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The issuer had certain agreements outstanding with counterparties as of year end. The following deficiencies were identified: · The firm did not evaluate whether the agreements were appropriately accounted for and disclosed in accordance with GAAP. (AS 2810.30 and .31)

The issuer had certain agreements outstanding with counterparties as of year end. The following deficiencies were identified: · The firm did not obtain an understanding of and test the inputs methods and assumptions used to estimate the fair value of the recorded assets related to these transactions. (AS 2502.09 .26 and .28)

The issuer had certain agreements outstanding with counterparties as of year end. The following deficiencies were identified: · The firm did not evaluate whether the transactions should be identified as transactions with related parties because the counterparties were controlled by an individual who was listed as an officer of the issuer in a public filing and certain of the collateral was held by an entity the issuer disclosed as an entity with control. (AS 2410.14)

The firm did not evaluate the appropriateness of the issuer's presentation of these assets at year end (AS 2810.30 and .31)

With respect to a certain asset to evaluate the possible impairment of this asset the issuer estimated the fair value of this asset using forecasted cash flows and other assumptions. The firm did not perform any procedures beyond inquiry of management and reviewing the issuer's analysis to test the issuer's fair value measurement. (AS 2502.15)

The firm did not evaluate the nature of these assets when evaluating the appropriateness of the issuer's presentation of the assets in the issuer's financial statements. (AS 2810.30)