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Public Comment Letters


Date Organization Response
22-May-2023 United States Congress Joint IIA Chapter Letter Requesting the Inclusion of Internal Audit in Cryptocurrency Exchanges
04-May-2023 United States Congress Proposed Legislative Text for Enhancing Corporate Governance at Cryptocurrency Exchanges
24-April-2023 International Accounting and Auditing Standards Board (IAASB) Comments Regarding Proposed International Standards on Auditing 500
07-April-2023  Iowa House of Representatives Concerns Regarding Amendment H-1177 to Senate File 478
27-March-2023  Securities and Exchange Commission (SEC) Comments Regarding Prohibition Against Conflicts of Interest in Certain Securitizations
22-March-2023 United States House of Representatives Joint IIA Chapter Letter Requesting the Inclusion of Internal Audit in Future Data Privacy and Security Legislation
16-March-2023 Iowa House of Representatives Concerns Regarding Senate File 478
23-February-2023 National Institute of Standards and Technology  Comments Regarding NIST Cybersecurity Framework (CSF) 2.0 Concept Paper
06-February-2023 Public Company Accounting Oversight Board (PCAOB) Comments to the PCAOB’s proposed auditing standard “The Auditor’s Use of Confirmation, and Other Proposed Amendments to PCAOB Standards.
09-January-2023 New York Department of Financial Services Comments to the Proposed Second Amendment to 23 New York Codes, Rules, and Regulations (NYCRR) Part 500 ("Part 500")    


Date Organization Response
05-December-2022 United States Congress IIA Letter on Crypto to US Congress
21-October-2022 The Organisation for Economic Co-operation and Development (OECD) Response to OECD Corporate Governance Principles
30-September-2022  American Institute of Certified Public Accountants Response to AICPA Exposure Draft on CPA Exam
29-July-2022 International Sustainability Standards Board (ISSB) Response to ISSB Climate Disclosures Exposure
29-July-2022 International Sustainability Standard Board (ISSB) Response to ISSB Sustainability Disclosures Exposure
6-June-2022 Securities and Exchange Commission (SEC) Letter regarding SEC Climate-Related Disclosure Rules
10-May-2022 Securities and Exchange Commission (SEC) Letter regarding SEC Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure proposal.
28-April-2022 National Institute of Standards and Technology (NIST) Letter regarding the NIST's AI Risk Management Framework
16-Feb-2022 European Commission Letter regarding Consultation on Corporate Reporting
14-Feb-2022 Basel Committee on Banking Supervision Letter regarding consultative Paper on Principles for Effective Management and Supervision of Climate-Related Financial Risks
10-Feb-2022 Office of the Comptroller of the Currency Letter regarding the OCC’s Principles for Climate-Related Financial Risk Management for Large Banks
31-Jan-2022 IAASB ​Letter to the International Accounting and Auditing Standards Board regarding the role of internal audit in audits of financial statements of less complex entities.


Date Organization Response
3-Sept-2021 IOSCO ​Response to IOSCO on ESG Ratings and Data Products Providers
23-Aug-2021 SEC Response to SEC Climate Change Disclosures proposal
6-Aug-2021 US House Armed Services Committee Response to proposed budget cuts, Naval Audit Service
28-July-2021 IFRS Foundation Response to the International Financial Reporting Standards Foundation on draft changes to create an International Sustanability Standards Board
11-June-2021 OSFI Comment letter to Assurance on Capital, Leverage and Liquidity Returns
21-May-2021 SEC Response to request for public comments on Climate Change Disclosures
13-May-2021 INTOSAI Response to Performance Audit Subcommittee on draft Using the Work of Internal Auditors in Performance Audits
12-April-2021 OSFI Comment letter to Navigating Uncertainty in Climate Change: Promoting Preparedness and Resilience to Climate-Related Risks
2-March-2021 OECD Response to the Organisation for Economic Co-operation and Development on draft Best Practice Principles on International Regulatory Co-operation.


