Is the definition of the “internal audit function” sufficiently clear?
There is no definition of internal auditing provided. Under Institute of Internal Auditor Standards and as widely practiced by most major companies: “Internal auditing is an independent, objective assurance and consulting activity designed to add value and improve an organization’s operations. It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes.” The SEC needs to better understand what modern internal audit functions provide to their organizations. The Institute of Internal Auditors, representing over 80,000 global professionals has this information and would welcome the opportunity for consultation as they have in the past. • We solicit comment on whether an exception should be provided for small businesses. If so, what criteria should we consider in providing such an exception? No. The auditor is working in a management or employee capacity and
