Public and private companies are reminded to take note of the March 31 comment deadline on the Exposure Draft released in December 2011 by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), updating COSO's 1992 Internal Control-Integrated Framework.
The ED can be downloaded from www.coso.org. Members of all of COSO's constituent organizations (the AAA, AICPA, FEI, IIA, and IMA) will find the updated internal control framework of interest, including its implications for management's and the auditor's reports on internal control over financial reporting required under Sarbanes-Oxley Section 404 and related rulemaking of the SEC and PCAOB.
Private companies should also consider implications of the updated COSO guidance with respect to internal control assertions that reference COSO in rep letters to their audit firms, and with respect to requirements placed on audit firms by AICPA standards applicable to audits of private companies.
Read more about the COSO ED, on which comments are due March 31, and learn about an FEI webcast being held on March 19 from 1-2:30 pm EST on the COSO ED. The webcast will help inform you about key aspects of the ED, and help you and your company determine whether to file a comment letter and significant points you may wish to make to assist COSO in redeliberating the ED and moving toward final guidance.