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The issuer used various service organizations for the custody recordkeeping and processing of certain investment transactions and these service organizations used sub-service organizations for certain functions. The firm obtained the service auditor's reports for each of these service organizations and identified certain complementary user controls that the service auditor's reports described as necessary. The following deficiencies were identified: · The firm selected for testing a control that addressed the issuer's review of certain investments for potential impairment. The firm did not evaluate whether the control was designed to consider all of the relevant requirements of FASB ASC Topic 326 Current Expected Credit Losses when assessing whether an impairment loss or credit impairment existed for these investments. (AS 2201.42 and .B22)

The issuer used various service organizations for the custody recordkeeping and processing of certain investment transactions and these service organizations used sub-service organizations for certain functions. The firm obtained the service auditor's reports for each of these service organizations and identified certain complementary user controls that the service auditor's reports described as necessary. The following deficiencies were identified: · The firm selected for testing a control that addressed the issuer's review of certain investments for potential impairment. The firm did not evaluate whether the control was designed to consider all of the relevant requirements of FASB ASC Topic 326 Current Expected Credit Losses when assessing whether an impairment loss or credit impairment existed for these investments. (AS 2201.42 and .B22)

The issuer used various service organizations for the custody recordkeeping and processing of certain investment transactions and these service organizations used sub-service organizations for certain functions. The firm obtained the service auditor's reports for each of these service organizations and identified certain complementary user controls that the service auditor's reports described as necessary. The following deficiencies were identified: · The firm did not obtain an understanding of or test any relevant controls at certain sub-service organizations. (AS 2201.39 and .B19)

The issuer used various service organizations for the custody recordkeeping and processing of certain investment transactions and these service organizations used sub-service organizations for certain functions. The firm obtained the service auditor's reports for each of these service organizations and identified certain complementary user controls that the service auditor's reports described as necessary. The following deficiencies were identified: · For one sub-service organization the firm did not perform any procedures to evaluate whether there were any changes in the sub-service organization's controls from the date of the service auditor's report to year end given the length of period under audit not covered by the service auditor's report. (AS 2201.B24 and .B25)

The firm did not identify and test any controls over the appropriateness of the classification of investments. (AS 2201.39)

The firm selected for testing a control that included the issuer's review of the categorization of the available-for-sale and trading securities within the fair value hierarchy as set forth in FASB ASC Topic 820 Fair Value Measurement. The firm did not perform procedures to test the aspect of the control related to assessing the appropriateness of the categorization of these securities within the fair value hierarchy. (AS 2201.42 and .44)

The issuer used two service organizations to initiate and process investment transactions. The firm did not identify and test any of the complementary user controls over the existence of investments. (AS 2201.B22)

The issuer used two service organizations for the custody recordkeeping and processing of certain transactions related to an investment and these service organizations used sub-service organizations for certain functions. The firm obtained the service auditor's reports for these service organizations and identified certain complementary user controls that the service auditor's reports described as necessary. The following deficiencies were identified: · The firm selected for testing controls over the issuer's authorization of these transactions with the custodian. The firm did not test the aspects of these controls that addressed whether the custodian's system was configured to require appropriate authorizations prior to completing these transactions. (AS 2201.42 .44 and .B22)

The issuer used two service organizations for the custody recordkeeping and processing of certain transactions related to an investment and these service organizations used sub-service organizations for certain functions. The firm obtained the service auditor's reports for these service organizations and identified certain complementary user controls that the service auditor's reports described as necessary. The following deficiencies were identified: · The firm selected for testing controls over the issuer's authorization of these transactions with the custodian. The firm did not identify and test any controls over an authentication device that the issuer used to authorize these transactions. (AS 2201.39)

The issuer used two service organizations for the custody recordkeeping and processing of certain transactions related to an investment and these service organizations used sub-service organizations for certain functions. The firm obtained the service auditor's reports for these service organizations and identified certain complementary user controls that the service auditor's reports described as necessary. The following deficiencies were identified: · The firm did not obtain an understanding of or test any relevant controls at certain sub-service organizations. (AS 2201.39 and .B19)

The issuer used various service organizations for the custody recordkeeping and processing of investment transactions and these service organizations used sub-service organizations for certain functions. For certain sub-service organizations and one service organization the firm did not obtain an understanding of or test any relevant controls for the year under audit. (AS 2201.39 and .B19)

The firm obtained the service auditor's reports for certain of these service organizations and identified certain complementary user controls that the service auditor's reports described as necessary. The following deficiencies were identified: · The firm selected for testing a complementary user control that addressed the issuer's review of updates to its investment policies but did not test the design and operating effectiveness of this control. (AS 2201.39 and .B22)

The firm obtained the service auditor's reports for certain of these service organizations and identified certain complementary user controls that the service auditor's reports described as necessary. The following deficiencies were identified: · The firm did not perform any procedures to evaluate whether the issuer implemented certain other complementary user controls as described in the service auditor's reports. (AS 2201.39 and .B22)

The firm did not identify and test any controls over the issuer's determination of the categorization of its AFS securities within the fair value hierarchy as set forth in FASB ASC Topic 820. (AS 2201.39)

The firm did not identify and test controls over the existence of investments. (AS 2201.39)