What impact, if any, has COSO had outside the United States? Does COSO coordinate with international professional organizations?
Rittenberg: COSO has certainly had a significant impact outside of the United States, especially through multinational corporations. Our ERM and internal control frameworks have been translated into most of the major languages around the globe, including French, Spanish, Chinese, Russian, Portuguese, Italian, Finnish, and Swedish. Corporate governance and internal control issues are very important in many countries. The Australians, the British, the Canadians, the French, the Germans, the Malaysians, and the Taiwanese, among others, have all developed conceptual models of governance, control, and risk management. Control and risk management frameworks, however, vary in terms of the detail involved. Some frameworks are based on detailed processing objectives over processes. COSO is one of the few frameworks with a significant review of the control environment. Look at some of the major recent corporate failures. Where did the problems fundamentally arise? They occurred primarily because