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The forecasts the issuer used in its analyses to assess goodwill for possible impairment for this one reporting unit assumed significant revenue growth for certain years and improved gross margin percentages. The firm concluded that the forecasted revenue growth rates were reasonable without performing any substantive procedures to evaluate the issuer's ability to carry out certain of its planned strategies to achieve the forecasts beyond inquiring of management. The firm's procedures to test the forecasted gross margin percentages were not sufficient because they were limited to inquiring of management about the issuer's planned strategies and comparing the forecasted gross margin percentages to the actual gross margin percentages of another reporting unit. (AS 2502.26 .28 .31 and .36)

The firm selected for testing change management controls over an information technology ('IT') application the issuer used to process and record revenue and related accounts ('revenue transactions') and goodwill. The firm did not perform procedures to test the completeness of all types of changes in the population of changes from which it made its selections. (AS 1105.10)

The firm selected for testing automated and IT-dependent manual controls over revenue transactions and goodwill that used data and reports generated by the issuer's IT application. The firm's approach to test the accuracy and completeness of the data and reports depended on effective information technology general controls ('ITGCs') including those pertaining to change management. As a result of the deficiency in the firm's testing of change management controls discussed above the firm's testing of the automated and IT-dependent manual controls over revenue transactions and goodwill was not sufficient. (AS 2201.46)

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 performed its annual goodwill impairment assessment as of an interim date. The following deficiencies were identified: · The firm selected for testing controls that included the issuer's assessment of triggering events between its annual assessment date and year end. The firm did not evaluate whether the controls were designed to address whether certain adverse market conditions and deteriorating financial results that arose before year end would have required an impairment test as of year end. (AS 2201.42)

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's internal inspection program had inspected this audit reviewed the goodwill area and also identified the deficiency below. For four of the issuer's reporting units the firm selected for testing controls that consisted of the issuer's reviews of the forecasts and valuation model used in its goodwill impairment analysis including the assumptions used. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of these assumptions. (AS 2201.42 and .44)

The firm's approach for substantively testing the impairment of goodwill was to test the issuer's process. The firm did not sufficiently evaluate whether the method the issuer used to perform its impairment analyses was in conformity with the applicable financial reporting framework including the requirements of International Accounting Standard 36 Impairment of Assets (“IAS 36”) because the firm did not evaluate whether the period of cash flow projections the issuer used to evaluate goodwill for impairment was in accordance with IAS 36. (AS 2501.10)

The firm selected for testing a control that included the review of the issuer's annual goodwill impairment analysis. The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the review of the qualitative or quantitative analysis based on the reporting unit used in the issuer's annual goodwill impairment assessment. The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a control over the valuation of goodwill. The firm did not identify and test controls over the accuracy of data used in the operation of this control. (AS 2201.39)

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)

For one reporting unit the issuer engaged an external specialist to perform a quantitative assessment to evaluate goodwill for impairment. The firm's approach for substantively testing the quantitative assessment was to test the issuer's process and develop an independent expectation. The following deficiency was identified: • The firm did not perform procedures to evaluate the reasonableness of certain significant assumptions used by the company's specialist in the quantitative assessment and/or used by the firm in developing its independent expectation. (AS 1105.A8b; AS 2501.16)

For one reporting unit the issuer engaged an external specialist to perform a quantitative assessment to evaluate goodwill for impairment. The firm's approach for substantively testing the quantitative assessment was to test the issuer's process and develop an independent expectation. The following deficiency was identified: • The firm did not perform procedures to demonstrate it had a reasonable basis for certain assumptions it independently derived and used in its independent expectation. (AS 2501.22)

For another reporting unit the issuer performed a qualitative assessment to evaluate goodwill for impairment and determined that it was not more likely than not that the carrying value of the reporting unit was more than its fair value. The firm's approach for substantively testing whether this goodwill was impaired was to develop an independent expectation of the fair value of the reporting unit. The firm did not perform procedures to demonstrate it had a reasonable basis for certain assumptions it independently derived and used in developing its independent expectation. (AS 2501.22)

The issuer performed a quantitative assessment using a discounted cash flow analysis to assess goodwill for impairment. The firm did not perform procedures to test the issuer's quantitative assessment beyond comparing the analysis with prior year analyses testing the mathematical accuracy of the analysis and researching general industry economic conditions. (AS 2501.07)

The firm did not identify and/or test controls related to the issuer's (1) determination of the reporting units it used in its goodwill impairment analysis and (2) assignment of assets and liabilities to its reporting units in conformity with FASB ASC Topic 350 Intangibles - Goodwill and Other. (AS 2201.39) Unrelated to our review the issuer reevaluated its accounting related to the identification of reporting units and evaluation of the possible impairment of goodwill and concluded that a material misstatement existed that had not been previously identified. The issuer subsequently restated its financial statements to correct this and other material misstatements and the firm revised and reissued its report on the financial statements. In conjunction with its reevaluation of controls over long-lived assets discussed below the issuer also reevaluated its controls over the identification of reporting units and evaluation of the possible impairment of goodwill. The issuer concluded that a material weakness related to goodwill and long-lived assets existed that had not been previously identified. The issuer subsequently revised its report on ICFR to reflect this material weakness and the other material weaknesses discussed herein and the firm modified its opinion on the effectiveness of the issuer's ICFR to express an adverse opinion and reissued its report.

