●  CDW Corp · FY 2021 

Controls & Procedures

While management and independent auditors concluded that internal controls over financial reporting were effective at CDW Corp as of December 31, 2021, the assessment included a significant structural exclusion. The ICFR evaluation explicitly omitted Sirius Computer Solutions, Inc., which had been acquired on December 1, 2021, and accounted for approximately 30% of consolidated total assets upon year-end.

CDW L1 Synthesis
●  SYMBOLOGY.ONLINE l1 SYNTHESIS 

Cdw Corp Controls & Procedures Synthesis

Analysis of Disclosure Controls and Internal Controls over Financial Reporting

Management Conclusions on Control Effectiveness

Management has concluded that CDW Corp maintained effective internal controls across both its disclosure processes and financial reporting functions as of December 31, 2021.

Disclosure Controls and Procedures (DCP)
  • Assessment: Management concluded that the Company's DCP were effective.
  • Evidence: The evaluation confirmed that the controls were effective "in recording, processing, summarizing, and reporting, on a timely basis, information required to be disclosed by the Company in the reports that it files or submits under the Exchange Act."
Internal Control over Financial Reporting (ICFR)
  • Assessment: Management concluded that its ICFR was effective.
  • Evidence: This conclusion was based on an assessment conducted using the COSO 2013 framework. The independent auditor, Ernst & Young LLP, concurred with this finding, stating in their opinion that CDW Corp "maintained, in all material respects, effective internal control over financial reporting as of December 31, 2021."

Identified Weaknesses and Deficiencies

The provided documentation does not identify any material weaknesses or significant deficiencies within the Company's controls.

Absence of Material Issues
  • Observation: Neither management nor the independent auditor reported identifying any material weaknesses in ICFR as of December 31, 2021.
  • Note on Limitations: The report acknowledges the inherent limitations of internal control over financial reporting, stating that it "may not prevent or detect misstatements" and can only provide reasonable assurance.

Changes and Noteworthy Procedural Updates

The reporting period showed stability in existing controls but included a notable procedural change related to recent acquisitions.

Stability of Controls
  • Observation: There were no changes reported in the internal control over financial reporting during the quarter ended December 31, 2021 that were deemed likely to materially affect the ICFR.
Noteworthy Procedural Exclusion (Acquisition)
  • Change/Note: Management and the auditor noted a specific exclusion from the scope of their assessment due to an acquisition.
  • Evidence: The internal control assessment for Sirius Computer Solutions, Inc. was excluded because it was acquired on December 1, 2021. This entity accounted for approximately 30% of consolidated total assets as of year-end. Both management and the auditor explicitly stated that their assessments did not include the ICFR of this newly acquired business.