procedures After the 
Report Date''), is amended as follows:
    a. The section number ``AU Section 390'' is replaced with ``AS 
2901.''
    b. In the last sentence of paragraph .01, the reference to 
``section 561'' is replaced with ``AS 2905, Subsequent Discovery of 
Facts Existing at the Date of the Auditor's Report.''
    c. In footnote 2 to paragraph .02, the reference to ``section 161, 
The Relationship of Generally Accepted Auditing Standards to Quality 
Control Standards, paragraph .02'' is replaced with ``paragraph .02 of 
AS 1110, Relationship of Auditing Standards to Quality Control 
Standards.''
    d. In paragraph .06, the reference to ``section 561.05-.09'' is 
replaced with ``AS 2905.05-.09.''
AU sec. 410, ``Adherence to Generally Accepted Accounting Principles''
    SAS No. 1, ``Codification of Auditing Standards and Procedures'' 
(AU sec. 410, ``Adherence to Generally Accepted Accounting 
Principles''), as amended, is rescinded.
AU sec. 9410, ``Adherence to Generally Accepted Accounting Principles: 
Auditing Interpretations of Section 410''
    AU sec. 9410, ``Adherence to Generally Accepted Accounting 
Principles: Auditing Interpretations of Section 410,'' as amended, is 
rescinded.
AU sec. 411, ``The Meaning of Present Fairly in Conformity With 
Generally Accepted Accounting Principles''
    SAS No. 69, ``The Meaning of Present Fairly in Conformity With 
Generally Accepted Accounting Principles'' (AU sec. 411, ``The Meaning 
of Present Fairly in Conformity With Generally Accepted Accounting 
Principles''), as amended, is amended as follows:
    a. The section number ``AU Section 411'' is replaced with ``AS 
2815.''
    b. The title ``The Meaning of Present Fairly in Conformity With 
Generally Accepted Accounting Principles'' is replaced with ``The 
Meaning of `Present Fairly in Conformity with Generally Accepted 
Accounting Principles.' ''
    c. Footnote * to the title of the standard is deleted.
    d. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 5)'' is deleted.
    e. In the second sentence of paragraph .01, the parenthetic 
reference to ``section 508.08h'' is replaced with ``paragraph .08h of 
AS 3101, Reports on Audited Financial Statements.''
    f. In paragraph .04:
     In item (c), the parenthetic reference to ``paragraph 31 
of Auditing Standard No. 14'' is replaced with ``paragraph .31 of AS 
2810.''
     In item (d), the parenthetic reference to ``paragraph 31 
of Auditing Standard No. 14, Evaluating Audit Results'' is replaced 
with ``AS 2810.31.''
     In the last sentence of footnote 1:
     The parenthetic reference to ``sections 150.04'' is 
deleted.
     The parenthetic reference to ``Auditing Standard No. 11'' 
is replaced with ``AS 2105.''
     The parenthetic reference to ``508.36'' is replaced with 
``3101.36.''
    g. In the second sentence of paragraph .08:
     The reference to ``Section 544, Lack of Conformity With 
Generally Accepted Accounting Principles, paragraph .04'' is replaced 
with ``Paragraph .04 of AS 3310, Special Reports on Regulated 
Companies,.''
     The reference to ``section 623, Special Reports'' is 
replaced with ``AS 3305, Special Reports,.''
AU sec. 504, ``Association With Financial Statements''
    SAS No. 26, ``Association With Financial Statements'' (AU sec. 504, 
``Association With Financial Statements''), as amended, is amended as 
follows:
    a. The section number ``AU Section 504'' is replaced with ``AS 
3320.''

[[Page 36624]]

    b. In the title, the ``W'' in the word ``With'' is changed to lower 
case.
    c. In the references before paragraph .01, the phrase ``(Supersedes 
Statement on Auditing Standards No. 1, Sections 516, 517, and 518 and 
Statement on Auditing Standards No. 15, paragraph 13-15)'' is deleted.
    d. In paragraph .01:
     The introductory phrase ``The fourth standard of reporting 
is:'' is deleted.
     In the last sentence, the phrase ``fourth reporting 
standard'' is replaced with ``preceding paragraph.''
    e. In paragraph .02:
     In the first sentence, the phrase ``the fourth reporting 
standard'' is replaced with ``paragraph .01.''
     In the last sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
    f. In paragraph .04:
     In the second sentence, the reference to ``section 508'' 
is replaced with ``AS 3101.''
     In the last sentence, the reference to ``section 722, 
Interim Financial Information'' is replaced with ``AS 4105, Reviews of 
Interim Financial Information.''
    g. In paragraph .05:
     Following the first sentence, the parenthetic phrase ``, 
city and state or country,'' is added following ``(Signature.''
     In the second sentence, the phrase ``the fourth standard 
of reporting'' is replaced with ``paragraph .01.''
    h. In paragraph .07:
     The parenthetic reference to ``section 623.02-.10'' is 
replaced with ``paragraphs .02-.10 of AS 3305.''
     Following the second sentence, the parenthetic phrase ``, 
city and state or country,'' is added following ``(Signature.''
    i. In paragraph .08:
     In the first sentence, the phrase ``The second general 
standard requires that'' is deleted.
     The quotation marks included in the first sentence are 
deleted.
    j. In the first sentence of paragraph .09, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    k. Following the last sentence of paragraph .10, the parenthetic 
phrase ``, city and state or country,'' is added following 
``(Signature.''
    l. In the first sentence of paragraph .15, the parenthetic 
reference to ``section 530.06-.08'' is replaced with ``paragraphs 
.06-.08 of AS 3110, Dating of the Independent Auditor's Report.''
    m. In paragraph .18, the phrase ``applicable standards established 
by the American Institute of Certified Public Accountants'' is replaced 
with ``the standards of the PCAOB.''
    n. In paragraph .19:
     The parenthetic reference to ``section 634'' is replaced 
with ``AS 6101.''
     Footnote * is deleted.
    o. In paragraph [.20], the parenthetic reference to ``section 634'' 
is replaced with ``AS 6101.''
AU sec. 9504, ``Association With Financial Statements: Auditing 
Interpretations of Section 504''
    AU sec. 9504, ``Association With Financial Statements: Auditing 
Interpretations of Section 504,'' as amended, is amended as follows:
    a. The section number ``AU Section 9504'' is replaced with ``AI 
25.''
    b. The title ``Association With Financial Statements: Auditing 
Interpretations of Section 504'' is replaced with ``Association with 
Financial Statements: Auditing Interpretations of AS 3320.''
    c. In paragraph .07, the reference to ``section 722'' is replaced 
with ``AS 4105, Reviews of Interim Financial Information,.''
    d. In paragraph .15:
     In the first sentence, the reference to ``Section 150.02'' 
is replaced with ``Paragraph .04 of AS 3101, Reports on Audited 
Financial Statements,.''
     In the second sentence, the reference to ``Section 
504.03'' is replaced with ``Paragraph .03 of AS 3320, Association with 
Financial Statements,.''
    e. In the first sentence of paragraph .19, the reference to 
``Section 504'' is replaced with ``AS 3320.''
    f. In paragraph .20:
     In the first sentence, the reference to ``Section 504'' is 
replaced with ``AS 3320.''
     The third and fourth sentences are deleted.
    g. Paragraph .21 is replaced with ``PCAOB Rules establish 
requirements regarding auditor independence.''
    h. In the first sentence of paragraph .22, the reference to 
``Section 504.10'' is replaced with ``AS 3320.10.''
AU sec. 508, ``Reports on Audited Financial Statements''
    SAS No. 58, ``Reports on Audited Financial Statements'' (AU sec. 
508, ``Reports on Audited Financial Statements''), as amended, is 
amended as follows:
    a. The section number ``AU Section 508'' is replaced with ``AS 
3101.''
    b. Footnote * to the title of the standard is deleted.
    c. In the references before paragraph .01, the phrase ``(Supersedes 
sections 505, 509, 542, 545, and 546)'' is deleted.
    d. In paragraph .01:
     In footnote 1:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     The second sentence is deleted.
     In the note:
     In the second sentence:
     The reference to ``paragraphs 85-98 of PCAOB Auditing 
Standard No. 5'' is replaced with ``paragraphs .85-.98 of AS 2201.''
     The reference to ``Appendix C, Special Reporting 
Situations, of PCAOB Auditing Standard No. 5, An Audit of Internal 
Control Over Financial Reporting That Is Integrated with An Audit of 
Financial Statements'' is replaced with ``Appendix C, Special Reporting 
Situations, of AS 2201.''
     In the last sentence, the reference to ``paragraphs 86-88 
of PCAOB Auditing Standard No. 5, An Audit of Internal Control Over 
Financial Reporting That Is Integrated with An Audit of Financial 
Statements'' is replaced with ``AS 2201.86-.88.''
    e. In paragraph .02:
     The reference to ``section 504, Association With Financial 
Statements'' is replaced with ``AS 3320, Association with Financial 
Statements.''
     The reference to ``section 623'' is replaced with ``AS 
3305.''
    f. In paragraph .03:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     The second sentence is deleted.
     In the last sentence, the phrase ``fourth reporting 
standard'' is replaced with ``requirements in paragraph .04.''
    g. In paragraph .04, the introductory phrase ``The fourth standard 
of reporting is as follows:'' is deleted.
    h. In paragraph .05:
     In the first sentence, the phrase ``fourth standard'' is 
replaced with ``requirements in paragraph .04.''
     In the second sentence, the phrase ``the fourth reporting 
standard'' is replaced with ``paragraph .04.''
     In the third sentence, the parenthetic phrase ``fourth 
standard of reporting'' is replaced with ``requirements in paragraph 
.04.''
    i. In the last sentence of paragraph .07, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    j. In the last sentence of footnote 3 to paragraph .08a, the phrase 
``section 504, Association With Financial Statements,'' is replaced 
with ``AS 3320.''

[[Page 36625]]

    k. In paragraph .08d:
     The phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     The parenthetic phrase ``auditing standards generally 
accepted in the United States of America or U.S. generally accepted 
auditing standards'' is replaced with ``the standards of the Public 
Company Accounting Oversight Board (United States).''
    l. In the first sentence of footnote 5 to item (3) of paragraph 
.08f, the reference to ``Section 411, The Meaning of Present Fairly in 
Conformity With Generally Accepted Accounting Principles, paragraphs 
.03 and .04,'' is replaced with ``Paragraphs .03 and .04 of AS 2815, 
The Meaning of `Present Fairly in Conformity with Generally Accepted 
Accounting Principles,.' ''
    m. Footnote 6 to paragraph .08h is deleted.
    n. Paragraph ``.08k'' is replaced with ``.08l.''
    o. Paragraph ``.08j'' is replaced with ``.08k.''
    p. Paragraph .08j is added:
    The city and state (or city and country, in the case of non-U.S. 
auditors) from which the auditor's report has been issued.
    q. Footnote 6A is added to the end of the added paragraph .08j:
    See SEC Rule 2-02(a) of Regulation S-X, 17 C.F.R. Sec.  210.2-
02(a).
    r. In the first sentence of footnote 7 to paragraph .08j, the 
reference to ``section 530'' is replaced with ``AS 3110.''
    s. In the first example report following paragraph .08j:
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the second paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     The phrase ``[City and State or Country]'' is added 
following the term ``[Signature].''
    t. In the second example report following paragraph .08j:
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the second paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     The phrase ``[City and State or Country]'' is added 
following the term ``[Signature].''
    u. In the first sentence of footnote 11 to paragraph .11b, the 
reference to ``Section 341, The Auditor's Consideration of an Entity's 
Ability to Continue as a Going Concern'' is replaced with ``AS 2415, 
Consideration of an Entity's Ability to Continue as a Going Concern.''
    v. In the last sentence of paragraph .11f, the parenthetic 
reference to ``section 722, Interim Financial Information, paragraph 
.50'' is replaced with ``paragraph .50 of AS 4105, Reviews of Interim 
Financial Information.''
    w. In the last sentence of paragraph .11g, the parenthetic 
reference to ``section 558, Required Supplementary Information, 
paragraph .02'' is replaced with ``paragraph .02 of AS 2705, Required 
Supplementary Information.''
    x. In the last sentence of paragraph .11h, the parenthetic 
reference to ``section 550, Other Information in Documents Containing 
Audited Financial Statements, paragraph. 04'' is replaced with 
``paragraph .04 of AS 2710, Other Information in Documents Containing 
Audited Financial Statements.''
    y. In the last sentence of paragraph .12, the parenthetic reference 
to ``section 543, Part of Audit Performed by Other Independent 
Auditors'' is replaced with ``AS 1205, Part of the Audit Performed by 
Other Independent Auditors.''
    z. Following paragraph .13:
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the second paragraph in the 
example report, the phrase ``auditing standards generally accepted in 
the United States of America'' is replaced with ``the standards of the 
Public Company Accounting Oversight Board (United States).''
    aa. In the first sentence of paragraph .17A, the reference to 
``PCAOB Auditing Standard No. 6'' is replaced with ``AS 2820.''
    bb. In the first sentence of paragraph .22, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    cc. In the third sentence of footnote 14 to paragraph .24, the 
reference to ``section 331, Inventories'' is replaced with ``AS 2510, 
Auditing Inventories.''
    dd. Following paragraph .26:
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the first paragraph in the 
example report, the phrase ``auditing standards generally accepted in 
the United States of America'' is replaced with ``the standards of the 
Public Company Accounting Oversight Board (United States).''
    ee. In the fourth sentence of paragraph .28, the reference to 
``section 530, Dating of the Independent Auditor's Report,'' is 
replaced with ``AS 3110.''
    ff. Following paragraph .34:
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the second paragraph in the 
example report, the phrase ``auditing standards generally accepted in 
the United States of America'' is replaced with ``the standards of the 
Public Company Accounting Oversight Board (United States).''
    gg. In the first sentence of paragraph .35, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    hh. Following paragraph .39, the heading ``Independent Auditor's 
Report'' above the example report is replaced with ``Report of 
Independent Registered Public Accounting Firm.''
    ii. In the third sentence of paragraph .41, the reference to 
``Statement on Auditing Standards'' is replaced with ``PCAOB 
standard.''
    jj. Following paragraph .42, the heading ``Independent Auditor's 
Report'' above the example report is replaced with ``Report of 
Independent Registered Public Accounting Firm.''
    kk. Following paragraph .44, the heading ``Independent Auditor's 
Report'' above the example report is replaced with ``Report of 
Independent Registered Public Accounting Firm.''
    ll. In the last sentence of paragraph .49, the parenthetic 
reference to ``paragraph 13 of Auditing Standard No. 14'' is replaced 
with ``paragraph .13 of AS 2810.''
    mm. Following paragraph .52, the heading ``Independent Auditor's 
Report'' above the example report is replaced with ``Report of 
Independent Registered Public Accounting Firm.''
    nn. Following paragraph .60, the heading ``Independent Auditor's 
Report'' above the example report is replaced with ``Report of 
Independent Registered Public Accounting Firm.''
    oo. In the first sentence of footnote 20 to paragraph .62, the 
reference to ``Section 504, Association With

[[Page 36626]]

Financial Statements, paragraph .05'' is replaced with ``AS 3320.05.''
    pp. Following paragraph .63:
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the second sentence of footnote 21 to the example 
report, the phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
    qq. In paragraph .65:
     In the first sentence, the phrase ``The fourth standard of 
reporting'' is replaced with ``Paragraph .04.''
     In the second sentence, the phrase ``the fourth reporting 
standard'' is replaced with ``paragraph .04.''
     The parenthetic reference to ``section 530, Dating of the 
Independent Auditor's Report, paragraph .01'' is replaced with ``AS 
3110.01.''
    rr. In the first sentence of footnote 23 to paragraph .65, the 
parenthetic reference to ``section 530, Dating of the Independent 
Auditor's Report, paragraphs .06 through .08'' is replaced with ``AS 
3110.06 through .08.''
    ss. In the second sentence of paragraph .66, the parenthetic 
reference to ``paragraph 31 of Auditing Standard No. 14, Evaluating 
Audit Results'' is replaced with ``AS 2810.31.''
    tt. Following paragraph .67:
     The heading ``Independent Auditor's Report'' above each 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the first paragraph in the 
example report titled, ``Standard Report on the Current-Year Financial 
Statements With a Disclaimer of Opinion on the Prior-Year Statements of 
Income, Retained Earnings, and Cash Flows,'' the phrase ``auditing 
standards generally accepted in the United States of America'' is 
replaced with ``the standards of the Public Company Accounting 
Oversight Board (United States).''
     In the last sentence of footnote 25 to the example report 
titled, ``Standard Report on the Current-Year Financial Statements With 
a Disclaimer of Opinion on the Prior-Year Statements of Income, 
Retained Earnings, and Cash Flows,'' the reference to ``PCAOB Auditing 
Standard No. 6, Evaluating Consistency of Financial Statements,'' is 
replaced with ``AS 2820.''
    uu. Following paragraph .69, the heading ``Independent Auditor's 
Report'' above the example report is replaced with ``Report of 
Independent Registered Public Accounting Firm.''
    vv. In the sixth sentence of paragraph .71, the reference to 
``section 543, Part of Audit Performed by Other Independent Auditors, 
paragraphs .10 through .12'' is replaced with ``AS 1205.10 through 
.12.''
    ww. In the first sentence of footnote 28 to paragraph .71, the 
reference to ``section 333'' is replaced with ``AS 2805.''
    xx. In paragraph .73, the parenthetic reference to ``section 530, 
Dating of the Independent Auditor's Report, paragraph .05'' is replaced 
with ``AS 3110.05.''
    yy. Following paragraph .74, the heading ``Independent Auditor's 
Report'' above the example report is replaced with ``Report of 
Independent Registered Public Accounting Firm.''
AU sec. 9508, ``Reports on Audited Financial Statements: Auditing 
Interpretations of Section 508''
    AU sec. 9508, ``Reports on Audited Financial Statements: Auditing 
Interpretations of Section 508,'' as amended, is amended as follows:
    a. The section number ``AU Section 9508'' is replaced with ``AI 
23.''
    b. The title ``Reports on Audited Financial Statements: Auditing 
Interpretations of Section 508'' is replaced with ``Reports on Audited 
Financial Statements: Auditing Interpretations of AS 3101.''
    c. In the first sentence of paragraph .01, the reference to 
``Section 508, Reports on Audited Financial Statements, paragraph .24'' 
is replaced with ``Paragraph .24 of AS 3101, Reports on Audited 
Financial Statements,.''
    d. In paragraph .02:
     In the first sentence, the reference to ``section 331, 
Inventories, paragraphs .09-.12'' is replaced with ``paragraphs .09-.12 
of AS 2510, Auditing Inventories.''
     In the last sentence, the reference to ``Section 331.09'' 
is replaced with ``AS 2510.09.''
    e. In the first sentence of paragraph .03, the reference to 
``Section 331.10 and .11'' is replaced with ``AS 2510.10 and .11.''
    f. In the first sentence of paragraph .04:
     The reference to ``Section 331.12'' is replaced with ``AS 
2510.12.''
     The reference to ``section 331.09-.11'' is replaced with 
``AS 2510.09-.11.''
    g. In paragraph .36:
     In the first sentence of the second paragraph of the 
Report on Single Year Financial Statements in Year of Adoption of 
Liquidation Basis example report, the phrase ``auditing standards 
generally accepted in the United States of America'' is replaced with 
``the standards of the Public Company Accounting Oversight Board 
(United States).''
     In the first sentence of the second paragraph of the 
Report on Comparative Financial Statements in Year of Adoption of 
Liquidation Basis example report, the phrase ``auditing standards 
generally accepted in the United States of America'' is replaced with 
``the standards of the Public Company Accounting Oversight Board 
(United States).''
    h. In the second sentence of paragraph .52, the reference to 
``section 508, Reports on Audited Financial Statements,'' is replaced 
with ``AS 3101.''
    i. The title of auditing interpretation 14 ``Reporting on Audits 
Conducted in Accordance With Auditing Standards Generally Accepted in 
the United States of America and in Accordance With International 
Standards on Auditing'' is replaced with ``Reporting on Audits 
Conducted in Accordance with the Standards of the PCAOB and in 
Accordance with International Standards on Auditing.''
    j. In paragraph .56:
     In the first sentence:
     The reference to ``Section 508, Reports on Audited 
Financial Statements,'' is replaced with ``AS 3101.''
     The phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     In the last sentence, the phrase ``standards generally 
accepted in the United States of America'' is replaced with ``the 
standards of the PCAOB.''
    k. In paragraph .57:
     In the second sentence:
     The reference to ``Section 508'' is replaced with ``AS 
3101.''
     The phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     The reference to ``section 508'' is replaced with ``AS 
3101.''
     Footnote 1 is deleted.
    l. In paragraph .58:
     The phrase ``auditing standards generally accepted in the 
United States of America'' is replaced with ``the standards of the 
PCAOB.''
     The phrase ``generally accepted in the United States of 
America'' is replaced with ``of the PCAOB.''
    m. In the first sentence of paragraph .59:
     The first occurrence of the phrase ``auditing standards 
generally accepted in the United States'' is replaced with ``the 
standards of the PCAOB.''
     The second occurrence of the phrase ``auditing standards 
generally accepted in the United States of

[[Page 36627]]