The firm did not perform substantive procedures to evaluate the appropriateness of the issuer's reporting units and the issuer's assignment of assets and liabilities to its reporting units. (AS 2810.30) Unrelated to our review the issuer reevaluated its accounting related to the identification of reporting units and evaluation of the possible impairment of goodwill and concluded that a material misstatement existed that had not been previously identified. The issuer subsequently restated its financial statements to correct this and other material misstatements and the firm revised and reissued its report on the financial statements. In conjunction with its reevaluation of controls over long-lived assets discussed below the issuer also reevaluated its controls over the identification of reporting units and evaluation of the possible impairment of goodwill. The issuer concluded that a material weakness related to goodwill and long-lived assets existed that had not been previously identified. The issuer subsequently revised its report on ICFR to reflect this material weakness and the other material weaknesses discussed herein and the firm modified its opinion on the effectiveness of the issuer's ICFR to express an adverse opinion and reissued its report.

The issuer performed an analysis to assess the possible impairment of goodwill using a combination of the income approach and the market approach. The firm selected for testing controls that consisted of the issuer's reviews of this analysis including the significant inputs and assumptions. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of the EBITDA multiples used in the market approach and the issuer's cash-flow forecast used in the income approach. (AS 2201.42 and .44) Unrelated to our review the issuer reevaluated its accounting related to the identification of reporting units and evaluation of the possible impairment of goodwill and concluded that a material misstatement existed that had not been previously identified. The issuer subsequently restated its financial statements to correct this and other material misstatements and the firm revised and reissued its report on the financial statements. In conjunction with its reevaluation of controls over long-lived assets discussed below the issuer also reevaluated its controls over the identification of reporting units and evaluation of the possible impairment of goodwill. The issuer concluded that a material weakness related to goodwill and long-lived assets existed that had not been previously identified. The issuer subsequently revised its report on ICFR to reflect this material weakness and the other material weaknesses discussed herein and the firm modified its opinion on the effectiveness of the issuer's ICFR to express an adverse opinion and reissued its report.

The forecast the issuer used in its analysis to assess the possible impairment of goodwill for one of the issuer's reporting units assumed significant revenue growth in the early years of the forecast. The firm concluded that the forecasted revenue growth rates were reasonable without performing any substantive procedures beyond inquiring of management to evaluate the issuer's ability to carry out its planned strategies to achieve the forecast. (AS 2502.26 .28 .31 and .36) Unrelated to our review the issuer reevaluated its accounting related to the identification of reporting units and evaluation of the possible impairment of goodwill and concluded that a material misstatement existed that had not been previously identified. The issuer subsequently restated its financial statements to correct this and other material misstatements and the firm revised and reissued its report on the financial statements. In conjunction with its reevaluation of controls over long-lived assets discussed below the issuer also reevaluated its controls over the identification of reporting units and evaluation of the possible impairment of goodwill. The issuer concluded that a material weakness related to goodwill and long-lived assets existed that had not been previously identified. The issuer subsequently revised its report on ICFR to reflect this material weakness and the other material weaknesses discussed herein and the firm modified its opinion on the effectiveness of the issuer's ICFR to express an adverse opinion and reissued its report.

The forecast the issuer used in its analysis to assess the possible impairment of goodwill for one of the issuer's reporting units assumed significant revenue growth in the early years of the forecast. The firm did not perform substantive procedures to test or (as a result of the ITGC deficiencies discussed above) sufficiently test controls over the accuracy and completeness of certain system-generated data it used to test the issuer's goodwill impairment analysis. (AS 2502.39) Unrelated to our review the issuer reevaluated its accounting related to the identification of reporting units and evaluation of the possible impairment of goodwill and concluded that a material misstatement existed that had not been previously identified. The issuer subsequently restated its financial statements to correct this and other material misstatements and the firm revised and reissued its report on the financial statements. In conjunction with its reevaluation of controls over long-lived assets discussed below the issuer also reevaluated its controls over the identification of reporting units and evaluation of the possible impairment of goodwill. The issuer concluded that a material weakness related to goodwill and long-lived assets existed that had not been previously identified. The issuer subsequently revised its report on ICFR to reflect this material weakness and the other material weaknesses discussed herein and the firm modified its opinion on the effectiveness of the issuer's ICFR to express an adverse opinion and reissued its report.

