Regions Bank 2008 Annual Report Download - page 95

Assistance Program to help borrowers struggling with their mortgage payments and alerting them sooner about
available options. Restructurings were primarily due to modification of rates below market and extensions of
maturities.
At December 31, 2008 and December 31, 2007, Regions had approximately $812.6 million and $221.5
million, respectively, of potential problem commercial and commercial real estate loans that were not included in
non-accrual loans or in the accruing loans 90 days past due categories, but for which management had concerns
as to the ability of such borrowers to comply with their present loan repayment terms. At December 31, 2008,
$11.9 million of the $221.5 million from 2007 remained categorized as potential problem loans. The remaining
loans either migrated to non-performing status or were no longer considered potential problem loans.
FINANCIAL DISCLOSURE AND INTERNAL CONTROLS
Regions has always maintained internal controls over financial reporting, which generally include those
controls relating to the preparation of the consolidated financial statements in conformity with accounting
principles generally accepted in the U.S. Regions’ process for evaluating internal controls over financial
reporting starts with understanding the risks facing each of its functions and areas; how those risks are controlled
or mitigated; and how management monitors those controls to ensure that they are in place and effective. These
risks, control procedures and monitoring tools are documented in a standard format. This format not only
documents the internal control structures over all significant accounts, but also places responsibility on
management for establishing feedback mechanisms to ensure that controls are effective. These monitoring
procedures are also part of management’s testing of internal controls. At least quarterly, each area updates and
assesses the adequacy of its documented internal controls. If changes are necessary, updates are made more
frequently.
Regions also has established processes to ensure appropriate disclosure controls and procedures are
maintained. These controls and procedures as defined by the SEC are generally designed to ensure that financial
and non-financial information required to be disclosed in reports filed with the SEC is reported within the time
periods specified in the SEC’s rules and forms, and that such information is communicated to management,
including the Chief Executive Officer (“CEO”) and Chief Financial Officer (“CFO”), as appropriate, to allow
timely decisions regarding required disclosure.
Regions’ Disclosure Review Committee, which includes representatives from the legal, risk management,
accounting, investor relations and audit departments, meets quarterly to review recent internal and external
events to determine whether all appropriate disclosures have been made in reports filed with the SEC. In
addition, the CEO and CFO meet quarterly with the SEC Filings Review Committee, which includes senior
representatives from accounting, legal, risk management, audit, operations and technology, as well as from the
core business segments. The SEC Filings Review Committee reviews certain reports to be filed with the SEC,
including Forms 10-K and 10-Q, and Proxy filings, and evaluates the adequacy and accuracy of the disclosures.
As part of this process, certifications of internal control effectiveness are obtained from all core business
segments, accounting, legal, risk management, and operations and technology. These certifications are reviewed
and presented to the CEO and CFO as evidence of the Company’s assessment of internal controls over financial
reporting. The Forms 10-K and 10-Q are presented to the Audit Committee of the Board of Directors for
approval. Financial results and other financial information are also reviewed with the Audit Committee on a
quarterly basis.
As required by applicable regulatory pronouncements, the CEO and the CFO review and make various
certifications regarding the accuracy of Regions’ periodic public reports filed with the SEC, as well as the
effectiveness of disclosure controls and procedures and internal controls over financial reporting. With the
assistance of the financial review committees, Regions will continue to assess and monitor disclosure controls
and procedures and internal controls over financial reporting, and will make refinements as necessary.
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