America'' (found in the example paragraph) is replaced with ``the 
standards of the Public Company Accounting Oversight Board (United 
States).''
    n. In paragraph .61:
     In the first sentence, the reference to ``section 508, 
Reports on Audited Financial Statements, paragraph .74'' is replaced 
with ``AS 3101.74.''
     In the third sentence, the reference to ``section 508'' is 
replaced with ``AS 3101.''
    o. In paragraph .63:
     In the second sentence, the reference to ``section 
508.74'' is replaced with ``AS 3101.74.''
     In the last sentence, the reference to ``section 561'' is 
replaced with ``AS 2905.''
    p. In footnote 4 to paragraph .67:
     In the second sentence, the reference to ``section 315'' 
is replaced with ``AS 2610.''
     In the last sentence, the reference to ``Section 561'' is 
replaced with ``AS 2905.''
    q. In the first sentence of paragraph .71, the reference to 
``section 508.74'' is replaced with ``AS 3101.74.''
    r. In paragraph .74, the reference to ``section 508.74'' is 
replaced with ``AS 3101.74.''
    s. In the second sentence of paragraph .75, the reference to 
``Section 508.74'' is replaced with ``AS 3101.74.''
    t. Auditing Interpretation 16 is deleted.
    u. Footnotes 6 and 7 to paragraph .84 are deleted.
AU sec. 530, ``Dating of the Independent Auditor's Report''
    SAS No. 1, ``Codification of Auditing Standards and Procedures'' 
section 530, ``Dating of the Independent Auditor's Report'' (AU sec. 
530, ``Dating of the Independent Auditor's Report''), as amended, is 
amended as follows:
    a. The section number ``AU Section 530'' is replaced with ``AS 
3110.''
    b. In paragraph .02:
     In the last sentence, the reference to ``section 
711.10-.13'' is replaced with ``paragraphs .10-.13 of AS 4101, 
Responsibilities Regarding Filings Under Federal Securities Statutes.''
     In footnote 1, the reference to ``section 561'' is 
replaced with ``AS 2905, Subsequent Discovery of Facts Existing at the 
Date of the Auditor's Report,.''
     Footnote * is deleted.
    c. In the first sentence of paragraph .03, the parenthetic 
reference to ``section 560.03'' is replaced with ``paragraph .03 of AS 
2801, Subsequent Events.''
    d. In the first sentence of paragraph .04, the parenthetic 
reference to ``section 560.05'' is replaced with ``AS 2801.05.''
    e. In the last sentence of paragraph .05, the reference to 
``section 560.12'' is replaced with ``AS 2801.12.''
    f. In paragraph .06:
     In the fifth sentence:
     The reference to ``section 711'' is replaced with ``AS 
4101.''
     The reference to ``section 508.70-.73'' is replaced with 
``paragraphs .70-.73 of AS 3101, Reports on Audited Financial 
Statements.''
     Footnote * is deleted.
    g. In the second sentence of paragraph .07, the reference to 
``section 560.08'' is replaced with ``AS 2801.08.''
    h. In the first sentence of paragraph .08, the parenthetic 
reference to ``section 560.05 and 560.08'' is replaced with ``AS 
2801.05 and AS 2801.08.''
AU sec. 532, ``Restricting the Use of an Auditor's Report''
    SAS No. 87, ``Restricting the Use of an Auditor's Report'' (AU sec. 
532, ``Restricting the Use of an Auditor's Report''), as amended, is 
rescinded.
AU sec. 543, ``Part of Audit Performed by Other Independent Auditors''
    SAS No. 1, ``Codification of Auditing Standards and Procedures'' 
section 543, ``Part of Audit Performed by Other Independent Auditors'' 
(AU sec. 543, ``Part of Audit Performed by Other Independent 
Auditors''), as amended, is amended as follows:
    a. The section number ``AU Section 543'' is replaced with ``AS 
1205.''
    b. The title ``Part of Audit Performed by Other Independent 
Auditors'' is replaced with ``Part of the Audit Performed by Other 
Independent Auditors.''
    c. In paragraph .01:
     In footnote 1, the reference to ``Section 315'' is 
replaced with ``AS 2610, Initial Audits--Communications Between 
Predecessor and Successor Auditors,.''
     In the first note:
     The reference to ``paragraphs C8-C11'' is replaced with 
``paragraphs .C8-.C11.''
     The reference to ``PCAOB Auditing Standard No. 5'' is 
replaced with ``AS 2201.''
     In the second note:
     The reference to ``AU sec. 543'' is replaced with ``AS 
1205.''
     The reference to ``Auditing Standard No. 10'' is replaced 
with ``AS 1201.''
    d. Following paragraph .09:
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the second paragraph in the 
example report, the phrase ``auditing standards generally accepted in 
the United States of America'' is replaced with ``the standards of the 
Public Company Accounting Oversight Board (United States).''
    e. In paragraph .10b, the phrase ``American Institute of Certified 
Public Accountants and, if appropriate,'' is replaced with ``PCAOB 
and.''
    f. In item (ii) of paragraph .10c, the phrase ``generally accepted 
auditing standards promulgated by the American Institute of Certified 
Public Accountants'' is replaced with ``standards of the PCAOB.''
    g. In paragraph .12, the reference to ``AU sec. 543.10'' is 
replaced with ``AS 1205.10.''
    h. In paragraph .12a, the reference to ``paragraphs 12 and 13 of 
PCAOB Auditing Standard No. 3'' is replaced with ``paragraphs .12 and 
.13 of AS 1215, Audit Documentation.''
    i. In paragraph .12c, the reference to ``paragraph 8 of PCAOB 
Auditing Standard No. 3'' is replaced with ``AS 1215.08.''
    j. In footnote 5 to paragraph .12:
     The reference to ``AU sec. 324'' is replaced with ``AS 
2601, Consideration of an Entity's Use of a Service Organization.''
     The reference to ``section 543.12'' is replaced with ``AS 
1205.12.''
AU sec. 9543, ``Part of Audit Performed by Other Independent Auditors: 
Auditing Interpretations of Section 543''
    AU sec. 9543, ``Part of Audit Performed by Other Independent 
Auditors: Auditing Interpretations of Section 543,'' as amended, is 
amended as follows:
    a. The section number ``AU Section 9543'' is replaced with ``AI 
10.''
    b. The title ``Part of Audit Performed by Other Independent 
Auditors: Auditing Interpretations of Section 543'' is replaced with 
``Part of the Audit Performed by Other Independent Auditors: Auditing 
Interpretations of AS 1205.''
    c. In the first sentence of paragraph .01, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    d. In the first sentence of footnote 2 to paragraph .01, the 
reference to ``section 543'' is replaced with ``AS 1205, Part of the 
Audit Performed by Other Independent Auditors,.''
    e. In paragraph .02:
     In the first sentence, the reference to ``Section 543, 
Part of Audit Performed by Other Independent Auditors, paragraph .10,'' 
is replaced with ``AS 1205.10.``

[[Page 36628]]

     In the last sentence, the reference to ``Section 
543.10c(iv)'' is replaced with ``AS 1205.10c(iv).''
    f. In paragraph .04:
     In the first sentence, the reference to ``Section 543, 
Part of Audit Performed by Other Independent Auditors,'' is replaced 
with ``AS 1205.''
     In the second sentence, the reference to ``Section 
543.03'' is replaced with ``AS 1205.03.''
    g. In paragraph .05:
     In the first sentence, the phrase ``Section 334, Related 
Parties, states that there may be inquiry of the principal auditor 
regarding related parties.'' is deleted.
     In the second sentence:
     The phrase ``In addition,'' is deleted.
     The ``b'' in ``before'' is capitalized.
    h. In footnote 3 to paragraph .11, the reference to ``section 
9543.04-.07'' is replaced with ``paragraphs .04-.07.''
    i. In paragraph .15, the reference to ``section 9543.11'' is 
replaced with ``paragraph .11.''
    j. In footnote 5 to paragraph .17, the reference to ``section 561'' 
is replaced with ``AS 2905.''
    k. In paragraph .18:
     In the first sentence, the reference to ``section 543'' is 
replaced with ``AS 1205.''
     In the last sentence, the reference to ``section 543.12'' 
is replaced with ``AS 1205.12.''
    l. In the last sentence of paragraph .19, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
AU sec. 544, ``Lack of Conformity With Generally Accepted Accounting 
Principles''
    SAS No. 1, ``Codification of Auditing Standards and Procedures'' 
section 544, ``Lack of Conformity With Generally Accepted Accounting 
Principles'' (AU sec. 544, ``Lack of Conformity With Generally Accepted 
Accounting Principles''), as amended, is amended as follows:
    a. The section number ``AU Section 544'' is replaced with ``AS 
3310.''
    b. The title ``Lack of Conformity With Generally Accepted 
Accounting Principles'' is replaced with ``Special Reports on Regulated 
Companies.''
    c. In paragraph .02:
     In the third sentence, the phrase ``first reporting 
standard'' is replaced with ``requirement in paragraph .08h of AS 3101, 
Reports on Audited Financial Statements,.''
     In footnote 1, the parenthetic reference to ``section 623, 
Special Reports, paragraphs .02 and .10'' is replaced with ``paragraphs 
.02 and .10 of AS 3305, Special Reports.''
    d. In the last sentence of paragraph .04:
     The parenthetic reference to ``section 508, Reports on 
Audited Financial Statements, paragraph .08'' is replaced with ``AS 
3101.08.''
     The parenthetic reference to ``section 508.35-.60'' is 
replaced with ``AS 3101.35-.60.''
AU sec. 550, ``Other Information in Documents Containing Audited 
Financial Statements''
    SAS No. 8, ``Other Information in Documents Containing Audited 
Financial Statements'' (AU sec. 550, ``Other Information in Documents 
Containing Audited Financial Statements''), as amended, is amended as 
follows:
    a. The section number ``AU Section 550'' is replaced with ``AS 
2710.''
    b. In paragraph .03:
     In the second sentence:
     The parenthetic reference to ``sections 634'' is replaced 
with ``AS 6101, Letters for Underwriters and Certain Other Requesting 
Parties.''
     The parenthetic reference to ``711'' is replaced with ``AS 
4101, Responsibilities Regarding Filings Under Federal Securities 
Statutes.''
     Footnote [dagger] is deleted.
     Footnote [dagger][dagger] is deleted.
     In the last sentence:
     The parenthetic reference to ``Auditing Standard No. 17'' 
is replaced with ``AS 2701.''
     The reference to ``AU sec. 623'' is replaced with ``AS 
3305, Special Reports.''
     Footnote ** is deleted.
AU sec. 9550, ``Other Information in Documents Containing Audited 
Financial Statements: Auditing Interpretations of Section 550''
    AU sec. 9550, ``Other Information in Documents Containing Audited 
Financial Statements: Auditing Interpretations of Section 550,'' as 
amended, is amended as follows:
    a. The section number ``AU Section 9550'' is replaced with ``AI 
20.''
    b. The title ``Other Information in Documents Containing Audited 
Financial Statements: Auditing Interpretations of Section 550'' is 
replaced with ``Other Information in Documents Containing Audited 
Financial Statements: Auditing Interpretations of AS 2710.''
    c. In the first sentence of paragraph .07, the reference to 
``section 550, Other Information in Documents Containing Audited 
Financial Statements, paragraph .02'' is replaced with ``paragraph .02 
of AS 2710, Other Information in Documents Containing Audited Financial 
Statements,.''
    d. In paragraph .09, each reference to ``section 550'' is replaced 
with ``AS 2710.''
    e. In paragraph .11:
     In the second sentence, the reference to ``section 550'' 
is replaced with ``AS 2710.''
     In the last sentence, the reference to ``section 550.06'' 
is replaced with ``AS 2710.06.''
    f. In the first sentence of paragraph .12, the reference to 
``section 550, Other Information in Documents Containing Audited 
Financial Statements, paragraph .02'' is replaced with ``AS 2710.02.''
    g. In paragraph .13:
     Each reference to ``section 550'' is replaced with ``AS 
2710.''
     In the last sentence, the reference to ``section 550.06'' 
is replaced with ``AS 2710.06.''
    h. In paragraph .14:
     In the second sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``PCAOB auditing standards.''
     In the last sentence, the reference to ``section 550.06'' 
is replaced with ``AS 2710.06.''
    i. In paragraph .15:
     In the first sentence, the reference to ``The auditing 
interpretation of section 325, Communication of Internal Control 
Related Matters Noted in an Audit, titled `Reporting on the Existence 
of Material Weaknesses' (section 9325.01-.07)'' is replaced with ``AI 
12, Communications About Control Deficiencies in an Audit of Financial 
Statements: Auditing Interpretations of AS 1305, titled `Reporting on 
the Existence of Material Weaknesses' (AI 12.01-.07).''
     In the first sentence of footnote 8, the reference to 
``Section 325.8'' is replaced with ``Paragraph .08 of AS 1305, 
Communications About Control Deficiencies in an Audit of Financial 
Statements,.''
    j. In paragraph .17:
     In the first sentence, the reference to ``section 550, 
Other Information in Documents Containing Audited Financial 
Statements'' is replaced with ``AS 2710.''
     In the last sentence, each reference to ``section 550'' is 
replaced with ``AS 2710.''
    k. In the second sentence of paragraph .18, the reference to 
``section 550'' is replaced with ``AS 2710.''
AU sec. 552, ``Reporting on Condensed Financial Statements and Selected 
Financial Data''
    SAS No. 42, ``Reporting on Condensed Financial Statements and 
Selected Financial Data'' (AU sec. 552,

[[Page 36629]]

``Reporting on Condensed Financial Statements and Selected Financial 
Data''), as amended, is amended as follows:
    a. The section number ``AU Section 552'' is replaced with ``AS 
3315.''
    b. Footnote * to the title of the standard is deleted.
    c. In paragraph .01:
     In footnote 1, the reference to ``section 504, Association 
With Financial Statements, footnote 2'' is replaced with ``footnote 2 
of AS 3320, Association with Financial Statements.''
     In the last sentence, the reference to ``Auditing Standard 
No. 17'' is replaced with ``AS 2701.''
    d. In paragraph .02, the reference to ``section 508, Reports on 
Audited Financial Statements, paragraphs .41 through .44, section 623, 
Special Reports, or other applicable Statements on Auditing Standards'' 
is replaced with ``paragraphs .41 through .44 of AS 3101, Reports on 
Audited Financial Statements, AS 3305, Special Reports, or other 
applicable PCAOB auditing standards.''
    e. In footnote 4 to paragraph .05, the parenthetic reference to 
``section 711, Filings Under Federal Securities Statutes'' is replaced 
with ``AS 4101, Responsibilities Regarding Filings Under Federal 
Securities Statutes.''
    f. Following paragraph .06:
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the first paragraph in the 
example report, the phrase ``auditing standards generally accepted in 
the United States of America'' is replaced with ``the standards of the 
Public Company Accounting Oversight Board (United States).''
    g. In footnote 6 to paragraph .07:
     In the second sentence, the parenthetic reference to 
``section 508, Reports on Audited Financial Statements, paragraphs .41 
through .44'' is replaced with ``AS 3101.41 through .44.''
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the fourth sentence of the example report, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
    h. In paragraph .08:
     In item c of footnote 8, the parenthetic reference to 
``section 722, Interim Financial Information, paragraph .03'' is 
replaced with ``paragraph .03 of AS 4105, Reviews of Interim Financial 
Information.''
     In the example independent auditor's review report 
following paragraph .08:
     In the first sentence of the second paragraph, the phrase 
``standards established by the American Institute of Certified Public 
Accountants'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     In the third sentence of the second paragraph, the phrase 
``generally accepted auditing standards'' is replaced with ``the 
standards of the Public Company Accounting Oversight Board.''
     In the first sentence of the fourth paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board.''
    i. In footnote 11 to paragraph .09, the reference to ``section 623, 
Special Reports,'' is replaced with ``AS 3305.''
    j. Following paragraph .10:
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the example report:
     In the first sentence of the second paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     In the first sentence of the fourth paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board.''
AU sec. 558, ``Required Supplementary Information''
    SAS No. 52, ``Omnibus Statement on Auditing Standards--1987, 
Required Supplementary Information'' (AU sec. 558, ``Required 
Supplementary Information''), as amended, is amended as follows:
    a. The section number ``AU Section 558'' is replaced with ``AS 
2705.''
    b. In the references before paragraph .01, the phrase ``(Supersedes 
section 553)'' is deleted.
    c. Footnote * is deleted.
    d. Footnote 1 to paragraph .01 is deleted.
    e. In paragraph .02:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     In the second sentence of footnote 2, the reference to 
``section 550'' is replaced with ``AS 2710.''
    f. In the last sentence of paragraph .03, the reference to 
``section 550,'' is replaced with ``AS 2710.''
    g. In paragraph .04:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
     In the second sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``PCAOB auditing standards.''
    h. In paragraph .05:
     In the first sentence, the reference to ``section 550'' is 
replaced with ``AS 2710.''
     In the second sentence, the reference to ``Auditing 
Standard No. 17'' is replaced with ``AS 2701.''
    i. In the last sentence of footnote 6 to paragraph .07b, the 
reference to ``section 552, Reporting on Condensed Financial Statements 
and Selected Financial Data, paragraph .10'' is replaced with 
``paragraph .10 of AS 3315, Reporting on Condensed Financial Statements 
and Selected Financial Data.''
    j. In paragraph .07c, the parenthetic reference to ``section 333'' 
is replaced with ``AS 2805.''
    k. In paragraph .07d, the phrase ``, interpretations, guides, or 
statements of position'' is replaced with ``or interpretations.''
    l. In footnote 7 to paragraph .08, the reference to ``Auditing 
Standard No. 17, Auditing Supplemental Information Accompanying Audited 
Financial Statements,'' is replaced with ``AS 2701.''
    m. In the second sentence of paragraph .09, the reference to 
``section 550.07'' is replaced with ``AS 2701.''
AU sec. 9558, ``Required Supplementary Information: Auditing 
Interpretations of Section 558''
    AU sec. 9558, ``Required Supplementary Information: Auditing 
Interpretations of Section 558,'' is amended as follows:
    a. The section number ``AU Section 9558'' is replaced with ``AI 
19.''
    b. The title ``Required Supplementary Information: Auditing 
Interpretations of Section 558'' is replaced with ``Required 
Supplementary Information: Auditing Interpretations of AS 2705.''
    c. In the last sentence of paragraph .01, the reference to 
``section 558'' is replaced with ``AS 2705.''
    d. In the second sentence of paragraph .02, the reference to 
``section 558'' is replaced with ``AS 2705.''

[[Page 36630]]

    e. In the first sentence of paragraph .04, the reference to 
``section 558'' is replaced with ``AS 2705.''
    f. In the first sentence of paragraph .06, the reference to 
``section 558'' is replaced with ``AS 2705.''
AU sec. 560, ``Subsequent Events''
    SAS No. 1, ``Codification of Auditing Standards and Procedures,'' 
section 560, ``Subsequent Events'' (AU sec. 560, ``Subsequent 
Events''), as amended, is amended as follows:
    a. The section number ``AU Section 560'' is replaced with ``AS 
2801.''
    b. In the note to paragraph .01, the reference to ``paragraphs 93-
97 of PCAOB Auditing Standard No. 5'' is replaced with ``paragraphs 
.93-.97 of AS 2201.''
    c. In paragraph .09, the parenthetic reference to ``section 
508.19'' is replaced with ``paragraph .19 of AS 3101, Reports on 
Audited Financial Statements.''
    d. In paragraph .12d, the parenthetic reference to ``section 337'' 
is replaced with ``AS 2505, Inquiry of a Client's Lawyer Concerning 
Litigation, Claims, and Assessments.''
    e. In paragraph .12e, the parenthetic reference to ``section 333'' 
is replaced with ``AS 2805.''
AU sec. 561, ``Subsequent Discovery of Facts Existing at the Date of 
the Auditor's Report''
    SAS No. 1, ``Codification of Auditing Standards and Procedures,'' 
section 561, ``Subsequent Discovery of Facts Existing at the Date of 
the Auditor's Report'' (AU sec. 561, ``Subsequent Discovery of Facts 
Existing at the Date of the Auditor's Report''), as amended, is amended 
as follows:
    a. The section number ``AU Section 561'' is replaced with ``AS 
2905.''
    b. In paragraph .01:
     In the first sentence of footnote 1, the reference to 
``section 560'' is replaced with ``AS 2801.''
     In the note, the reference to ``paragraph 98 of PCAOB 
Auditing Standard No. 5'' is replaced with ``paragraph .98 of AS 
2201.''
    c. In the first sentence of footnote 2 to paragraph .03, the 
reference to ``section 711.10-.13'' is replaced with ``paragraphs 
.10-.13 of AS 4101, Responsibilities Regarding Filings Under Federal 
Securities Statutes,.''
AU sec. 9561, ``Subsequent Discovery of Facts Existing at the Date of 
the Auditor's Report: Auditing Interpretations of Section 561''
    AU sec. 9561, ``Subsequent Discovery of Facts Existing at the Date 
of the Auditor's Report: Auditing Interpretations of Section 561,'' is 
amended as follows:
    a. The section number ``AU Section 9561'' is replaced with ``AI 
22.''
    b. The title ``Subsequent Discovery of Facts Existing at the Date 
of the Auditor's Report: Auditing Interpretations of Section 561'' is 
replaced with ``Subsequent Discovery of Facts Existing at the Date of 
the Auditor's Report: Auditing Interpretations of AS 2905.''
    c. In the second sentence of paragraph .02, the reference to 
``Section 561'' is replaced with ``AS 2905.''
AU sec. 623, ``Special Reports''
    SAS No. 62, ``Special Reports'' (AU sec. 623, ``Special Reports''), 
as amended, is amended as follows:
    a. The section number ``AU Section 623'' is replaced with ``AS 
3305.''
    b. In the references before paragraph .01, the phrase ``(Supersedes 
section 621)'' is deleted.
    c. In the first sentence of paragraph .02, the phrase ``Generally 
accepted auditing standards'' is replaced with ``The standards of the 
PCAOB.''
    d. In paragraph .03:
     In the first sentence, the parenthetic reference to 
``section 411, The Meaning of Present Fairly in Conformity With 
Generally Accepted Accounting Principles'' is replaced with ``AS 2815, 
The Meaning of 'Present Fairly in Conformity with Generally Accepted 
Accounting Principles.' ''
     In the second sentence, the parenthetic reference to 
``section 411.05'' is replaced with ``AS 2815.05.''
    e. In the last sentence of footnote 1 to paragraph .05a, the 
reference to ``section 504, Association With Financial Statements'' is 
replaced with ``AS 3320, Association with Financial Statements.''
    f. In item (1) of paragraph .05c:
     The phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     The parenthetic phrase ``auditing standards generally 
accepted in the United States of America or U.S. generally accepted 
auditing standards'' is replaced with ``the standards of the Public 
Company Accounting Oversight Board (United States).''
    g. In footnote 5 to paragraph .05f, the reference to ``section 544, 
Lack of Conformity With Generally Accepted Accounting Principles'' is 
replaced with ``AS 3310, Special Reports on Regulated Companies.''
    h. Paragraph ``.05h'' is replaced with ``.05i.''
    i. Paragraph .05h is added:
    The city and state (or city and country, in the case of non-U.S. 
auditors) from which the auditor's report has been issued.
    j. Footnote 5A is added to the end of the added paragraph .05h:
    See SEC Rule 2-02(a) of Regulation S-X, 17 C.F.R. Sec.  210.2-
02(a).
    k. In footnote 6 to paragraph .05h, the reference to ``section 
530'' is replaced with ``AS 3110.''
    l. In paragraph .06, the parenthetic reference to ``section 508, 
Reports on Audited Financial Statements, paragraph .08'' is replaced 
with ``paragraph .08 of AS 3101, Reports on Audited Financial 
Statements.''
    m. Following paragraph .08:
     The heading ``Independent Auditor's Report'' above each 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the second paragraph of each 
example report, the phrase ``auditing standards generally accepted in 
the United States of America'' is replaced with ``the standards of the 
Public Company Accounting Oversight Board (United States).''
    n. In the third sentence of paragraph .09, the reference to 
``section 411, The Meaning of Present Fairly in Conformity With 
Generally Accepted Accounting Principles, paragraph .04'' is replaced 
with ``AS 2815.04.''
    o. In the last sentence of paragraph .11, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    p. In paragraph .12:
     In the second sentence:
     The phrase ``first standard of reporting'' is replaced 
with ``requirement in AS 3101.08h.''
     The phrase ``ten generally accepted auditing standards'' 
is replaced with ``standards of the PCAOB.''
     In the last sentence, the phrase ``The first standard of 
reporting'' is replaced with ``AS 3101.08h.''
    q. In paragraph .14, the parenthetic reference to ``section 508, 
Reports on Audited Financial Statements, paragraph .64'' is replaced 
with ``AS 3101.64.''
    r. In item (1) of paragraph .15c:
     The phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     The parenthetic phrase ``auditing standards generally 
accepted in the United States of America or U.S. generally accepted 
auditing standards'' is replaced with ``the standards of the Public 
Company Accounting Oversight Board (United States).''
    s. In footnote 12 to paragraph .15e, the reference to ``Paragraph 
31'' is replaced with ``Paragraph .31.''
    t. Paragraph ``.15h'' is replaced with ``.15i.''
    u. Paragraph .15h is added:
    The city and state (or city and country, in the case of non-U.S.

