In some cases, the controls failed with respect to newer risk exposures that were not identified, or growth put strains on existing control processes that were not suitable for a larger organization. Section 302 of Sarbanes-Oxley requires senior management to assess and report on the effectiveness of disclosure controls and procedures as well as on internal controls for financial reporting.
This broader certification addresses controls and procedures related to public disclosure, including financial information, such as Management’s Discussion and Analysis, that is reported outside of the financial statements.