外文翻译 较小型上市公司财务报告内部控制指南 COSO的概述和评价.doc

外文翻译--较小型上市公司财务报告内部控制指南-COSO征求意见稿的概述和评价 Guidance for smaller public companies reporting on internal controls An Overview and Assessment of the COSO Exposure draft Since the passage of the Sarbanes-Oxley Act of 2002 SOX , there has been an increased focus on the control environment over financial reporting. SOX section 404 requires management to evaluate internal controls over financial reporting and report on their effectiveness. Large public companies have been using the Committee of Sp- onsoring Organizations COSO framework, issued in 1992,to assess the effectiveness of their controls; however, due to concerns over the cost and complexity of companies for smaller public companies SPC ,the deadline for these companies non-accelerated filers has been extended to fiscal years ending after July 2007. Additional uncertainty regarding the timing and applicability of section 404 to SPCs surfaced recently when an SEC advisory panel recommended exempting a significant proportion of these companies from section 404 compliance based upon market capitalization. While some SPCs will wait to see what legislation requires before looking at internal controls, other SPCs, not-for-profits, and educational institutions are moving forward even without legislative requirements and can use additional guidance. As a result of the implementation concerns for SPCs，and the appropriateness of its framework, COSO issued an exposure draft ED in October 2005 intended to provide important guidance to SPCs when assessing the effectiveness of their internal controls over financial reporting. Analyzing responses to the ED reveals a concern that one of the most significant issues facing section404 compliance by SPCs, cost-effective implementation, had not been addressed and that the ED lacked specific applicability to the smallest of SPCs. This article provides an overview of the ED and highlights the major concerns raised by 176 respondents, covering broad spectrum of interested parties,