Our team do not oppose on the planned adoption of non-residency approach.

However, considering
that all audit teams will be physically transferred to the Regional Office (RO) and PSAOs, we think that
the current facilities (i.e. stable internet connection, parking space) and working space of the RO and
PSAOs are not sufficient to accommodate all audit teams.

Moreover, since most of the agency records and supporting documents will remain in the storage space
in the agency premises, it will entail additional time and cost (transportation allowance) for the auditors
to travel to and from the agency to conduct the necessary audit activities.