COSO Committee of Sponsoring Organizations of the Treadway Commission
Some respondents questioned the sufficiency of the overall due process activities surrounding COSO's initiative to update the Framework, suggesting, for instance, that PwC and COSO conduct additional outreach and public consultations before releasing the Framework. The COSO Board believes the extensive level of activities over the past several years have captured a wide range of views on the proposed revisions to the Framework as described in Appendix D, Methodology for Revising the Framework. As part of this approach, PwC and COSO:
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Surveyed users and stakeholders in the original framework to capture user views on the nature and extent of necessary updates, receiving over 700 responses (December 2010 to September 2011)
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Conducted eleven meetings with the Advisory Council (whose members include representatives of AICPA, AAA, FEI, IIA, IMA, public accounting firms, other professional organizations and various regulatory observers)
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Provided exposure drafts of the updated Framework for public comments (December 2011 to March 2012)
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Made available a revised draft of the Framework for public comments, in connection with providing exposure drafts of the proposed Internal Control over External Financial Reporting: A Compendium of Approaches and Examples, along with Framework and Illustrative Tools for Assessing Effectiveness of a System of Internal Control (September to December 2012)
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Participated in many conferences, webinars, and seminars with membership of COSO to seek additional views from stakeholders and users (January 2011 to January 2013)
COSO believes there has been a substantive due process effort to capture views on proposed updates to the Framework and Appendices, Internal Control over External Financial Reporting: A Compendium of Approaches and Examples, and Illustrative Tools for Assessing Effectiveness of a System of Internal Control.
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