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The issuer also held an investment in an entity for which it had a majority ownership but the entity was not consolidated due to certain qualitative considerations. The firm did not evaluate these qualitative considerations in assessing whether the issuer's accounting was in conformity with FASB ASC Topic 323 Investments — Equity Method and Joint Ventures. (AS 2810.30)

The issuer reported in its financial statements that it had fully benefit-responsive investment contracts that were recorded at contract value. The firm did not evaluate whether these investment contracts met the criteria to be recorded at contract value in conformity with FASB ASC Topic 962 Plan Accounting —Defined Contribution Pension Plans. (AS 2810.30)

The firm identified that the issuer's categorization of certain investments within the fair value hierarchy was not in conformity with FASB ASC Topic 820 Fair Value Measurement. The firm did not appropriately evaluate the effect of this GAAP departure on the issuer's financial statements. (AS 2810.30 and .31)

The firm did not identify and evaluate a departure from GAAP related to the issuer's omission of a disclosure required by FASB ASC Topic 235 Notes to Financial Statements. (AS 2810.30 and .31) Unrelated to our review the issuer reevaluated its disclosures for investments and determined that a disclosure was omitted. The issuer subsequently corrected this omission in a restatement of its financial statements and the firm issued an audit report on the issuer's restated financial statements.

During the year the issuer invested in an entity. The following deficiency was identified: · The firm did not identify and evaluate that the issuer's presentation of this investment within the statement of cash flows was not in conformity with FASB ASC Topic 230 Statement of Cash Flows. (AS 2810.30 and .31) Unrelated to our review the issuer reevaluated its accounting for this investment and concluded that a material misstatement existed that had not been previously identified. The issuer corrected this misstatement in a subsequent filing.

The issuer held certain investments that were categorized as level 3 within the fair value hierarchy as set forth in FASB ASC Topic 820 Fair Value Measurement. The firm's approach for substantively testing the fair value of these investments was to develop an independent expectation using certain interim financial results and other data about the underlying investments. The following deficiencies were identified: · The firm did not identify and evaluate a misstatement in a required disclosure under FASB ASC Topic 235 Notes to Financial Statements related to another investment. (AS 2810.30 and .31) In connection with our review the issuer reevaluated this disclosure and concluded that misstatements existed that had not been previously identified. The issuer subsequently restated its financial statements to correct these misstatements and the firm revised and reissued its report on the financial statements.