1. Are you a member of one or more of the COSO organizations?

flutheronioneyedSoftware and s/w Development

Dec 13, 2013 (3 years and 10 months ago)

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Institut für Interne Revision
Österreich

Schönbrunner Str. 218
-
220, U4 Center, Stiege B, 3.OG, A
-
1120 Wien



Date:
13.12.2013

From: Mag.
Angela Witzany

Phone
:
+43 (0) 501006
-
75272

E
-
Mail: angela.witzany@internerevision.at



1. Are you a member of one or more of the COSO organizations?

The Institute of Internal Auditors

2. Are you responding on behalf of yourself or an organization or
company?

Organization

3. Where do you reside?

Europe

4. Where within your organization do you apply the COSO
Framework?

In selected areas of the organizations only

4a. Compliance activities







yes

4b. External financial reporting






yes

4c. External
non
-
financial reporting





no

4d. Internal management reporting (financial or non
-
financial)

yes

4e. Internal control reporting






yes

4f. Internal audit








yes

4g. Operations activities







yes

4h. Other









no





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5. The updated Framework wil
l help strengthen an entity’s systems of
internal control

Neither agree nor disagree


6. The updated Framework is internally consistent and logical

Neither agree nor disagree


7. The updated Framework is written in a manner that is
understandable and provi
des ease of use

Neither agree nor disagree


8. The updated Framework is applicable to organizations of varying
legal structures and sizes, and operating in various geographies and
industries

Somewhat agree


9. The updated Framework will impose additional
burdens on entities’
reporting on internal control


e.g. reporting on internal control over
external financial reporting based on Sarbanes

Oxley Act of 2002 (
SOX) requirements

Somewhat disagree


9A. If you believe that there is an additional burden, is t
he
change appropriate? If not, why not?

---


10. Compared to the 1992 framework, the updated Framework creates
a higher threshold for attaining effectiveness of internal control

Neither the treshold is the same


11. The 17 principles set out in the updated

Framework a complete set
of principles

Somewhat agree


12. The 17 principles with related attributes are helpful in describing
important considerations of an effective system of internal control
*

Soemwhat agree


13. There are necessary changes to the pri
nciples

Soemwhat agree


14. An entity can conclude that it has effective internal control if one or
more of the 17 principles are not present and functioning

Neither agree nor disagree



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15. The updated Framework appropriately expands the reporting
objectiv
e category (i.e. internal and external reporting, financial and
non
-
financial reporting)

Somewhat agree


16. The expanded reporting objective, and the manner in which this
objective category is presented in the Framework, does not diminish
our ability to a
pply the Framework when reporting on internal control
over external financial reporting

Strongly agree


17. The updated Framework provides an appropriate balances of
reporting, operations, and compliance related approaches and examples

Somewhat agree


18.
Are there any other general comments that you would like to
provide?

Knowledge in management not widespread and in ‚competition‘
with ISO and COBIT hard to argue with management

Change from ‚financial reporting‘ to ‚reporting‘ means covering
many areas not

yet covered because of to narrow view in original
version 1992

Status of ‚compliant with COSO‘ can not be independently and
objectively stated

Parallel existence of COSO IC
-
IF and COSO ERM could/should be
transformed to either a merged new framework or
transformed to a
two steps of development (simplified


expert)

Exact differences between the old and new document are hard to
establish as there exists no mark
-
up version with the changes
highlighted



Institut für Interne Revision Österreich



IIA Austri
a

Mag. Angela Witzany
, CIA, CRMA

President IIA Austria