The purpose of the DC&P and ICFR evaluations is to determine whether the issuer’s DC&P and ICFR designs are operating as intended. To support a conclusion that DC&P or ICFR is effective, certifying officers should obtain sufficient appropriate evidence at the date of their assessment that the components of DC&P and ICFR that they designed, or caused to be designed, are operating as intended. Regardless of the approach the certifying officers use to design DC&P or ICFR, they could use a top-down, risk-based approach to evaluate DC&P or ICFR in order to limit the evaluation to those controls and procedures that are necessary to address the risks that might reasonably result in a material misstatement.
Form 52-109F1 requires disclosure of each material weakness relating to the operation of the issuer’s ICFR. Therefore, the scope of the ICFR evaluation must be sufficient to identify any such material weaknesses.