​​​​​​​Comments on the COSO Draft Update of the Internal Controls Framework

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​COSO has released a draft update of its excellent 1992 Internal Control–Integrated Framework as an exposure draft for comment.

This is a very important update to a critical piece of work, relied upon by a variety of practitioners, consultants, and external auditors around the world. It is the only framework explicitly recognized by the SEC as the foundation of a SOX assessment of internal control over financial reporting.

I urge everybody to follow the link in the first line to review and then submit comments to COSO.

I have submitted my comments, which you can find here. I previously posted a blog on the process in the draft for assessing internal controls.

Whether you agree with my comments or not, please give this your careful attention and share your views with COSO. We need this to be the best possible guidance on internal control, to benefit risk, compliance, and assurance professionals around the world.

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