Responses to Regulators and Oversight Bodies

Formal IIA Contributions and Responses to Matters of Global Importance to the Profession

The Institute of Internal Auditors (IIA) works closely with lawmakers, thought leaders, and other regulatory groups. We weigh in on any proposed guidelines or policies that could impact how today’s professionals carry out the practice of internal auditing.

The Global Board of Directors makes official statements on behalf of The IIA, while the Chairman of the Board and/or the President and CEO serve as spokespeople. At certain times, we may delegate this responsibility to other members of our staff.

The process of preparing and writing responses to other organizations is governed by a due diligence process described on The IIA website. See Structure and Processes for responses.

View The IIA's responses to exposure drafts and requests for comment from other organizations.

2022

Date	Organization	Response
14-Jan-2022	CSA	Response to Canadian Securities Administrators (CSA’s) continued efforts to address climate change disclosure.

2021

Date	Organization	Response
22-Dec-2021	SEC	Response to proposed rule on Electronic Recordkeeping Requirements for Broker-Dealers, Security-Based Swap Dealers, and Major Security-Based Swap Participants
18-Nov-2021	IASB	Response to International Accounting Standards Board on Management Commentary exposure draft
3-Sept-2021	IOSCO	Response to IOSCO on ESG Ratings and Data Products Providers
23-Aug-2021	SEC	Response to SEC Climate Change Disclosures proposal
6-Aug-2021	US House Armed Services Committee	Response to proposed budget cuts, Naval Audit Service
28-July-2021	IFRS Foundation	Response to the International Financial Reporting Standards Foundation on draft changes to create an International Sustainability Standards Board
11-June-2021	OSFI	Comment letter to Assurance on Capital, Leverage and Liquidity Returns
21-May-2021	SEC	Response to request for public comments on Climate Change Disclosures
13-May-2021	INTOSAI	Response to Performance Audit Subcommittee on draft Using the Work of Internal Auditors in Performance Audits
12-April-2021	OSFI	Comment letter to Navigating Uncertainty in Climate Change: Promoting Preparedness and Resilience to Climate-Related Risks
2-March-2021	OECD	Response to the Organisation for Economic Co-operation and Development on draft Best Practice Principles on International Regulatory Co-operation.

2020

Date	Organization	Response
28-Dec-2020	IFRS Foundation	Recommendations regarding creation of new Sustainability Standards Board and internal audit's role in sustainability reporting.
15-Dec-2020	OSFI	Comment letter to Developing Financial Sector Resilience in a Digital World: Selected Themes in Technology and Related Risks
26-Oct-2020	INTOSAI	Response to IDI exposure draft of Performance Audit ISSAI Implementation Handbook, Version 0.
2-Oct-2020	IAASB	Response to the International Audit and Assurance Standards Board exposure draft of ISA 600 (Revised) Audits of Group Financial Statements.
23-Sept-2020	INTOSAI	Response to the Public Standards Committee secretariat of the International Organization of Supreme Audit Institutions on Framework of Professional Pronouncements 2020-2022, Component 1.
9-Sept-2020	Global Sustainability Standards Board	Recommendations to GSSB on exposure draft of Global Reporting Initiative Universal Standards GRI 101, GRI 102 and GRI 103.
14-Aug-2020	International Integrated Reporting Council	Recommendations on the final exposure of the IIRC's <IR> Framework to better reflect internal audit's role in organizational sustainability reporting.
22-July-2020	INTOSAI	Recommendations to International Organization of Supreme Audit Institutions on draft privatization audit guidance
9-July-2020	International Auditing and Assurance Standards Board	Response to IAASB's proposed guidance on Extended External Reporting Assurance
12-June-2020	World Economic Forum	Response to WEF's proposed Environmental, Social and Governance (ESG) Metrics
02-June-2020	IESBA	Response to International Ethics Standards Board for Accountants on Proposed Revisions to the Non-assurance Services Provisions of the Code
28-April-2020	Accountancy Europe	Comments to Accountancy Europe urging a change in mindset around financial and nonfinancial reporting.
20-March-2020	IIRC	Response to questions from the International Integrated Reporting Council (IIRC) on proposed changes to the International <IR> Framework.
13-Jan-2020	NIST (National Institute of Standards and Technology)	Comments urging greater emphasis on the unique role of internal audit in the National Initiative for Cybersecurity Education (NICE) Cybersecurity Workforce Framework.
8-Jan-2020	City of Palo Alto, CA City Council	Internal Audit Practices: City of Palo Alto Relative to Industry Practices

