We e ready to evaluate the effectiveness of our disclosure controls and procedures. How do we determine the level of effort required?
MI 52-109 suggests that the level of effort, the nature of the work, and the nature and extent of the evidence to support the effectiveness of your disclosure controls is “a matter of judgment for the certifying officers.” The CEO and CFO should consider the company’s unique circumstances, including size, the nature of the business and the complexity of operations. The level of effort required is also impacted by the nature and magnitude of the disclosure risks identified.
