How do the new rules affect our procedures for internal audit controls?
Certifying officers are required to disclose to the company’s auditors and audit committee deficiencies in internal controls. Under Section 13(b) of the Exchange Act, the company is required to maintain a system of internal controls designed to provide reasonable assurances that (i) transactions are executed in accordance with management’s authorization, (ii) transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP and to maintain accountability for assets, (iii) access to assets is permitted only in accordance with management’s authorization and (iv) the recorded accountability for assets is compared with existing assets at reasonable intervals and appropriate action is taken with respect to any differences. These controls often comprise elements such as technical testing and audit firm attestations. At the open meeting at which the new rules were adopted, the director of the division of corporation finance confirmed that, to a signi