Date Organization Response
​28-Dec-2020 ​IFRS Foundation ​Recommendations regarding creation of new Sustainability Standards Board and internal audit's role in sustainability reporting
​15-Dec-2020 ​OSFI ​Comment letter to Developing Financial Sector Resilience in a Digital World: Selected Themes in Technology and Related Risks
​26-Oct-2020 ​INTOSAI ​Response to IDI exposure draft of Performance Audit ISSAI Implementation Handbook, Version 0.
​2-Oct-2020 ​IAASB ​Response to the International Auditing and Assurance Standards Board exposure draft of ISA 600 (Revised) Audits of Group Financial Statements.
​23-Sept-2020 ​INTOSAI ​Response to the Public Standards Committee secretariat of the International Organization of Supreme Audit Institutions on Framework of Professional Pronouncements 2020-2022, Component 1.
​9-Sept-2020 ​Global Sustainability Standards Board ​Recommendations to GSSB on exposure draft of Global Reporting Initiative Universal Standards GRI 101, GRI 102 and GRI 103.
​14-Aug-2020 ​International Integrated Reporting Council ​Recommendations on the final exposure of the IIRC's <IR> Framework to better reflect internal audit's role in organizational sustainability reporting.
​22-July-2020 ​INTOSAI ​Recommendations to International Organization of Supreme Audit Institutions on draft privatization audit guidance
​9-July-2020 ​International Auditing and Assurance Standards Board ​Response to IAASB's proposed guidance on Extended External Reporting Assurance
​12-June-2020 ​World Economic Forum ​Response to WEF's proposed Environmental, Social and Governance (ESG) Metrics
02-June-2020 ​IESBA ​Response to International Ethics Standards Board for Accountants on Proposed Revisions to the Non-assurance Services Provisions of the Code​
​28-April-2020 ​Accountancy Europe ​Comments to Accountancy Europe urging a change in mindset around financial and nonfinancial reporting.
​20-March-2020 ​IIRC ​Response to questions from the International Integrated Reporting Council (IIRC) on proposed changes to the International <IR> Framework.
​13-Jan-2020 ​NIST (National Institute of Standards and Technology) ​Comments urging greater emphasis on the unique role of internal audit in the National Initiative for Cybersecurity Education (NICE) Cybersecurity Workforce Framework.
​8-Jan-2020 ​City of Palo Alto, CA City Council ​Internal Audit Practices: City of Palo Alto Relative to Industry Practices


Date Organization Response
​06-Aug-2019 ​US Senate Committee on Finance ​Response to Support for S.379
​05-Aug-2019 ​City of Brownsville, TX ​Response to Restoration of City Oversight and Audit Committee
​01-Aug-2019 ​AASB ​Response to Auditing Assurance Standards Board Exposure Draft on Assurance and Related Services Guidelines 50
​20-June-2019 ​IESBA ​Response to International Ethics Standards Board for Accountants on proposed revisions to Part 4B of the Code to Reflect Terms and Concepts Used in ISAE 3000 (Revised).
​20-June-2019 ​IAASB ​Feedback on draft guidance for applying ISAE 3000 (Revised) to extended external reporting (EER) assurance engagements.
​04-June-2019 ​IAASB ​Feedback on IAASB consultation paper Proposed Strategy for 2020-2023 and Work Plan for 2020-2021​
​20-May-2019 ​Department of Justice ​DOJ Criminal Division Guidance Document - Evaluation of Corporate Compliance Programs
​10-May-2019 ​Glendale, Arizona City Council ​Ordinance No. 019-43 -- Eliminating the office of City Auditor
​29-April-2019 ​OECD ​Working Group on Bribery should add internal audit to the OECD's 2009 Anti-bribery Recommendation
​24-April-2019 ​INTOSAI ​Response to Supreme Audit Institution guidance on auditing information systems and security
​27-March-2019 ​ICAI ​Response to the Institute of Chartered Accountants of India Exposure Drafts of Standards for Internal Audit
​27-March-2019 ​INTOSAI ​Response to the INTOSAI Working Group on Key National Indicators exposure draft on development and use of key national indicators.
22-Feb-2019​ ​INTOSAI–WGVBS ​Guidance for Supreme Audit Institutions on issue of Sustainable Development Goals (SDGs)