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The issuer determined that it had certain reporting units including one reporting unit that consisted of two components (“Reporting Unit”). The issuer performed a quantitative assessment to test goodwill for impairment at the Reporting Unit and the firm's approach for substantively testing this assessment was to test the issuer's process. The following deficiency was identified: • The firm selected for testing a control that consisted of the issuer's review of the determination of the reporting units. The firm did not test an aspect of this control that addressed the considerations for the aggregation of the two components into one reporting unit including the similarity of the economic characteristics of the components and various qualitative factors as required by FASB ASC Topic 350 Intangibles – Goodwill and Other. (AS 2201.42 and .44)

The issuer determined that it had certain reporting units including one reporting unit that consisted of two components (“Reporting Unit”). The issuer performed a quantitative assessment to test goodwill for impairment at the Reporting Unit and the firm's approach for substantively testing this assessment was to test the issuer's process. The following deficiency was identified: • The firm did not perform sufficient procedures to evaluate whether the issuer identified the reporting units in conformity with FASB ASC Topic 350 because it did not perform any procedures to evaluate the similarities in the economic characteristics of the components and the various qualitative factors considered by the issuer when determining whether the two components should be aggregated into one reporting unit. (AS 2301.08 and .11)

The firm did not evaluate whether the issuer was required to disclose the amount of goodwill allocated to reporting units with zero or negative carrying amounts in conformity with FASB ASC Topic 350 Intangibles – Goodwill and Other beyond asserting that this disclosure would not be material to the financial statements. (AS 2301.08)

The issuer reported goodwill related to certain reporting units. The firm did not perform any procedures to evaluate whether the issuer identified its reporting units in conformity with FASB ASC Topic 350 Intangibles – Goodwill and Other. (AS 2301.08 and .13)

The issuer reduced the number of its reporting units in the current year and reallocated the goodwill balance to the remaining reporting units based on their relative fair values. The following deficiencies were identified: · The firm did not identify and evaluate that this reallocation was not in conformity with FASB ASC Topic 350 Intangibles – Goodwill and Other. (AS 2810.30 and .31) In connection with our review the issuer reevaluated its allocation of goodwill to its reporting units and determined that an error existed that had not been previously identified. The issuer did not file an amended Form 10-K or Form 8-K indicating that its previously issued financial statements should not be relied on. Instead the issuer adjusted this allocation in a subsequent filing.

The issuer completed a quantitative assessment that indicated that goodwill was not impaired but recorded an impairment of goodwill based solely on qualitative information. The firm did not identify and appropriately address a departure from GAAP related to the issuer recording an impairment solely on qualitative information which is not in conformity with FASB ASC Topic 350 Intangibles — Goodwill and Other. (AS 2502.15; AS 2810.30) Unrelated to our review the issuer reevaluated its accounting for the goodwill impairment 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 revised and reissued its report on the financial statements.

The firm's post-issuance monitoring program had inspected this audit and reviewed these areas but did not identify the deficiencies below. The firm did not sufficiently evaluate whether the method used by the issuer to develop the fair value of its reporting units was in conformity with FASB ASC Topic 350 because the firm did not perform procedures to evaluate the appropriateness of the issuer's identification of its reporting units. (AS 2501.10)

The issuer used the fair value of the acquired business at the acquisition date to record a goodwill impairment at year end. The following deficiencies were identified: - The firm did not identify and appropriately address a GAAP departure related to the issuer's omission of disclosures related to the facts and circumstances leading to the goodwill impairment as required by FASB ASC Topic 350 Intangibles — Goodwill and Other. (AS 2810.30 and .31)

During the year events or changes in circumstances existed indicating that the carrying value of the issuer's long-lived assets may not be recoverable. The firm did not evaluate whether the issuer performed an assessment of long-lived assets for possible impairment which in conformity with FASB ASC Topic 350 and FASB ASC Topic 360 was required to be performed prior to performing an impairment assessment of goodwill. (AS 2301.08 and .11)

The firm's approach for substantively testing the issuer's goodwill impairment analyses for certain reporting units was to develop independent expectations. The firm did not identify and evaluate the significance to the financial statements of a departure from GAAP related to the issuer's omission of disclosures with respect to goodwill as required by FASB ASC Topic 350 Intangibles — Goodwill and Other. (AS 2810.30 and .31)