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In our comment letter, we support the efforts of the Government Accountability Office (GAO) to update the Federal Information System Controls Audit Manual (FISCAM) to reflect changes in relevant auditing standards, guidance, control criteria and technology since the last revision in 2009. We suggest certain clarifications to enhance the proposed guidance and reduce potential diversity in implementation. FISCAM provides the methodology to assess the design, implementation and operating effectiveness of controls over information systems in audits of federal and governmental entities.