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Should Deficiencies Under COSO Update Be Reported Now?

Tammy Whitehouse | December 17, 2013

Companies adopting a new internal control framework, recently updated by the Committee of Sponsoring Organizations, will have to think hard about whether control deficiencies they identify under the new framework might also signal deficiencies that need to be reported now under the old framework.

Internal control experts at a national conference of the American Institute of Certified Public Accountants said implementation of the freshly revised 2013 COSO framework should begin with a gap analysis to determine where companies may need to shore up controls or documentation. But because the 17 core principles in the new framework are not different from those contained in the old one—only more explicitly listed and described as requirements for effective internal control—deficiencies identified as part of implementation should be assessed even under the existing framework for possible year-end 2013 reporting.

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