October 8, 2012

COSO Seeks Public Comment on Its Proposed Internal Control over External Financial Reporting

Holland & Knight Bulletin

On September 18, 2012, the Committee of Sponsoring Organizations of the Treadway Commission (COSO) released an exposure draft of its Internal Control over External Financial Reporting: Compendium of Approaches and Examples (ICEFR). The proposed ICEFR is a compendium of approaches and examples that illustrate how the principles set forth in COSO's Internal Control-Integrated Framework ("framework") can be applied in designing, implementing and conducting internal control over external financial reporting.

The release of the ICEFR is part of a larger project announced by COSO in November 2010 to review and update the framework, which was originally released in 1992 and is a leading framework worldwide for designing, implementing, and conducting internal control and assessing the effectiveness of internal control. COSO hopes to increase the framework's relevance so that organizations can better design, implement and assess internal control. COSO is a joint initiative of five private sector organizations and is committed to providing thought leadership through the development of frameworks and guidance on issues such as enterprise risk management, internal control and fraud deterrence.

To assist with the public's review of the ICEFR, COSO also released the following:

  • an updated version of the framework, which incorporates revisions made to the framework based on comments obtained through the public-exposure process that ended on March 31, 2012
  • Illustrative Tools for Assessing Effectiveness of a System of Internal Control ("illustrative tools"), which is a collection of templates and scenarios to assist users of the framework when assessing the effectiveness of a system of internal control based on the requirements set forth in the framework

The ICEFR, updated framework and illustrative tools are available for download at http://www.ic.coso.org/. The public comment period on the ICEFR ends on November 16, 2012.

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