[[Page 36631]]

auditors) from which the auditor's report has been issued.
    v. Footnote 13A is added to the end of the added paragraph .15h:
    See footnote 5A.
    w. In paragraph .17, the reference to ``section 508, Reports on 
Audited Financial Statements, paragraph .11'' is replaced with ``AS 
3101.11.''
    x. Following paragraph .18:
     The heading ``Independent Auditor's Report'' above each 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the second paragraph in the 
example report titled, ``Report Relating to Accounts Receivable,'' the 
phrase ``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     In the first sentence of the second paragraph in the 
example report titled, ``Report Relating to Amount of Sales for the 
Purpose of Computing Rental,'' the phrase ``auditing standards 
generally accepted in the United States of America'' is replaced with 
``the standards of the Public Company Accounting Oversight Board 
(United States).''
     In the first sentence of the second paragraph in the 
example report titled, ``Report Relating to Royalties,'' the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     In the example report titled, ``Report on Profit 
Participation'':
     In the first sentence of the first paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     In the first sentence of the second paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board.''
     In the example report titled, ``Report on Federal and 
State Income Taxes Included in Financial Statements'':
     In the first sentence of the first paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     In the first sentence of the second paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board.''
    y. In footnote 18 to paragraph .19, the reference to ``section 801, 
Compliance Auditing Applicable to Governmental Entities and Other 
Specified Recipients of Governmental Financial Assistance'' is replaced 
with ``AS 6110, Compliance Auditing Considerations in Audits of 
Recipients of Governmental Financial Assistance.''
    z. In the first sentence of paragraph .20b:
     The phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     The parenthetic phrase ``auditing standards generally 
accepted in the United States of America or U.S. generally accepted 
auditing standards'' is replaced with ``the standards of the Public 
Company Accounting Oversight Board (United States).''
    aa. Paragraph ``.20g'' is replaced with ``.20h.''
    bb. Paragraph .20g is added:
    The city and state (or city and country, in the case of non-U.S. 
auditors) from which the auditor's report has been issued.
    cc. Footnote 20A is added to the end of the added paragraph .20g:
    See footnote 5A.
    dd. Following paragraph .21:
     The heading ``Independent Auditor's Report'' above each 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the example report titled, 
``Report on Compliance With Contractual Provisions Given in a Separate 
Report,'' the phrase ``auditing standards generally accepted in the 
United States of America'' is replaced with ``the standards of the 
Public Company Accounting Oversight Board (United States).''
     In the first sentence of the example report titled, 
``Report on Compliance With Regulatory Requirements Given in a Separate 
Report When the Auditor's Report on the Financial Statements Included 
an Explanatory Paragraph Because of an Uncertainty,'' the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
    ee. In the fourth sentence of paragraph .24, the parenthetic 
reference is deleted.
    ff. In item (1) of paragraph .25c:
     The phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     The parenthetic phrase ``auditing standards generally 
accepted in the United States of America or U.S. generally accepted 
auditing standards'' is replaced with ``the standards of the Public 
Company Accounting Oversight Board (United States).''
    gg. Paragraph ``.25h'' is replaced with ``.25i.''
    hh. Paragraph .25h is added:
    The city and state (or city and country, in the case of non-U.S. 
auditors) from which the auditor's report has been issued.
    ii. Footnote 28A is added to the end of the added paragraph .25h:
    See footnote 5A.
    jj. Following paragraph .26:
     The heading ``Independent Auditor's Report'' above each 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the second paragraph of the 
example report titled, ``Report on a Schedule of Gross Income and 
Certain Expenses to Meet a Regulatory Requirement and to Be Included in 
a Document Distributed to the General Public,'' the phrase ``auditing 
standards generally accepted in the United States of America'' is 
replaced with ``the standards of the Public Company Accounting 
Oversight Board (United States).''
     In the first sentence of the second paragraph of the 
example report titled, ``Report on a Statement of Assets Sold and 
Liabilities Transferred to Comply With a Contractual Agreement,'' the 
phrase ``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
    kk. In item (1) of paragraph .29c:
     The phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     The parenthetic phrase ``auditing standards generally 
accepted in the United States of America or U.S. generally accepted 
auditing standards'' is replaced with ``the standards of the Public 
Company Accounting Oversight Board (United States).''
    ll. Paragraph ``.29i'' is replaced with ``.29j.''
    mm. Paragraph .29i is added:
    The city and state (or city and country, in the case of non-U.S. 
auditors) from which the auditor's report has been issued.
    nn. Footnote 33A is added to the end of the added paragraph .29i:
    See footnote 5A.
    oo. Following paragraph .30:
     The heading ``Independent Auditor's Report'' above the 
example

[[Page 36632]]

report is replaced with ``Report of Independent Registered Public 
Accounting Firm.''
     In the first sentence of the second paragraph of the 
example report, the phrase ``auditing standards generally accepted in 
the United States of America'' is replaced with ``the standards of the 
Public Company Accounting Oversight Board (United States).''
    pp. In the last sentence of paragraph .31a, the reference to 
``section 508, Reports on Audited Financial Statements, paragraphs .16 
through .18'' is replaced with ``AS 3101.16 through .18.''
    qq. In footnote 39 to paragraph .31b, the reference to ``section 
341, The Auditor's Consideration of an Entity's Ability to Continue as 
a Going Concern'' is replaced with ``AS 2415, Consideration of an 
Entity's Ability to Continue as a Going Concern.''
    rr. In the last sentence of paragraph .31c, the reference to 
``section 508, Reports on Audited Financial Statements, paragraphs .12 
and .13'' is replaced with ``AS 3101.12 and .13.''
    ss. In the last sentence of paragraph .31d, the reference to 
``section 508, Reports on Audited Financial Statements, paragraphs .68 
and .69'' is replaced with ``AS 3101.68 and .69.''
AU sec. 9623, ``Special Reports: Auditing Interpretations of Section 
623''
    AU sec. 9623, ``Special Reports: Auditing Interpretations of 
Section 623,'' as amended, is amended as follows:
    a. The section number ``AU Section 9623'' is replaced with ``AI 
24.''
    b. The title ``Special Reports: Auditing Interpretations of Section 
623'' is replaced with ``Special Reports: Auditing Interpretations of 
AS 3305.''
    c. Footnote * to paragraphs [.01-.08], is deleted.
    d. In paragraph .41, the phrase ``generally accepted auditing 
standards'' is replaced with ``the standards of the PCAOB.''
    e. In paragraph .42:
     In the first sentence, the reference to ``Section 623.11 
through .18 provides'' is replaced with ``Paragraphs .11 through .18 of 
AS 3305, Special Reports, provide.''
     In the Illustrative report:
     The first paragraph is deleted.
     The phrase ``City and State or Country'' is added below 
the term ``Signature.''
    f. Paragraphs .43 through .46 are deleted.
    g. The last sentence of paragraph .47 is deleted.
    h. In paragraph .50, the parenthetic reference to ``section 623, 
Special Reports, paragraph .08'' is replaced with ``AS 3305.08.''
    i. In paragraph .51, each reference to ``Section 623'' or ``section 
623'' is replaced with ``AS 3305.''
    j. Following paragraph .52:
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the example report:
     In the first sentence of the second paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     The phrase ``[City and State or Country]'' is added below 
the term ``[Signature].''
    k. In the first sentence of paragraph .53, the parenthetic 
reference to ``section 623.08'' is replaced with ``AS 3305.08.''
    l. In the last sentence of footnote 10 to paragraph .55:
     The reference to ``section 508'' is replaced with ``AS 
3101.''
     The phrase ``, and the applicable industry audit guide'' 
is deleted.
    m. In the first sentence of paragraph .57, the reference to 
``section 623, Special Reports, paragraph .29'' is replaced with ``AS 
3305.29.''
    n. Following paragraph .58:
     The heading ``Independent Auditor's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the example report in paragraph .58:
     In the first sentence of the second paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     The phrase ``[City and State or Country]'' is added below 
the term ``[Signature].''
    o. In paragraph .61:
     In the first sentence, the reference to ``section 623, 
Special Reports, paragraph .04)'' is replaced with ``AS 3305.04.''
     In the second sentence, the reference to ``Section 
623.09'' is replaced with ``AS 3305.09.''
     In the last sentence, the reference to ``section 411, The 
Meaning of Present Fairly in Conformity With Generally Accepted 
Accounting Principles, paragraph .04'' is replaced with ``paragraph .04 
of AS 2815, The Meaning of `Present Fairly in Conformity with Generally 
Accepted Accounting Principles.' ''
    p. In paragraph .62:
     In the first sentence:
     The reference to ``Section 623.02'' is replaced with ``AS 
3305.02.''
     The phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     In the last sentence:
     The phrase ``Thus, in accordance with the third standard 
of reporting,'' is deleted.
     The quotation marks are deleted.
     The first ``i'' in ``informative'' is capitalized.
    q. In paragraph .64:
     In the first sentence the reference to ``Section 623.09 
and .10'' is replaced with ``AS 3305.09 and .10.''
     In the last sentence, the reference to ``Section 623.10'' 
is replaced with ``AS 3305.10.''
    r. In the third sentence of paragraph .82, the reference to 
``Section 623, Special Reports, paragraph .22'' is replaced with ``AS 
3305.22.''
    s. In the last sentence of paragraph .83, the reference to 
``section 508, Reports on Audited Financial Statements, paragraphs 
.35-.44 and .58-.60'' is replaced with ``AS 3101.35-.44 and .58-.60.''
    t. In the last sentence of paragraph .85, the reference to 
``section 623.22-.26'' is replaced with ``AS 3305.22-.26.''
    u. In paragraph .86, the reference to ``section 508.35-.44 and 
.58-.60'' is replaced with ``AS 3101.35-.44 and .58-.60.''
    v. In paragraph .90:
     In the first sentence, the reference to ``Section 623, 
Special Reports, paragraph .10'' is replaced with ``AS 3305.10.''
     Each reference to ``section 623.10'' is replaced with ``AS 
3305.10.''
AU sec. 625, ``Reports on the Application of Accounting Principles''
    SAS No. 50, ``Reports on the Application of Accounting Principles'' 
(AU sec. 625, ``Reports on the Application of Accounting Principles''), 
as amended, is amended as follows:
    a. The section number ``AU Section 625'' is replaced with ``AS 
6105.''
    b. In the last sentence of footnote 1 to paragraph .01, the 
reference to ``section 623, Special Reports, paragraph .04'' is 
replaced with ``paragraph .04 of AS 3305, Special Reports,.''
    c. Footnote 3 to paragraph .02 is deleted.
    d. In paragraph .08, the parenthetic reference to ``section 411, 
The Meaning of Present Fairly in Conformity With Generally Accepted 
Accounting Principles'' is replaced with ``AS 2815, The Meaning of 
`Present Fairly in Conformity with Generally Accepted Accounting 
Principles.' ''

[[Page 36633]]

    e. In the last sentence of paragraph .09, the reference to 
``section 315, Communications Between Predecessor and Successor 
Auditors, paragraph .10'' is replaced with ``paragraph .10 of AS 2610, 
Initial Audits--Communications Between Predecessor and Successor 
Auditors.''
    f. In paragraph .10a, the phrase ``applicable AICPA standards'' is 
replaced with ``the standards of the PCAOB.''
    g. The first sentence of footnote 7 to paragraph .10f is deleted.
    h. In the last sentence of the paragraph following the subheading 
``Introduction'' following paragraph .11, the phrase ``standards 
established by the American Institute of Certified Public Accountants'' 
is replaced with ``the standards of the Public Company Accounting 
Oversight Board (United States).''
AU sec. 634, ``Letters for Underwriters and Certain Other Requesting 
Parties''
    SAS No. 72, ``Letters for Underwriters and Certain Other Requesting 
Parties'' (AU sec. 634, ``Letters for Underwriters and Certain Other 
Requesting Parties''), as amended, is amended as follows:
    a. The section number ``AU Section 634'' is replaced with ``AS 
6101.''
    b. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 49)'' is deleted.
    c. In footnote 3 to paragraph .03, the parenthetic reference to 
``section 9634.01-.09'' is replaced with ``paragraphs .01-.09 of AI 27, 
Letters for Underwriters and Certain Other Requesting Parties: Auditing 
Interpretations of AS 6101.''
    d. In paragraph .09b:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the Public 
Company Accounting Oversight Board (United States).''
     In the last sentence, the phrase ``standards established 
by the American Institute of Certified Public Accountants'' is replaced 
with ``the standards of the Public Company Accounting Oversight 
Board.''
    e. In paragraph .12:
     Each phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     In footnote 8, the parenthetic reference to ``section 
9711.12-.15'' is replaced with ``paragraphs .12-.15 of AI 26, 
Responsibilities Regarding Filings Under Federal Securities Statutes: 
Auditing Interpretations of AS 4101.''
     In the first sentence of footnote 9, the reference to 
``section 711, Filings Under Federal Securities Statutes'' is replaced 
with ``AS 4101, Responsibilities Regarding Filings Under Federal 
Securities Statutes,.''
    f. In the first sentence of footnote 13 to paragraph .16, the 
reference to ``SAS No. 71 [section 722]'' is replaced with ``AS 4105, 
Reviews of Interim Financial Information.''
    g. In the first sentence of footnote 18 to paragraph .27:
     The parenthetic reference to ``section 722.50'' is 
replaced with ``AS 4105.50.''
     The reference to ``section 558, Required Supplementary 
Information, paragraphs .08 through .11'' is replaced with ``paragraphs 
.08 through .11 of AS 2705, Required Supplementary Information.''
    h. In footnote 20 to paragraph .28, the reference to ``section 530, 
Dating of the Independent Auditor's Report, paragraphs .03 through 
.08'' is replaced with ``AS 3110.03 through .08.''
    i. In paragraphs .29a and b, each parenthetic reference to 
``section 552'' is replaced with ``AS 3315.''
    j. In paragraph .29c, the parenthetic reference to ``section 722'' 
is replaced with ``AS 4105.''
    k. In the fifth sentence of paragraph .29, the reference to 
``section 325'' is replaced with ``AS 1305.''
    l. In paragraph .30:
     In the first sentence:
     The reference to ``section 722'' is replaced with ``AS 
4105.''
     The reference to ``section 558, Required Supplementary 
Information,'' is replaced with ``AS 2705.''
     In the second sentence:
     The reference to ``Section 722'' is replaced with ``AS 
4105.''
     The reference to ``section 558'' is replaced with ``AS 
2705.''
     In the last sentence, the reference to ``sections 722 and 
558'' is replaced with ``AS 4105 and AS 2705.''
    m. In paragraph .31, the sixth and seventh sentences are deleted.
    n. In paragraphs .35a and b, each reference to ``SAS No. 71 
[section 722]'' is replaced with ``AS 4105.''
    o. In paragraph .37:
     Each reference to ``section 722'' is replaced with ``AS 
4105.''
     In the second sentence of footnote 28, the reference to 
``section 722'' is replaced with ``AS 4105.''
    p. In the first sentence of paragraph .38, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    q. In paragraphs .39a and b, each reference to ``SAS No. 71 
[section 722]'' is replaced with ``AS 4105.''
    r. In the third sentence of paragraph .42, the reference to ``SAS 
No. 71 [section 722]'' is replaced with ``AS 4105.''
    s. In the second bullet of paragraph .46, the reference to ``SAS 
No. 71 [section 722]'' is replaced with ``AS 4105.''
    t. In paragraph .59:
     In the fourth sentence, the parenthetic reference to 
``(see section 435, Segment Information)'' is deleted.
     In footnote 34, the reference to ``section 558'' is 
replaced with ``AS 2705.''
    u. In paragraph .64:
     Following subtitle ``Example A: Typical Comfort Letter'':
     In the third sentence of the second paragraph following 
item 2d, the reference to ``section 722'' is replaced with ``AS 4105, 
Reviews of Interim Financial Information,.''
     In item 4a(i) of the letter in Example A:
     The phrase ``American Institute of Certified Public 
Accountants'' is replaced with ``Public Company Accounting Oversight 
Board (United States).''
     The reference to ``SAS No. 71, Interim Financial 
Information'' is replaced with ``AS 4105, Reviews of Interim Financial 
Information.''
     In the first sentence following item 4b(ii) of the letter 
in Example A, the phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the Public Company Accounting 
Oversight Board.''
     In footnote 6 to item 5a(i) of the letter in Example A, 
the reference to ``Section 722'' is replaced with ``AS 4105.''
     Following the subtitle ``Example B: Letter When a Short-
Form Registration Statement Is Filed Incorporating Previously Filed 
Forms 10-K and 10-Q by Reference'':
     In item 4a(i) of the letter in Example B:
     The phrase ``American Institute of Certified Public 
Accountants'' is replaced with ``Public Company Accounting Oversight 
Board (United States).''
     The reference to ``SAS No. 71, Interim Financial 
Information'' is replaced with ``AS 4105, Reviews of Interim Financial 
Information.''
     In the first sentence following item 4b(ii) of the letter 
in Example B, the phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the Public Company Accounting 
Oversight Board.''
     In the third sentence of item 5, (following the subtitle 
``Example D: Comments on Pro Forma Financial Information''), the 
reference to ``SAS No. 71 [section 722]'' is replaced with ``AS 4105.''

[[Page 36634]]

     In item 8 (following the subtitle ``Example E: Comments on 
a Financial Forecast''):
     In the first sentence, the reference to ``AICPA'' is 
replaced with ``AT section 301, Financial Forecasts and Projections,.''
     Each phrase ``standards established by the American 
Institute of Certified Public Accountants'' is replaced with ``the 
standards of the Public Company Accounting Oversight Board.''
     In the first sentence of footnote 10 to item 7 (following 
the subtitle ``Example F: Comments on Tables, Statistics, and Other 
Financial Information--Complete Description of Procedures and 
Findings''), the reference to ``section 552'' is replaced with ``AS 
3315.''
     Following the subtitle ``Example L: Alternate Wording When 
Recent Earnings Data Are Presented in Capsule Form'':
     In the first sentence of item 13, the reference to 
``section 722'' is replaced with ``AS 4105.''
     In item 4a(i) of the letter in Example L:
     The phrase ``American Institute of Certified Public 
Accountants'' is replaced with ``Public Company Accounting Oversight 
Board (United States).''
     The reference to ``SAS No. 71, Interim Financial 
Information'' is replaced with ``AS 4105, Reviews of Interim Financial 
Information.''
     In item 4b(ii) of the letter in Example L:
     The phrase ``American Institute of Certified Public 
Accountants'' is replaced with ``Public Company Accounting Oversight 
Board.''
     The reference to ``SAS No. 71, Interim Financial 
Information,'' is replaced with ``AS 4105.''
     In the first sentence following item 4b(iii) of the letter 
in Example L, the phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the Public Company Accounting 
Oversight Board.''
     The subtitle ``Example O: Alternate Wording When the 
Procedures That the Underwriter Has Requested the Accountant to Perform 
on Interim Financial Information Are Less Than an SAS No. 71 Review'' 
is replaced with ``Example O: Alternate Wording When the Procedures 
That the Underwriter Has Requested the Accountant to Perform on Interim 
Financial Information Are Less Than an AS 4105 Review.''
     Following the subtitle ``Example O: Alternate Wording When 
the Procedures That the Underwriter Has Requested the Accountant to 
Perform on Interim Financial Information Are Less Than an SAS No. 71 
Review'':
     In the third sentence of item 16, the reference to ``SAS 
No. 71 [section 722]'' is replaced with ``AS 4105.''
     In the first sentence following item 4c of the letter in 
Example O, the phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the Public Company Accounting 
Oversight Board (United States).''
     In the second paragraph to item 6 of the letter in Example 
O:
     In the first sentence:
     The phrase ``standards established by the American 
Institute of Certified Public Accountants'' is replaced with ``the 
standards of the Public Company Accounting Oversight Board.''
     The reference to ``AICPA'' is replaced with ``AT section 
301, Financial Forecasts and Projections,.''
     In the last sentence, the phrase ``standards established 
by the AICPA'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board.''
     Following the subtitle ``Example P: A Typical Comfort 
Letter in a Non-1933 Act Offering, Including the Required Underwriter 
Representations'':
     In the third sentence of item 17, the reference to ``SAS 
No. 71 [section 722]'' is replaced with ``AS 4105.''
     In the first sentence of item 6 of the letter in Example 
P, the phrase ``generally accepted auditing standards'' is replaced 
with ``the standards of the Public Company Accounting Oversight Board 
(United States).''
     In the letter following the subtitle ``Example Q: Letter 
to a Requesting Party That Has Not Provided the Representation Letter 
Described in Paragraphs .06 and .07'':
     In the second paragraph, the phrase ``rule 101 of the 
AICPA's Code of Professional Conduct, and its interpretations and 
rulings'' is replaced with ``Public Company Accounting Oversight Board 
Rule 3520, Auditor Independence.''
     In Item 6:
     In the first sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the Public 
Company Accounting Oversight Board (United States).''
     In the last sentence, the phrase ``standards established 
by the American Institute of Certified Public Accountants'' is replaced 
with ``the standards of the Public Company Accounting Oversight 
Board.''
     Following the subtitle ``Example R: Comfort Letter That 
Includes Reference to Examination of Annual MD&A and Review of Interim 
MD&A'':
     In the fifth sentence of item 19, the reference to 
``section 722'' is replaced with ``AS 4105.''
     In the first sentence following item 5b(ii) of the letter 
in Example R, the phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the Public Company Accounting 
Oversight Board (United States).''
AU sec. 9634, ``Letters for Underwriters and Certain Other Requesting 
Parties: Auditing Interpretations of Section 634''
    AU sec. 9634, ``Letters for Underwriters and Certain Other 
Requesting Parties: Auditing Interpretations of Section 634,'' as 
amended, is amended as follows:
    a. The section number ``AU Section 9634'' is replaced with ``AI 
27.''
    b. The title ``Letters for Underwriters and Certain Other 
Requesting Parties: Auditing Interpretations of Section 634'' is 
replaced with ``Letters for Underwriters and Certain Other Requesting 
Parties: Auditing Interpretations of AS 6101.''
    c. In paragraph .03, the parenthetic reference to ``section 
634.33'' is replaced with ``paragraph .33 of AS 6101, Letters for 
Underwriters and Certain Other Requesting Parties.''
    d. In the first sentence of paragraph .04:
     The phrase ``generally accepted auditing standards'' is 
replaced with ``the standards of the PCAOB.''
     The parenthetic reference to ``section 550'' is replaced 
with ``AS 2710, Other Information in Documents Containing Audited 
Financial Statements.''
    e. In paragraph .05:
     In the third sentence:
     The reference to ``section 634'' is replaced with ``AS 
6101.''
     The reference to ``section 634.54-.60'' is replaced with 
``AS 6101.54-.60.''
     In the first sentence of footnote 3, the reference to 
``Section 634.12'' is replaced with ``AS 6101.12.''
     In the fourth sentence, the reference to ``section 
634.55'' is replaced with ``AS 6101.55.''
     In the fifth sentence, the reference to ``section 634.55 
and .57'' is replaced with ``AS 6101.55 and .57.''
    f. In paragraph .06, each reference to ``section 634.57'' or 
``Section 634.57'' is replaced with ``AS 6101.57.''
    g. In the last sentence of paragraph .07, the reference to 
``section 634.55'' is replaced with ``AS 6101.55.''
    h. In the last sentence of paragraph .09, the reference to 
``section 634.31'' is replaced with ``AS 6101.31.''
    i. In the first sentence of paragraph .16, the reference to 
``Section 634,

