Capital One 2015 Annual Report Download - page 243

CAPITAL ONE FINANCIAL CORPORATION
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
224 Capital One Financial Corporation (COF)
Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure
None.
Item 9A. Controls and Procedures
Overview
We are required under applicable laws and regulations to maintain controls and procedures, which include disclosure controls and
procedures as well as internal control over financial reporting, as further described below.
(a) Disclosure Controls and Procedures
Disclosure Controls and Procedures
Disclosure controls and procedures refer to controls and other procedures designed to provide reasonable assurance that information
required to be disclosed in our financial reports is recorded, processed, summarized and reported within the time periods specified
by SEC rules and forms and that such information is accumulated and communicated to management, including our Chief Executive
Officer and Chief Financial Officer, as appropriate, to allow timely decisions regarding our required disclosure. In designing and
evaluating our disclosure controls and procedures, we recognize that any controls and procedures, no matter how well designed
and operated, can provide only reasonable assurance of achieving the desired control objectives, and we must apply judgment in
evaluating and implementing possible controls and procedures.
Evaluation of Disclosure Controls and Procedures
As required by Rule 13a-15 of the Securities Exchange Act of 1934 (the “Exchange Act”), our management, including the Chief
Executive Officer and Chief Financial Officer, conducted an evaluation of the effectiveness of our disclosure controls and procedures
(as that term is defined in Rules 13a-15(e) and 15d-15(e) of the Exchange Act) as of December 31, 2015, the end of the period
covered by this Annual Report on Form 10-K. Based upon that evaluation, the Chief Executive Officer and Chief Financial Officer
concluded that our disclosure controls and procedures were effective as of December 31, 2015, at a reasonable level of assurance,
in recording, processing, summarizing and reporting information required to be disclosed within the time periods specified by the
SEC rules and forms.
(b) Changes in Internal Control Over Financial Reporting
We regularly review our disclosure controls and procedures and make changes intended to ensure the quality of our financial
reporting. During the fourth quarter of 2015, we implemented a new human resource management system including necessary
changes to processes, information technology and other components of internal control over financial reporting. There have been
no other changes in internal control over financial reporting that occurred during the fourth quarter of 2015 which have materially
affected, or are reasonably likely to materially affect, the Company’s internal control over financial reporting.
(c) Management’s Report on Internal Control Over Financial Reporting
Management’s Report on Internal Control Over Financial Reporting is included in “Part II—Item 8. Financial Statements and
Supplementary Data” and is incorporated herein by reference. The Report of Independent Registered Public Accounting Firm on
Internal Control Over Financial Reporting also is included in “Part II—Item 8. Financial Statements and Supplementary Data”
and incorporated herein by reference.
Item 9B. Other Information
None.