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The issuer used various internally and externally developed models to estimate the quantitative component of the ACL for loans collectively evaluated for impairment. These models used various data and assumptions. The following deficiencies were identified: · The firm's approach for substantively testing the quantitative component of the ACL for loans collectively evaluated for impairment was to test the issuer's process and the firm used an auditor-employed specialist to evaluate certain significant assumptions the issuer used including the underlying models and assumptions. The firm did not sufficiently evaluate the reasonableness of these significant assumptions because it did not identify that the specialist's procedures were limited to inquiring of management and reading issuer-prepared reports and analyses. (AS 1201.C6 and .C7; AS 2501.16)

The issuer used two IT systems to process and record transactions related to the ALL. In its testing of controls over this account the firm tested certain IT-dependent manual controls that used data and reports generated or maintained by these IT systems. As a result of the deficiencies in the firm's testing of ITGCs discussed below the firm's testing of these IT-dependent manual controls was not sufficient. (AS 2201.46)

The issuer used two IT systems to process and record transactions related to the ALL. In its testing of controls over this account the firm tested certain IT-dependent manual controls that used data and reports generated or maintained by these IT systems. The following ITGC deficiencies were identified: · The firm selected for testing controls over the issuer's review of user access to these IT systems but did not evaluate the specific review procedures that the control owners performed to determine whether to approve user access that had been requested or whether user access that had been previously approved continued to be appropriate. (AS 2201.42 and .44)

The issuer used two IT systems to process and record transactions related to the ALL. In its testing of controls over this account the firm tested certain IT-dependent manual controls that used data and reports generated or maintained by these IT systems. The following ITGC deficiencies were identified: · The firm selected for testing a control over change management but did not perform any procedures to test or in the alternative test any controls over the completeness of the population of changes from which it made its selections for testing. (AS 1105.10)

As a result of the firm's ITGC testing deficiencies the firm did not perform sufficient substantive procedures as follows: · The firm did not perform any substantive procedures to test or sufficiently test controls over the accuracy and completeness of certain system-generated data and reports the firm used in its substantive testing. (AS 1105.10)

As a result of the firm's ITGC testing deficiencies the firm did not perform sufficient substantive procedures as follows: · The sample size the firm used in certain of its substantive procedures to test the ALL was too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The issuer maintained an ALL related to loans receivable which included a collectively assessed component ('Collective Reserve') and an individually assessed component ('Individual Reserve'). The issuer used various models and assumptions to estimate the ALL. The following deficiencies were identified: - The firm's approach for substantively testing the Collective Reserve was to review and test management's process. The firm did not sufficiently evaluate the reasonableness of the Collective Reserve because the firm did not perform procedures to test certain assumptions the issuer used to determine the reserve including the loss rates and portfolio segmentation. (AS 2501.09 .10 and .11) [This citation refers to AS 2501 Auditing Accounting Estimates which was in effect for this audit. This standard was replaced by AS 2501 Auditing Accounting Estimates Including Fair Value Measurements which became effective for audits of financial statements for fiscal years ending on or after December 15 2020.]

The issuer maintained an ALL related to loans receivable which included a collectively assessed component ('Collective Reserve') and an individually assessed component ('Individual Reserve'). The issuer used various models and assumptions to estimate the ALL. The following deficiencies were identified: - The firm did not perform procedures to test the Individual Reserve beyond recalculating the days past due for each loan in the population determining the aging bucket for the respective loans and re-performing the issuer's calculation of the reserve using the issuer's loan risk level and associated loss rate assumptions. (AS 2501.07) [This citation refers to AS 2501 Auditing Accounting Estimates which was in effect for this audit. This standard was replaced by AS 2501 Auditing Accounting Estimates Including Fair Value Measurements which became effective for audits of financial statements for fiscal years ending on or after December 15 2020.]

