Concerned that companies are investing much in internal controls but then risking it all by not monitoring those controls, COSO, the Committee of Sponsoring Organizations of the Treadway Commission, has issued a discussion document that may eventually become a full set of guidelines on monitoring.COSO chairman Larry Rittenberg said he has been pondering this project ever since the Sarbanes-Oxley Act of 2002's Section 404 went into effect.

"After spending so much money on building an internal control system and evaluating it every year, companies ought to look at internal control as a process and then monitor the controls to determine whether they continue to be effective," Rittenberg said. "Companies already have a lot of information that could indicate whether controls are continuing to operate effectively, or signal that they are not."

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