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Public Comment Letters

2024

Date	Organization	Response
9-October-2024	Basel Commitee on Banking Supervision	Comments regarding Basel Committee on Banking Supervision’s (Basel Committee) consultative draft titled, Principles for the sound management of third-party risk.
09-September-2024	Competition Bureau Canada	Comments on Competition Act's New Greenwashing Provisions
24-June-2024	Standing Committee on Public Safety and National Security	Critical Cyber Systems Protection Act (Bill C-26, Part II)
14-June-2024	Financial Services Regulatory Authority of Ontario (FSRA)	Comments on FSRA’s Proposed Corporate Governance and Operational Risk
14-June-2024	Autorité des marchés financiers	Issues and Discussion Paper: Best Practices for the Responsible Use of AI in the Financial Sector
9-May-2024	International Ethics Standards Board for Accountants (IESBA)	Comments Regarding IESBA’s Proposed International Ethics Standards for Sustainability Assurance (including International Independence Standards) (IESSA) and Other Revisions to the Code relating to Sustainability Assurance and Reporting

2023

Date	Organization	Response
1-December-2023	International Auditing and Assurance Standards Board (IAASB)	Comments Regarding IAASB’s International Standard on Sustainability Assurance (ISSA) 5000, General Requirements for Sustainability Assurance Engagements
30-November-2023	United States Congress	Comments Regarding the Proposed National AI Commission Act
6-November-2023	National Institute of Standards and Technology (NIST)	Comments Regarding NIST Cybersecurity Framework (CSF) 2.0 Initial Public Draft
7-October-2023	Organization: INTOSAI	Comments Regarding Guidance on Cooperation with Internal Auditors
11-September-2023	Organisation for Economic Co-operation and Dvelopment	Comments Regarding OECD Guidelines on Corporate Governance of State-Owned Enterprises
14-August-2023	New York Department of Financial Services	Comments on the Revised Proposed Second Amendment to 23 NYCRR 500
07-July-2023	The White House Office of Science and Technology Policy (OSTP)	Comment Regarding Artificial Intelligence
31-May-2023	Office of the Superintendent of Financial Institutions (OSFI)	In regards to the Culture and Behaviour Risk Guideline
22-May-2023	United States Congress	Joint IIA Chapter Letter Requesting the Inclusion of Internal Audit in Cryptocurrency Exchanges
04-May-2023	United States Congress	Proposed Legislative Text for Enhancing Corporate Governance at Cryptocurrency Exchanges
24-April-2023	International Accounting and Auditing Standards Board (IAASB)	Comments Regarding Proposed International Standards on Auditing 500
07-April-2023	Iowa House of Representatives	Concerns Regarding Amendment H-1177 to Senate File 478
31-March-2023	Financial Services Regulatory Authority of Ontario (FSRA)	Comments regrading Proposed IT Risk Management Guidance Consultation
27-March-2023	Securities and Exchange Commission (SEC)	Comments Regarding Prohibition Against Conflicts of Interest in Certain Securitizations
22-March-2023	United States House of Representatives	Joint IIA Chapter Letter Requesting the Inclusion of Internal Audit in Future Data Privacy and Security Legislation
16-March-2023	Iowa House of Representatives	Concerns Regarding Senate File 478
23-February-2023	National Institute of Standards and Technology	Comments Regarding NIST Cybersecurity Framework (CSF) 2.0 Concept Paper
06-February-2023	Public Company Accounting Oversight Board (PCAOB)	Comments to the PCAOB’s proposed auditing standard “The Auditor’s Use of Confirmation, and Other Proposed Amendments to PCAOB Standards.
09-January-2023	New York Department of Financial Services	Comments to the Proposed Second Amendment to 23 New York Codes, Rules, and Regulations (NYCRR) Part 500 ("Part 500")

2022

Date	Organization	Response
05-December-2022	United States Congress	IIA Letter on Crypto to US Congress
21-October-2022	The Organisation for Economic Co-operation and Development (OECD)	Response to OECD Corporate Governance Principles
30-September-2022	American Institute of Certified Public Accountants	Response to AICPA Exposure Draft on CPA Exam
29-July-2022	International Sustainability Standards Board (ISSB)	Response to ISSB Climate Disclosures Exposure
29-July-2022	International Sustainability Standard Board (ISSB)	Response to ISSB Sustainability Disclosures Exposure
6-June-2022	Securities and Exchange Commission (SEC)	Letter regarding SEC Climate-Related Disclosure Rules
10-May-2022	Securities and Exchange Commission (SEC)	Letter regarding SEC Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure proposal.
28-April-2022	National Institute of Standards and Technology (NIST)	Letter regarding the NIST's AI Risk Management Framework
16-Feb-2022	European Commission	Letter regarding Consultation on Corporate Reporting
14-Feb-2022	Basel Committee on Banking Supervision	Letter regarding consultative Paper on Principles for Effective Management and Supervision of Climate-Related Financial Risks
10-Feb-2022	Office of the Comptroller of the Currency	Letter regarding the OCC’s Principles for Climate-Related Financial Risk Management for Large Banks
31-Jan-2022	IAASB	Letter to the International Accounting and Auditing Standards Board regarding the role of internal audit in audits of financial statements of less complex entities.

2021

Date	Organization	Response
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 Sustanability 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 Auditing 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	Response to Restoration of City Oversight and 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 IAASB 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, Arizona 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 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)