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The issuer entered into revenue arrangements with multiple elements including arrangements that contained fees contingent upon the resolution of certain matters that were beyond the issuer's control (“contingent fees”). The issuer's policy was to recognize revenue and the related receivable from certain arrangements that contained contingent fees when services were provided which generally occurred before the resolution of the contingent matters. The following deficiencies were identified: · The firm did not evaluate whether (1) the issuer identified all elements in its arrangements and appropriately determined the units of accounting and (2) separate contracts entered into with the same individual customers within a short time frame should have been combined and accounted for as multiple-element arrangements. (AS 2301.08)

The issuer entered into revenue arrangements with multiple elements including arrangements that contained fees contingent upon the resolution of certain matters that were beyond the issuer's control (“contingent fees”). The issuer's policy was to recognize revenue and the related receivable from certain arrangements that contained contingent fees when services were provided which generally occurred before the resolution of the contingent matters. The following deficiencies were identified: · For certain of the issuer's revenue the firm did not identify and test any controls that addressed whether the issuer's revenue recognition policies for its multiple-element arrangements including those with contingent fees were in conformity with GAAP. (AS 2201.39)

The issuer entered into revenue arrangements with multiple elements including arrangements that contained fees contingent upon the resolution of certain matters that were beyond the issuer's control (“contingent fees”). The issuer's policy was to recognize revenue and the related receivable from certain arrangements that contained contingent fees when services were provided which generally occurred before the resolution of the contingent matters. The following deficiencies were identified: · The firm did not evaluate whether the issuer's accounting for recognizing revenue for contingent fees prior to the resolution of the contingent matters and the determination of the amount to be collected was in conformity with FASB ASC Topic 605 Revenue Recognition and with GAAP as interpreted by the SEC Codification of Staff Accounting Bulletins Topic 13 Revenue Recognition. (AS 2810.30)

The firm did not evaluate the appropriateness of the issuer's classification of these receivables as current assets in conformity with FASB ASC Topic 210 Balance Sheet. (AS 2810.30 and .31)

The firm did not identify and evaluate various misstatements in the issuer's disclosures related to accounts receivable and other liabilities. (AS 2810.30 and .31)

The issuer disclosed that it presented its accounts receivable net of certain unpaid costs. The firm did not perform any substantive procedures to evaluate whether this presentation was in conformity with FASB ASC Topic 210 Balance Sheet. (AS 2301.08)

The issuer's accounts receivable from related and unrelated parties consisted of nonrefundable fees from agreements discussed above which had payment terms beyond one year. The firm did not evaluate whether the issuer's accounts receivable that were not expected to be collected within 12 months should have been classified as non-current assets in conformity with FASB ASC Topic 310 Receivables. (AS 2810.30)

The firm did not perform any procedures to evaluate whether the issuer's disclosure of the credit quality of certain accounts receivable was in conformity with FASB ASC Topic 326 Financial Instruments — Credit Losses. (AS 2810.30 and .31)

The firm did not perform procedures to evaluate whether the issuer's classification of certain accounts receivable as current assets was in conformity with FASB ASC Topic 210 Balance Sheet. (AS 2810.30 and .31)