Explorer

The firm selected for testing controls that consisted of the issuer's reviews of the fair value of certain investments. The firm did not evaluate the specific review procedures that the control owners performed to assess the (1) reasonableness of the methodologies and assumptions the issuer used to determine the fair value of these investments and (2) accuracy and completeness of a report used in the operation of these controls. (AS 2201.42 and .44)

The issuer recorded the fair value of certain of its available-for-sale (AFS) securities based on prices it obtained from an external pricing service. The firm selected for testing a control that consisted of the issuer's comparison of its recorded prices to prices obtained from another external pricing service and the issuer's investigation of price variances that exceeded certain thresholds. The firm did not evaluate the specific review procedures that the control owner performed to (1) assess whether the prices the issuer used in this comparison were derived from independent sources and (2) investigate identified variances and determine whether items identified for follow up had been appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a control over the valuation of certain investments that consisted of the review of analyses and memoranda summarizing established fair values. The firm did not evaluate the review procedures that the control owners performed including the criteria that the control owners used to identify items for follow up and whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a control that included the issuer's review of the comparison of fair values of certain investments provided by external parties for one investment from each investment type held by the issuer. The firm did not evaluate whether the control could effectively prevent or detect a material misstatement as designed. Further 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 held certain investments in portfolio companies that were categorized as level 3 within the fair value hierarchy as set forth in FASB ASC Topic 820. The following deficiencies were identified: · The firm selected for testing a control that consisted of the issuer's review of the fair values of these investments. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of the assumptions that the issuer used to determine the fair values including the relevance of certain external market data. (AS 2201.42 and .44)

The firm selected for testing a control that included the issuer's review of the fair values of investments. The firm did not evaluate the specific review procedures that the control owner performed to assess the reasonableness of these fair values. (AS 2201.42 and .44)

The issuer determined the fair value of an investment using projected cash flows of the investee company. The following deficiencies were identified: · The firm selected for testing a control that included a review of the reasonableness of the cash flows provided by the investee company. The firm did not evaluate the specific review procedures the control owner performed to assess the reasonableness of these cash flows. (AS 2201.42 and .44) As a result of our inspection procedures the firm reevaluated the issuer's control over the reasonableness of the cash flows used to determine the fair value of this investment and concluded along with the issuer that a control deficiency existed that constituted a material weakness that had not been previously identified. The issuer subsequently filed a Form 8-K and disclosed that the firm's opinion related to the effectiveness of the issuer's ICFR should no longer be relied upon due to this material weakness and the material weakness discussed below.

The firm selected for testing a control that consisted of the review of the categorization of AFS securities within the fair value hierarchy as set forth in FASB ASC Topic 820 Fair Value Measurement. The firm did not evaluate the review procedures that the control owner performed including the criteria the control owner used to identify items for follow up and whether those items were appropriately resolved. (AS 2201.42 and 44)

The firm selected for testing a control that included the issuer's review of the fair values of certain investments. The firm did not evaluate the specific review procedures that the control owner performed to assess the reasonableness of certain assumptions the issuer used to determine the fair values of these investments. (AS 2201.42 and .44)