[[Page 36635]]

Letters for Underwriters and Certain Other Requesting Parties, 
paragraph .57,'' is replaced with ``AS 6101.57.''
    j. In the first sentence of paragraph .18, the reference to 
``Section 634.55'' is replaced with ``AS 6101.55.''
    k. In the third sentence of paragraph .19, the reference to 
``section 634.55'' is replaced with ``6101.55.''
    l. In paragraph .29:
     In the first sentence, the reference to ``section 634.64'' 
is replaced with ``6101.64.''
     In the last sentence of footnote 4 to the table following 
paragraph .29, the reference to ``section 634.55'' is replaced with 
``AS 6101.55.''
AU sec. 711, ``Filings Under Federal Securities Statutes''
    SAS No. 37, ``Filings Under Federal Securities Statutes'' (AU sec. 
711, ``Filings Under Federal Securities Statutes''), as amended, is 
amended as follows:
    a. The section number ``AU Section 711'' is replaced with ``AS 
4101.''
    b. The title ``Filings Under Federal Securities Statutes'' is 
replaced with ``Responsibilities Regarding Filings Under Federal 
Securities Statutes.''
    c. Footnote * to the section number of the standard is deleted.
    d. In the note to paragraph .02, the reference to ``paragraphs C16-
C17 of Appendix C, Special Reporting Situations, of PCAOB Auditing 
Standard No. 5'' is replaced with ``paragraphs .C16-.C17 of Appendix C, 
Special Reporting Situations, of AS 2201.''
    e. In the fourth sentence of paragraph .10, the reference to 
``section 560.12'' is replaced with ``paragraph .12 of AS 2801, 
Subsequent Events.''
    f. In the last sentence of paragraph .11, the parenthetic reference 
to ``section 508'' is replaced with ``AS 3101, Reports on Audited 
Financial Statements.''
    g. In paragraph .12:
     In the first sentence, the references to ``sections 560 
and 561'' are replaced with ``AS 2801 and AS 2905, Subsequent Discovery 
of Facts Existing at the Date of the Auditor's Report.''
     In the second sentence, the reference to ``sections 530.05 
and 530.07 and .08'' is replaced with ``paragraph .05 of AS 3110, 
Dating of the Independent Auditor's Report, and AS 3110.07 and .08.''
     In the third sentence, the reference to ``section 561.08 
and .09'' is replaced with ``AS 2905.08 and .09.''
    h. In paragraph .13a:
     The reference to ``section 561'' is replaced with ``AS 
2905.''
     The parenthetic reference to ``section 722.46'' is 
replaced with ``paragraph .46 of AS 4105, Reviews of Interim Financial 
Information.''
AU sec. 9711, ``Filings Under Federal Securities Statutes: Auditing 
Interpretations of Section 711''
    AU sec. 9711, ``Filings Under Federal Securities Statutes: Auditing 
Interpretations of Section 711,'' as amended, is amended as follows:
    a. The section number ``AU Section 9711'' is replaced with ``AI 
26.''
    b. The title ``Filings Under Federal Securities Statutes: Auditing 
Interpretations of Section 711'' is replaced with ``Responsibilities 
Regarding Filings Under Federal Securities Statutes: Auditing 
Interpretations of AS 4101.''
    c. In paragraph .03:
     In the first sentence, the reference to ``Section 711, 
Filings Under Federal Securities Statutes, paragraph .05'' is replaced 
with ``Paragraph .05 of AS 4101, Responsibilities Regarding Filings 
Under Federal Securities Statutes.''
     In the last sentence, the parenthetic reference to 
``section 711.10 and .11'' is replaced with ``AS 4101.10 and .11.''
    d. In paragraph .05, the reference to ``section 711.10 and .11'' is 
replaced with ``AS 4101.10 and .11.''
    e. In paragraph .09:
     In the second sentence, the parenthetic reference to 
``section 552, Reporting on Condensed Financial Statements and Selected 
Financial Data, paragraph .08'' is replaced with ``paragraph .08 of AS 
3315, Reporting on Condensed Financial Statements and Selected 
Financial Data.''
     In the last sentence, the parenthetic reference to 
``section 711.10 and .11'' is replaced with ``AS 4101.10 and .11.''
    f. In paragraph .10:
     In the first sentence, the reference to ``section 711'' is 
replaced with ``AS 4101.''
     In the last sentence, the reference to ``section 711.10 
and .11'' is replaced with ``AS 4101.10 and .11.''
    g. In the last sentence of paragraph .11, the reference to 
``Section 711.12 and .13'' is replaced with ``AS 4101.12 and .13.''
AU sec. 722, ``Interim Financial Information''
    SAS No. 100, ``Interim Financial Information'' (AU sec. 722, 
``Interim Financial Information''), as amended, is amended as follows:
    a. The section number ``AU Section 722'' is replaced with ``AS 
4105.''
    b. The title ``Interim Financial Information'' is replaced with 
``Reviews of Interim Financial Information.''
    c. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 71)'' is deleted.
    d. In the second sentence of paragraph .01:
     The word ``three'' is deleted.
     The phrase ``discussed in section 150, Generally Accepted 
Auditing Standards, paragraph .02),'' is deleted.
     Footnote 1A is added following the term ``standards'':
    See AS 1005, Independence, AS 1010, Training and Proficiency of the 
Independent Auditor, and AS 1015, Due Professional Care in the 
Performance of Work.
    e. In the first sentence of paragraph .04, the reference to 
``Section 315, Communications Between Predecessor and Successor 
Auditors'' is replaced with ``AS 2610, Initial Audits--Communications 
Between Predecessor and Successor Auditors.''
    f. In footnote 5 to paragraph .05, the last sentence is deleted.
    g. In the second sentence of paragraph .07, the phrase ``generally 
accepted auditing standards'' is replaced with ``the standards of the 
PCAOB.''
    h. In the eighth bullet of paragraph .09:
     In the first sentence, the phrase ``standards established 
by the AICPA'' is replaced with ``the standards of the PCAOB.''
     In the third sentence, the phrase ``generally accepted 
auditing standards'' is replaced with ``the standards of the PCAOB.''
    i. In the first sentence of footnote 7 to the first bullet of 
paragraph .11, the reference to ``Paragraphs 10 through 23 of Auditing 
Standard No. 14'' is replaced with ``Paragraphs .10 through .23 of AS 
2810.''
    j. In the third sentence of paragraph .13, the reference to 
``Auditing Standard No. 12'' is replaced with ``AS 2110.''
    k. In the last sentence of paragraph .16, the reference to 
``section 329'' is replaced with ``AS 2305.''
    l. In footnote 11 to paragraph .18b, the parenthetic reference to 
``section 543, Part of Audit Performed by Other Independent Auditors'' 
is replaced with ``AS 1205, Part of the Audit Performed by Other 
Independent Auditors.''
    m. In the last sentence of paragraph .18f, the reference to 
``section 550, Other Information in Documents Containing Audited 
Financial Statements, paragraphs .04 through .06)'' is replaced with 
``paragraphs .04 through .06 of AS 2710, Other Information in Documents 
Containing Audited Financial Statements.''
    n. In the first sentence of footnote 15 to paragraph .21, the 
reference to ``section 341, The Auditor's Consideration of an Entity's 
Ability to Continue as a Going Concern, paragraph .10'' is replaced 
with ``paragraph .10 of

[[Page 36636]]

AS 2415, Consideration of an Entity's Ability to Continue as a Going 
Concern.''
    o. In footnote 16 to paragraph .24, the reference to ``section 333, 
Management Representations, paragraphs .08 through .12'' is replaced 
with ``paragraphs .08 through .12 of AS 2805, Management 
Representations.''
    p. In the last sentence of paragraph .30, the reference ``paragraph 
25 of Auditing Standard No. 16'' is replaced with ``paragraph .25 of AS 
1301.''
    q. In paragraph .32:
     The reference to ``AU sec. 316'' is replaced with ``AS 
2401.''
     The reference to ``AU sec. 317'' is replaced with ``AS 
2405.''
    r. In paragraph .34:
     In the first sentence, the reference to ``Auditing 
Standard No. 16, Communications with Audit Committees'' is replaced 
with ``AS 1301.''
     In the fourth sentence, the reference to ``paragraph 12 of 
Auditing Standard No. 16, Communications with Audit Committees'' is 
replaced with ``AS 1301.12.''
    s. In the last sentence of paragraph .36, the reference to 
``paragraph 25 of Auditing Standard No. 16, Communications with Audit 
Committees'' is replaced with ``AS 1301.25.''
    t. In paragraph .37d, the phrase ``standards established by the 
AICPA'' is replaced with ``the standards of the PCAOB.''
    u. In paragraph .37f, the phrase ``generally accepted auditing 
standards'' is replaced with ``the standards of the PCAOB.''
    v. Paragraph ``.37i'' is replaced with ``.37j.''
    w. Paragraph .37i is added:
    The city and state (or city and country, in the case of non-U.S. 
auditors) from which the auditor's report has been issued.
    x. Footnote 24A is added to the end of the added paragraph .37i:
    See SEC Rule 2-02(a) of Regulation S-X, 17 CFR 210.2-02(a).
    y. In footnote 25 to paragraph .37i:
     The reference to ``sections 530'' is replaced with ``AS 
3110.''
     The reference to ``560'' is replaced with ``AS 2801.''
    z. In the Independent Accountant's Report following paragraph .38:
     The heading ``Independent Accountant's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the second paragraph, the phrase 
``standards established by the American Institute of Certified Public 
Accountants'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     In the third sentence of the second paragraph, the phrase 
``generally accepted auditing standards'' is replaced with ``the 
standards of the Public Company Accounting Oversight Board.''
     The phrase ``[City and State or Country]'' is added 
following the term ``[Signature].''
    aa. In the Independent Accountant's Report following paragraph .39:
     The heading ``Independent Accountant's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the second paragraph, the phrase 
``standards established by the American Institute of Certified Public 
Accountants'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     In the third sentence of the second paragraph, the phrase 
``generally accepted auditing standards'' is replaced with ``the 
standards of the Public Company Accounting Oversight Board.''
     In the first sentence of the fourth paragraph, the phrase 
``auditing standards generally accepted in the United States of 
America'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board.''
     The phrase ``[City and State or Country]'' is added 
following the term ``[Signature].''
    bb. In footnote 29 to paragraph .40, the reference to ``section 
543, Part of Audit Performed by Other Independent Auditors'' is 
replaced with ``AS 1205.''
    cc. In the Independent Accountant's Report following paragraph .40:
     The heading ``Independent Accountant's Report'' above the 
example report is replaced with ``Report of Independent Registered 
Public Accounting Firm.''
     In the first sentence of the third paragraph, the phrase 
``standards established by the American Institute of Certified Public 
Accountants'' is replaced with ``the standards of the Public Company 
Accounting Oversight Board (United States).''
     In the third sentence of the third paragraph, the phrase 
``generally accepted auditing standards'' is replaced with ``the 
standards of the Public Company Accounting Oversight Board.''
     The phrase ``[City and State or Country]'' is added 
following the term ``[Signature].''
    dd. In footnote 30 to paragraph .41, the reference to ``section 
508, Reports on Audited Financial Statements, paragraph .15'' is 
replaced with ``paragraph .15 of AS 3101, Reports on Audited Financial 
Statements.''
    ee. In the first sentence of footnote 32 to paragraph .43, the 
reference to ``section 341, The Auditor's Consideration of an Entity's 
Ability to Continue as a Going Concern, paragraph .10'' is replaced 
with ``AS 2415.10.''
    ff. In the last sentence of paragraph .46, the reference to 
``section 561'' is replaced with ``AS 2905.''
    gg. In the last sentence of paragraph .50d, the phrase ``standards 
established by the American Institute of Certified Public Accountants'' 
is replaced with ``the standards of the Public Company Accounting 
Oversight Board.''
    hh. In Appendix B, footnote 36 to bullet 16 of item B1 in paragraph 
.55, the reference to ``section 342, Auditing Accounting Estimates, 
paragraphs .05 and .06'' is replaced with ``paragraphs .05 and .06 of 
AS 2501, Auditing Accounting Estimates.''
    ii. In Appendix C of paragraph .56:
     In item C2:
     In the third sentence, the reference to ``section 333'' is 
replaced with ``AS 2805.''
     The last sentence is deleted.
     In the second sentence of item C5:
     The reference to ``section 316'' is replaced with ``AS 
2401.''
     The phrase ``related parties'' is italicized.
     The reference to ``Auditing Standard No. 18'' is replaced 
with ``AS 2410.''
     In the last sentence of item C6, the reference to 
``section 333.08'' is replaced with ``AS 2805.08.''
     In the bracketed sentence of paragraph 15 of the second 
management representation letter titled ``Illustrative Representation 
Letter for a Review of Interim Financial Information (Statements),'' 
the reference to ``section 333, Management Representations, paragraph 
.17)'' is replaced with ``paragraph .17 of AS 2805, Management 
Representations.''
AU sec. 801, ``Compliance Auditing Considerations in Audits of 
Governmental Entities and Recipients of Governmental Financial 
Assistance''
    SAS No. 74, ``Compliance Auditing Considerations in Audits of 
Governmental Entities and Recipients of Governmental Financial 
Assistance'' (AU sec. 801, ``Compliance Auditing Considerations in 
Audits of Governmental Entities and Recipients of Governmental 
Financial Assistance''), as amended, is amended as follows:

[[Page 36637]]

    a. The section number ``AU Section 801'' is replaced with ``AS 
6110.''
    b. The title ``Compliance Auditing Considerations in Audits of 
Governmental Entities and Recipients of Governmental Financial 
Assistance'' is replaced with ``Compliance Auditing Considerations in 
Audits of Recipients of Governmental Financial Assistance.''
    c. In the references before paragraph .01, the phrase ``(Supersedes 
SAS No. 68)'' is deleted.
    d. In paragraph .01, in the first sentence, the phrase ``generally 
accepted auditing standards (GAAS)'' is replaced with ``the standards 
of the PCAOB.''
    e. Footnote 5 to paragraph .02 is deleted.
    f. In paragraph .02a, the reference to ``section 317'' is replaced 
with ``AS 2405.''
    g. In the first sentence of paragraph .06:
     The reference to ``Section 317'' is replaced with ``AS 
2405.''
     The term ``GAAS'' is replaced with ``the standards of the 
PCAOB.''
    h. In the first sentence of paragraph .09, the term ``GAAS'' is 
replaced with ``the standards of the PCAOB.''
    i. In paragraph .10a, the term ``GAAS'' is replaced with ``the 
standards of the PCAOB.''
    j. In the last sentence of paragraph .11, the term ``GAAS'' is 
replaced with ``the standards of the PCAOB.''
    k. Footnote 12 to paragraph .12 is deleted.
    l. Footnote 14 to paragraph .16 is deleted.
    m. In footnote 15 to paragraph .17c, the term ``GAAS'' is replaced 
with ``the standards of the PCAOB.''
    n. In the last sentence of paragraph .18, the reference to 
``section 350'' is replaced with ``AS 2315.''
    o. In paragraph .22:
     In the first sentence, the term ``GAAS'' is replaced with 
``The standards of the PCAOB.''
     In the second sentence:
     The phrase ``a GAAS'' is replaced with ``an.''
     The phrase ``in accordance with the standards of the 
PCAOB'' is added following the term ``statements.''
     The second term ``GAAS'' is replaced with ``the standards 
of the PCAOB.''
     In the last sentence, the term ``GAAS'' is replaced with 
``the standards of the PCAOB.''
    p. In the last sentence of paragraph .23, the reference to 
``section 317'' is replaced with ``AS 2405.''
AU sec. 901, ``Public Warehouses--Controls and Auditing Procedures for 
Goods Held''
    SAS No. 1, ``Codification of Auditing Standards and Procedures'' 
(AU sec. 901, ``Public Warehouses--Controls and Auditing Procedures for 
Goods Held''), as amended, is rescinded.

Attestation Standards

Attestation Standard No. 1, ``Examination Engagements Regarding 
Compliance Reports of Brokers and Dealers''
    Attestation Standard No. 1, ``Examination Engagements Regarding 
Compliance Reports of Brokers and Dealers,'' is amended as follows:
    a. In footnote 8 to paragraph 4, the reference to ``Auditing 
Standard No. 15'' is replaced with ``AS 1105.''
    b. In the second note to paragraph 6, the reference to ``Auditing 
Standard No. 3'' is replaced with ``AS 1215.''
    c. In the first sentence of footnote 12 to paragraph 8, the 
reference to ``Auditing Standard No. 17'' is replaced with ``AS 2701.''
    d. In footnote 18 to paragraph 35, the reference to ``Auditing 
Standard No. 16'' is replaced with ``AS 1301.''
    e. In footnote 3 to paragraph C10, the reference to ``AU sec. 317'' 
is replaced with ``AS 2405.''
Attestation Standard No. 2, ``Review Engagements Regarding Exemption 
Reports of Brokers and Dealers''
    Attestation Standard No. 2, ``Review Engagements Regarding 
Exemption Reports of Brokers and Dealers,'' is amended as follows:
    a. In the second note to paragraph 5, the reference to ``Auditing 
Standard No. 3'' is replaced with ``AS 1215.''
    b. In the first sentence of footnote 9 to paragraph 7, the 
reference to ``Auditing Standard No. 17'' is replaced with ``AS 2701.''
    c. In footnote 12 to paragraph 15, the reference to ``Auditing 
Standard No. 16'' is replaced with ``AS 1301.''
AT sec. 101, ``Attestation Engagements''
    AT sec. 101, ``Attestation Engagements,'' as amended, is amended as 
follows:
    a. The following note is added at the end of paragraph .01:
    Note: In connection with an engagement performed in accordance with 
this attestation standard, whenever the practitioner is required to 
make reference in a report to attestation standards established by the 
American Institute of Certified Public Accountants, the practitioner 
must instead refer to ``the standards of the Public Company Accounting 
Oversight Board (United States).'' A practitioner must also include the 
city and state (or city and country, in the case of non-U.S. 
practitioners) from which the practitioner's report has been issued.
    b. In the last sentence of paragraph .04f, the reference to ``PCAOB 
Auditing Standard No. 4'' is replaced with ``AS 6115.''
    c. In paragraph .91:
     The parenthetic reference to ``AU section 634'' is 
replaced with ``AS 6101.''
     The parenthetic reference to ``AU section 711, Filings 
Under Federal Securities Statues'' is replaced with ``AS 4101, 
Responsibilities Regarding Filings Under Federal Securities Statues.''
    d. In the last sentence of paragraph .99, the reference to ``AU 
section 561'' is replaced with ``AS 2905.''
AT sec. 9101, ``Attest Engagements: Attest Engagements Interpretations 
of Section 101''
    AT sec. 9101, ``Attest Engagements: Attest Engagements 
Interpretations of Section 101,'' is amended as follows:
    a. In the last sentence of paragraph .12, the reference to ``AU 
section 322, The Auditor's Consideration of the Internal Audit Function 
in an Audit of Financial Statements'' is replaced with ``AS 2605, 
Consideration of the Internal Audit Function.''
    b. In the second bullet of paragraph .28, the reference to ``AU 
section 722, Interim Financial Information'' is replaced with ``AS 
4105, Reviews of Interim Financial Information.''
    c. Paragraph .43 is deleted.
    d. Paragraph 44 is replaced with the following:
    Illustrative letters in response to a regulatory request for access 
to or copies of the attest documentation related to an examination 
engagement performed in accordance with section 601, Compliance 
Attestation, and an agreed-upon procedures engagement performed in 
accordance with section 201, Agreed-Upon Procedures Engagements, 
follow.
    e. In footnote 7 to paragraph .45, the parenthetic reference to 
``AU section 9339.11-.15'' is deleted.
    f. In footnote 12 to paragraph .46:
     The parenthetic reference to ``AU section 9339.11-.15'' is 
deleted.
     A comma is added after the second word ``access.''
AT sec. 201, ``Agreed-Upon Procedures Engagements''
    AT sec. 201, ``Agreed-Upon Procedures Engagements,'' is amended as 
follows:
    a. The following note is added at the end of paragraph .01:

[[Page 36638]]

