US Bank 2003 Annual Report Download - page 63

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reasonableness of its valuations including public market DISCLOSURE CONTROLS AND PROCEDURES
comparables, multiples of recent mergers and acquisitions of
Under the supervision and with the participation of the
similar businesses. Valuation multiples may be based on
Company’s management, including its principal executive
revenue, price-to-earnings and tangible capital ratios of
officer and principal financial officer, the Company has
comparable public companies and business segments. These
evaluated the effectiveness of the design and operation of its
multiples may be adjusted to consider competitive
disclosure controls and procedures (as defined in
differences including size, operating leverage and other
Rules 13a-15(e) and 15d-15(e) under the Securities
factors. The carrying amount of a reporting unit is
Exchange Act of 1934 (the ‘‘Exchange Act’’)). Based upon
determined based on the capital required to support the
this evaluation, the principal executive officer and principal
reporting unit’s activities including its tangible and
financial officer have concluded that, as of the end of the
intangible assets. The determination of a reporting unit’s
period covered by this report, the Company’s disclosure
capital allocation requires management judgment and
controls and procedures were effective to ensure that
considers many factors including the regulatory capital
information required to be disclosed by the Company in
regulations and capital characteristics of comparable public
reports that it files or submits under the Exchange Act is
companies in relevant industry sectors. In certain
recorded, processed, summarized and reported within the
circumstances, management will engage a third-party to
time periods specified in Securities and Exchange
independently validate its assessment of the fair value of its
Commission rules and forms.
business segments.
During the most recently completed fiscal quarter, there
The Company’s annual assessment of potential
was no change made in the Company’s internal controls
goodwill impairment was completed during the second
over financial reporting (as defined in Rules 13a-15(f)
quarter of 2003. Based on the results of this assessment, no
and 15d-15(f) under the Exchange Act) that has materially
goodwill impairment was recognized.
affected, or is reasonably likely to materially affect, the
Company’s internal control over financial reporting.
U.S. Bancorp 61