Accounting

COSO Update: Jan. 2015

COSO's updated Internal Control-Integrated Framework, "COSO 2013," superseded COSO's 1992 internal control framework on Dec. 15, 2014.Although not a regulator per se (COSO is a private sector organization founded by the AAA, AICPA, FEI, IIA and IMA), COSO's internal control framework is a de facto requirement for public companies and their auditors in assessing the effectiveness of, and making assertions related to the effectiveness of internal control over financial reporting, as required by Section 404 of the Sarbanes-Oxley Act. The reference to use of COSO's framework for this purpose is found in the U.S. Securities and Exchange Commission's rule on management reporting (pertaining to Section 404a of the Sarbanes-Oxley Act) and cross-referenced in the Public Company Accounting Oversight Board's Auditing Standard No. 5 (AS5) applicable to audits of internal control over financial reporting as specified under Section 404b of the Sarbanes-Oxley Act. SEC staff have stated, including in remarks at the AICPA's National Conference on Current SEC and PCAOB Developments in December, 2015, that they will not challenge companies that have not yet adopted COSO 2013 as of year-end 2014; however, there is an increased chance companies will receive comments/questions from the SEC (e.g. in comment letters on filings) the longer a company takes to adopt COSO 2013.When ordering your copy of the COSO framework from www.coso.org  (when you click on the link to purchase the guidance, you will be redirected to the AICPA's CPA2Biz site to place your order), enter your FEI member discount code, FEIIC, when prompted.  FEI COSO ResourcesFEI provides its members with a variety of resources to assist you in adopting COSO 2013. See FEI's COSO Resources page, www.financialexecutives.org/coso, for upcoming and archived webcasts and related publications and programs.See also these articles from FEI Daily providing coverage of remarks of SEC and AICPA staff, leading financial executives and auditors, at FEI's CFRI conference in Nov., 2014, and the AICPA SEC - PCAOB Conference in Dec., 2014:  AICPA, SEC Discuss COSO Transition (12/16/14) COSO Internal Control Patrol Says Mind Your ELCs, POFs, OSPs (12/ 15/14) COSO 2013 'Dream Team' Shares Implementation Advice (11/18/14) New Report: COSO in the Cyber AgeOn Jan. 14, 2015 COSO published a new report...

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