First Data 2011 Annual Report Download - page 132

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, 2011. 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, 2011, 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, 2011,
based on the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission ("COSO") Framework to
Internal Control Environment. Based on this assessment and those criteria, management believes that the Company maintained
effective internal control over financial reporting as of December 31, 2011.
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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