Comments on the COSO Draft Update of the Internal Controls Framework

Norman Marks, CRMA, CPA, is a vice president for SAP and has been a chief audit executive and chief risk officer at major global corporations for more than 20 years.


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.

Posted on Feb 11, 2012 by Norman Marks

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  1.  I agree with all of Norman Marks' comments of above and the attached referenced document. I have myself penned remarks to COSO and as well posted such commentaries on the following LinkedIn sites. Unfortunately cannot post it on this site as it is too voluminous but you will find it in three separate streams on each site below. It provides additional perspective from my viewpoint as to how we got into this mess to begin with. I think it is important for all IIA members to understand this clearly

    Risk Managers

    Audit Committee

    Internal Control Worldwide Network

    Institute of internal auditors -global site

    Risk Management EXecutives and Professionals

    Institute of Risk Management

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