First Data 2009 Annual Report Download - page 192

ITEM 9. CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND
FINANCIAL DISCLOSURE
None.
ITEM 9A. CONTROLS AND PROCEDURES
Evaluation of disclosure controls and procedures.
The Company has evaluated, under the supervision of the Company’s Chief Executive Officer and the Chief
Financial Officer, the effectiveness of disclosure controls and procedures as of December 31, 2009. Based on this
evaluation, the Chief Executive Officer and Chief Financial Officer concluded that the Company’s disclosure
controls and procedures were effective as of December 31, 2009, to ensure that information the Company is
required to disclose in reports that are filed or submitted under the Securities Exchange Act of 1934 is recorded,
processed, summarized and reported within the time periods specified in SEC rules and forms.
Management’s Report on Internal Control over Financial Reporting.
Management of the Company is responsible for establishing and maintaining adequate internal control over
financial reporting as defined in Rules 13a-15(f) and 15d-15(f) under the Securities Exchange Act of 1934. The
Company’s internal control over financial reporting is 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. The Company’s internal control over financial reporting includes
those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the assets of the Company; (2) 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 being made only
in accordance with authorizations of management and directors of the Company; and (3) 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 consolidated financial statements.
Because of its inherent limitations, internal control over financial reporting may not prevent or detect
misstatements. All control systems have inherent limitations so that no evaluation of controls can provide
absolute assurance that all control issues are detected. Also, projections of any evaluation of effectiveness to
future periods are subject to the risk that controls may become inadequate because of changes in conditions, or
that the degree of compliance with the policies or procedures may deteriorate.
Management assessed the effectiveness of the Company’s internal control over financial reporting as of
December 31, 2009, based on the criteria set forth by the Committee of Sponsoring Organizations of the
Treadway Commission (“COSO”) in Internal Control-Integrated Framework. Based on this assessment and those
criteria, management believes that the Company maintained effective internal control over financial reporting as
of December 31, 2009.
Ernst & Young LLP, an independent registered public accounting firm, has issued an attestation report on
the Company’s internal control over financial reporting which is contained below.
Changes in internal control over financial reporting.
There were no changes in the Company’s internal control over financial reporting identified in connection
with the above evaluation that occurred during the last fiscal quarter that has materially affected, or is reasonably
likely to materially affect, the Company’s internal control over financial reporting.
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