    Note: In connection with an engagement performed in accordance with 
this attestation standard, whenever the practitioner is required to 
make reference in a report to attestation standards established by the 
American Institute of Certified Public Accountants, the practitioner 
must instead refer to ``the standards of the Public Company Accounting 
Oversight Board (United States).'' A practitioner must also include the 
city and state (or city and country, in the case of non-U.S. 
practitioners) from which the practitioner's report has been issued.
    b. In paragraph .02a, the reference to ``AU section 623'' is 
replaced with ``AS 3305.''
    c. In paragraph .02b, the reference to ``AU section 801, Compliance 
Auditing Considerations in Audits of Governmental Entities and 
Recipients of Governmental Financial Assistance'' is replaced with ``AS 
6110, Compliance Auditing Considerations in Audits of Recipients of 
Governmental Financial Assistance.''
    d. In paragraph .02c, the reference to ``AU section 324, Service 
Organizations, paragraph .58'' is replaced with ``paragraph .58 of AS 
2601, Consideration of an Entity's Use of a Service Organization.''
    e. In paragraph .02d, the reference to ``AU section 634'' is 
replaced with ``AS 6101.''
    f. In footnote 3 to paragraph .03, the reference to ``AU section 
623.11-.18'' is replaced with ``AS 3305.11-.18.''
    g. In footnote 7 to paragraph .22, the reference to ``AU section 
322, The Auditor's Consideration of the Internal Audit Function in an 
Audit of Financial Statements'' is replaced with ``AS 2605, 
Consideration of the Internal Audit Function.''
    h. In footnote 13 to paragraph .31k:
     In the first sentence, the reference to ``AU section 504, 
Association With Financial Statements'' is replaced with ``AS 3320, 
Association with Financial Statements.''
     In the second sentence:
     The reference to ``AU section 504.04'' is replaced with 
``AS 3320.04.''
     The reference to ``AU section 722, Interim Financial 
Information'' is replaced with ``AS 4105, Reviews of Interim Financial 
Information).''
     The reference to ``AU section 504.05'' is replaced with 
``AS 3320.05.''
    i. In footnote 16 to paragraph .36, the reference to ``AU section 
530, Dating of the Independent Auditor's Report, paragraphs .06 and 
.07'' is replaced with ``paragraphs .06 and .07 of AS 3110, Dating of 
the Independent Auditor's Report.''
    j. In footnote 18 to paragraph .40, the bracketed reference to ``AU 
section 508'' is replaced with ``AS 3101.''
AT sec. 301, ``Financial Forecasts and Projections''
    AT sec. 301, ``Financial Forecasts and Projections,'' is amended as 
follows:
    a. The following note is added at the end of paragraph .01:
    Note: In connection with an engagement performed in accordance with 
this attestation standard, whenever the practitioner is required to 
make reference in a report to attestation standards established by the 
American Institute of Certified Public Accountants, the practitioner 
must instead refer to ``the standards of the Public Company Accounting 
Oversight Board (United States).'' A practitioner must also include the 
city and state (or city and country, in the case of non-U.S. 
practitioners) from which the practitioner's report has been issued.
    b. In footnote 4 to paragraph .08e, the reference to ``AU section 
623'' is replaced with ``AS 3305.''
    c. In footnote 12 to paragraph .23, the parenthetic reference to 
``AU section 9504.19-.22'' is replaced with ``paragraphs .19-.22 of AI 
25, Association with Financial Statements: Auditing Interpretations of 
AS 3320.''
    d. In paragraph .24:
     In footnote 13, the reference to ``AU section 504, 
Association With Financial Statements'' is replaced with ``AS 3320, 
Association with Financial Statements.''
     In footnote 14, the reference to ``AU section 552'' is 
replaced with ``AS 3315.''
    e. In paragraph .48:
     In footnote 23, the reference to ``AU section 504'' is 
replaced with ``AS 3320.''
     In footnote 24, the reference to ``AU section 552'' is 
replaced with ``AS 3315.''
    f. In footnote 26 to paragraph .52, the reference to ``AU section 
634'' is replaced with ``AS 6101.''
    g. In paragraph .60:
     In footnote 29:
     In the first sentence, the reference to ``AU section 550'' 
is replaced with ``AS 2710.''
     In the second sentence:
     The reference to ``AU section 550'' is replaced with ``AS 
2710.''
     The bracketed reference to ``AU section 711, Filings Under 
Federal Securities Statutes'' is replaced with ``AS 4101, 
Responsibilities Regarding Filings Under Federal Securities Statutes.''
     In the last sentence, the reference to ``AU section 550'' 
is replaced with ``AS 2710.''
    h. In the first sentence of footnote 5 to item 11d of paragraph 
.70, Appendix C, the reference to ``AU section 722, Interim Financial 
Information, paragraphs .13 through .19'' is replaced with ``paragraphs 
.13 through .19 of AS 4105, Reviews of Interim Financial Information.''
AT sec. 401, ``Reporting on Pro Forma Financial Information''
    AT sec. 401, ``Reporting on Pro Forma Financial Information,'' is 
amended as follows:
    a. In footnote 1 to paragraph .01:
     In the first sentence, the reference to ``AU section 634, 
Letters for Underwriters and Certain Other Requesting Parties, 
paragraphs .03 through .05'' is replaced with ``Paragraphs .03 through 
.05 of AS 6101, Letters for Underwriters and Certain Other Requesting 
Parties.''
     In the last sentence, the reference to ``AU section 
634.03'' is replaced with ``AS 6101.03.''
    b. The following note is added at the end of paragraph .01:
    Note: In connection with an engagement performed in accordance with 
this attestation standard, whenever the practitioner is required to 
make reference in a report to attestation standards established by the 
American Institute of Certified Public Accountants, the practitioner 
must instead refer to ``the standards of the Public Company Accounting 
Oversight Board (United States).'' A practitioner must also include the 
city and state (or city and country, in the case of non-U.S. 
practitioners) from which the practitioner's report has been issued.
    c. In paragraph .02, the reference to ``AU section 550, Other 
Information in Documents Containing Audited Financial Statements, and 
AU section 711, Filings Under Federal Securities Statutes'' is replaced 
with ``AS 2710, Other Information in Documents Containing Audited 
Financial Statements, and AS 4101, Responsibilities Regarding Filings 
Under Federal Securities Statutes.''
    d. In footnote 2 to paragraph .03:
     In the second sentence, the reference to ``AU section 560, 
Subsequent Events, paragraph .05'' is replaced with ``paragraph .05 of 
AS 2801, Subsequent Events.''
     In the last sentence, the reference to ``AU section 508, 
Reports on Audited Financial Statements, paragraph .28'' is replaced 
with ``paragraph .28 of AS 3101, Reports on Audited Financial 
Statements.''
    e. In the second sentence of footnote 5 to paragraph .07b, the 
reference to ``AU section 722, Interim Financial

[[Page 36639]]

Information'' is replaced with ``AS 4105, Reviews of Interim Financial 
Information.''
AT sec. 601, ``Compliance Attestation''
    AT sec. 601, ``Compliance Attestation,'' as amended, is amended as 
follows:
    a. The following note is added at the end of paragraph .01:
    Note: In connection with an engagement performed in accordance with 
this attestation standard, whenever the practitioner is required to 
make reference in a report to attestation standards established by the 
American Institute of Certified Public Accountants, the practitioner 
must instead refer to ``the standards of the Public Company Accounting 
Oversight Board (United States).'' A practitioner must also include the 
city and state (or city and country, in the case of non-U.S. 
practitioners) from which the practitioner's report has been issued.
    b. In paragraph .02:
     In item b, the reference to ``AU section 623, Special 
Reports, paragraphs .19 through .21'' is replaced with ``paragraphs .19 
through .21 of AS 3305, Special Reports.''
     In item c, the reference to ``AU section 801, Compliance 
Auditing Considerations in Audits of Governmental Entities and 
Recipients of Governmental Financial Assistance'' is replaced with ``AS 
6110, Compliance Auditing Considerations in Audits of Recipients of 
Governmental Financial Assistance.''
     In item d, the reference to ``AU section 634'' is replaced 
with ``AS 6101.''
    c. In footnote 5 to paragraph .19, the reference to ``AU section 
322, The Auditor's Consideration of the Internal Audit Function in an 
Audit of Financial Statements'' is replaced with ``AS 2605, 
Consideration of the Internal Audit Function.''
    d. In the second sentence of paragraph .33, the reference to ``AU 
section 316A, Consideration of Fraud in a Financial Statement Audit, 
paragraphs .16 through .19'' is replaced with ``AS 2401, Consideration 
of Fraud in a Financial Statement Audit.''
    e. In the last sentence of paragraph .43, the reference to ``AU 
section 336'' is replaced with ``AS 1210.''
    f. In the last sentence of paragraph .44, the reference to ``AU 
section 322, The Auditor's Consideration of the Internal Audit Function 
in an Audit of Financial Statements'' is replaced with ``AS 2605, 
Consideration of the Internal Audit Function.''
    g. In the second sentence of paragraph .47, the reference to ``AU 
section 325, Communication of Internal Control Related Matters Noted in 
an Audit'' is replaced with ``AS 1305, Communications About Control 
Deficiencies in an Audit of Financial Statements.''
    h. In the last sentence of paragraph .48, the reference to ``AU 
section 350'' is replaced with ``AS 2315.''
    i. In the first sentence of paragraph .50, the reference to ``AU 
section 560'' is replaced with ``AS 2801.''
    j. In footnote 22 to paragraph .68, the reference to ``AU section 
333, Management Representations, paragraph .09'' is replaced with 
``Paragraph .09 of AS 2805, Management Representations.''
AT sec. 701, ``Management's Discussion and Analysis''
    AT sec. 701, ``Management's Discussion and Analysis,'' is amended 
as follows:
    a. The following note is added at the end of paragraph .01:
    Note: In connection with an engagement performed in accordance with 
this attestation standard, whenever the practitioner is required to 
make reference in a report to attestation standards established by the 
American Institute of Certified Public Accountants or auditing 
standards generally accepted in the United States of America, the 
practitioner must instead refer to ``the standards of the Public 
Company Accounting Oversight Board (United States).'' A practitioner 
must also include the city and state (or city and country, in the case 
of non-U.S. practitioners) from which the practitioner's report has 
been issued.
    b. In the last sentence of footnote 6 to paragraph .02:
     The reference to ``Statement on Auditing Standards (SAS) 
No. 71'' is deleted.
     The parenthetic reference to ``AU section 722, Interim 
Financial Information'' is replaced with ``AS 4105, Reviews of Interim 
Financial Information.''
    c. In footnote 7 to paragraph .02, the reference to ``AU section 
634'' is replaced with ``AS 6101.''
    d. In paragraph .11a, the reference to ``AU section 722, Interim 
Financial Information,'' is replaced with ``AS 4105.''
    e. In item (2) of paragraph .14a, the reference to ``AU section 
722'' is replaced with ``AS 4105.''
    f. In footnote 16 to paragraph .20:
     In the first sentence, the reference to ``AU section 329, 
Analytical Procedures'' is replaced with ``AS 2305, Substantive 
Analytical Procedures.''
     In the last sentence, the reference to ``AU section 329'' 
is replaced with ``AS 2305.''
    g. The first sentence of paragraph .39 is deleted.
    h. Footnote 18 to paragraph .44 is deleted.
    i. In paragraph .47:
     In the third sentence, the reference to ``AU section 336'' 
is replaced with ``AS 1210.''
     In the last sentence, the reference to ``AU section 311, 
Planning and Supervision'' is replaced with ``AS 1201, Supervision of 
the Audit Engagement.''
    j. In the last sentence of paragraph .48, the reference to ``AU 
section 322, The Auditor's Consideration of the Internal Audit Function 
in an Audit of Financial Statements'' is replaced with ``AS 2605, 
Consideration of the Internal Audit Function.''
    k. In the last sentence of paragraph .58:
     The reference to ``AU section 325, Communication of 
Internal Control Related Matters Noted in an Audit'' is replaced with 
``AS 1305, Communications About Control Deficiencies in an Audit of 
Financial Statements.''
     The reference to ``AU section 380, Communication With 
Audit Committees'' is replaced with ``AS 1301, Communications with 
Audit Committees.''
    l. In footnote 24 to paragraph .66:
     In the second sentence, the reference to ``AU section 
561'' is replaced with ``AS 2905.''
     In the last sentence, the reference to ``AU section 711, 
Filings Under Federal Securities Statutes'' is replaced with ``AS 4101, 
Responsibilities Regarding Filings Under Federal Securities Statutes.''
    m. In footnote 25 to paragraph .66c, the reference to ``AU section 
337'' is replaced with ``AS 2505.''
    n. In the first sentence of paragraph .102, the reference to ``AU 
section 315, Communications Between Predecessor and Successor Audits'' 
is replaced with ``AS 2610, Initial Audits--Communications Between 
Predecessor and Successor Audits.''
    o. In paragraph .106:
     In the second sentence, the reference to ``SAS No. 8'' is 
replaced with ``AS 2710.''
     In the last sentence, the reference to ``AU section 711, 
Filings Under Federal Securities Statutes,'' is replaced with ``AS 
4101.''
    p. In footnote 30 to paragraph .107, the reference to ``AU section 
550, Information in Documents Containing Audited Financial 
Statements,'' is replaced with ``AS 2710.''

[[Page 36640]]

    q. In the last sentence of paragraph .108, the reference to ``AU 
section 317, Illegal Acts, paragraphs .17, .22, and .23)'' is replaced 
with ``paragraphs .17, .22, and .23 of AS 2405, Illegal Acts by 
Clients.''
    r. In the last sentence of paragraph .109, the reference to ``AU 
section 316'' is replaced with ``AS 2401.''
    s. In footnote 31 to paragraph .110:
     In the first sentence, the reference to ``AU section 333, 
Management Representations, paragraph .09'' is replaced with 
``Paragraph .09 of AS 2805, Management Representations.''
     In the second sentence, the reference to ``AU section 
711.10'' is replaced with ``AS 4101.10.''
    t. In the title of Appendix D:
     The reference to ``SAS No. 8'' is replaced with ``AS 
2710.''
     Footnote * is deleted.
    u. In the table in paragraph .117, the column heading ``SAS No. 8'' 
is replaced with ``AS 2710.''
Quality Control Standards
QC sec. 20, ``System of Quality Control for a CPA Firm's Accounting and 
Auditing Practice''
    QC section (``sec.'') 20, ``System of Quality Control for a CPA 
Firm's Accounting and Auditing Practice,'' is amended as follows:
    a. In the first sentence of paragraph .10, the reference to ``AU 
section 220'' is replaced with ``AS 1005.''
    b. In footnote 7 to paragraph .10, the reference to ``AU section 
220.02'' is replaced with ``AS 1005.02.''
    c. In the last sentence of paragraph .18, the reference to ``PCAOB 
Auditing Standard No. 7'' is replaced with ``AS 1220.''
Ethics and Independence Standards
ET sec. 101, ``Independence''
    ET sec. 101, ``Independence,'' is amended as follows:
    a. The note in paragraph .05 is deleted.
ET sec. 102, ``Integrity and Objectivity''
    ET sec. 102, ``Integrity and Objectivity,'' is amended as follows:
    a. In footnote 1 to paragraph .05, the reference to ``paragraph 
5.b. of Auditing Standard No. 10, Supervision of the Audit Engagement, 
and paragraph 12.d. of Auditing Standard No. 3, Audit Documentation'' 
is replaced with ``paragraph .05b of AS 1201, Supervision of the Audit 
Engagement, and paragraph .12d of AS 1215, Audit Documentation.''

II. Board's Statement of the Purpose of, and Statutory Basis for, the 
Proposed Rules

    In its filing with the Commission, the Board included statements 
concerning the purpose of, and basis for, the proposed rules and 
discussed comments it received on the proposed rules. The text of these 
statements may be examined at the places specified in Item IV below. 
The Board has prepared summaries, set forth in sections A, B, and C 
below, of the most significant aspects of these statements. In 
addition, the Board is requesting that the Commission approve the 
proposed rules, pursuant to Section 103(a)(3)(C) of the Sarbanes-Oxley 
Act, for application to audits of emerging growth companies (``EGCs''), 
as that term is defined in Section 3(a)(80) of the Securities Exchange 
Act of 1934 (``Exchange Act''). The Board's request is set forth in 
section D.

A. Board's Statement of the Purpose of, and Statutory Basis for, the 
Proposed Rules

(a) Purpose
Introduction
    The Board is reorganizing its auditing standards using a topical 
structure and a single, integrated numbering system. To implement this 
reorganization, the Board is adopting amendments to its auditing 
standards and rules and is also rescinding certain auditing standards 
that are no longer necessary under the reorganization. These amendments 
do not impose new requirements on auditors or change the substance of 
the requirements for performing and reporting on audits under PCAOB 
standards. Specifically, the amendments to implement the reorganization 
include updates to the section numbers, cross references, and titles of 
certain standards. Other related amendments include, among others, 
removing standards that are no longer necessary, replacing references 
to generally accepted auditing standards, and updating certain PCAOB 
rules to reflect the reorganized auditing standards.
    The new organizational structure is intended to improve the 
usability of the Board's standards, including helping users navigate 
the standards more easily. To facilitate navigation, the standards are 
organized into a logical structure by topic areas that generally follow 
the flow of the audit process. For example, auditing standards that 
apply to procedures performed near the completion of the audit are 
arranged in the same area. The reorganization also uses a numbering 
convention that is different from conventions used by other standard 
setters, which should help to avoid the potential for confusion between 
the standards of the Board and those of other standard setters.
Background and the Need for Improvement
    In April 2003, the Board adopted, on an interim, transitional 
basis, the generally accepted auditing standards, originally issued by 
the Auditing Standards Board (``ASB'') of the American Institute of 
Certified Public Accountants (``AICPA''), that were in existence at the 
time.\2\ When the Board adopted those auditing standards, it continued 
to use the topical organization and reference numbers (``AU sections'') 
in the ASB's then-existing codification of its standards.\3\ Auditing 
standards issued by the Board (``AS standards'') were not codified or 
otherwise organized by topic, but were numbered in sequential order 
based upon when they were issued. Thus far, the Board has issued 18 
auditing standards (AS Nos. 1-18), which have superseded 12 interim 
auditing standards and amended the majority of the remaining interim 
auditing standards to varying degrees. As a result, the Board's 
auditing standards are organized using two separate numbering systems: 
(i) The numbering system used by the ASB when the Board adopted the 
interim standards and (ii) the numbering system used by the Board for 
the standards it has issued.
---------------------------------------------------------------------------

    \2\ See Establishment of Interim Professional Auditing 
Standards, PCAOB Release No. 2003-006 (Apr. 18, 2003) (adopting Rule 
3200T, Interim Auditing Standards).
    \3\ Since 2003, the ASB has modified the organizational 
structure of its standards as part of its Clarity Project.
---------------------------------------------------------------------------

    The Board undertook a project to consider the reorganization of the 
Board's auditing standards. In 2013, the Board proposed to reorganize 
its auditing standards using a single, integrated numbering system and 
a topical structure that generally follows the flow of the audit 
process (``original proposal'').\4\ The proposed reorganization was 
intended to enhance the usability of the standards, help users navigate 
the standards more easily (for example, by helping users find the 
relevant standard for a particular area of the audit), help avoid 
potential confusion between the Board's standards and the standards of 
the International Auditing and Assurance Standards Board (``IAASB'') or 
the ASB, and provide a structure for updating

[[Page 36641]]

PCAOB standards in the future. The original proposal also included 
amendments to rescind certain interim auditing standards that the Board 
believed were no longer necessary.
---------------------------------------------------------------------------

    \4\ See Proposed Framework for Reorganization of PCAOB Auditing 
Standards and Related Amendments to PCAOB Auditing Standards and 
Rules, PCAOB Release 2013-002 (March 26, 2013).
---------------------------------------------------------------------------

    In May 2014, the Board issued a supplemental request for comment 
(``supplemental request'') on the original proposal.\5\ The 
supplemental request included proposed line-by-line amendments to PCAOB 
auditing standards and rules necessary to implement the proposed 
reorganization, along with certain changes to the reorganization as 
presented in the original proposal.\6\ The supplemental request also 
reopened the comment period on the original proposal to seek further 
comment on matters discussed in the original proposal, as well as on 
the implementing amendments in the supplemental request.
---------------------------------------------------------------------------

    \5\ See Supplemental Request for Comment: Proposed Framework for 
Reorganization of PCAOB Auditing Standards and Related Amendments to 
PCAOB Auditing Standards and Rules, PCAOB Release 2014-001 (May 7, 
2014).
    \6\ At the same time, the Board released on its Web site an 
online demonstration version that presented the existing auditing 
standards as they would look if reorganized according to the 
proposed reorganization. The demonstration version of the 
reorganized auditing standards can be accessed at http://pcaobus.org/Rules/Rulemaking/Pages/Docket040.aspx.
---------------------------------------------------------------------------

The Reorganization

    After considering the suggestions from commenters on the original 
proposal and supplemental request, the Board is adopting amendments to 
reorganize the standards substantially as proposed, with some 
refinements as described below.
    Under the reorganization, the individual standards will be grouped 
into the following topical categories:
     General Auditing Standards--Standards on broad auditing 
principles, concepts, activities, and communications;
     Audit Procedures--Standards for planning and performing 
audit procedures and for obtaining audit evidence;
     Auditor Reporting--Standards for auditors' reports;
     Matters Relating to Filings Under Federal Securities 
Laws--Standards on certain auditor responsibilities relating to SEC 
filings for securities offerings and reviews of interim financial 
information; and
     Other Matters Associated with Audits--Standards for other 
work performed in conjunction with an audit of an issuer or of a broker 
or dealer.
    Within each category are subcategories to further organize similar 
topics, such as standards related to auditor communications in the 
``General Auditing Standards'' category. This section includes an 
illustration of the reorganization, including the categories and 
subcategories for PCAOB auditing standards. The integrated referencing 
system uses an ``AS'' prefix to identify the auditing standards, which 
is consistent with common practice for describing standards issued by 
the Board (for example, ``AS No. 7'' for the standard on engagement 
quality review).
    Each standard is assigned a unique section number, based on a four-
digit numbering system.\7\ Using a four-digit system facilitates the 
grouping of auditing standards into logical categories and 
subcategories by topic and avoids potential confusion with the 
standards of the IAASB or the ASB.\8\
---------------------------------------------------------------------------

    \7\ Each standard retains its current paragraph numbers, but the 
paragraph number format of the standards issued by the Board has 
been changed to match the format of the paragraph numbers of its 
other auditing standards. Each paragraph is numbered ``.01,'' 
``.02,'' etc. For example, the reference for the first paragraph of 
the standard on audit planning will be ``AS 2101.01.''
    \8\ After the Board adopted the standards issued by the ASB, the 
ASB undertook a project to clarify its auditing standards that 
resulted in, among other things, a renumbering and reorganization of 
their standards. Consequently, the PCAOB's interim auditing standard 
AU section (``sec.'') 230, Due Professional Care in the Performance 
of Work, for example, described the auditor's responsibility for 
applying due professional care in planning and performing audits, 
whereas the ASB standard with the same number now relates to audit 
documentation.
---------------------------------------------------------------------------

    The topical organization also provides a structure for future 
updates to PCAOB auditing standards. For example, future auditing 
standards will be issued as new or replacement sections and paragraphs 
within the new structure.
Changes to PCAOB Standards and Rules
    Item I presents the amendments to PCAOB standards and rules to 
implement the reorganization of the PCAOB's auditing standards and 
other related amendments. These amendments are technical changes that 
include rescinding certain interim auditing standards that the Board 
believes are no longer necessary and eliminating certain inoperative 
language or references. The changes do not impose new requirements on 
auditors or change the substance of the requirements for performing and 
reporting on audits under PCAOB standards.
Changes to PCAOB Standards
    The amendments primarily update section numbers, update cross-
references among standards using a new numbering system, and change the 
titles of certain standards, as described below. For example, for AU 
sec. 324, Service Organizations, the amendments replace ``AU sec.'' 
with ``AS'' and ``324'' with ``2601.'' The title of this standard is 
changed to ``Consideration of an Entity's Use of a Service 
Organization.'' As described above, the paragraph numbers within the 
standard remain the same. For example, AU sec. 324.05 becomes AS 
2601.05.
    Other amendments rescind certain interim standards and remove or 
update certain terms and phrases in the standards, such as references 
to generally accepted auditing standards (``GAAS''). Those changes are 
discussed in the following paragraphs.

