The Committee of Sponsoring Organizations of the Treadway
Commission (COSO)1 has recently issued a proposed update
to its internal control framework.2 The proposal is an
effort to modernize COSO's nearly 20-year-old framework for
designing, implementing and evaluating the effectiveness of an
internal control system to manage risks to the achievement of
organizational objectives. COSO seeks comment on its proposal
through March 31, 2012.
The internal control framework has gained widespread acceptance
by companies over the years. Although the basic construct of the
framework has not changed, COSO has found it necessary to update it
to reflect the evolution of corporate structures, processes and
technologies. Accordingly, amendments have been proposed to reflect
current thinking and practices in use to improve the effectiveness
of internal control systems. One of the key proposed updates is the
introduction of 17 "principles" and
"attributes" that add clarity to the
