Internal Control — Integrated Framework - 會計師事務所

1 Committee of Sponsoring Organizations of the Treadway CommissionInternal Control Integrated FrameworkCommittee of Sponsoring Organizations of the Treadway CommissionTo submit comments on this Public Exposure Draft, please visit the website. Responses are due by November 16, will be asked to respond to a series of questions. Those questions may be found on-line at and in a separate document provided at the time of download. Respondents may upload letters through this site. Please do not send responses by fax.

2 Written comments on this exposure draft will become part of the public record and will be available on-line March 31, 2012 Internal Control over External Financial Reporting: A Compendium of Approaches and ExamplesDraft for DiscussionDraft for Discussion 2012 All Rights Reserved. No part of this publication may be reproduced, redistributed, transmitted or displayed in any form or by any means without written permission. For information regarding licensing and reprint permissions please contact the American Institute of Certified Public Accountants, licensing and permissions agent for coso copyrighted materials.

3 Direct all inquiries to or to AICPA, Attn: Manager, Rights and Permissions, 220 Leigh Farm Rd., Durham, NC 27707. Telephone inquiries may be directed to Control Integrated FrameworkTo submit comments on this Public Exposure Draft, please visit the website. Responses are due by November 16, will be asked to respond to a series of questions. Those questions may be found on-line at and in a separate document provided at the time of download. Respondents may upload letters through this site.

4 Please do not send responses by fax. Written comments on this exposure draft will become part of the public record and will be available on-line March 31, 2012 Internal Control over External Financial Reporting: A Compendium of Approaches and ExamplesCommittee of Sponsoring Organizations of the Treadway CommissionDraft for DiscussionDraft for DiscussionCommittee of Sponsoring Organizations of the Treadway Commission Board Members Representative coso Chair David L. LandsittelAmerican Accounting Association Mark S.

5 Beasley Douglas F. PrawittThe Institute of Internal Auditors Richard F. ChambersAmerican Institute of Certified Public Accountants Charles E. LandesFinancial Executives International Marie N. HolleinInstitute of Management Accountants Sandra Rictermeyer Jeffrey C. Thomson PwCAuthorPrincipal Contributors Miles Everson Engagement Leader New York, USA Stephen E. Soske Project Lead Partner Boston, USA J. Aaron Garcia Project Lead Director San Diego, USA Cara M. Beston Partner San Jose, USA Charles E.

6 Harris Partner Florham Park, USA Eric M. Bloesch Managing Director Philadelphia, USAJ ames M. Downs Director San Francisco, USA (Through January 2012)Frank J. Martens Director Vancouver, Canada Jay A. Posklensky Director Florham Park, USAC harles J. Finn Senior Manager Detroit, USAN atalie Protze Senior Manager Washington , USA (July 2011 to March 2012)Draft for DiscussionAdvisory CouncilSponsoring Organizations RepresentativesAudrey A. Gramling Bellarmine University Fr. Raymond J. Treece Endowed ChairSteven E.

7 Jameson Community Trust Bank Executive Vice President and Chief Internal Audit & Risk OfficerJ. Stephen McNallyCampbell Soup Company Finance Director/ControllerRay Purcell Pfizer Director of Financial ControlsBill Schneider AT&T Director of AccountingMembers at LargeJennifer BurnsDeloittePartnerJim DeLoach Protiviti Managing DirectorTrent Gazzaway Grant Thornton PartnerCees Klumper The Global Fund to Fight AIDS, Tuberculosis and Malaria Chief Risk OfficerThomas Montminy PwC PartnerAl Paulus E&Y PartnerThomas Ray KPMG PartnerDr.

8 Larry E. RittenbergUniversity of WisconsinEmeritus Professor of Accounting Chair Emeritus COSOKen Vander Wal ISACA PresidentRegulatory Observers and Other ObserversJames Dalkin Government Accountability Office Director in the Financial Management and Assurance TeamHarrison E. Greene, Jr. Federal Deposit Insurance Corporation Assistant Chief AccuntantChristian Peo Securities and Exchange Commission Professional Accounting Fellow (Through June 2012)Amy SteeleSecurities and Exchange CommissionAssociate Chief Accountant (Commencing July 2012)

9 Vincent Tophoff International Federation of AccountantsSenior Technical ManagerKeith Wilson Public Company Accounting Oversight Board Deputy Chief AuditorDraft for DiscussionAdditional PwC ContributorsMark CohenPartner San Francisco, USAA ndrew DahlePartner Chicago, USAJ unya HakodaPartner (Retired)Tokyo, JapanBrian KinmanPartner St. Louis, USAPat McNameePartner Florham Park, USAJ onathan MullinsPartner (Retired)Dallas, USAA lexander YoungPartner Toronto, CanadaAntoine ElachkarManaging DirectorWashington , USAGary MossManaging DirectorMilwaukee, USAC atherine JourdanDirectorParis, FranceFrank MaggioDirectorChicago, USAC hristopher MichaelsonDirectorMinneapolis, USAS allie Jo PerragliaManagerNew York, USAT racy WalkerDirectorBangkok, ThailandQiao PanSenior AssociateNew York, USAD raft for DiscussionPrefaceThis project was commissioned by coso .

10 Which is dedicated to providing thought lead-ership through the development of comprehensive frameworks and guidance on Internal Control , enterprise risk management, and fraud deterrence designed to improve organi-zational performance and oversight and to reduce the extent of fraud in organizations. coso is a private sector initiative, jointly sponsored and funded by: American Accounting Association (AAA) American Institute of Certified Public Accountants (AICPA) Financial Executives International (FEI) Institute of Management Accountants (IMA) The Institute of Internal Auditors (IIA)Draft for DiscussionTable of ContentsForeword.