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New COSO Framework improves guidance, provides focus; update processes now

The Committee of Sponsoring Organizations of the Treadway Commission (COSO) recently released for comment a draft 2012 Internal Control—Integrated Framework. The 2012 framework, expected to be released later this year, addresses changes in the globalization of markets, operations, and business models; rapidly changing technology; increasingly complex regulatory requirements; and growing expectations for governance oversight that […]


Not all controls are equal: a fresh look at SOX 404

In my work with smaller companies I’m seeing that there’s still much more they can do to strengthen their control environment, create efficiencies and reduce compliance costs in their SOX 404 program by taking a top-down risk-based approach—focusing more effort in higher-risk areas and relying on preventive and monitoring controls in lower-risk areas. While the […]