TCF Bank 2015 Annual Report Download - page 125
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110
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, 2015. 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, 2015.
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, 2015.
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.