Final guidance is forthcoming from COSO on Monitoring Internal Control Systems. The guidance follows from COSO’s earlier Exposure Draft released earlier this year, with the COSO Project Team – led by Grant Thornton – incorporating certain changes based on comments received. COSO’s upcoming publication focuses on Monitoring – one of the five elements of internal control established in COSO’s 1992 Internal Control-Integrated Framework. (The five elements are: control environment, risk assessment, control activities, information & communication, and monitoring.)
Public and private companies have certain requirements set forth by the SEC/PCAOB and AICPA respectively relating to generally accepted internal control frameworks which reference the COSO framework. For example, the SEC’s rule for management reporting under Sarbox 404 states (in Section II. B. 3. a. of the SEC rule): “The COSO Framework satisfies our criteria and may be used as an evaluation framework for purposes of management's annual internal control evaluation and disclosure requirements.” [Footnote 67 in the SEC rule notes there may be other acceptable frameworks used outside the U.S., such as guidance issued by the Canadian Institute of Chartered Accountants and the ICAEW’s Turnbull Report]. Additionally, the SEC's rule states: “The final rules require management's report to identify the evaluation framework used by management to assess the effectiveness of the company's internal control over financial reporting.” Similar sentiments are expressed in PCAOB’s Auditing Standards No. 5 (AS5) (see e.g. AS 5 footnote 7, para. 87 and 88).
We referenced once before, but in case you missed it or were waiting to see how your calendar lined up, it’s not too late to register for a webcast taking place tomorrow where you can learn more about COSO’s Guidance on Monitoring Internal Control Systems – expected to be issued in December or early January. Tune into the webcast sponsored by Financial Executives International and Grant Thornton on Tues. Dec. 2 at 2:00 pm EST by registering at the following link; all registrants should enter company code 710004.
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