Learning Center
Plans & pricing Sign in
Sign Out

Feedback Exposure draft COSO


									Institut für Interne Revision Österreich
Schönbrunner Str. 218-220, U4 Center, Stiege B, 3.OG, A-1120 Wien

                                                                    Date: 09.09.2012
                                                                    From: Mag. Angela Witzany
                                                                    Phone:+43 (0) 501006-75272

      1. Are you a member of one or more of the COSO organizations?
             The Institute of Internal Auditors
      2. Are you responding on behalf of yourself or an organization or
      3. Where do you reside?
      4. Where within your organization do you apply the COSO
      Framework? In selected areas of the organizations only
             4a. Compliance activities
             4b. External financial reporting
             4c. External non-financial reporting
             4d. Internal management reporting (financial or non-financial)
             4e. Internal control reporting
             4f. Internal audit
             4g. Operations activities
             4h. Other
5. The updated Framework will help strengthen an entity’s systems of
internal control
       Neither agree nor disagree

6. The updated Framework is internally consistent and logical
       Neither agree nor disagree

7. The updated Framework is written in a manner that is
understandable and provides ease of use
       Neither agree nor disagree

8. The updated Framework is applicable to organizations of varying
legal structures and sizes, and operating in various geographies and
        Somewhat agree

9. The updated Framework will impose additional burdens on entities’
reporting on internal control – e.g. reporting on internal control over
external financial reporting based on Sarbanes–Oxley Act of 2002 (
SOX) requirements
       Somewhat disagree

        9A. If you believe that there is an additional burden, is the
        change appropriate? If not, why not?

10. Compared to the 1992 framework, the updated Framework creates
a higher threshold for attaining effectiveness of internal control
       Neither the treshold is the same

11. The 17 principles set out in the updated Framework a complete set
of principles
       Somewhat agree

12. The 17 principles with related attributes are helpful in describing
important considerations of an effective system of internal control *
      Soemwhat agree

13. There are necessary changes to the principles
       Soemwhat agree

14. An entity can conclude that it has effective internal control if one or
more of the 17 principles are not present and functioning
       Neither agree nor disagree

Seite 2 von 3
15. The updated Framework appropriately expands the reporting
objective category (i.e. internal and external reporting, financial and
non-financial reporting)
       Somewhat agree

16. The expanded reporting objective, and the manner in which this
objective category is presented in the Framework, does not diminish
our ability to apply the Framework when reporting on internal control
over external financial reporting
       Strongly agree

17. The updated Framework provides an appropriate balances of
reporting, operations, and compliance related approaches and examples
       Somewhat agree

18. Are there any other general comments that you would like to
       Knowledge in management not widespread and in ‚competition‘
       with ISO and COBIT hard to argue with management
       Change from ‚financial reporting‘ to ‚reporting‘ means covering
       many areas not yet covered because of to narrow view in original
       version 1992
       Status of ‚compliant with COSO‘ can not be independently and
       objectively stated
       Parallel existence of COSO IC-IF and COSO ERM could/should be
       transformed to either a merged new framework or transformed to a
       two steps of development (simplified – expert)
       Exact differences between the old and new document are hard to
       establish as there exists no mark-up version with the changes

Institut für Interne Revision Österreich – IIA Austria
Mag. Angela Witzany, CIA, CRMA
President IIA Austria

Seite 3 von 3

To top