TCF Bank 2014 Annual Report Download - page 117

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Management’s Report on Internal Control Over Financial Reporting
Management is responsible for establishing and maintaining adequate internal control over financial reporting for TCF Financial
Corporation (the Company). Internal control over financial reporting is a process designed to provide reasonable assurance
regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with
generally accepted accounting principles.
Internal control over financial reporting includes those policies and procedures that pertain to the maintenance of records that in
reasonable detail accurately and fairly reflect the transactions and dispositions of the assets of the Company; provide reasonable
assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally
accepted accounting principles and that receipts and expenditures of the Company are only being made in accordance with
authorizations of management and directors of the Company; and provide reasonable assurance regarding prevention or timely
detection of unauthorized acquisition, use, or disposition of the Company’s assets that could have a material effect on the
financial statements.
Management, with the participation of the Chief Executive Officer (Principal Executive Officer) and Chief Financial Officer
(Principal Financial Officer), completed an assessment of TCF’s internal control over financial reporting as of December 31, 2014.
This assessment was based on criteria for evaluating internal control over financial reporting established in Internal Control –
Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission in May 2013. Based
on this assessment, management concluded that TCF’s internal control over financial reporting was effective as of
December 31, 2014.
KPMG LLP, the Company’s independent registered public accounting firm that audited the consolidated financial statements
included in this annual report, has issued an unqualified attestation report on the effectiveness of the Company’s internal control
over financial reporting as of December 31, 2014.
Any control system, no matter how well conceived and operated, can provide only reasonable, not absolute, assurance that the
objectives of the control system are met. The design of a control system inherently has limitations and the benefits of controls
must be weighed against their costs. Additionally, controls can be circumvented by the individual acts of some persons, by
collusion of two or more people or by management override of the controls. Therefore, no assessment of a cost-effective system
of internal controls can provide absolute assurance that all control issues and instances of fraud, if any, will be detected.
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