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Which institutions have to conduct an assessment of internal control over financial reporting and include a report of the assessment in its annual report?

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Which institutions have to conduct an assessment of internal control over financial reporting and include a report of the assessment in its annual report?

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Under our rule at § 620.3(d), the deciding factor for determining whether an institution is required to conduct an assessment of internal control over financial reporting is whether its total assets are more than $1 billion on the last day of the prior fiscal year. All institutions meeting this requirement must conduct the assessment and then include management’s report on the assessment in their annual reports for the reporting period. Fluctuations in assets during a fiscal year do not affect an institution’s compliance with the requirement; it is an institution’s total assets status on the last day of the prior fiscal year that determines applicability of the requirement.

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