2019

Date	Organization	Response
06-Aug-2019	US Senate Committee on Finance	Response to Support for S.379
05-Aug-2019	City of Brownsville, TX, USA	Response to Restoration of City Oversight & Audit Committee
01-Aug-2019	AASB	Response to Auditing Assurance Standards Board Exposure Draft on Assurance and Related Services Guidelines 50
20-June-2019	IESBA	Response to International Ethics Standards Board for Accountants on proposed revisions to Part 4B of the Code to Reflect Terms and Concepts Used in ISAE 3000 (Revised).
20-June-2019	IAASB	Feedback on draft guidance for applying ISAE 3000 (Revised) to extended external reporting (EER) assurance engagements.
04-June-2019	IAASB	Feedback on consultation paper Proposed Strategy for 2020-2023 and Work Plan for 2020-2021
20-May-2019	Department of Justice	DOJ Criminal Division Guidance Document - Evaluation of Corporate Compliance Programs
10-May-2019	Glendale, AZ City Council	Ordinance No. 019-43, Eliminating the office of City Auditor
29-April-2019	OECD	Working Group on Bribery should add internal audit to the OECD's 2009 Anti-bribery Recommendation
24-April-2019	INTOSAI	Response to Supreme Audit Institution's draft guidance on auditing information systems and security
27-March-2019	ICAI	Response to the Institute of Chartered Accountants of India Exposure Drafts of Standards for Internal Audit
27-March-2019	INTOSAI	Response to the INTOSAI Working Group on Key National Indicators exposure draft on development and use of key national indicators.
22-Feb-2019	INTOSAI–WGVBS	Guidance for Supreme Audit Institutions on issue of Sustainable Development Goals (SDGs)

2018

Date	Organization	Response
1-Nov-2018	IAASB	Response to the International Auditing and Assurance Standards Board’s Proposed International Standards on Auditing 315 (Revised)
15-Aug-2018	IESBA	International Ethics Standards Board for Accountants (IESBA) response regarding consultation paper, Professional Skepticism — Meeting Public Expectations
19-July-2018	IOSCO	International Organization of Securities Commissions (IOSCO) Response regarding consultation report Good Practices for Audit Committees in Supporting Audit Quality.
26-Feb-2018	Federal Reserve	Response to Proposed Guidance Clarifying Expectations Related to Risk Management for Large Financial Institutions
08-Feb-2018	Monitoring Group	Response to Monitoring Group Consultation on Strengthening the Governance and Oversight of the International Audit-Related Standard-Setting Boards in the Public Interest
16-Jan-2018	ICAI	Response to ICAI Exposure on Framework and Standards on Internal Audit and Framework Governing Internal Audit

2017

Date	Organization	Response
18-Dec-2017	Sustainability Accounting Standards Board (SASB)	RE: SASB's Exposure Draft Standards
09-Oct-2017	Federal Reserve	Response to Proposed Guidance on Supervisory Expectation for Boards of Directors
23-Aug-2017	SEC	RE: SEC Release No. 34-81187
26-June-2017	U.S. (GAO)	2017 Updates to Generally Accepted Government Auditing Standards ("Yellow Book")
31-May-2017	INTOSAI	Response to Liaison with External Stakeholders
29-April-2017	IIRC	International Framework Implementation Feedback
16-Jan-2017	OCC	Enhanced Cyber Risk Management Standards

2016

Date	Organization	Response
7-Dec-2016	AICPA	AICPA's Cybersecurity Risk Management Initiative
26-Sept-2016	COSO	Enterprise Risk Management — Aligning Strategy and Performance
3-Aug-2016	INTOSAI	New INTOSAI Framework of Professional Pronouncements
18-May-2016	King IV	Response to the King IV Corporate Governance Code
13-May-2016	Environmental Protection Agency	Risk Management Programs Under the Clean Air Act
1-Feb-2016	INTOSAI	Response ISSAI 30 Code of Ethics

