Frequently Asked Questions Regarding Compliance with OMB Circular A-123

The Sarbanes-Oxley Act of 2002 (SOX) served as an impetus for the federal government to re-evaluate its policies relating to internal control over financial reporting. The result was the revised Office of Management and Budget (OMB) Circular A-123 in December 2004. This revised OMB Circular A-123 adopts much of what is contained in SOX Section 404.

In this booklet, we answer questions about complying with OMB Circular A-123, applicability to various federal agencies, the role of management, the Committee of Sponsoring Organizations of the Treadway Commission (COSO) Internal Controls - Integrated Framework (New Framework), risks and control objectives, and key dates.