The Capital Committee of the Securities Industry Association (SIA)* submits comments to the American Institute of Certified Public Accountants (AICPA) on a proposed audit interpretation of Statement on Auditing Standards No. 73, Using the Work of a Specialist, File No. 2605. The intended purpose of the draft is to provide guidance regarding the use of a legal specialist’s finding as audit evidence to support Management’s assertion that a transfer of financial assets meets legal isolation criterion.  SIA believes that the proposal, in its current form, requires a level of legal assurance that is likely to be unattainable or extremely difficult to obtain in many instances.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.