Interim Auditing Standards To Be Rescinded

    As proposed, the Board is rescinding the following interim 
standards: \9\
---------------------------------------------------------------------------

    \9\ The original proposal also discussed why the Board proposed 
to rescind the standards and why AU sec. 534, Reporting on Financial 
Statements Prepared for Use in Other Countries, would not appear in 
the reorganized PCAOB auditing standards.
---------------------------------------------------------------------------

     AU sec. 150, Generally Accepted Auditing Standards
     AU sec. 201, Nature of the General Standards
     AU sec. 410, Adherence to Generally Accepted Accounting 
Principles
     AU sec. 532, Restricting the Use of an Auditor's Report
     AU sec. 901, Public Warehouses--Controls and Auditing 
Procedures for Goods Held

Interpretive Publications

    Among other things, AU sec. 150 described the auditor's 
responsibilities regarding interpretive publications, which consist of 
auditing interpretations of the interim auditing standards, appendices 
to the interim auditing standards, auditing guidance included in AICPA 
Audit and Accounting Guides, and AICPA auditing Statements of 
Position.\10\
---------------------------------------------------------------------------

    \10\ See AU sec. 150.06. Pursuant to PCAOB Rule 3200T, the 
auditor's responsibilities regarding interpretive publications 
relate to the publications described in AU sec. 150.06 that were in 
existence as of April 16, 2003, to the extent not amended or 
superseded by the Board.
---------------------------------------------------------------------------

    The Board proposed to retain almost all \11\ of the AICPA auditing 
interpretations and to present the auditing interpretations separately 
from the auditing standards on the Board's

[[Page 36642]]

Web site in a manner similar to PCAOB guidance. As discussed in the 
supplemental request, the proposed amendments numbered the 
interpretations consecutively using a two-digit section number that 
followed an ``AI'' prefix and used title language in the form of 
``Auditing Interpretations of AS xxxx.'' The auditing interpretations 
will be presented on the guidance page of the Board's Web site, 
consistent with their presentation in the online demonstration version 
that accompanied the supplemental request. Because the Board proposed 
to retain the auditing interpretations, the Board similarly proposed to 
retain the existing requirement that auditors be aware of and consider 
the auditing interpretations.\12\
---------------------------------------------------------------------------

    \11\ As discussed in the original proposal, the Board proposed 
to not retain auditing interpretations related to standards that 
will not be in the reorganization, specifically, the interpretations 
of AU sec. 410 and AU sec. 534. Also, the Board proposed to remove 
interpretation 16 (paragraphs .76-.84) of AU sec. 9508, Reports on 
Audited Financial Statements: Auditing Interpretations of Section 
508, which does not relate to audits of issuers, brokers, or 
dealers.
    \12\ The Board proposed to add this requirement to AS 1001, 
Responsibilities and Functions of the Independent Auditor.
---------------------------------------------------------------------------

    The Board is adopting the organizational structure and numbering of 
the auditing interpretations as proposed. The Board also proposed to 
retain almost all of the appendices \13\ to the interim auditing 
standards and to continue presenting those appendices together with 
their related auditing standards in the same manner that the appendices 
to Board-issued standards are presented.\14\ In addition, the Board 
proposed to retain the American Bar Association's Statement of Policy 
Regarding Lawyers' Responses to Auditors' Requests for Information, 
currently included as Exhibit II of AU sec. 337, Inquiry of a Client's 
Lawyer Concerning Litigation, Claims, and Assessments.\15\ The Board 
received no specific comments on these matters. The Board is retaining 
the interim standards' appendices and Exhibit II of AU sec. 337 in the 
reorganized standards as proposed.
---------------------------------------------------------------------------

    \13\ The Board proposed to delete the appendices that contain 
paragraphs .86 and .87 of AU sec. 316, Consideration of Fraud in a 
Financial Statement Audit, which provide amendments to AU sec. 230, 
Due Professional Care in the Performance of Work, and AU sec. 333, 
Management Representations, respectively, because these amendments 
already are reflected in the standards themselves.
    \14\ Appendices to Board-issued standards are an integral part 
of those standards. See Auditing Standards Related to the Auditor's 
Assessment of and Response to Risk and Related Amendments to PCAOB 
Standards, PCAOB Release No. 2010-004, at A10-3 (August 5, 2010).
    \15\ The Board also proposed to delete the exhibit that includes 
AU sec. 316.88 as it provides guidance to management regarding 
antifraud programs and controls. In addition, the Board proposed to 
delete Exhibit I of AU sec. 337 because it merely presents excerpts 
of Financial Accounting Standard Board (``FASB'') Statement No. 5, 
Accounting for Contingencies, which are set forth in the FASB's 
Accounting Standards Codification.
---------------------------------------------------------------------------

    The Board also proposed and is adopting amendments to remove 
references to AICPA Audit and Accounting Guides and AICPA auditing 
Statements of Position because the guides referenced in PCAOB standards 
are outdated.\16\
---------------------------------------------------------------------------

    \16\ AICPA Audit and Accounting Guides and auditing Statements 
of Position referenced in PCAOB standards are the editions of those 
publications as in existence on April 16, 2003.
---------------------------------------------------------------------------

Other Changes to PCAOB Standards

    In the supplemental request, the Board proposed amendments to 
replace references to GAAS throughout the auditing standards with 
references to the standards of the PCAOB or PCAOB auditing standards 
and, accordingly, to supersede Auditing Standard No. 1, References in 
Auditors' Reports to the Standards of the Public Company Accounting 
Oversight Board. Commenters generally supported these changes.
    Auditing Standard No. 1 provides that whenever the auditor is 
required by existing standards to reference GAAS in a report, the 
auditor must instead refer to ``the standards of the Public Company 
Accounting Oversight Board (United States).'' Auditing Standard No. 1 
also includes a requirement for the report to include the city and 
state (or city and country) of the auditor. Because Auditing Standard 
No. 1 also applies to reports issued in accordance with the PCAOB's 
attestation standards, the Board proposed similar amendments to update 
GAAS references and to include the city and state (or city and country) 
in the interim attestation standards. The Board is adopting the 
amendments and superseding Auditing Standard No. 1 as proposed.
    The Board also proposed to eliminate certain inoperative language 
in auditing standards and interpretations and to eliminate inoperative 
references to AICPA standards or rules. For example, the Board proposed 
to remove references to provisions of the AICPA Code of Professional 
Conduct or ethics rules that were not adopted as interim standards of 
the PCAOB and to replace references to AICPA standards with references 
to PCAOB standards, where appropriate.\17\ As part of this effort the 
Board also proposed to remove references to superseded standards.\18\ 
The Board is adopting the amendments as proposed except for the 
proposed amendments to interpretation 4 of AT sec. 9101, Attest 
Engagements: Attest Engagements Interpretations of Section 101, which 
addresses letters to regulators when they request access to or copies 
of attestation documentation. This interpretation includes illustrative 
letters preceded by introductory paragraphs that discuss the use of 
such letters. The introductory paragraphs include a reference to a 
superseded auditing standard and auditing interpretation. The proposed 
amendments would have removed the introductory paragraphs, leaving only 
the illustrative letters to this interpretation. Commenters stated that 
the introductory paragraphs are necessary to provide context to the 
illustrative letters. The Board has revised the amendments to include a 
paragraph that introduces the illustrative letters while eliminating 
the superseded references.
---------------------------------------------------------------------------

    \17\ For example, the Board proposed to delete from AS 1005, 
Independence, and AS 2605, Consideration of the Internal Audit 
Function, references to AICPA independence requirements that were 
never adopted by the Board. Similar types of changes were made to AS 
2705, Required Supplementary Information, AS 6101, Letters for 
Underwriters and Certain Other Requesting Parties, AS 6105, Reports 
on the Application of Accounting Principles, AI 24, Special Reports: 
Auditing Interpretations of AS 3305, and AI 25, Association with 
Financial Statements: Auditing Interpretations of AS 3320.
    \18\ For example, the Board proposed to remove references to 
superseded standards in AS 3305, Special Reports, AS 4105, Reviews 
of Interim Financial Information, AI 10, Part of the Audit Performed 
by Other Independent Auditors: Auditing Interpretations of AS 1205, 
AI 23, Reports on Audited Financial Statements: Auditing 
Interpretations of AS 3101, AI 24, Special Reports: Auditing 
Interpretations of AS 3305, AT Section 701, Management's Discussion 
and Analysis, AT Section 9101, Attest Engagements: Attest 
Engagements Interpretations of Section 101, and ET Section 101, 
Independence.
---------------------------------------------------------------------------

Changes to PCAOB Rules
    In conjunction with the reorganization of PCAOB auditing standards, 
the Board proposed to amend PCAOB Rule 3200T, which requires auditors 
to comply with the Board's interim auditing standards, to remove (i) 
the reference to AU sec. 150, which, as discussed above, would not be 
included in the reorganized standards, and (ii) terms such as ``interim 
auditing standards'' and ``generally accepted auditing standards.'' 
Those terms are not relevant under the proposed reorganization and 
could be confusing to some users of the standards. In addition, the 
Board would make the rule a permanent rule rather than a temporary rule 
and, therefore, would remove the word ``Interim'' from the title of the 
rule.\19\ The amended rule, as proposed, would require compliance with 
all PCAOB auditing standards.
---------------------------------------------------------------------------

    \19\ The Board also proposed a conforming amendment to Rule 
3101, Certain Terms Used in Auditing and Related Professional 
Practice Standards, as described in Item I. The Board received no 
comments on that amendment and is adopting it as proposed. The 
amendment does not change the meaning or scope of that rule.

---------------------------------------------------------------------------

[[Page 36643]]

    The Board received no comments on the proposed amendments to Rule 
3200T and is adopting them as proposed. These changes do not modify the 
auditor's existing responsibilities for complying with PCAOB auditing 
standards. Instead, the changes update Rule 3200T so that it describes, 
in one rule, the auditor's responsibilities for complying with all of 
the auditing standards included in the reorganization--those that the 
Board adopted as interim standards in 2003 and those that the Board has 
adopted since.
Additional Amendments for Auditing Standard No. 18
    The Board has adopted certain additional amendments beyond those 
included in the original proposal or supplemental request. 
Specifically, on June 10, 2014, after the supplemental request, the 
Board adopted Auditing Standard No. 18, Related Parties, amendments to 
certain PCAOB auditing standards regarding significant unusual 
transactions, and certain other amendments to PCAOB auditing 
standards.\20\ The Board is adopting additional amendments to 
incorporate Auditing Standard No. 18 and the other amendments into the 
reorganized auditing standards.\21\ Notably, these amendments, like the 
other adopted amendments, are technical in nature and do not 
substantively affect the requirements in PCAOB standards or rules.
---------------------------------------------------------------------------

    \20\ See Auditing Standard No. 18--Related Parties, Amendments 
to Certain PCAOB Auditing Standards Regarding Significant Unusual 
Transactions, and Other Amendments to PCAOB Auditing Standards, 
PCAOB Release No. 2014-002 (June 10, 2014).
    \21\ Separately, the Board also is making a technical amendment 
to AS 2610.09 (formerly AU sec. 315.09) to consolidate the bullet 
points in the paragraph, and AS 2705.09 (formerly AU sec 558.09) to 
update an outdated reference. Item I includes these amendments.

        Illustration of the Reorganized PCAOB Auditing Standards
------------------------------------------------------------------------
 
------------------------------------------------------------------------
General Auditing Standards
------------------------------------------------------------------------
1000..............................  General Principles and
                                     Responsibilities
1001..............................  Responsibilities and Functions of
                                     the Independent Auditor
1005..............................  Independence
1010..............................  Training and Proficiency of the
                                     Independent Auditor
1015..............................  Due Professional Care in the
                                     Performance of Work
1100..............................  General Concepts
1101..............................  Audit Risk
1105..............................  Audit Evidence
1110..............................  Relationship of Auditing Standards
                                     to Quality Control Standards \22\
1200..............................  General Activities
1201..............................  Supervision of the Audit Engagement
1205..............................  Part of the Audit Performed by Other
                                     Independent Auditors
1210..............................  Using the Work of a Specialist
1215..............................  Audit Documentation
1220..............................  Engagement Quality Review
1300..............................  Auditor Communications
1301..............................  Communications with Audit Committees
1305..............................  Communications About Control
                                     Deficiencies in an Audit of
                                     Financial Statements
------------------------------------------------------------------------
Audit Procedures
------------------------------------------------------------------------
2100..............................  Audit Planning and Risk Assessment
2101..............................  Audit Planning
2105..............................  Consideration of Materiality in
                                     Planning and Performing an Audit
2110..............................  Identifying and Assessing Risks of
                                     Material Misstatement
2200..............................  Auditing Internal Control Over
                                     Financial Reporting
2201..............................  An Audit of Internal Control Over
                                     Financial Reporting That Is
                                     Integrated with An Audit of
                                     Financial Statements
2300..............................  Audit Procedures in Response to
                                     Risks--Nature, Timing, and Extent
2301..............................  The Auditor's Responses to the Risks
                                     of Material Misstatement
2305..............................  Substantive Analytical Procedures
2310..............................  The Confirmation Process
2315..............................  Audit Sampling
2400..............................  Audit Procedures for Specific
                                     Aspects of the Audit
2401..............................  Consideration of Fraud in a
                                     Financial Statement Audit
2405..............................  Illegal Acts by Clients
2410..............................  Related Parties
2415..............................  Consideration of an Entity's Ability
                                     to Continue as a Going Concern \23\
2500..............................  Audit Procedures for Certain
                                     Accounts or Disclosures
2501..............................  Auditing Accounting Estimates
2502..............................  Auditing Fair Value Measurements and
                                     Disclosures
2503..............................  Auditing Derivative Instruments,
                                     Hedging Activities, and Investments
                                     in Securities
2505..............................  Inquiry of a Client's Lawyer
                                     Concerning Litigation, Claims, and
                                     Assessments
2510..............................  Auditing Inventories \24\
2600..............................  Special Topics
2601..............................  Consideration of an Entity's Use of
                                     a Service Organization \25\
2605..............................  Consideration of the Internal Audit
                                     Function \26\
2610..............................  Initial Audits--Communications
                                     Between Predecessor and Successor
                                     Auditors \27\
2700..............................  Auditor's Responsibilities Regarding
                                     Supplemental and Other Information
2701..............................  Auditing Supplemental Information
                                     Accompanying Audited Financial
                                     Statements
2705..............................  Required Supplementary Information
2710..............................  Other Information in Documents
                                     Containing Audited Financial
                                     Statements \28\
2800..............................  Concluding Audit Procedures
2801..............................  Subsequent Events
2805..............................  Management Representations
2810..............................  Evaluating Audit Results
2815..............................  The Meaning of ``Present Fairly in
                                     Conformity with Generally Accepted
                                     Accounting Principles''
2820..............................  Evaluating Consistency of Financial
                                     Statements
2900..............................  Post-Audit Matters
2901..............................  Consideration of Omitted Procedures
                                     After the Report Date
2905..............................  Subsequent Discovery of Facts
                                     Existing at the Date of the
                                     Auditor's Report
------------------------------------------------------------------------
Auditor Reporting
------------------------------------------------------------------------
3100..............................  Reporting on Audits of Financial
                                     Statements
3101..............................  Reports on Audited Financial
                                     Statements \29\
3110..............................  Dating of the Independent Auditor's
                                     Report
3200..............................  Reserved
3300..............................  Other Reporting Topics
3305..............................  Special Reports
3310..............................  Special Reports on Regulated
                                     Companies \30\
3315..............................  Reporting on Condensed Financial
                                     Statements and Selected Financial
                                     Data
3320..............................  Association with Financial
                                     Statements
------------------------------------------------------------------------
Matters Relating to Filings Under Federal Securities Laws
------------------------------------------------------------------------
4101..............................  Responsibilities Regarding Filings
                                     Under Federal Securities Statutes
                                     \31\
4105..............................  Reviews of Interim Financial
                                     Information \32\
5000..............................  Reserved
------------------------------------------------------------------------
Other Matters Associated with Audits
------------------------------------------------------------------------
6101..............................  Letters for Underwriters and Certain
                                     Other Requesting Parties
6105..............................  Reports on the Application of
                                     Accounting Principles
6110..............................  Compliance Auditing Considerations
                                     in Audits of Recipients of
                                     Governmental Financial Assistance
                                     \33\
6115..............................  Reporting on Whether a Previously
                                     Reported Material Weakness
                                     Continues to Exist
------------------------------------------------------------------------


[[Page 36644]]

     
---------------------------------------------------------------------------

    \22\ AU sec. 161 is entitled, The Relationship of Generally 
Accepted Auditing Standards to Quality Control Standards. The Board 
is amending the title of this standard to make it more consistent in 
style with other standards without changing its substance.
    \23\ AU sec. 341 is entitled, The Auditor's Consideration of an 
Entity's Ability to Continue as a Going Concern. The Board is 
amending the title of this standard to make it more consistent in 
style with other standards without changing its substance.
    \24\ AU sec. 331 is entitled, Inventories. The Board is amending 
the title of this standard to make it more consistent in style with 
other standards without changing its substance.
    \25\ AU sec. 324 is entitled, Service Organizations. The Board 
is amending the title of this standard to make it more consistent in 
style with other standards without changing its substance.
    \26\ AU sec. 322 is entitled, The Auditor's Consideration of the 
Internal Audit Function in an Audit of Financial Statements. The 
Board is amending the title of this standard to make it more 
consistent in style with other standards without changing its 
substance.
    \27\ AU sec. 315 is entitled, Communications Between Predecessor 
and Successor Auditors. The Board is amending the title of this 
standard to clarify the subject of the standard without changing its 
substance. Additionally, this standard addresses audits of financial 
statements that have been audited previously.
    \28\ The Board has proposed a new auditing standard, The 
Auditor's Responsibilities Regarding Other Information in Certain 
Documents Containing Audited Financial Statements and the Related 
Auditor's Report. See PCAOB Release No. 2013-005 (August 13, 2013). 
If adopted by the Board and approved by the SEC, that proposed 
standard would become AS 2710.
    \29\ The Board has proposed a new auditing standard, The 
Auditor's Report on an Audit of Financial Statements When the 
Auditor Expresses an Unqualified Opinion. See Proposed Auditing 
Standards--The Auditor's Report on an Audit of Financial Statements 
When the Auditor Expresses an Unqualified Opinion; The Auditor's 
Responsibilities Regarding Other Information in Certain Documents 
Containing Audited Financial Statements and the Related Auditor's 
Report; and Related Amendments to PCAOB Standards, PCAOB Release No. 
2013-005 (August 13, 2013). If adopted by the Board and approved by 
the SEC, that proposed standard would substantially amend AS 3101.
    \30\ AU sec. 544 is entitled, Lack of Conformity With Generally 
Accepted Accounting Principles. The Board is amending the title of 
this standard to clarify the subject of the standard without 
changing its substance.
    \31\ AU sec. 711 is entitled, Filings Under Federal Securities 
Statutes. The Board is amending the title of this standard to 
clarify the subject of the standard without changing its substance.
    \32\ AU sec. 722 is entitled, Interim Financial Information. The 
Board is amending the title of this standard to clarify the subject 
of the standard without changing its substance.
    \33\ AU sec. 801 is entitled, Compliance Auditing Considerations 
in Audits of Governmental Entities and Recipients of Governmental 
Financial Assistance. The Board is amending the title of this 
standard to clarify the subject of the standard without changing its 
substance.
---------------------------------------------------------------------------

Comparison of Existing PCAOB Auditing Standards to Reorganization of 
PCAOB Auditing Standards
    The following presents the existing PCAOB auditing standards (``AS 
No.'' or ``AU sec.'') along with their respective AS reference under 
the adopted reorganization of PCAOB auditing standards.
    Standards that note ``Rescind'' in the AS Reference column are 
existing standards that the Board is rescinding in conjunction with the 
reorganization.
---------------------------------------------------------------------------

    \34\ Auditing Standard No. 1 is superseded as a result of the 
amendments made to other standards.

------------------------------------------------------------------------
 PCAOB reference  (AU section
          or AS No.)                 Current title        AS reference
------------------------------------------------------------------------
AS No. 1......................  References in           Supersede.\34\
                                 Auditors' Reports to
                                 the Standards of the
                                 Public Company
                                 Accounting Oversight
                                 Board.
AS No. 3......................  Audit Documentation...  1215.
AS No. 4......................  Reporting on Whether a  6115.
                                 Previously Reported
                                 Material Weakness
                                 Continues to Exist.
AS No. 5......................  An Audit of Internal    2201.
                                 Control Over
                                 Financial Reporting
                                 That Is Integrated
                                 with An Audit of
                                 Financial Statements.
AS No. 6......................  Evaluating Consistency  2820.
                                 of Financial
                                 Statements.
AS No. 7......................  Engagement Quality      1220.
                                 Review.
AS No. 8......................  Audit Risk............  1101.
AS No. 9......................  Audit Planning........  2101.
AS No. 10.....................  Supervision of the      1201.
                                 Audit Engagement.
AS No. 11.....................  Consideration of        2105.
                                 Materiality in
                                 Planning and
                                 Performing an Audit.
AS No. 12.....................  Identifying and         2110.
                                 Assessing Risks of
                                 Material Misstatement.
AS No. 13.....................  The Auditor's           2301.
                                 Responses to the
                                 Risks of Material
                                 Misstatement.
AS No. 14.....................  Evaluating Audit        2810.
                                 Results.
AS No. 15.....................  Audit Evidence........  1105.
AS No. 16.....................  Communications with     1301.
                                 Audit Committees.
AS No. 17.....................  Auditing Supplemental   2701.
                                 Information
                                 Accompanying Audited
                                 Financial Statements.
AS No. 18.....................  Related Parties.......  2410.
AU sec. 110...................  Responsibilities and    1001.
                                 Functions of the
                                 Independent Auditor.
AU sec. 150...................  Generally Accepted      Rescind.
                                 Auditing Standards.
AU sec. 161...................  The Relationship of     1110.
                                 Generally Accepted
                                 Auditing Standards to
                                 Quality Control
                                 Standards.
AU sec. 201...................  Nature of the General   Rescind.
                                 Standards.
AU sec. 210...................  Training and            1010.
                                 Proficiency of the
                                 Independent Auditor.
AU sec. 220...................  Independence..........  1005.
AU sec. 230...................  Due Professional Care   1015.
                                 in the Performance of
                                 Work.
AU sec. 315...................  Communications Between  2610.
                                 Predecessor and
                                 Successor Auditors.
AU sec. 316...................  Consideration of Fraud  2401.
                                 in a Financial
                                 Statement Audit.
AU sec. 317...................  Illegal Acts by         2405.
                                 Clients.
AU sec. 322...................  The Auditor's           2605.
                                 Consideration of the
                                 Internal Audit
                                 Function in an Audit
                                 of Financial
                                 Statements.
AU sec. 324...................  Service Organizations.  2601.
AU sec. 325...................  Communications About    1305.
                                 Control Deficiencies
                                 in an Audit of
                                 Financial Statements.
AU sec. 328...................  Auditing Fair Value     2502.
                                 Measurements and
                                 Disclosures.
AU sec. 329...................  Substantive Analytical  2305.
                                 Procedures.
AU sec. 330...................  The Confirmation        2310.
                                 Process.
AU sec. 331...................  Inventories...........  2510.
AU sec. 332...................  Auditing Derivative     2503.
                                 Instruments, Hedging
                                 Activities, and
                                 Investments in
                                 Securities.
AU sec. 333...................  Management              2805.
                                 Representations.
AU sec. 336...................  Using the Work of a     1210.
                                 Specialist.
AU sec. 337...................  Inquiry of a Client's   2505.
                                 Lawyer Concerning
                                 Litigation, Claims,
                                 and Assessments.

