This letter provides GAO's response to the exposure draft Improving the Structure of the Code of Ethics for Professional Accountants--Phase 1. GAO promulgates generally accepted government auditing standards (GAGAS) in the United States. GAGAS provides a framework for conducting high-quality audits of government awards with competence, integrity, objectivity, and independence. GAGAS use is required of auditors of both domestic and international U.S. government awards. Therefore, we anticipate that professional accountants who comply with international auditing standards will, under some circumstances, be required to simultaneously practice in accordance with GAGAS and the revised International Ethics Standards Board for Accountants' (IESBA) Code of Ethics for Professional Accountants (the Code).