The firm selected for testing a control that included the issuer's reviews of analyses of the possible impairment of goodwill and indefinite-lived intangible assets. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of certain inputs and assumptions the issuer used in these analyses. (AS 2201.42 and .44)

The firm did not identify and test any controls that addressed whether corporate assets and liabilities were appropriately allocated to the issuer's reporting units. (AS 2201.39)

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 firm did not identify and test any controls over the issuer's determination of the reporting units that it used in its annual goodwill impairment analysis. (AS 2201.39)

The firm did not perform any substantive procedures to evaluate the appropriateness of the issuer's determination of the reporting units used in its goodwill impairment analysis. (AS 2301.08)

The firm selected for testing two controls that included the issuer's review of the valuation methods and the underlying assumptions used in its goodwill impairment analysis. The firm did not evaluate the specific review procedures that the control owner performed to evaluate the appropriateness of the valuation methods and the reasonableness of the underlying assumptions. (AS 2201.42 and .44)

The firm selected for testing two controls that included the issuer's review of the valuation methods and the underlying assumptions used in its goodwill impairment analysis. The firm did not identify and test any controls over the accuracy and completeness of certain information used in the operation of these controls. (AS 2201.39)

The issuer engaged an external specialist to perform a quantitative assessment of goodwill for impairment at an interim date. The issuer also performed a qualitative assessment of goodwill for impairment at year-end and concluded that the performance of an additional quantitative assessment of goodwill was unnecessary. The firm's approach for substantively testing goodwill was to review and test management's process. The following deficiencies were identified: · The firm did not perform substantive procedures beyond inquiry of management to evaluate the reasonableness of certain assumptions used by the specialist to perform the quantitative assessment of goodwill including taking into account the issuer's ability to carry out its stated intentions regarding the assumptions. (AS 2501.16 and .17; AS 1105.A8b)

The issuer engaged an external specialist to perform a quantitative assessment of goodwill for impairment at an interim date. The issuer also performed a qualitative assessment of goodwill for impairment at year-end and concluded that the performance of an additional quantitative assessment of goodwill was unnecessary. The firm's approach for substantively testing goodwill was to review and test management's process. The following deficiencies were identified: · The firm did not perform sufficient procedures to evaluate whether a quantitative assessment was required at year-end because it did not evaluate whether relevant events and circumstances were sufficient to offset unfavorable indicators of impairment. (AS 2501.07; AS 2810.03)

The issuer engaged an external specialist to perform a quantitative assessment of goodwill for impairment at an interim date. The issuer also performed a qualitative assessment of goodwill for impairment at year-end and concluded that the performance of an additional quantitative assessment of goodwill was unnecessary. The firm's approach for substantively testing goodwill was to review and test management's process. The following deficiencies were identified: · The firm did not perform any substantive procedures to determine whether the issuer evaluated a portion of goodwill for impairment. (AS 2301.08 and .11)

The firm selected for testing certain controls that included the review of goodwill and intangible assets for potential impairment. The firm did not evaluate the specific review procedures performed by the control owners to assess the reasonableness of the methodologies and assumptions used in the issuer's goodwill and indefinite-lived intangible assets impairment analyses. (AS 2201.42 and .44)

The firm did not perform any procedures to test (1) the appropriateness of the issuer's determination that it operated as a single reporting unit for purposes of its impairment analysis in accordance with FASB ASC Topic 350 Intangibles – Goodwill and Other and (2) whether the issuer's conclusion that the customer relationship intangible asset had an indefinite life was in accordance with FASB ASC Topic 350. (AS 2301.08 and .11)

The issuer evaluated certain goodwill for impairment using a discounted cash flow model which was developed using various assumptions. The firm's approach for substantively testing this goodwill for impairment was to test the issuer's process. The firm did not perform procedures to evaluate the reasonableness of certain significant assumptions used by the issuer to evaluate this goodwill for impairment beyond for certain assumptions comparing the assumptions to the most recent approved budget and prior year impairment tests performing a sensitivity analysis and inquiring of management and for certain other assumptions comparing the assumptions to the most recent approved budget and prior year impairment tests. (AS 2501.16)

The firm selected for testing a control that consisted of management's review of the assumptions used in the issuer's models to estimate the recoverable amount of goodwill. 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 2201.42 and .44)

The issuer estimated the value-in-use (VIU) of its cash-generating units ('CGUs') to evaluate goodwill for impairment. For two of the issuer's CGUs the firm did not evaluate the significance to the financial statements of the issuer's use of estimated post-tax future cash flows and a post-tax discount rate to estimate the VIU of the CGUs rather than using estimated pre-tax future cash flows and a pre-tax discount rate in the VIU calculations in conformity with IAS 36 Impairment of Assets ('IAS 36'). (AS 2810.30)