The issuer maintained an ALL related to loans receivable which included a collectively assessed component ('Collective Reserve') and an individually assessed component ('Individual Reserve'). The issuer used various models and assumptions to estimate the ALL. The following deficiencies were identified: - The firm did not identify and appropriately address a departure from IFRS related to the issuer's presentation of repayments of loans from customers as cash flows from investing activities in the statement of cash flows rather than cash flows from operating activities in conformity with IAS 7 Statement of Cash Flows. (AS 2810.30 and .31) Unrelated to our review the issuer reevaluated the presentation of cash flows from the repayment of loans from customers in the statement of cash flows and concluded that a material misstatement existed that had not been previously identified. The issuer subsequently corrected this misstatement in a restatement of its financial statements and the firm issued a special report regarding those adjustments.

To test the reasonableness of assigned loan grades to non-impaired loans which are an input used in estimating the ALL the firm selected loans originated in prior years that exceeded a monetary threshold for testing. The firm did not perform any procedures to test the remaining population of loans originated in prior years. (AS 1105.27; AS 2301.08)

The issuer's ALL included a reserve for loans individually evaluated for impairment ('specific reserve') and a reserve for loans collectively evaluated for impairment ('collective reserve'). The issuer's collective reserve included a component that was determined by using certain qualitative factors ('qualitative component'). The following deficiencies were identified: · The firm selected for testing controls that consisted of the issuer's reviews of the ALL including the collective reserve. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of the ALL including the appropriateness of the basis points applied to determine the qualitative component. (AS 2201.42 and .44)

The issuer's ALL included a reserve for loans individually evaluated for impairment ('specific reserve') and a reserve for loans collectively evaluated for impairment ('collective reserve'). The issuer's collective reserve included a component that was determined by using certain qualitative factors ('qualitative component'). The following deficiencies were identified: · The firm selected for testing controls that consisted of the issuer's reviews of the ALL including the collective reserve. The firm did not identify and test any controls over the accuracy and completeness of certain data and/or reports used in the operation of these controls. (AS 2201.39)

The issuer's ALL included a reserve for loans individually evaluated for impairment ('specific reserve') and a reserve for loans collectively evaluated for impairment ('collective reserve'). The issuer's collective reserve included a component that was determined by using certain qualitative factors ('qualitative component'). The following deficiencies were identified: · The firm selected for testing controls that consisted of the issuer's reviews of its loan portfolio to identify potentially impaired loans for the specific reserve. The firm did not evaluate the specific review procedures that the control owners performed to assess the completeness of loans the issuer assessed individually for impairment. (AS 2201.42 and .44)

The issuer's ALL included a reserve for loans individually evaluated for impairment ('specific reserve') and a reserve for loans collectively evaluated for impairment ('collective reserve'). The issuer's collective reserve included a component that was determined by using certain qualitative factors ('qualitative component'). The following deficiencies were identified: · The firm selected for testing controls that consisted of the issuer's reviews of its loan portfolio to identify potentially impaired loans for the specific reserve. The firm did not identify and test any controls over the accuracy and completeness of certain data and/or reports used in the operation of these controls. (AS 2201.39)

The issuer's ALL included a reserve for loans individually evaluated for impairment ('specific reserve') and a reserve for loans collectively evaluated for impairment ('collective reserve'). The issuer's collective reserve included a component that was determined by using certain qualitative factors ('qualitative component'). The following deficiencies were identified: · The firm selected for testing a control that consisted of the issuer's review of the valuation of impaired loans. The firm did not evaluate the specific review procedures that the control owner performed to assess the appropriateness of the methods and assumptions used to determine the valuation of the specific reserve for these impaired loans. (AS 2201.42 and .44)

The issuer's ALL included a reserve for loans individually evaluated for impairment ('specific reserve') and a reserve for loans collectively evaluated for impairment ('collective reserve'). The issuer's collective reserve included a component that was determined by using certain qualitative factors ('qualitative component'). The following deficiencies were identified: · The firm's approach for substantively testing the collective reserve was to review and test management's process. The firm did not perform procedures to evaluate the reasonableness of the basis points that were applied to determine the qualitative component beyond comparing these basis points to the basis points that were applied in prior years and assessing whether certain changes or lack thereof to the basis points from the prior year were directionally consistent with internal or external data and performing procedures to test certain data. (AS 2501.09 .10 and .11) [This citation refers to AS 2501 Auditing Accounting Estimates which was in effect for this audit. This standard was replaced by AS 2501 Auditing Accounting Estimates Including Fair Value Measurements which became effective for audits of financial statements for fiscal years ending on or after December 15 2020.]