[[Page 36645]]

 
AU sec. 341...................  The Auditor's           2415.
                                 Consideration of an
                                 Entity's Ability to
                                 Continue as a Going
                                 Concern.
AU sec. 342...................  Auditing Accounting     2501.
                                 Estimates.
AU sec. 350...................  Audit Sampling........  2315.
AU sec. 390...................  Consideration of        2901.
                                 Omitted Procedures
                                 After the Report Date.
AU sec. 410...................  Adherence to Generally  Rescind.
                                 Accepted Accounting
                                 Principles.
AU sec. 411...................  The Meaning of Present  2815.
                                 Fairly in Conformity
                                 With Generally
                                 Accepted Accounting
                                 Principles.
AU sec. 504...................  Association With        3320.
                                 Financial Statements.
AU sec. 508...................  Reports on Audited      3101.
                                 Financial Statements.
AU sec. 530...................  Dating of the           3110.
                                 Independent Auditor's
                                 Report.
AU sec. 532...................  Restricting the Use of  Rescind.
                                 an Auditor's Report.
AU sec. 534...................  Reporting on Financial  Not Included.
                                 Statements Prepared
                                 for Use in Other
                                 Countries.
AU sec. 543...................  Part of Audit           1205.
                                 Performed by Other
                                 Independent Auditors.
AU sec. 544...................  Lack of Conformity      3310.
                                 With Generally
                                 Accepted Accounting
                                 Principles.
AU sec. 550...................  Other Information in    2710.
                                 Documents Containing
                                 Audited Financial
                                 Statements.
AU sec. 552...................  Reporting on Condensed  3315.
                                 Financial Statements
                                 and Selected
                                 Financial Data.
AU sec. 558...................  Required Supplementary  2705.
                                 Information.
AU sec. 560...................  Subsequent Events.....  2801.
AU sec. 561...................  Subsequent Discovery    2905.
                                 of Facts Existing at
                                 the Date of the
                                 Auditor's Report.
AU sec. 623...................  Special Reports.......  3305.
AU sec. 625...................  Reports on the          6105.
                                 Application of
                                 Accounting Principles.
AU sec. 634...................  Letters for             6101.
                                 Underwriters and
                                 Certain Other
                                 Requesting Parties.
AU sec. 711...................  Filings Under Federal   4101.
                                 Securities Statutes.
AU sec. 722...................  Interim Financial       4105.
                                 Information.
AU sec. 801...................  Compliance Auditing     6110.
                                 Considerations in
                                 Audits of
                                 Governmental Entities
                                 and Recipients of
                                 Governmental
                                 Financial Assistance.
AU sec. 901...................  Public Warehouses--     Rescind.
                                 Controls and Auditing
                                 Procedures for Goods
                                 Held.
------------------------------------------------------------------------

Comparison of the Reorganization of PCAOB Auditing Standards to 
Existing PCAOB Auditing Standards and the Standards of the 
International Auditing and Assurance Standards Board and Auditing 
Standards Board
    The following presents the adopted reorganization of PCAOB auditing 
standards (``AS'') along with their references in existing PCAOB 
auditing standards and the analogous standards of the International 
Auditing and Assurance Standards Board (``IAASB'') and the Auditing 
Standards Board of the American Institute of Certified Public 
Accountants (``ASB'').
---------------------------------------------------------------------------

    \35\ The responsibilities, functions, training, and proficiency 
of the independent auditor; independence requirements; exercising 
due professional care; and audit risk are included in multiple PCAOB 
standards (AS 1001, 1005, 1010, 1015, and 1101, respectively) but 
are included in one IAASB standard (ISA 200) and one ASB standard 
(AU-C 200).
    \36\ The relationship of auditing standards to quality control 
standards, supervision of the audit engagement, and engagement 
quality review are covered in separate PCAOB standards (AS 1110, 
1201, and 1220, respectively) but are included in one IAASB standard 
(ISA 220) and one ASB standard (AU-C 220).
    \37\ Under PCAOB standards, agreeing to the terms of an audit 
and communications with audit committees are covered in one 
standard, whereas those subjects are covered by separate standards 
under IAASB standards (ISA 210 and 260, respectively) and ASB 
standards (AU-C 210 and 260, respectively).
    \38\ The PCAOB has a standard for auditing internal control over 
financial reporting when auditing financial statements. The IAASB 
does not have a standard on auditing internal control over financial 
reporting, and the ASB addresses that subject in its attestation 
standards (AT 501).
    \39\ Under PCAOB standards, substantive analytical procedures 
are covered in a separate standard (AS 2305) and analytical 
procedures performed in the overall review are included in the 
standard on evaluating audit results (AS 2810), whereas those 
subjects are both included in one IAASB standard (ISA 520) and one 
ASB standard (AU-C 520).
    \40\ The PCAOB has separate standards for auditing accounting 
estimates (AS 2501) and auditing fair value measurements and 
disclosures (AS 2502), whereas the IAASB and ASB standards each have 
one standard on auditing accounting estimates including fair value 
estimates and disclosures (ISA 540 and AU-C 540, respectively).
    \41\ The PCAOB has a separate standard for auditing derivative 
instruments, hedging activities, and investments in securities (AS 
2503). In ASB standards, that subject is included in the standard on 
specific considerations regarding audit evidence (AU-C 501). The 
IAASB has a practice note on auditing financial instruments but does 
not have a standard on the subject.
    \42\ The PCAOB has a separate standard on inquiry of a client's 
lawyers (AS 2505). In IAASB and ASB standards, inquiry of a client's 
lawyers is included in the standard on specific considerations 
regarding audit evidence (ISA 501 and AU-C 501, respectively).
    \43\ The PCAOB has a separate standard on auditing inventories 
(AS 2510). In IAASB and ASB standards, auditing inventories is 
included in the standard on specific considerations regarding audit 
evidence (ISA 501 and AU-C 501, respectively).
    \44\ In PCAOB standards, the subjects of subsequent events and 
subsequent discovery of facts existing at the report date are 
covered by separate standards (AS 2801 and 2905, respectively). In 
IAASB and ASB standards, those subjects are included in the standard 
on subsequent events (ISA 560 and AU-C 560, respectively).
    \45\ In PCAOB standards, the subject of evaluating audit results 
is covered in one standard (AS 2810). In IAASB and ASB standards, 
various topics related to evaluating audit results are covered in 
multiple standards, particularly, the standards related to the 
auditor's responsibilities regarding fraud, the auditor's responses 
to assessed risks, evaluation of misstatements, audit evidence, and 
analytical procedures (ISA 240, 330, 450, 500, and 520 and AU-C 240, 
330, 450, 500, and 520, respectively).
    \46\ The PCAOB has separate standards on the subjects of present 
fairly in conformity with generally accepted accounting principles 
(AS 2815) and reporting on audited financial statements, including 
emphasis paragraphs, departures from the standard opinion, and 
reporting on comparative statements (AS 3101). In IAASB and ASB 
standards, the subject of presenting fairly is included in the 
standard on forming an opinion and reporting on audited financial 
statements (ISA 700 and AU-C 700, respectively), but there are 
separate standards for emphasis paragraphs and departures from the 
standard opinion (ISA 705 and 706, respectively, and AU-C 705 and 
706, respectively). In IAASB standards, reporting on comparative 
financial statements also is covered in a separate standard (ISA 
710), whereas that subject is included in the ASB standard on 
forming an opinion and reporting on audited financial statements 
(AU-C 700).
    \47\ Under PCAOB standards, the subject of dating the 
independent auditor's report is covered in a single standard (AS 
3110). Under IAASB and ASB standards, the standard requirement for 
dating the auditor's report is covered in the reporting standard 
(ISA 700 and AU-C 700, respectively), and the subject of dating the 
auditor's report when there is a subsequent discovery of facts is 
covered in the subsequent events standard (ISA 560 and AU-C 560, 
respectively).
    \48\ Under PCAOB standards, financial statements prepared in 
accordance with special purpose frameworks and reporting on 
specified elements, accounts or items of a financial statement are 
covered in one standard (AS 3305). Under IAASB and ASB standards, 
those subjects are covered by separate standards (ISA 800 and 805, 
respectively) and ASB standards (AU-C 800 and 805, respectively). 
Reporting on compliance with contractual agreements or regulatory 
requirements in connection with audited financial statements also is 
covered by the PCAOB standard, whereas that subject is not covered 
by the IAASB standards and is covered by a separate ASB standard 
(AU-C 806).
    \49\ Under PCAOB standards, the subject of reporting on 
financial statements prepared in accordance with a regulatory basis 
of accounting is covered in a separate standard (AS 3310). That 
subject is covered in the IAASB standard on agreeing to the terms of 
audit engagements (ISA 210) and in the ASB standard on financial 
statements prepared in accordance with special purpose frameworks 
(AU-C 800).
    \50\ In PCAOB standards, the subject of conducting a review of 
interim financial information is covered in AS 4105. Under IAASB 
standards, that subject is covered in their review standards 
(International Standard on Review Engagements 2410). Reviewing 
interim financial information is covered by the ASB standards in AU-
C 930.

[[Page 36646]]



--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                               Analogous IAASB standard
     AS reference              Title             PCAOB reference (AU section or AS No.)                 (ISA)              Analogous ASB standard (AU-C)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1001.................  Responsibilities and  AU sec. 110..................................  200 \35\.....................  200.
                        Functions of the
                        Independent Auditor.
1005.................  Independence........  AU sec. 220..................................  200..........................  200.
1010.................  Training and          AU sec. 210..................................  200..........................  200.
                        Proficiency of the
                        Independent Auditor.
1015.................  Due Professional      AU sec. 230..................................  200..........................  200.
                        Care in the
                        Performance of Work.
1101.................  Audit Risk..........  AS No. 8.....................................  200..........................  200.
1105.................  Audit Evidence......  AS No. 15....................................  500..........................  500.
1110.................  Relationship of       AU sec. 161..................................  220 \36\.....................  220.
                        Auditing Standards
                        to Quality Control
                        Standards.
1201.................  Supervision of the    AS No. 10....................................  220..........................  220.
                        Audit Engagement.
1205.................  Part of the Audit     AU sec. 543..................................  600..........................  600.
                        Performed by Other
                        Independent
                        Auditors.
1210.................  Using the Work of a   AU sec. 336..................................  500, 620.....................  500, 620.
                        Specialist.
1215.................  Audit Documentation.  AS No. 3.....................................  230..........................  230.
1220.................  Engagement Quality    AS No. 7.....................................  220..........................  220.
                        Review.
1301.................  Communications with   AS No. 16....................................  210, 260 \37\................  210, 260.
                        Audit Committees.
1305.................  Communications About  AU sec. 325..................................  265..........................  265.
                        Control
                        Deficiencies in an
                        Audit of Financial
                        Statements.
2101.................  Audit Planning......  AS No. 9.....................................  300..........................  300.
2105.................  Consideration of      AS No. 11....................................  320..........................  320.
                        Materiality in
                        Planning and
                        Performing an Audit.
2110.................  Identifying and       AS No. 12....................................  315..........................  315.
                        Assessing Risks of
                        Material
                        Misstatement.
2201.................  An Audit of Internal  AS No. 5.....................................  N/A \38\.....................  AT 501.
                        Control Over
                        Financial Reporting
                        That Is Integrated
                        with An Audit of
                        Financial
                        Statements.
2301.................  The Auditor's         AS No. 13....................................  330..........................  330.
                        Responses to the
                        Risks of Material
                        Misstatement.
2305.................  Substantive           AU sec. 329..................................  520 \39\.....................  520.
                        Analytical
                        Procedures.
2310.................  The Confirmation      AU sec. 330..................................  505..........................  505.
                        Process.
2315.................  Audit Sampling......  AU sec. 350..................................  530..........................  530.
2401.................  Consideration of      AU sec. 316..................................  240..........................  240.
                        Fraud in a
                        Financial Statement
                        Audit.
2405.................  Illegal Acts by       AU sec. 317..................................  250..........................  250.
                        Clients.
2410.................  Related Parties.....  AS No. 18....................................  550..........................  550.
2415.................  Consideration of an   AU sec. 341..................................  570..........................  570.
                        Entity's Ability to
                        Continue as a Going
                        Concern.
2501.................  Auditing Accounting   AU sec. 342..................................  540 \40\.....................  540.
                        Estimates.
2502.................  Auditing Fair Value   AU sec. 328..................................  540..........................  540.
                        Measurements and
                        Disclosures.
2503.................  Auditing Derivative   AU sec. 332..................................  N/A \41\.....................  501.
                        Instruments,
                        Hedging Activities,
                        and Investments in
                        Securities.
2505.................  Inquiry of a          AU sec. 337..................................  501 \42\.....................  501.
                        Client's Lawyer
                        Concerning
                        Litigation, Claims,
                        and Assessments.
2510.................  Auditing Inventories  AU sec. 331..................................  501 \43\.....................  501.
2601.................  Consideration of an   AU sec. 324..................................  402..........................  402.
                        Entity's Use of a
                        Service
                        Organization.
2605.................  Consideration of the  AU sec. 322..................................  610..........................  610.
                        Internal Audit
                        Function.
2610.................  Initial Audits--      AU sec. 315..................................  510..........................  510.
                        Communications
                        Between Predecessor
                        and Successor
                        Auditors.
2701.................  Auditing              AS No. 17....................................  N/A..........................  725.
                        Supplemental
                        Information
                        Accompanying
                        Audited Financial
                        Statements.
2705.................  Required              AU sec. 558..................................  N/A..........................  730.
                        Supplementary
                        Information.
2710.................  Other Information in  AU sec. 550..................................  720..........................  720.
                        Documents
                        Containing Audited
                        Financial
                        Statements.
2801.................  Subsequent Events...  AU sec. 560..................................  560 \44\.....................  560.
2805.................  Management            AU sec. 333..................................  580..........................  580.
                        Representations.

[[Page 36647]]

 
2810.................  Evaluating Audit      AS No. 14....................................  240, 330, 450, 500, 520 \45\.  240, 330, 450, 500, 520.
                        Results.
2815.................  The Meaning of        AU sec. 411..................................  700 \46\.....................  700.
                        ``Present Fairly in
                        Conformity with
                        Generally Accepted
                        Accounting
                        Principles``.
2820.................  Evaluating            AS No. 6.....................................  N/A..........................  708.
                        Consistency of
                        Financial
                        Statements.
2901.................  Consideration of      AU sec. 390..................................  N/A..........................  585.
                        Omitted Procedures
                        After the Report
                        Date.
2905.................  Subsequent Discovery  AU sec. 561..................................  560..........................  560.
                        of Facts Existing
                        at the Date of the
                        Auditor's Report.
3101.................  Reports on Audited    AU sec. 508..................................  700, 705, 706, 710...........  700, 705, 706.
                        Financial
                        Statements.
3110.................  Dating of the         AU sec. 530..................................  560, 700 \47\................  560, 700.
                        Independent
                        Auditor's Report.
3305.................  Special Reports.....  AU sec. 623..................................  800, 805 \48\................  800, 805, 806.
3310.................  Special Reports on    AU sec. 544..................................  210 \49\.....................  800.
                        Regulated Companies.
3315.................  Reporting on          AU sec. 552..................................  810..........................  810.
                        Condensed Financial
                        Statements and
                        Selected Financial
                        Data.
3320.................  Association with      AU sec. 504..................................  N/A..........................  Withdrawn by ASB.
                        Financial
                        Statements.
4101.................  Responsibilities      AU sec. 711..................................  N/A..........................  925.
                        Regarding Filings
                        Under Federal
                        Securities Statutes.
4105.................  Reviews of Interim    AU sec. 722..................................  ISRE 2410 \50\...............  930.
                        Financial
                        Information.
6101.................  Letters for           AU sec. 634..................................  N/A..........................  920.
                        Underwriters and
                        Certain Other
                        Requesting Parties.
6105.................  Reports on the        AU sec. 625..................................  N/A..........................  915.
                        Application of
                        Accounting
                        Principles.
6110.................  Compliance Auditing   AU sec. 801..................................  N/A..........................  935.
                        Considerations in
                        Audits of
                        Recipients of
                        Governmental
                        Financial
                        Assistance.
6115.................  Reporting on Whether  AS No. 4.....................................  N/A..........................  N/A.
                        a Previously
                        Reported Material
                        Weakness Continues
                        to Exist.
--------------------------------------------------------------------------------------------------------------------------------------------------------

(b) Statutory Basis
    The statutory basis for the proposed rules is Title I of the Act.

B. Board's Statement on Burden on Competition

    Not applicable. The Board's consideration of the economic impacts 
of the proposed rules is discussed in section D.

C. Board's Statement on Comments on the Proposed Rules Received From 
Members, Participants or Others

    The Board initially released the proposed rules for public comment 
on March 26, 2013, in PCAOB Release No. 2013-002. The original proposal 
was discussed with members of the academic community at the PCAOB's 
Academic Conference on April 26, 2013 and with the PCAOB's Standing 
Advisory Group (``SAG'') on May 15, 2013. The Board received 19 comment 
letters on the original proposal.
    On May 7, 2014, the Board released a supplemental request for 
comment on the proposed reorganization in PCAOB Release No. 2014-001. 
In conjunction with issuing the supplemental request, the Board also 
released on its website a demonstration version of the reorganized 
auditing standards to facilitate review and comment on the proposed 
amendments. The online demonstration version presented the existing 
auditing standards as they would look if reorganized according to the 
proposed amendments included in the supplemental request. The Board 
received 7 comment letters on the supplemental request.
    The Board has carefully considered all comments received. The 
Board's response to the comments it received and the changes made to 
the rules in response to the comments received are discussed below.
Comments on the Proposed Approach for Reorganizing PCAOB Auditing 
Standards
    Commenters generally supported the proposed reorganization of PCAOB 
auditing standards. Commenters that supported the Board's use of a 
distinguishable organizational structure generally supported the 
category and subcategory approach to reorganizing the auditing 
standards and the use of a four-digit numbering system.
    The Board has made certain refinements to the reorganization that 
are consistent with comments received. Those changes include: Moving 
the subcategory ``Auditing Internal Control Over Financial Reporting'' 
and its related standard to follow the subcategory ``Audit Planning and 
Risk Assessment''; \51\ moving Auditing Standard No. 4, Reporting on 
Whether a Previously Reported Material Weakness Continues to Exist, to 
the ``Other Matters Associated with Audits'' category; \52\ changing 
the title of existing standard AU sec. 331, Inventories, to ``Auditing 
Inventories''; \53\ and expanding the numbering interval between 
standards to allow more flexibility for future standard setting.\54\
---------------------------------------------------------------------------

    \51\ The illustration of the reorganized auditing standards 
presented above reflects the movement of the subcategory ``Auditing 
Internal Control Over Financial Reporting'' and its related standard 
after the subcategory ``Audit Planning and Risk Assessment.''
    \52\ The illustration of the reorganized auditing standards 
presented above reflects the amendments to move this standard to the 
category ``Other Matters Associated with Audits.''
    \53\ In addition to this name change, the illustration of the 
reorganized auditing standards presented above reflects the 
amendments to change the auditing standard titles to make them more 
consistent in style with other standards or to clarify the subject 
of the standard. These changes include: (i) Renaming subcategory 
2700 as ``Auditor's Responsibilities Regarding Supplemental and 
Other Information'' (from ``Auditor's Responsibilities Regarding 
Supplementary and Other Information'') to be consistent with the 
title of AS 2701, Auditing Supplemental Information Accompanying 
Audited Financial Statements, and (ii) changing the reference number 
of AS 3105, Dating of the Independent Auditor's Report, to AS 3110 
to make room if the proposed auditing standard, The Auditor's Report 
on an Audit of Financial Statements When the Auditor Expresses an 
Unqualified Opinion, is adopted by the Board.
    \54\ The supplemental request included a refinement to generally 
expand the numbering interval within the subcategories from a four-
digit number structure using consecutive numbering to using 
increments of five. This change allows for more flexibility for 
future standards. However, the amendments do not change the 
intervals between AS 2501, Auditing Accounting Estimates, AS 2502, 
Auditing Fair Value Measurements and Disclosures, and AS 2503, 
Auditing Derivative Instruments, Hedging Activities, and Investments 
in Securities, as the Board has a standard-setting project that is, 
among other things, considering a combined standard to include the 
topics addressed by these standards. As part of that project, the 
Board will decide which topics, if any, to combine, which topics 
will be maintained as separate standards, and whether the numbering 
of these standards should be modified.

