This tool contains two sample policies that establish standards and procedures for the internal disclosure certification process, which is designed to improve comfort for the executives responsible for signing the external disclosure certification required by the Sarbanes-Oxley (SOX) Act.

In these samples, procedures are established for the design and evaluation of disclosure controls to ensure the fair presentation and disclosure of financial results. For each section within Management’s Discussion and Analysis (MD&A), the notes, and all parts preceding and following these sections, the preparer will prepare a checklist of procedures designed to ensure the accuracy of the disclosure.