The firm's internal inspection program had inspected this audit and reviewed this area but did not identify the deficiencies below. The firm's approach to test ACL was to test management's process. The issuer engaged a specialist to prepare a model validation report over the issuer's model to estimate the quantitative component of the ACL. The firm did not test or test controls over the accuracy and completeness of the company-produced data used by the company's specialist in its model validation report. (AS 1105.A8a)

The firm's internal inspection program had inspected this audit and reviewed this area but did not identify the deficiencies below. To determine the qualitative component of the ACL the issuer identified one or more data inputs relevant to each identified qualitative factor and established quantitative ranges for these inputs corresponding with the risk level expected to be assigned to each factor and loan pool. The firm did not perform sufficient procedures to evaluate the reasonableness of the significant assumptions related to the assessed risk levels and related basis points applied to the collateral factor reserves. (AS 2501.16)

The issuer's ALL included a qualitative component. The firm's approach for substantively testing the ALL was to review and test management's process. The firm did not sufficiently evaluate the reasonableness of the qualitative component of the ALL because the firm's procedures to test certain assumptions the issuer used to determine the qualitative component were limited to comparing these assumptions to prior periods inquiring about changes and recalculating the allowance. (AS 2501.09 .10 and .11)

The firm's approach to testing loans and the ALL included reliance on certain controls. The issuer used a service organization to process and record transactions related to loans and this loan information was used in the firm's procedures to test loans and the ALL. The firm did not perform procedures beyond inquiring of management to test complementary user controls over loans identified in the service auditor's report. (AS 2601.14)

The issuer's ALL consisted of a qualitative component and an unallocated reserve component. The firm's approach for substantively testing the ALL was to both test the issuer's process and develop an independent expectation of the estimate. The following deficiencies were identified: · The firm used the issuer's loan grades in its independent expectation. The firm selected loans that met specific criteria to test the loan's assigned grade. The firm did not perform procedures to test loan grades for the remaining population of loans. (AS 1105.27; AS 2301.08 and .11)

The issuer's ALL consisted of a qualitative component and an unallocated reserve component. The firm's approach for substantively testing the ALL was to both test the issuer's process and develop an independent expectation of the estimate. The following deficiencies were identified: · The firm did not evaluate whether the issuer had a reasonable basis for the significant assumptions it used to develop the qualitative component. (AS 2501.16)

The issuer's ALL consisted of a qualitative component and an unallocated reserve component. The firm's approach for substantively testing the ALL was to both test the issuer's process and develop an independent expectation of the estimate. The following deficiencies were identified: · The firm did not evaluate the reasonableness of the significant assumptions the issuer used to develop the unallocated reserve component. (AS 2501.16)

The issuer's ALL consisted of a qualitative component and an unallocated reserve component. The firm's approach for substantively testing the ALL was to both test the issuer's process and develop an independent expectation of the estimate. The following deficiencies were identified: · The firm did not evaluate the relevance of external information it used to develop its independent expectation. (AS 1105.04 and .06)

The issuer's ALL consisted of a qualitative component and an unallocated reserve component. The firm's approach for substantively testing the ALL was to both test the issuer's process and develop an independent expectation of the estimate. The following deficiencies were identified: · The firm did not perform procedures to demonstrate it had a reasonable basis for certain assumptions it used to develop its independent expectation. (AS 2501.22)

The firm selected for testing controls that consisted of management's review of qualitative factors and the reasonableness of loan grade basis points used in the determination of the ALL. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the qualitative factors and loan grade basis points. (AS 2301.19 and .21)

