Date of Conferral



Doctor of Business Administration (D.B.A.)


Business Administration


Kevin Davies


Some community bank compliance professionals lack strategies to comply with the 2013 Committee of Sponsoring Organizations of the Treadway Commission (COSO) internal control framework statement, so they have been slow to adapt to the new COSO framework. However, they will be under increased regulatory pressure to do so. Grounded in Cressey's fraud triangle theory, the purpose of this qualitative single case study was to explore strategies community bank compliance professionals use to comply with the revised COSO internal control framework. Four compliance professionals at a community bank in the Boston, Massachusetts area who have successfully implemented strategies for internal control oversight participated in semistructured interviews. Bank managers provided company internal control documents. Data were analyzed using Yin's 5 step process: compiling, disassembling, reassembling and arraying, interpreting, and concluding. Also, methodological triangulation ensured data reliability. Four primary themes emerged: monitoring controls, communication, separation of duties, and training. Bank managers who implement the 4 strategies found in this study are more likely to comply with the COSO internal control framework statement. The implications for positive include the potential for corporate governance to provide accountability for bank management and line employees, contributing to a stable community banking system. Bank compliance, in turn, helps build a more stable economy for communities in which the small banks operate, supporting small businesses, particularly those hurt by the 2020 coronavirus pandemic.