AICPA Letter Helps Persuade COSO to Postpone Release of Internal Control Framework

June 13, 2012

“The AICPA is pleased that COSO is carefully considering the feedback from us and others in fulfilling their due process responsibilities,” said Susan Coffey, AICPA senior vice president, public practice & global alliances.

On April 30, 2012, COSO announced it was postponing the release of the Updated Internal Control-Integrated Framework and related supporting documents until the first quarter of 2013.

The American Institute of CPAs emphasized in its March comment letter to COSO, the Committee of Sponsoring Organizations of the Treadway Commission, it believes the updated framework will continue to be an excellent and valuable resource to practitioners in helping businesses design and evaluate systems of internal control.

The AICPA said it generally agrees that inclusion of the internal control principles and attributes provides helpful clarity to the various aspects of an effective system of internal control and realizes that their inclusion could increase the complexity of an organization’s internal control evaluation process.  The AICPA recommended that 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 and that COSO should provide flexibility for smaller entities. 

COSO expects to issue an exposure draft of the Internal Control over External Financial Reporting Approaches and Examples (which will replace the 2006 Internal Control over Financial Reporting – Guidance for Smaller Public Companies) for public comment in summer 2012 and to release the final ICEFR Approaches and Examples with the updated Internal Control – Integrated Framework in early 2013.

COSO, the Committee of Sponsoring Organizations of the Treadway Commission, 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.

For more information about the internal control framework and the new timeline, read the April 2012 Journal of Accountancy article.