---------------------------------------------------------------------------

[[Page 36648]]

    Some commenters suggested other changes to certain categories and 
subcategories. For example, some commenters suggested renaming 
subcategory 2200 ``Audit Procedures in Response to Risks--Nature, 
Timing, and Extent'' as ``Audit Evidence'' and eliminating 
subcategories 2300 (``Audit Procedures for Specific Aspects of the 
Audit'') and 2400 (``Audit Procedures for Certain Accounts or 
Disclosures''). Those commenters also suggested moving the auditing 
standards under those subcategories into the retitled subcategory 
because such standards relate to obtaining audit evidence. However, 
those commenters did not suggest moving other standards that also 
involve obtaining audit evidence, such as the standard on identifying 
and assessing risks. Revising the titles of certain categories and 
subcategories to be more general, thereby encompassing more standards, 
would make the reorganized standards more difficult to navigate and 
would not follow the audit process as closely as the proposed 
reorganization. Therefore these changes were not made.
    The Board also received comments that suggested moving individual 
standards to different categories. Some commenters suggested moving AU 
sec. 336, Using the Work of a Specialist, and AU sec. 543, Part of 
Audit Performed by Other Independent Auditors, from the ``General 
Auditing Standards'' category to the ``Audit Procedures'' category as 
these standards include specific auditing procedures. Another commenter 
suggested keeping these standards within the general category but 
moving them into a new subcategory titled ``Using the Work of Others.'' 
These changes were not made. These standards were intentionally placed 
near Auditing Standard No. 10, Supervision of the Audit Engagement, 
because, in certain situations, other auditors and auditors' 
specialists already are required to be supervised pursuant to that 
supervision standard. Also, some commenters suggested moving one or 
more of the following standards from the ``Audit Procedures'' category 
to the ``Auditor Reporting'' category as these standards include 
aspects related to reporting on the financial statements: (i) Auditing 
Standard No. 17, Auditing Supplemental Information Accompanying Audited 
Financial Statements; (ii) AU sec. 558, Required Supplementary 
Information; and (iii) Auditing Standard No. 6, Evaluating Consistency 
of Financial Statements. However, moving these standards to the 
reporting section of the reorganization might lead auditors to overlook 
performance requirements in those standards. Thus, those three 
standards remain in the ``Audit Procedures'' category.
Comments on Rescinding Certain Interim Auditing Standards
    Some commenters suggested retaining AU sec. 532, noting that 
auditors sometimes need to restrict the use of their reports, and 
expressed a concern that rescinding AU sec. 532 might be perceived as 
precluding auditors from restricting the use of those reports. The 
commenters cited examples of specific situations in which the use of 
audit reports should be restricted and indicated that auditors look to 
AU sec. 532 for the applicable reporting language. The Board observed 
that the examples cited by the commenters related to situations that 
were already addressed by other PCAOB standards or rules.\55\ 
Accordingly, retaining AU sec. 532 is unnecessary in those situations.
---------------------------------------------------------------------------

    \55\ Specifically, commenters cited situations covered by AU 
sec. 325, Communications About Control Deficiencies in an Audit of 
Financial Statements, and AU sec. 623, Special Reports, which 
address use restrictions in those situations. One commenter 
identified PCAOB Rule 3524, Audit Committee Pre-approval of Certain 
Tax Services, Rule 3525, Audit Committee Pre-approval of Non-audit 
Services Related to Internal Control Over Financial Reporting, and 
Rule 3526, Communication with Audit Committees Concerning 
Independence. That commenter acknowledged, however, that those 
communications are not reports that are covered by AU sec. 532, 
which applies to audit reports that are the ``by-product'' of an 
audit.
---------------------------------------------------------------------------

    Commenters also cited Auditing Standard No. 16, Communications with 
Audit Committees, but that standard, by its terms, does not require the 
auditor to restrict the use of audit committee communications. Since 
the comments received did not identify a specific need for retaining AU 
sec. 532, the Board asked in the supplemental request for examples of 
situations that support keeping this standard.
    Some commenters also raised questions regarding restricting the use 
of audit committee communications under Auditing Standard No. 16. 
Specifically, commenters observed that footnote 41 of Auditing Standard 
No. 16 cites AU sec. 532 and that AU sec. 532, as amended, lists audit 
committee communications pursuant to Auditing Standard No. 16 as ``by-
product'' reports whose use should be restricted.\56\ However, even in 
the absence of AU sec. 532, nothing precludes auditors from restricting 
the use of communications to audit committees under Auditing Standard 
No. 16.\57\ Therefore, the Board is rescinding AU sec. 532 as proposed.
---------------------------------------------------------------------------

    \56\ See paragraphs .07 and .11 of AU sec. 532. AU sec. 532.07 
also listed reports issued pursuant to AU sec. 325 and AU sec. 623 
as by-product reports.
    \57\ If an auditor decides to restrict the use of certain 
reports to a company's audit committee, he or she may consider the 
direction provided by other standards that address restricting the 
use of reports, such as AS 1305.06 (formerly AU sec. 325.6). That 
standard requires that the auditor's written communication to the 
audit committee include a statement that the communication is 
intended solely for the information and use of the board of 
directors, audit committee, management, and others within the 
organization. It further provides that when there are requirements 
established by governmental authorities to furnish such written 
communications, specific reference to such regulatory authorities 
may be made.
---------------------------------------------------------------------------

    The Board also received comments about retaining or rescinding 
other interim auditing standards. One commenter suggested retaining AU 
sec. 901 and combining it with AU sec. 331, Inventories. As discussed 
in the original proposal, AU sec. 901 reports the conclusions of a 1966 
study of the AICPA Committee on Auditing Procedure on the 
accountability of warehousemen for goods stored in public warehouses. 
AU sec. 901 is unnecessary because the specific auditing requirements 
regarding inventory held in public warehouses are set forth in AU sec. 
331. Therefore, the Board is rescinding this standard as proposed.
    A commenter suggested rescinding AU sec. 625, Reports on the 
Application of Accounting Principles, AU sec. 801, Compliance Auditing 
Considerations in Audits of Governmental Entities and Recipients of 
Governmental Financial Assistance, and AU sec. 544, Lack of Conformity 
with Generally Accepted Accounting Principles. Another commenter 
expressed support for retaining AU sec. 625. The Board is not 
rescinding these standards at this time because they cover situations 
that may be related to audits of issuers.
Comments on Interpretive Publications
    Some commenters suggested that the PCAOB retain the practice of 
presenting interpretations with the related auditing standards along 
with adding other Board-issued guidance. Another commenter suggested a 
numbering convention analogous to the existing auditing 
interpretations, specifically, using a ``9'' prefix before the standard 
number. The Board is adopting the

[[Page 36649]]

organizational structure and numbering of the auditing interpretations 
as proposed. It is important to distinguish standards from auditing 
interpretations and guidance because, among other reasons, an auditor's 
responsibility related to auditing standards differs from the auditor's 
responsibility regarding auditing interpretations and other 
interpretive publications. The Board is also adopting the numbering 
convention as presented in the supplemental request. The titles of the 
interpretations (along with the hyperlinks) identify the corresponding 
standards, which should help auditors and other users associate the 
interpretations with their related standards. The Board will continue 
to assess the need to update the guidance in the auditing 
interpretations.
    The Board proposed to remove from PCAOB auditing standards 
references to AICPA Audit and Accounting Guides and AICPA auditing 
Statements of Position. Commenters responded that auditors historically 
have used audit and accounting guides in their audits of companies in 
specialized industries, and they offered a variety of suggestions about 
how the Board should treat them, such as retaining the existing 
references in PCAOB standards, acknowledging the usefulness of current 
editions of the guides, or replacing them with the Board's own 
specialized industry guidance.
    The Board is adopting the amendments to remove references to AICPA 
Audit and Accounting Guides and AICPA auditing Statements of Position 
because the guides referenced in PCAOB standards are outdated.\58\ 
While auditors might consider more recent editions of audit and 
accounting guides or other materials to be useful reference materials--
for example, for information about specialized industries--the 
auditor's responsibility is to comply with PCAOB auditing and related 
professional practice standards. In connection with its oversight 
activities, the PCAOB will continue to consider developing guidance on 
the application of PCAOB standards when the need arises.
---------------------------------------------------------------------------

    \58\ AICPA Audit and Accounting Guides and auditing Statements 
of Position referenced in PCAOB standards are the editions of those 
publications as in existence on April 16, 2003.
---------------------------------------------------------------------------

Comments on Amendments to Illustrative Auditor's Reports
    As described above, the Board proposed amendments to update the 
illustrative auditor's reports within the interim standards with the 
requirements in Auditing Standard No. 1 and thus supersede the 
respective auditing standard. Although the Board received no comments 
on its proposal to supersede Auditing Standard No. 1, one commenter 
suggested that the title of illustrative auditor's reports in the 
PCAOB's standards also be revised to reflect the title used in Auditing 
Standard No. 1's illustrative reports (that is, change the title of the 
illustrative reports to ``Report of Independent Registered Public 
Accounting Firm''). The Board is adopting the amendments and 
superseding Auditing Standard No. 1 as proposed and, as suggested, is 
adding amendments to change the title of illustrated reports included 
in the standards. The amendments do not change the requirements for the 
content of the auditor's report.\59\
---------------------------------------------------------------------------

    \59\ For example, the amendments would not preclude an 
unregistered firm that applies PCAOB standards from omitting 
``Registered'' from the title of its report.
---------------------------------------------------------------------------

Comments on Amendments To Remove References to Superseded Standards
    As discussed above, the Board received comments on its amendments 
to remove references to a superseded auditing standard and auditing 
interpretation in interpretation 4 of AT sec. 9101, which includes 
illustrative letters to regulators when they request access to or 
copies of attestation documentation. Commenters indicated that the 
proposed amendments caused the interpretation to lack context because 
the amendments removed the introductory paragraphs to the illustrative 
letters. Therefore, the amendments as adopted by the Board include a 
paragraph that introduces the illustrative letters while eliminating 
the superseded references.
Comments on the Effective Date
    The original proposal requested commenters to provide factors the 
Board should consider in determining the effective date. Factors 
provided by commenters, among other things, included providing 
sufficient time for firms to update their methodologies, reference 
materials, and practice aids and to train staff. One commenter, an 
accounting firm, also suggested using a single transition date as 
opposed to a date dependent on the year end of an issuer, broker, or 
dealer as from that firm's perspective a single date would facilitate a 
more efficient transition to the reorganization.
    After considering the comments received and the timing of the 
adoption of the reorganization, the Board has determined that the 
accompanying reorganization and related amendments will be effective, 
subject to SEC approval, as of December 31, 2016. If the adopted 
amendments accompanying this release are approved by the SEC, nothing 
precludes auditors and others from using and referencing the 
reorganized standards before the effective date, as the amendments do 
not substantively change the standards' requirements.
Other Comments
    The Board received other comments that are not directly related to 
the amendments. Some comments generally related to possible other 
enhancements to the Board's standards or the presentation of standards 
on the PCAOB website, in many cases consistent with potential 
enhancements discussed in the original proposal and supplemental 
request. In general, these suggested enhancements involved:
     Updating outdated references to generally accepted 
accounting principles (``GAAP'') within the auditing standards;
     Reorganizing PCAOB guidance into an integrated topical 
structure;
     Adding links on the website from the auditing standards to 
related guidance; and
     Adding features to the Board's standards on the website, 
such as converting cross-references into hyperlinks.
    The Board plans to address GAAP references in its standards in the 
context of future standard-setting activities because updating these 
references could involve substantive changes to the auditing standards 
that are outside the near-term scope of this project. Also, the Board 
plans to consider ways to enhance the usability of PCAOB guidance. 
Additionally, the Board continues to consider opportunities for 
improving its website.\60\
---------------------------------------------------------------------------

    \60\ The Board updates its website to reflect changes to the 
Board rules and standards that are approved by the SEC. Accordingly, 
if the amendments are approved by the SEC, the PCAOB would update 
its website to reflect the auditing standards as reorganized.
---------------------------------------------------------------------------

    The Board also received comments advocating other actions besides 
reorganizing PCAOB auditing standards as described in the original 
proposal. For example, some of those commenters suggested full 
convergence with the IAASB or ASB standards or adopting the standards 
of the IAASB or ASB and adding incremental requirements for the auditor 
to perform when conducting an audit of an issuer. As the Board has 
explained previously:

    [B]ecause the Board's standards must be consistent with the 
Board's statutory mandate, differences will continue to exist

[[Page 36650]]

between the Board's standards and the standards of the IAASB and ASB 
e.g., when the Board decides to retain an existing requirement in 
PCAOB standards that is not included in IAASB or ASB standards. 
Also, certain differences are often necessary for the Board's 
standards to be consistent with relevant provisions of the federal 
securities laws or other existing standards or rules of the Board. 
Also, the Board's standards-setting activities are informed by and 
developed to some degree, in response to observations from its 
oversight activities.\61\
---------------------------------------------------------------------------

    \61\ See PCAOB Release 2010-004, at A10-91-A10-92.
---------------------------------------------------------------------------

    Nevertheless, the PCAOB continues to consider carefully the work of 
the IAASB and ASB in PCAOB standard-setting projects. Additionally, the 
Board will consider the organization and content of individual 
standards during the course of future standard-setting projects.
    For a discussion on comments received on the cost and benefits of 
the reorganization, see section D.

D. Economic Considerations and Application to Audits of Emerging Growth 
Companies

    This section discusses economic considerations related to the 
reorganization, specifically, the need for rulemaking, alternatives 
considered, description of the baseline, and consideration of benefits 
and costs. It also discusses considerations related to audits of EGCs 
and audits of brokers and dealers.
Need for Rulemaking
    As discussed in more detail in section A, the reorganization 
creates a standardized organizational structure of PCAOB auditing 
standards to enhance the usability of the standards, including helping 
users navigate the standards more easily. This could help auditors, for 
example, find more easily the relevant requirements in PCAOB standards 
for a particular area of the audit, which could facilitate compliance 
with PCAOB standards.
    The reorganization also could help avoid potential confusion 
between the Board's standards and the recently reorganized standards of 
the ASB, if the same AU section reference was used for different 
standards covering different topics.
    In addition, the reorganization would provide a structure for 
updating PCAOB standards in the future.
    Commenters generally supported the reorganization of PCAOB auditing 
standards.
Consideration of Alternatives
    In the original proposal, the Board outlined three alternatives to 
the proposed approach \62\ for reorganizing the standards:
---------------------------------------------------------------------------

    \62\ The Board proposed the approach described in section A 
because it addresses more fully the reasons for the reorganization.
---------------------------------------------------------------------------

    1. Continue issuing sequentially numbered standards until all of 
the interim standards are replaced;
    2. Retain the organizational structure of the existing interim 
standards and assign section numbers to Board-issued standards that 
would fit into the existing organizational structure; or
    3. Adopt the organizational structure of another auditing standard 
setter, such as the IAASB.
    The first alternative would eventually result in a single structure 
and would avoid the potential confusion between PCAOB auditing 
standards and the standards of other standard setters. However, this 
alternative would take years for users to receive its benefits, and, 
under this approach, the standards would be more difficult to navigate 
than a topical system.
    The second alternative would provide little benefit to users 
because it has few categories and is less intuitive than an organized 
structure that follows the flow of the audit process. In addition, as 
the ASB continues to use a three-digit system to reference its 
standards, the potential for confusion between the standards of the 
Board and the standards of the AICPA, as previously discussed in 
section A, would remain.
    The third alternative could be confusing to users if PCAOB 
standards and IAASB standards used the same section numbers for 
standards that address different topics. Similar issues would arise if 
the PCAOB adopted the organizational structure of the clarified ASB 
standards.
    Other commenters suggested that the PCAOB collaborate with other 
standard setters to develop a unified framework for auditing standards 
or to develop a codification of the auditing standards in a manner 
similar to the approach taken by the FASB with its accounting 
standards.\63\ Another commenter suggested that the Board limit time 
spent on this project and instead focus its efforts on other matters on 
the Board's standard-setting agenda. The Board's reorganization of the 
auditing standards provides immediate benefits to users, such as making 
standards easier to navigate and establishing a structure for future 
updates of the standards. Thus, the Board decided to proceed with this 
project.
---------------------------------------------------------------------------

    \63\ For example, this approach might apply an Area, Topic, 
Subtopic, and Section structure.
---------------------------------------------------------------------------

    As previously discussed, the majority of commenters were in favor 
of the Board using a distinguishable organizational structure. Those 
commenters supported the organization as proposed or offered 
suggestions to the proposed reorganization such as changes to the 
titles, categorization, or sequence of existing standards and guidance. 
The Board has made some refinements to the organizational structure and 
amendments presented in the original proposal and supplemental request, 
as discussed above.
Baseline
    The existing organizational structure of PCAOB auditing standards 
is described in section A as consisting of sequentially numbered AS 
standards and AU sections representing the remaining interim standards 
that the Board has not superseded. The Board believes this current 
organizational structure is generally reflected in references made in 
firm methodologies, commercially published guidance, and other 
technology tools, and therefore constitutes the baseline against which 
impacts can be considered.
Consideration of Benefits and Costs
    The reorganization of PCAOB auditing standards involves amendments 
that do not impose additional requirements on auditors or substantively 
change the requirements of PCAOB standards. Thus, the reorganization is 
not expected to affect the manner in which audits are performed and 
reported under PCAOB standards.
    As discussed previously, benefits of the reorganization stem from a 
single, integrated organizational structure for PCAOB auditing 
standards that is easier for auditors and others to use. Among other 
things, this could help auditors find more easily the relevant 
requirements in PCAOB standards for a particular area of the audit, 
which could facilitate compliance with PCAOB standards. It also could 
help avoid the potential for confusion between PCAOB standards and ASB 
standards.
    As discussed in the original proposal, the primary incremental 
costs of the changes related to the reorganization would be costs to 
registered firms of updating references within firm methodologies, 
related reference materials, and practice aids to reflect the new 
citations to PCAOB auditing standards, as well as training on the new 
organizational structure. The adopted reorganization is likely to have 
less cost than approaches suggested by some commenters--for example, a 
unified framework or FASB-like codification--that would involve 
substantial redrafting of PCAOB

[[Page 36651]]

auditing standards and therefore the potential for more extensive 
modifications to registered firms' methodologies and related materials.
    Comments on potential benefits and costs of the proposal generally 
were consistent with these views. Commenters who advocated using the 
IAASB or ASB organizational structure or working with other standard 
setters to develop a unified organizational structure cited additional 
costs associated with supporting compliance with two different sets of 
auditing standards. However, the costs cited by the commenters stem 
principally from differences in the standards themselves rather than 
how they are organized. Furthermore, the reorganization involves 
changing the titles, categorization, or sequence of existing standards 
and guidance; it does not create a new set of auditing standards. In 
addition, reorganizing the standards to make them easier to navigate 
should help users of the standards compare PCAOB standards to IAASB and 
ASB standards.
Application to Audits of Emerging Growth Companies
    The Board does not anticipate that the preceding economic 
considerations would be different for audits of EGCs, as defined by the 
Jumpstart Our Business Startups Act of 2012 (``JOBS Act'').\64\ 
Pursuant to Section 104 of the JOBS Act, any rules adopted by the Board 
subsequent to April 5, 2012, do not apply to the audits of EGCs (as 
defined in Section 3(a)(80) of the Exchange Act) unless the SEC 
``determines that the application of such additional requirements is 
necessary or appropriate in the public interest, after considering the 
protection of investors and whether the action will promote efficiency, 
competition, and capital formation.'' \65\
---------------------------------------------------------------------------

    \64\ See Section 101 of the JOBS Act. As of September 30, 2014, 
based on the PCAOB's research, 1,726 SEC registrants have identified 
themselves as EGCs in SEC filings. These companies operate in 
diverse industries with Standard Industrial Classification codes 
such as pharmaceutical preparations, blank checks, real estate 
investment trusts, prepackaged software services, business services, 
metal mining, and computer processing/data preparations services. 
For EGCs in which audited financial statements were available, those 
companies reported assets ranging from zero to approximately $13.0 
billion, with an average and median of $199.0 million and 
approximately $2.4 million, respectively. The companies reported 
revenue ranging from zero to approximately $993.5 million, with an 
average and median of $59.8 million and $21 thousand, respectively. 
Approximately 44 percent of the companies were audited by accounting 
firms that issued audit reports for more than 100 public company 
audit clients, and the remainder of the companies were audited by 
firms that issued audit reports for 100 or fewer public company 
audit clients.
    \65\ See JOBS Act, Public Law 112-106, Sec.  104.
---------------------------------------------------------------------------

    As discussed previously, the reorganization of PCAOB auditing 
standards would involve amendments that do not impose additional 
requirements on auditors or change substantively the requirements of 
PCAOB standards. Thus, the reorganization, including the amendments, is 
not expected to affect the manner in which audits are performed and 
reported under PCAOB standards, including audits of EGCs. The Board 
sought comment on the effect, if any, the reorganization would have 
specifically on audits of EGCs. Commenters indicated that they were not 
aware of any costs that would be specific to audits of EGCs when 
compared to costs of non-EGC audits.
    Accordingly and pursuant to the above discussion, the PCAOB 
requests that the Commission determine that it is necessary or 
appropriate in the public interest, after considering the protection of 
investors and whether the action will promote efficiency, competition, 
and capital formation, to apply these amendments to audits of EGCs.
Audits of Brokers and Dealers
    Section 982 of the Dodd-Frank Wall Street Reform and Consumer 
Protection Act (``Dodd-Frank Act'') \66\ expanded the authority of the 
Board to oversee the audits of brokers and dealers that are required 
under SEC rules. On July 30, 2013, the SEC amended its rules, including 
SEC Rule 17a-5 under the Exchange Act, to require, among other things, 
that audits of brokers' and dealers' financial statements and 
examinations of reports regarding compliance with SEC requirements be 
performed in accordance with the standards of the PCAOB, effective for 
fiscal years ending on or after June 1, 2014.\67\ Commenters agreed 
with the Board's view that the reorganization is appropriate for all 
audits, including audits of brokers and dealers.
---------------------------------------------------------------------------

    \66\ Public Law 111-203, 124 Stat. 1376 (July 21, 2010).
    \67\ See SEC, Broker-Dealer Reports, Securities Exchange Act of 
1934 Release No. 70073 (July 30, 2013), 78 Federal Register 51910 
(August 21, 2013), which includes the final rules.
---------------------------------------------------------------------------

III. Date of Effectiveness of the Proposed Rules and Timing for 
Commission Action

    Pursuant to Section 19(b)(2)(A)(ii) of the Exchange Act, and based 
on its determination that an extension of the period set forth in 
Section 19(b)(2)(A)(i) of the Exchange Act is appropriate in light of 
the PCAOB's request that the Commission, pursuant to Section 
103(a)(3)(C) of the Sarbanes-Oxley Act, determine that the proposed 
rules apply to audits of emerging growth companies, as defined in 
Section 3(a)(80) of the Exchange Act, the Commission has determined to 
extend to September 23, 2015 the date by which the Commission should 
take action on the proposed rules.

IV. Solicitation of Comments

    Interested persons are invited to submit written data, views and 
arguments concerning the foregoing, including whether the proposed 
rules are consistent with the requirements of Title I of the Act. 
Comments may be submitted by any of the following methods:

Electronic Comments

     Use the Commission's Internet comment form (http://www.sec.gov/rules/pcaob.shtml); or
     Send an e-mail to rule-comments@sec.gov. Please include 
File Number PCAOB-2015-01 on the subject line.

Paper Comments

     Send paper comments in triplicate to Brent J. Fields, 
Secretary, Securities and Exchange Commission, 100 F Street NE, 
Washington, DC 20549-1090.


[[Page 36652]]


All submissions should refer to File Number PCAOB-2015-01. This file 
number should be included on the subject line if e-mail is used. To 
help the Commission process and review your comments more efficiently, 
please use only one method. The Commission will post all comments on 
the Commission's Internet website (http://www.sec.gov/rules/pcaob.shtml). Copies of the submission, all subsequent amendments, all 
written statements with respect to the proposed rules that are filed 
with the Commission, and all written communications relating to the 
proposed rules between the Commission and any person, other than those 
that may be withheld from the public in accordance with the provisions 
of 5 U.S.C. 552, will be available for website viewing and printing in 
the Commission's Public Reference Room, 100 F Street NE., Washington, 
DC 20549-1090, on official business days between the hours of 10:00 
a.m. and 3:00 p.m. Copies of such filing will also be available for 
inspection and copying at the principal office of the PCAOB. All 
comments received will be posted without change; we do not edit 
personal identifying information from submissions. You should submit 
only information that you wish to make available publicly. All 
submissions should refer to File Number PCAOB-2015-01 and should be 
submitted on or before July 16, 2015.

    For the Commission, by the Office of the Chief Accountant, by 
delegated authority.\68\
---------------------------------------------------------------------------

    \68\ 17 CFR 200.30-11(b)(2).
---------------------------------------------------------------------------

Robert W. Errett,
Deputy Secretary.
[FR Doc. 2015-15571 Filed 6-24-15; 8:45 am]
BILLING CODE 8011-01-P


