The Center for Audit Quality sees benefits in the updated Internal Control-Integrated Framework recently proposed by the Committee of Sponsoring Organizations of the Treadway Commission, or COSO.

In a comment letter on COSO’s recent exposure draft of the updated framework, the CAQ noted, “The numerous enhancements made, most significantly the codification of internal control concepts from the 1992 Internal Control – Integrated Framework into 17 principles, with supporting attributes, will benefit organizations in establishing effective internal control and improving performance in an increasingly complex and changing environment.”

In the letter, CAQ executive director Cindy Fornelli encouraged COSO to work with the Securities and Exchange Commission, and other regulatory agencies as necessary, to provide guidance regarding the transition to the Updated Framework.

“Absent clarity with respect to how the two frameworks are intended to be used, we believe there could be inconsistent application by entities that have a requirement to evaluate and externally report on the effectiveness of internal control, as well as potential confusion amongst users of those reports,” the letter stated.

The CAQ also suggested that COSO incorporate key concepts and/or references within COSO’s Guidance on Monitoring Internal Control Systems document into the Updated Framework and provide additional guidance regarding the scalability of the Updated Framework for smaller organizations.

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