JetBlue Airlines 2010 Annual Report Download - page 90

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ITEM 9. CHANGES AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND
FINANCIAL DISCLOSURE
None.
ITEM 9A. CONTROLS AND PROCEDURES
Evaluation of Disclosure Controls and Procedures
We maintain disclosure controls and procedures (as defined in Rule 13a-15(e) under the Exchange Act)
that are designed to ensure that information required to be disclosed by us in reports that we file under the
Exchange Act is recorded, processed, summarized and reported as specified in the SEC’s rules and forms and
that such information required to be disclosed by us in reports that we file under the Exchange Act is
accumulated and communicated to our management, including our Chief Executive Officer, or CEO, and our
Chief Financial Officer, or CFO, to allow timely decisions regarding required disclosure. Management, with
the participation of our CEO and CFO, performed an evaluation of the effectiveness of our disclosure controls
and procedures as of December 31, 2010. Based on that evaluation, our CEO and CFO concluded that our
disclosure controls and procedures were effective as of December 31, 2010.
Management’s Report on Internal Control Over Financial Reporting
Our management is responsible for establishing and maintaining adequate internal control over financial
reporting (as defined in Rule 13a-15(f) under the Exchange Act). Under the supervision and with the
participation of our management, including our CEO and CFO, we conducted an evaluation of the
effectiveness of our internal control over financial reporting based on the framework in Internal Control —
Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission.
Based on that evaluation, our management concluded that our internal control over financial reporting was
effective as of December 31, 2010.
Ernst & Young LLP, the independent registered public accounting firm that audited our Consolidated
Financial Statements included in this Annual Report on Form 10-K, audited the effectiveness of our internal
control over financial reporting as of December 31, 2010. Ernst & Young LLP has issued their report which is
included elsewhere herein.
Remediation of Material Weakness in Internal Control over Financing Reporting
As reported in our Form 10Q/A for the quarter ended September 30, 2010, we did not maintain effective
controls to timely monitor and account for expired points and awards in our previous customer loyalty
program, TrueBlue. This resulted in a material weakness that was identified by our management.
During the fourth quarter of 2009, we migrated to a new customer loyalty management system and began
winding down our previous customer loyalty program. In connection with the winding down of the non-cash
liability for expiring customer loyalty points and awards in our previous program in the fourth quarter of 2010,
we concluded in January, 2011 there were errors in the accounting for expiring points and awards in the years
December 31, 2006 through 2009. We corrected the errors, recorded the appropriate adjustments in the proper
periods and restated each of the three years in the period ended December 31, 2009 to properly reflect the
non-cash revenue for expired customer loyalty points and awards in the periods in which the expirations
occurred. In 2010, including in the fourth quarter, we significantly strengthened our internal controls over our
new customer loyalty program by leveraging the enhanced automated controls of the new customer loyalty
system and by improving our reconciliation and review procedures.
Changes in Internal Control
Other than as expressly noted above in this Item 9A, there were no changes in our internal control over
financial reporting identified in connection with the evaluation of our controls performed during the quarter
ended December 31, 2010 that have materially affected, or are reasonably likely to materially affect, our
internal control over financial reporting.
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