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Three Lines of Defense:
Four Limitations (Second in series)
September 15, 2019
Many organizations worldwide have adopted the “three lines of defense” (3LOD) model. The Institute of Internal Auditors (IIA)’s position paper from January 2013 is the most commonly-cited reference.1 The IIA published an exposure draft seeking comments. So it’s a good time to revisit the position paper – flaws and all. Here are four things I believe are limitations to the IIA’s position paper. 1. It’s short. 2. It focuses on Internal Audit. 3. 2LOD audit is not differentiated from other 2LOD. 4. Governance isn’t explained.