Explorer

The issuer reported goodwill for several reporting units and performed a quantitative assessment of the impairment of goodwill for each reporting unit. The firm's approach for substantively testing the quantitative assessments was to test the issuer's process. The firm did not evaluate the reliability of data from external sources the issuer used to determine certain assumptions. (AS 1105.04 and .06)

The firm did not perform any procedures to test goodwill. (AS 2301.08)

The firm did not sufficiently evaluate the issuer's determination that it did not need to test goodwill for impairment between its annual tests because the firm did not identify that the issuer's evaluation did not consider certain adverse market conditions and deteriorating financial results that arose before and after year end. (AS 2301.08)

The issuer performed its annual goodwill impairment assessment as of an interim date. The following deficiencies were identified: · The firm did not sufficiently evaluate the issuer's determination that it did not need to test goodwill for impairment between its annual assessment and year end because it did not identify that the issuer's evaluation did not consider these adverse market conditions and deteriorating financial results that arose before year end. (AS 2301.08)

The firm did not perform sufficient substantive procedures to evaluate whether corporate assets and liabilities were appropriately allocated to the issuer's reporting units because its procedures were limited to reading the general ledger descriptions for the unallocated corporate assets and liabilities. (AS 2301.08)

The issuer performed its annual analysis of goodwill for potential impairment as of an interim date. The following deficiencies were identified: · The firm did not evaluate certain indicators of potential impairment that existed at year end for one of the issuer's reporting units. (AS 2301.08; AS 2810.03)

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 perform sufficient procedures to evaluate whether the goodwill associated with any of the previous reporting units may have been impaired at the time of the issuer's reduction in the number of reporting units because its procedures were limited to reading an issuer-prepared memorandum and inquiring of management. (AS 2301.08) 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 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 perform procedures beyond reviewing the issuer's fourth quarter triggering event assessment to evaluate whether a quantitative assessment was required during the fourth quarter including consideration of contrary evidence included in the firm's audit work papers. (AS 2301.08 and .11; AS 2810.03)

At year end the issuer concluded that it was not necessary to perform an additional quantitative assessment of goodwill for this reporting unit. The firm did not sufficiently evaluate the issuer's conclusion because it did not evaluate the issuer's basis for concluding that certain events and circumstances that occurred during the year did not indicate that it was more likely than not that the fair value of this reporting unit was below its carrying amount. (AS 2301.08; AS 2810.03)

The issuer performed its annual analysis of goodwill for potential impairment as of an interim date. The firm did not evaluate an indicator of potential impairment that existed at year end. (AS 2301.08; AS 2810.03)