2015

Date	Organization	Response
2-Nov-2015	U.S. Congress	H.R. 3557, FSOC Transparency and Accountability Act
7-Oct-2015	INTOSAI	ISSAI 3000, 3100, & 3200 Performance Audit Standards
21-Sept-2015	INTOSAI	ISSAI 4000 Compliance Audit Standard
8-Sept-2015	SEC	Concept Release: Possible Revisions to Audit Committee Disclosures
4-Sept-2015	IFAC	Non-Compliance with Laws and Regulations
5-Aug-2015	U.S. Congress	IIA Statement to Senate Judiciary Committee
3-June-2015	U.S. Congress	IIA Statement, “Watchdogs Needed: Top Government Investigator Positions Left Unfilled for Years”
9-Jan-2015	Basel Committee on Banking Supervision	Corporate Governance Principles for Banks
4-Jan-2015	OECD	OECD Principles of Corporate Governance IIA Comments

2014

Date	Organization	Response
5-Dec-2014	International Integrated Reporting Council	IIA Comment Letter—IIRC Assurance on IR Discussion
22-Sept-2014	US Congress	HR 5492, The Inspector General Empowerment Act of 2014
15-Sept-2014	US Department of Defense	Comment letter to proposal to amend Defense Federal Acquisition Regulations Supplement
10-Sept-2014	US Congress	The IIA’s Written Statement, House Oversight & Government Reform Committee
28-March-2014	OCC	OCC Proposed Guidelines Establishing Heightened Expectations for Large Banks
31-Jan-2014	FSB	FSB Risk Culture

2013

Date	Organization	Response
31-Dec-2013	ISACA	ISACA IS Audit and Assurance Exposure Documents
6-Dec-2013	NAIC	Proposed Revisions to Incorporate an Internal Audit Function Requirement into NAIC Model
25-Nov-2013	U.S. GAO	GAO 2013 Exposure Draft Standards for Internal Control in the Federal Government
30-Sept-2013	FSB	FSB Principles for an Effective Risk Appetite Framework
16-Sept-2013	IFAC/CIPFA	Good Governance in the Public Sector – Consultation Draft for an International Framework
29-July-2013	SEC	New York Stock Exchange - Internal Audit Requirement
12-July-2013	IIRC	Consultation Draft of the International Framework
12-July-2013	AICPA	Proposed SAS - Using the Work of Internal Auditors
8-July-2013	U.S. Congress	H.R., Audit Integrity and Job Protection Act
26-June-2013	INTOSAI	Response to Exposure Draft ISSAI 5700 Guideline for the Audit of Corruption Prevention in Government Agencies
21-June-2013	Basel Committee	Response to the Basel Committee on Banking Supervision Consultative Document – "External audits of banks"
3-June-2013	U.S. Congress	"The Unintended Consequences of Dodd-Frank’s Conflict Minerals Provision"
30-April-2013	IFAC	Exposure Drafts ED 2 & 3, Conceptual Framework for Public Sector Entities
12-April-2013	Chartered Institute of Internal Auditors	Chartered Institute of Internal Auditors Consultation Document: Effective Internal Audit in the Financial Services Sector ("the Consultation Document")
28-March-2013	NASDAQ	NASDAQ Notice of Filing of Proposed Rule Change to Require That Listed Companies Have an Internal Audit Function
25-March-2013	FFIEC	Social Media: Consumer Compliance Risk Management Guidance
14-March-2013	IFAC	Response to the International Auditing and Assurance Standards Board (IAASB) Exposure Draft - "The Auditor's Responsibilities Relating to Other Information in Documents Containing or Accompanying Audited Financial Statements and the Auditor's Report Thereon"
15-Feb-2013	INTOSAI	ISSAI 100 – 400: Fundamental Principles of Public Sector, Financial, Performance and Compliance Auditing - Cover Letter and Comments

