18.5 Changes in Internal Control Over Financial Reporting

Registrants are required to disclose any material changes in their ICFR in a Form 10-Q or Form 10-K in accordance with SEC Regulation S-K, Item 308(c). Accordingly, registrants will need to be mindful of these disclosure requirements when establishing new controls and processes related to the adoption of the leasing standard. For further discussion of ICFR, see Appendix E.