Big4Guy

Section 404 requires than management of a company should use an internal control framework in assessing its controls. Though without doubt COSO is the most popular internal control framework. There are other internal control frameworks as well. You can haed over here for more information on some other internal control frameworks such as CoCo, Kontrag, Turnbull etc.

The question that faces management is that whether a framework other than COSO be used for assessing internal controls. The SEC provides guidance in this respect. It specifically states that

"Management may use a framework other than COSO, if the framework is a suitable, recognized control framework".

The above guidance points towards internal control frameworks that have been established by a body or group following due-process procedures and broad distribution pf the internal control framework for public comment. Infact SEC's final rule on Management's reports in internal controls over financial reporting state that guidance published by the Canadian Institute of chartered Accountants and the Turnbull Report issued by the Institute of Chartered Accountants of England and Wales are suitable examples of Control Frameworks. To conclude, one can safely that internal control frameworks other that COSO can be used by organizations provided they meet the criteria mentioned above.

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