2012

Date	Organization	Response
28-Dec-2012	ISACA	Response to the Information Systems Assurance and Control Association (ISACA) - Invitation to Comment (ITC) - "IT Audit and Assurance Standards"
15-Dec-2012	IESBA	Response to the International Ethics Standards Board for Accountants (IESBA) Exposure Draft, Responding to a Suspected Illegal Act
4-Dec-2012	COSO	COSO Internal Control - Integrated Framework - Internal Control Over External Financial Reporting: A Compendium of Approaches and Examples (ICEFR), September 2012
8-Oct-2012	IAASB	Response to the International Auditing and Assurance Standards Board (IAASB) - Invitation to Comment (ITC) - "Improving the Auditor's Report" - Cover Letter and Appendix A
26-July-2012	U.S. Congress	IIA Statement to House Committee on Financial Services
25-May-2012	IFAC	Response to the International Ethics Standards Board for Accountants (IESBA) – Exposure Draft, Proposed Change to the Definition of "Engagement Team"
31-Mar-2012	COSO	COSO Draft Update of Internal Control – Integrated Framework - Comment Letter
2-Mar-2012	Basel Committee	Base Internal Audit Function in Banks - Comment Letter
29-Feb-2012	PCAOB	PCAOB Communications with Audit Committees - Comment Letter
29-Feb-2012	IFAC	IFAC Evaluating and Improving Internal Control - Comment Letter and Appendix A
15-Feb-2012	ICGFM	ICGFM’s comments on IPSASB Exposure Draft No. 46, Reporting on the Long-Term Sustainability of a Public Sector Entity’s Finances

2011

Date	Organization	Response
14-Dec-2011	IIRC	Response to the International Integrated Reporting Committee (IIRC) – “Discussion Paper on Towards Integrated Reporting – Communicating Value in the 21st Century” - Cover Letter and Appendix A
14-Dec-2011	PCAOB	Response to the Public Accounting Oversight Board (PCAOB) – “Concept Release on Auditor Independence and Audit Firm Rotation” - Cover Letter and Appendix A and B
30-Sep-2011	PCAOB	Response to the Public Company Accounting Oversight Board (PCAOB) - Concept Release on Possible Revisions to PCAOB Standards Related to Reports on Audited Financial Statements and Related amendments to PCAOB Standards (Ref Docket matter No.34) - Cover Letter and Attachment A
16-Sep-2011	IAASB	Response to the International Auditing and Assurance Standards Board (IAASB) - "Enhancing the Value of Auditor Reporting: Exploring Options for Change" - Cover Letter and Attachment A
22-July-2011	EU	Response to the Green Paper "The EU Corporate Governance Framework" - Cover Letter and Attachment A
4-April-2011	IAASB	Proposed Strategy and Work Program for 2012-2014

2010

Date	Organization	Response
17-Dec-2010	SEC	Proposed Rules for Implementing the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934 (File Number S7-33-10)
8-Dec-2010	European Union	Response to the Green Paper "Audit Policy: Lessons from the Crisis"
18-Nov-2010	Government Auditing Standards	Government Auditing Standards - 2010 Exposure Draft
12-Nov-2010	ISA	Richard Chambers cover letter on Proposed Revisions to ISAs 315 and 610
7-Sept-2010	PCAOB	Docket 028: Proposed Auditing Standard Related to Confirmation and Related Amendments to PCAOB Standards
13-July-2010	International Federation of Accountants (IFAC)	2010-2012 proposed business strategy and work plan of the Professional Accountants in Business (PAIB) Committee
15-June-2010	International Federation of Accountants (IFAC)	2010-2012 proposed strategy and work plan of the International Ethics Standards Board for Accountants (IESBA)
4-June-2010	Basel Committee	Consultative Document - Principles for Enhancing Corporate Governance issued by Basel Committee on Banking Supervision
27-May-2010	PCAOB	PCAOB Rulemaking Docket Matter No. 030, Proposed Auditing Standard Related to Communications With Audit Committees and Related Amendments to Certain PCAOB Auditing Standards - Cover Letter and Attachment A
3-May-2010	ISACA	Monitoring of Internal Controls and IT
27-April-2010	India Ministry of Corporate Affairs	Corporate Governance Voluntary Guidelines 2009 - Appointment of the Internal Auditor
15-April-2010	INTOSAI	ISSAI 40 - Quality Control for SAIs - Cover Letter and Attachment A
15-April-2010	INTOSAI	ISSAI 3100 - Performance Auditing Standards - Cover Letter and Attachment A
25-Feb-2010	Zambia Institute of Chartered Accountants	Practice Guide Note No. 2
18-Feb-2010	PCAOB	PCAOB Rulemaking Docket Matter No. 026: Proposed Auditing Standards Related to the Auditor’s Assessment of and Response to Risk