Internal Controls Integrated Framework: Response to COSO Public Draft Exposure
COSO Exposure Draft: Internal Controls Integrated Framework, December 2011
15 Pages Posted: 27 Apr 2012
Date Written: April 16, 2012
On 19 December 2011 the Committee of Sponsoring Organizations of the Treadway Commission (COSO) published a draft exposure of their long awaited upgrade of the 1992 Internal Controls - Integrated Framework (ICIF). This draft exposure was open for public comment until 31 March 2012. COSO’s goal in updating the framework is to increase its relevance in the increasingly complex and global business environment so that organizations worldwide can better design, implement, maintain and assess internal control.
Given the passage of time since 1992, the dramatic changes which have occurred, and the recent events which have highlighted weaknesses in existing corporate frameworks, an improved approach is required in order to better safeguard the interests of the stakeholders.
This submission addresses this issue from two perspectives:
1. Comments in Relation to the Draft Exposure
Comments in relation to certain aspects of the draft exposure itself which require further consideration so that they can perhaps be improved upon where possible. These include both general and specific observations.
2. Requirement for a More Holistic Interdisciplinary Framework
The fundamental requirement to develop an expanded interdisciplinary integrated framework, above and beyond the boundaries of the draft exposure. The objective here is to help focus attention on the broader context of raising the bar in improving organizational performance and oversight.
Keywords: internal controls, corporate defense, corporate governance, risk management, compliance, intelligence, security, resilience, controls, assurance
JEL Classification: G30, G34
Suggested Citation: Suggested Citation