Well, we are starting to get word from the field about companies’ progress implementing the new COSO framework for internal control. Apparently we have a few weaknesses to discuss.
In theory, compliance and internal audit teams have been working hard all summer to implement the new framework, scheduled to go into effect on Dec. 15. And from what I’ve heard—both in personal discussions with various compliance officers, and in articles written in Compliance Week and elsewhere—compliance departments are indeed trying to get the project done. But many still seem to be struggling with preliminary steps, such as explaining to their boards how the new COSO framework will be useful to them, or determining how to apply the new framework’s 17 principles beyond the basic realm of financial reporting.
