COSO 2011 Draft - Comments and Recommendations

11 Pages Posted: 19 Mar 2012

Date Written: March 14, 2012


This document contains the details comments and recommendations of John Kyriazoglou (credentials at the end of this document) as the result of reviewing the 2011 COSO Draft Exposure, available at:

These relate to a variety of issues, such as: Comparison of new COSO (2011 version) to COSO 1992 Model, Using and applying new COSO framework, Strategy, Importance of strategy, Strategic and operational control, Objectives, Objective setting and internal control, General business goals, Business objectives, Principles, Internal Control Activities, Preventive and Detective controls, The role of the board in strategy, Lines of Defense, Performance Measures, Performance and risks, Role of board and management in performance, Role of board and management in accountability for internal control, Role of data privacy officer, Technology general controls, General IT Controls, Application Systems Controls, Safeguarding of assets, Audit trail, Compliance measurement, Business process control activities and Glossary.

Keywords: COSO 2011 Comments, Internal Controls

JEL Classification: D20

Suggested Citation

Kyriazoglou, John, COSO 2011 Draft - Comments and Recommendations (March 14, 2012). Available at SSRN: or

John Kyriazoglou (Contact Author)

University of Toronto ( email )

Woodsworth College
Toronto, Ontario M5S 3G8

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