COSO Committee of Sponsoring Organizations of the Treadway Commission
A draft of the Compendium was issued for public comment from September 18, 2012, through December 4, 2012. There were twenty-three public comment letters and twenty-five responses to COSO's online survey. Each comment letter was considered by PwC and the COSO Board in finalizing this publication. This appendix summarizes the more significant issues that arose from these comment letters and the related revisions made to the Compendium.
Some respondents concurred with COSO that the Compendium provides useful illustrations of applying the Framework in an external financial reporting context. Some respondents expressed a view that the Compendium would not set a higher threshold for attaining effective internal control over external reporting or impose additional burdens on entities that report on internal control over external financial reporting.
Some agreed that the Compendium applies to both larger and smaller entities; however some requested additional examples specifically focused on smaller entities. PwC and the COSO Board note that many examples were obtained and updated from the COSO Guidance for Smaller Public Companies issued in 2006 and believe that most examples included in the Compendium apply to both larger and smaller entities.
Some respondents provided suggestions to clarify specific examples and requested additional examples. PwC and the COSO Board balanced these requests with comments provided by others that the Compendium is too large and included too many examples. Accordingly, a limited number of examples relevant to the application of principles in an ICEFR context were added, including:
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Reviewing Governmental Agency Financial Results and Underlying Internal Control
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Manually Assessing Incompatible Functions Across an Entity
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Reviewing Financial Statement Estimates
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Investigating and Reporting Whistle-Blower Allegations
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Identifying and Protecting Financial Data and Information
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Identifying and Analyzing Risk of Material Omission and Misstatement Due to Fraud
Additionally, the Introduction has been updated to include further discussions about:
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Limitations of Illustrations
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Objectives Established for External Financial Reporting
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Suitable Objectives of Financial Statements for External Purposes
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Risks to Achieving Suitable Objectives
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Risk Response
Copyright © 2013 – 2016 Committee of Sponsoring Organizations of the Treadway Commission and the American Accounting Association. All Rights Reserved. Use of materials is subject to COSO's Policy of Acceptable Use.
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