Finding Common Ground: COSO's Control Frameworks and the Levers of Control

We examine the extent to which the 2013 COSO Internal Control-Integrated Framework (ICIF) suc-ceeds in the goal to expand its application beyond a compliance framework. We do so by mapping the points of focus in the 2013 ICIF to the principles articulated in the Levers of Control (LOC) framework advocated by Simons (1995). The analysis shows how the revision achieves partial success. This identi-fication of areas in which the frameworks overlap promotes an integrated view of organizational con-trol and aids assessment of the efficacy of a firm's control over its strategic and operational processes. We also examine the extent to which the 2016 COSO Enterprise Risk Management (ERM) Exposure Draft captures non-overlapping areas between the 2013 ICIF and the LOC, and highlight implications for future work in this evolving area.