April 12, 2007 This document contains a letter of comment from NASBA to the International Ethics Standards Board for Accountants of the International Federation of Accountants in response to Exposure Draft Section 290 of the Code of Ethics Independence-Audit and Review Engagements. All U.S. Certified Public Accountants (“CPAs”) are licensed and regulated by State Boards of Public Accountancy (State Boards) for all services they provide to publicly listed companies, non-public entities or individuals. CPAs are subject to practice and ethics requirements of State Boards in addition to the jurisdiction of other State or Federal governmental authorities. The State Boards are collectively represented by NASBA. Our comments on the Exposure Draft focus on two key points:
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