CUNA Regulatory Comment Call

March 20, 2006

AICPA Proposal Regarding Attestation Engagements

EXECUTIVE SUMMARY

BACKGROUND

DISCUSSION OF THE PROPOSED STATEMENT

Definition of Internal Control

Management’s Responsibilities in an Examination of Internal Control

CPA’s Responsibilities in an Examination of Internal Controls

Management’s Documentation

Monitoring by Management

Management’s Assertion

Management’s Report on Internal Controls for External Parties

Examination Engagement

Testing

QUESTIONS REGARDING THE PROPOSED SSAE

  1. Do you feel that management’s responsibilities with respect to an examination as laid out in the proposal are reasonable?

    Yes ______ No ______

    If not, which responsibilities are not reasonable and why?
















  2. Do you think the criteria for management’s assertion are appropriate?

    Yes ______ No ______

    If not, please explain why not?
















  3. Are the documentation and monitoring requirements on management’s part proper?

    Yes ______ No ______

    If not, what are your suggestions?
















  4. Do the testing requirements make sense?

    Yes ______ No ______

    If not, why not?
















  5. Under this proposal, a credit union would have to have a CPA do the attestation. Further, one CPA may assist management in preparing or gathering documentation of a credit union’s internal control or recommending improvements to its internal control. However, another different CPA must perform the testing. This would require hiring one or more CPA firms. Does this seem overly burdensome?

    Yes ______ No ______

    If yes, please quantify the additional burden imposed, if possible.
















  6. Other comments?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com