Internal control over external financial reporting and internal control-integrated framework
COSO released for public comment its Exposure Draft on Internal Control over External Financial Reporting. COSO seeks comment on this draft, and on two related documents: (1) the revised Internal Control - Integrated Framework (pdf, 1.7mb) and (2) the proposed Illustrative Tools for Assessing Effectiveness of a System of Internal Control (pdf, 1.1mb) , by November 20.

Internal Control - Integrated Framework
The Committee of Sponsoring Organizations of the Treadway Commission (COSO) released for public comment a proposed update to the “Internal Control - Integrated Framework” that would codify the internal control concepts in the original 1992 framework into 17 principles and supporting attributes.

Comment letter - COSO’s revised internal control framework and compendium of approaches and examples
We support COSO’s efforts to update its 1992 Internal Control – Integrated Framework to reflect changes in the business and operating environment and believe the Compendium will provide users with helpful guidance. In our comment letter, we expressed our support for COSO’s efforts to update and enhance the framework to enable users to better develop, implement and monitor systems of internal control. We also expressed certain concerns and suggested modifications to the revised framework and compendium, including, among others, enhancing the guidance related to an organization’s assessment of the effectiveness of its internal controls; modifying its definitions of deficiencies and major deficiencies; providing guidance about the precision of management review controls; and providing additional guidance on the application of the Revised Framework to smaller organizations.

Comment Letter - Exposure draft of Internal Control - Integrated Framework
Our comment letter supports the Committee of Sponsoring Organization’s efforts to help organizations effectively and efficiently develop and maintain systems of internal control by enhancing the 1992 framework to reflect changes in the business and operating environment since its development. We also outline our concerns about the proposal and suggest modifications to clarify a number of areas in the proposed framework and to make it more helpful to users.