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During the year, the Bank enhanced its internal controls over financial reporting within Wholesale Banking through the creation of a new Middle Office group with the mandate to further develop cross-functional support for its derivatives businesses and to focus on enhancing infrastructure and controls. In addition, the Bank enhanced its controls in the financial reporting process through a detailed review of residual unallocated revenues and expenses in the Corporate segment. During the 2003 fiscal year, there have been no significant changes in the Bank’s internal controls over financial reporting that have materially affected, or are reasonably likely to materially affect the Bank’s internal controls over financial reporting. However, the Bank is continually improving its infrastructure and controls. An evaluation was performed under the supervision and with participation of the Bank’s management, including the President and Chief Executive Officer (CEO) and Chief Financial Officer (CFO), of the effectiveness of the design and operation of the Bank’s disclosure controls and procedures, as defined in the rules of the U.S. Securities and Exchange Commission (SEC), as of the end of the period covered by this Annual Report. Based on that evaluation, the Bank’s management, including the CEO and CFO, concluded that the Bank’s disclosure controls and procedures were effective as of October 31, 2003. |