Press Release



James Schiavone

AICPA Comment Letter on COSO Internal Control – Integrated Framework Exposure Draft 

Published April 04, 2012

The American Institute of CPAs Internal Control Task Force submitted comments on the Committee of Sponsoring Organizations of the Treadway Commission’s (COSO) exposure draft, Internal Control – Integrated Framework (the updated Framework).

The AICPA commends COSO for its efforts in updating the Framework in its comment letter and says it believes that the updated Framework will continue to be an excellent and valuable resource to practitioners.

In the comment letter, the AICPA states that it generally agrees that the inclusion of the internal control principles and attributes provides helpful clarity to the various aspects of an effective system of internal control and that their inclusion could increase the complexity of an organization’s internal control evaluation process. The AICPA recommends COSO develop additional guidance related to how an organization should consider weaknesses in - or absence of - a principle or attribute when evaluating internal control effectiveness.

While AICPA said it believes that the updated Framework meets the objectives identified by COSO to enable organizations to effectively and efficiently develop and maintain systems of internal control that can enhance the likelihood of achieving the entity’s objectives and can adapt to changes in the business and operating environments, it could be further improved by considering the points outlined in its letter, which is pasted below and available on aicpa.org.

COSO is a joint initiative of five private sponsoring organizations which is dedicated to providing thought leadership through the development of frameworks and guidance on enterprise risk management, internal control and fraud deterrence.  The AICPA is one of the sponsoring organizations.

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