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Public Comment Letters

2023

Date Organization Response
1-December-2023 International Auditing and Assurance Standards Board (IAASB) Comments Regarding IAASB’s International Standard on Sustainability Assurance (ISSA) 5000, General Requirements for Sustainability Assurance Engagements
30-November-2023 United States Congress Comments Regarding the Proposed National AI Commission Act
6-November-2023 National Institute of Standards and Technology (NIST) Comments Regarding NIST Cybersecurity Framework (CSF) 2.0 Initial Public Draft
7-October-2023 Organization: INTOSAI Comments Regarding Guidance on Cooperation with Internal Auditors
11-September-2023 Organisation for Economic
Co-operation and Dvelopment		 Comments Regarding OECD Guidelines on Corporate Governance of State-Owned Enterprises
14-August-2023 New York Department of Financial Services   Comments on the Revised Proposed Second Amendment to 23 NYCRR 500
07-July-2023 The White House Office of Science and Technology Policy (OSTP) Comment Regarding Artificial Intelligence
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")    


2022

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.


2021

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.


2020

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


2019

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)

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