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Controls (continued)
- The initial and ongoing valuation assumptions undergo extensive reviews, both internal and external, as noted in the diagram to the left.
- We have also created communication channels for our employees to use to report any suspicious or questionable procedures. For example, we have an independent “We Tip Hotline” that provides employees with the opportunity to anonymously refer issues directly to both our general counsel and our chief human resources officer. We also have an open employee suggestion forum where employees can submit suggestions directly to the CEO. Additionally, we have implemented a certification process whereby all senior management personnel and all key accounting personnel formally certify quarterly that “to the best of my knowledge, the accounting records for which I am responsible are accurate” and “I am not aware of anything (even outside my area) that is not being accurately reflected in our financial statements/disclosures.”
- Finally, to ensure that our shareholders have the ability to evaluate for themselves the appropriateness of our valuation assumptions, we clearly disclose those assumptions in our quarterly earnings announcements and SEC filings. While our SEC disclosures have been very extensive historically, we have further increased our disclosures in our current Annual Report on Form 10-K to address Financial Reporting Releases 60 and 61 and other recent industry guidance.
We also recognize a responsibility to our employees as our greatest asset. In connection with this responsibility, we modified our employees’ 401(k) plan effective January 1, 2002, to eliminate the use of IndyMac common stock to match employee contributions to their plan accounts. Employees now receive their matching funds in cash that vests over time and have the ability to invest the funds within the plan as they choose. While we are confident about IndyMac’s long-term potential, we also want to make sure our employees have a clear choice in this matter. |
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