The firm selected for testing a control that consisted of management's review of assigned loan risk ratings. The firm did not identify that this control only operated over newly originated loans and as designed would not prevent or detect a material misstatement related to the assignment of loan risk ratings to loans in the issuer's existing loan portfolio. (AS 2301.19)

The firm did not perform procedures to evaluate the reasonableness of the qualitative factors and loan grade basis points used by the issuer to determine the ALL beyond comparing the current period qualitative factors and loan grade basis points to those used in prior periods. (AS 2501.07)

The sample size the firm used in certain of its substantive procedures to test the reasonableness of assigned loan risk ratings was too small to provide sufficient appropriate audit evidence because these procedures were based on a level of control reliance that was not supported due to the deficiency in the firm's control testing described above. Further the sample size the firm used in certain of its substantive procedures to test the reasonableness of assigned loan risk ratings was too small to provide sufficient appropriate audit evidence because the firm did not take into account the relevant factors in determining its sample size including tolerable misstatement for the population the allowable risk of incorrect acceptance and the characteristics of the population. (AS 2301.16 .18 and .37; AS 2315.16 .19 .23 and .23A)

The issuer's ALL included a general reserve and a specific reserve for loans that are individually evaluated for impairment. The firm did not sufficiently test the reasonableness of the general reserve because it limited its procedures to reading an issuer-prepared memo and testing the mathematical accuracy of the reserve calculation. (AS 2501.07)

The issuer's ALL included a general reserve and a specific reserve for loans that are individually evaluated for impairment. The issuer assigned risk ratings to certain of its loans. The risk ratings were an important input in determining whether a loan would be individually evaluated for impairment as part of the specific reserve or considered as part of the general reserve. To test loans rated as pass the firm selected certain loans for testing from one loan portfolio. The firm did not perform any substantive procedures to test the risk ratings for the remaining population of pass-rated loans in other portfolios. (AS 1105.27; AS 2301.08)

The issuer's ALL included a general reserve and a specific reserve for loans that are individually evaluated for impairment. The issuer assigned risk ratings to certain of its loans. The risk ratings were an important input in determining whether a loan would be individually evaluated for impairment as part of the specific reserve or considered as part of the general reserve. To test loans not rated as pass the firm performed certain of its procedures as of an interim date. The firm did not perform procedures beyond inquiry to extend its conclusions on the risk ratings of these loans for the period between the interim testing date and year end. (AS 2301.45)

The firm selected for testing one review control over the qualitative component of the ALL. The firm did not perform sufficient procedures to test the operating effectiveness of this control because the firm did not evaluate the review procedures that the control owner performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.44)

The issuer determined the qualitative reserve component of the ALL for loans that were collectively evaluated for impairment. The following deficiencies were identified: · The firm selected for testing a control that included the issuer's review of (1) certain loans for potential impairment and (2) the qualitative component of the ALL. The firm did not evaluate the specific review procedures that the control owners performed to (1) determine whether all loans identified for potential impairment were reviewed and (2) assess the reasonableness of the qualitative component of the ALL. (AS 2201. 42 and .44)

The issuer determined the qualitative reserve component of the ALL for loans that were collectively evaluated for impairment. The following deficiencies were identified: · The firm's approach for substantively testing the ALL was to test the issuer's process. The firm did not sufficiently evaluate whether the issuer had a reasonable basis for the significant assumptions it used to determine the qualitative component of the ALL because the firm's procedures were limited to (1) reading the issuer's ALL analysis and (2) comparing the significant assumptions the issuer used at year end to those used in prior periods. (AS 2501.16)

The issuer determined the qualitative component of the ALL by applying basis points to qualitative factors. The following deficiency was identified: · The firm selected for testing a review control over the qualitative component of the ALL. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the reasonableness of the basis points applied to each qualitative factor. (AS 2201.42 and .44)

