Internal accounting controls

Internal Control over Financial Reporting (ICFR)

Under federal law, publicly traded companies are responsible for devising and maintaining a system of internal accounting controls sufficient to reasonably assure that:

• transactions are executed in accordance with management authorization;

• transactions are recorded as necessary to: 1) permit preparation of financial statements in conformity with GAAP and 2) maintain accountability for assets;

• access to assets is permitted only in accordance with management authorization; and

• recorded accountability for assets is compared with the existing assets at reasonable intervals, and appropriate action is taken regarding any differences.