. . [m]any of the independent units are actively involved in ensuring the integrity and clarity of the daily profit and loss statements," and that: The Risk Management Department is independent of all trading areas and reports to the chief risk officer... [t]he department supplements the communication between trading manager

e actively involved in ensuring the integrity and clarity of the daily profit and loss statements." 769. Moreover, the Form 10-K stated that the: The Risk Management Department is independent of all trading areas and reports to the chief risk officer... [t]he department supplements the communication between trading manager