Comments of the Auditing Standards Committee of the Auditing Section of the American Accounting Association on the PCAOB’s Proposed Auditing Standard—Designing and Performing Substantive Analytical Procedures and Amendments to Other PCAOB Standards

SUMMARY On June 12, 2024, the Public Company Accounting Oversight Board (the Board or PCAOB) issued a request for comment on Proposed Auditing Standard—Designing and Performing Substantive Analytical Procedures and Amendments to Other PCAOB Standards (PCAOB 2024a). This comment letter presents the views of the participating members of the Auditing Standards Committee of the Auditing Section of the American Accounting Association. We applaud the PCAOB for its ongoing commitment to improve audit quality by addressing enhancements to substantive analytical procedures. Based on our committee’s assessment of the proposal, we provide some overall observations, an analysis based on academic research, and perspectives on the proposal’s economic analysis.