COSO and NACD Propose New Corporate Governance Framework
SUMMARY Last week, the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”) and the National Association of Corporate Directors (“NACD”) released a public exposure draft of their Corporate Governance Framework for U.S. public companies (the “COSO/NACD Framework”). According to COSO, the COSO/NACD Framework is intended to provide an integrated and comprehensive governance framework that […]
Posted by C. Michelle Chen, Robert W. Downes, and Marc Treviño, Sullivan & Cromwell LLP, on Thursday, June 26, 2025
Editor's Note:
C. Michelle Chen, Robert W. Downes, and Marc Treviño are Partners at Sullivan & Cromwell LLP. This post is based on a Sullivan & Cromwell memorandum by Ms. Chen, Mr. Downes, Mr. Treviño, Julia Khomenko, Julia E. Paranyuk, and Davis R. Parker.
SUMMARY
Last week, the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”) and the National Association of Corporate Directors (“NACD”) released a public exposure draft of their Corporate Governance Framework for U.S. public companies (the “COSO/NACD Framework”).
According to COSO, the COSO/NACD Framework is intended to provide an integrated and comprehensive governance framework that unifies and enhances existing corporate governance practices. The COSO/NACD Framework is organized around six core components: (1) Oversight; (2) Strategy; (3) Culture; (4) People; (5) Communication; and (6) Resilience. The draft is open for public comment through July 11, 2025.
