Discussant's response to let's change GAAS!!! ???*&#@;

              Discussant's Response to
Let's Change GAAS!!! ??? *&# @
William L. Felix, Jr.
University of Arizona
Periodic reevaluation and reexamination of all aspects of our professional environment constitute an excellent idea. The authors of this paper are to be complimented on their efforts to take ill-formed feelings of dissatisfaction with current Generally Accepted Auditing Standards, identify a need for change, and develop a response that should provide all of us here today a chance to think and to argue about the changes to Generally Accepted Auditing Standards are currently appropriate. I do agree, in general, with their argument that Generally Accepted Auditing Standards need reevaluation and probably need change.
General Observations
I also have two rather strong reservations on the content of their paper which I will try to support with some of my more detailed comments later on. There is considerable unevenness in the presentation in this paper, and many of its views and positions are, at best, weakly supported. It is very distracting to try to agree with a paper and the arguments in it when many of these arguments are poorly supported. In addition, for a paper that is proposing basic modifications to the conceptual criteria for professional auditing, there is very little theory. In particular, I would like to have seen a careful identification of the appropriate level and content of overall standards; that is, a thorough discussion of the level of concept at which GAAS should exist. In addition, a systematic argument from this concept or theoretical framework as to what the specific standards ought to comprise is needed.
For example, there is no definition of the term "attestation." A well-thought-out definition that leads one to some of the constructs underlying this service to society would seem essential. I usually think of "attestation" in terms of third party assurance on the "quality" of reasonably objective economic information. I would argue that "quality" criteria that would provide a framework against which auditors could evaluate their performance should, as the authors point out in a place or two, be established at a high level. Detailed content specifying specific actions or lack of action should be avoided and deferred to later interpretations of the basic criteria promulgated by the appropriate senior committee of the AICPA. The definition given above would suggest that the overall criteria ought to include a description of acceptable third parties, general criteria for the process of forming a level of assurance, reporting criteria, and possibly, although debatably, other criteria. After developing such a setting, the paper could then move on to proposing specific standards and to comparing them with existing GAAS in a logically coherent fashion.
181