The firm selected for testing a control that included the issuer's review of certain assumptions that were used to determine the fair value of the issuer's goodwill and intangible assets for purposes of evaluating these assets for possible impairment. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of these assumptions. (AS 2201.42 and .44)

For one of its reporting units the issuer used a cash flow forecast to evaluate the goodwill and an intangible asset for possible impairment. Based on this evaluation the issuer recorded an impairment charge related to these assets. The firm did not sufficiently evaluate the reasonableness of the issuer's forecast because its procedures were limited to comparing certain amounts from the forecast to the corresponding amounts in a forecast prepared earlier in the year and inquiring of management about the variances. (AS 2502.26 and .28)

The firm selected for testing a control that consisted of the issuer's review and approval of its annual budget. The issuer used this budget in its qualitative assessment of goodwill for possible impairment. The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing controls that consisted of reviews of significant assumptions underlying the cash-flow forecasts used in the issuer's annual goodwill impairment assessment. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of these assumptions. (AS 2201.42 and .44)

The firm selected for testing controls that consisted of the issuer's reviews of forecasts and certain assumptions used in the annual goodwill impairment analyses. The firm did not identify and test any controls over the accuracy and completeness of certain data used in the operation of one of these controls. (AS 2201.39)

The firm selected for testing controls that consisted of the issuer's reviews of forecasts and certain assumptions used in the annual goodwill impairment analyses. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of the forecasts and certain assumptions used in these analyses. (AS 2201.42 and .44)

The issuer performed its annual analysis of goodwill for potential impairment as of an interim date. The following deficiencies were identified: · The firm selected for testing a control that consisted of the issuer's quarterly assessment of qualitative and quantitative factors to determine whether indicators of potential impairment of goodwill existed. The firm did not identify that this control was not designed to identify and evaluate certain qualitative indicators of potential impairment. (AS 2201.42)

The issuer performed its annual analysis of goodwill for potential impairment as of an interim date. The following deficiencies were identified: · The firm selected for testing a control that consisted of the issuer's quarterly assessment of qualitative and quantitative factors to determine whether indicators of potential impairment of goodwill existed. In testing the operating effectiveness of this control at year end the firm did not evaluate the specific review procedures that the control owner performed to evaluate certain indicators of potential impairment. (AS 2201.44)

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 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 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 issuer reported goodwill at several reporting units and evaluated certain reporting units for impairment using a discounted cash flow model ('DCF model') which relied on various assumptions. The firm's approach to substantively test the issuer's goodwill impairment analysis for one reporting unit was to test the issuer's process. The firm also developed an independent expectation of the issuer's annual revenue growth rates for this reporting unit and compared those expectations to the annual revenue growth rate assumptions used by the issuer in the DCF model. The following deficiency was identified: · The firm selected for testing a control that consisted of management's review of the goodwill impairment analysis for each reporting unit. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of certain assumptions used in the goodwill impairment analysis for certain reporting units. (AS 2201.42 and .44)

The issuer reported goodwill at several reporting units and evaluated certain reporting units for impairment using a discounted cash flow model ('DCF model') which relied on various assumptions. The firm's approach to substantively test the issuer's goodwill impairment analysis for one reporting unit was to test the issuer's process. The firm also developed an independent expectation of the issuer's annual revenue growth rates for this reporting unit and compared those expectations to the annual revenue growth rate assumptions used by the issuer in the DCF model. The following deficiency was identified: · For the one reporting unit referred to above the firm did not perform sufficient procedures to evaluate the reasonableness of the annual revenue growth assumptions which the firm considered to be significant assumptions used by the issuer in its goodwill impairment analysis because the firm did not demonstrate that it had a reasonable basis for (1) selecting the comparable companies it used to develop its independent expectation of the average annual revenue growth rate over a six-year period and (2) assuming that the ratio of advertising expenses to revenue ('advertising ratio') generated would be predictive of the revenue growth rate for 2023. Further the firm did not perform procedures to evaluate differences between the (1) annual revenue growth rate assumptions used by the issuer and the compound annual revenue growth rates for the industry beyond determining the market share the issuer would need to capture to achieve its revenue growth rate for 2023 and (2) industry advertising ratio and the advertising ratio used by the issuer. (AS 2501.16)

The issuer engaged a specialist to assist it in determining the fair value of its reporting units. The firm selected for testing controls that consisted of the issuer's determination of an expected range of reasonable outcomes for certain assumptions and comparison of those expected ranges to the assumptions determined by the company specialist. The firm did not evaluate beyond inquiry the procedures the control owner performed to determine the expected ranges. (AS 2201.42 and .44)