The issuer engaged valuation specialists to determine the fair value of the collateral for impaired loans. The following deficiency was identified: · The firm did not perform any procedures to evaluate whether the issuer had a reasonable basis for the significant assumptions it developed related to the adjustments the issuer made to the valuation of collateral. (AS 2501.16)

The firm selected for testing a control that consisted of management's reviews of the ACL. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the reasonableness of the qualitative component of the ACL. (AS 2201.42 and .44)

The issuer used certain data to determine the quantitative component of the ACL. The firm did not identify and test any controls over the accuracy and/or completeness of this data. (AS 2201.39) In addition the firm used this data to substantively test the ACL. The firm did not perform any procedures to test or (as discussed above) identify and test any controls over the accuracy of this data. (AS 2301.08)

The issuer used certain data to determine the quantitative component of the ACL. In addition the firm used this data to substantively test the ACL. The firm did not perform any procedures to test or (as discussed above) identify and test any controls over the accuracy of this data. (AS 2301.08)

The issuer determined the qualitative component of the ALL by applying basis points to qualitative factors. The following deficiency was identified: · The firm's approach for substantively testing the qualitative component of the ALL was to test the issuer's process. The firm did not evaluate whether the issuer had a reasonable basis for the significant assumptions related to basis points applied to the qualitative factors. (AS 2501.16)

Loan risk ratings were an important input in estimating the issuer's ALL. The following deficiency was identified: · The firm selected for testing a review control to address the risk related to inaccurate loan risk ratings. The firm did not evaluate the specific review procedures that the control owners performed to evaluate whether the loan risk ratings reviews were occurring timely. (AS 2201.42 and .44)

Loan risk ratings were an important input in estimating the issuer's ALL. The following deficiency was identified: · The sample size the firm used in its substantive procedure to test the reasonableness of loan risk ratings was too small to provide sufficient appropriate audit evidence because the procedure was designed based on a level of control reliance that was not supported due to the deficiency in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The issuer's ALL included reserves for impaired loans. The following deficiency was identified: · The firm selected for testing a control that included the review of impaired loans. The firm did not evaluate the specific review procedures that the control owners performed to evaluate whether impaired loans were appropriately reserved including the review of support for the collateral value of the loans. (AS 2201.42 and .44)

The issuer's ALL included reserves for impaired loans. The following deficiency was identified: · The sample size the firm used in its substantive procedure to test the valuation of impaired loans was too small to provide sufficient appropriate audit evidence because the procedure was designed based on a level of control reliance that was not supported due to the deficiency in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The issuer engaged valuation specialists to determine the fair value of the collateral for impaired loans. The following deficiency was identified: · The firm did not perform any procedures to evaluate the reasonableness of the significant assumptions developed and used by the company's specialists. (AS 1105.A8b)

The issuer engaged valuation specialists to determine the fair value of the collateral for impaired loans. The following deficiency was identified: · The firm did not test the accuracy and completeness of certain issuer-produced data used by the company's specialists. (AS 1105.A8a)

The issuer engaged valuation specialists to determine the fair value of the collateral for impaired loans. The following deficiency was identified: · The firm did not evaluate the relevance and reliability of certain data from external sources used by the company's specialists. (AS 1105.A8a)

The issuer's general reserve component of the ALL included a qualitative reserve component. In determining the qualitative reserve component the issuer used loan risk grades and basis point adjustments for qualitative factors. The following deficiencies were identified: - The firm identified and tested a control over the review of loan risk grades for loans that met certain criteria. The firm did not identify and test any controls over the review of loan risk grades for loans that did not meet the criteria. (AS 2201.39)

The issuer's general reserve component of the ALL included a qualitative reserve component. In determining the qualitative reserve component the issuer used loan risk grades and basis point adjustments for qualitative factors. The following deficiencies were identified: - The firm selected for testing a control that included the issuer's review of certain loans for potential impairment. The firm did not evaluate the specific review procedures that the control owners performed to review the loans for potential impairment. (AS 2201.42 and .44)