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Comments Coming into COSO on Internal Control ED

Looking for some good lunchtime (or weekend) reading? In advance of COSO's 3/31 comment deadline on its Exposure Draft updating the 1992 COSO Internal Control - Integrated Framework, 57 comment letters have been filed so far. The comment letters can be viewed at on the "View Comments" tab.

The ED itself can be downloaded after answering a quick online demographic questionaire (which does not require your name or the name of your company/organization), via the "View Exposure Draft" tab. Comments can be filed online using the "Provide Feedback" tab.

The comment letters are being posted in chronological order, with the most recent letters (including those of KPMG, McGladrey and the AICPA) near the top of the current list.

Archived Webcast Available
FEI, one of the five founding members ('sponsoring organizations') of COSO, held an informational webcast on 3/19 about the COSO ED,  the archived webcast is available to FEI members and the public. Featured speakers include PwC Partner Stephen Soske, FEI President and CEO Marie Hollein, who serves as FEI's representative on the COSO board, and Ray Purcell, Director, Financial Controls at Pfizer, who serves as Chairman of FEI's Working Group on COSO.

FEI Working Group on COSO to File Letter
The FEI Working Group on COSO (FEI WGC) is currently finalizing its comment letter on COSO's ED.

Issues anticipated to be addressed in the FEI WGC letter are currently expected to include (please reference the final letter when filed at ):
  • support for COSO's initiative in updating their Internal Control-Integrated Framework for changes in the business environment since the original framework was issued in 1992
  • support for the principles-based approach in the ED, resulting in the identification of 17 principles underlying the original five components of internal control from the 1992 framework, and the carry-forward of those original five components, which have stood the test of time 
  • concerns around potential unintended consequences that could arise from various aspects of the ED, including in relation to related upcoming volumes to be released by COSO later this year, including the length of the ED document(s), and the role of the of the 81 'attributes' that underlie the 17 'principles;' FEI is considering potential recommendations to reduce the risk of perception of an implied 'checklist' approach 
  • suggestions regarding transition period (e.g. for usage/reference under the SEC and PCAOB rules implementing Sarbanes-Oxley Section 404)
  • recognition of the need for COSO to conduct thorough due process in considering comments received on the ED and in proceeding with the remaining phases of the project
The points raised above are also found in a some of the comment letters currently on file on the ED at As is the case with many proposals relating to financial reporting (such as proposals of the FASB, IASB, SEC and PCAOB) it is possible that a fair amount of comment letters will be filed on or about the comment deadline (3/31). Additional information about COSO can be found at

Posted: 3/30/2012 12:21:55 PM by Edith Orenstein | with 1 comments
Filed under: Exposure Draft,FEI blog,FEI WGC,FEI Working Group on COSO,Internal Control over External Financial Reporting,Internal Control over Financial Reporting,Marie Hollein,Ray Purcell,Section 404,Stephen Soske,FASB,FEI,IASB,ICEFR,IC-IF,PCAOB,PwC,Sarbanes-Oxley,SEC,,COSO

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Edith Orenstein
FEI's comment letter to COSO has been filed and is currently posted in a news headline on FEI's website,, it will also be available at view comments.
4/2/2012 1:37:46 PM
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