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The issuer recorded the fair value for available-for-sale (“AFS”) and held-to-maturity (“HTM”) debt securities based on the prices it received from an external pricing service. The firm selected for testing a control that consisted of the issuer's comparison for a selection of securities from various security categories of the prices it received from the external pricing service to prices it obtained from other sources and evaluation of any pricing differences that exceeded monetary thresholds. The firm did not evaluate whether the control was designed to address the risks of material misstatement presented by the different risk characteristics inherent in the population of securities in each category not subject to the control given the selection method applied. (AS 2201.42)

The sample sizes the firm used in certain of its substantive procedures to test the valuation of the AFS and HFM debt securities were too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiency in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The issuer recorded the fair value for AFS securities based on the prices it received from an external pricing service. The firm selected for testing a control that consisted of (1) comparing the recorded fair values to prices obtained from another pricing service for a sample of securities selected from certain categories of securities and (2) the analysis of pricing differences that exceeded an established threshold. The firm did not evaluate whether the control was designed to address the risks of material misstatement presented by the population of securities not subject to the control given the selection method applied by the issuer and the different valuation methods used by the issuer's external pricing services to value the securities. (AS 2201.42)

The sample sizes the firm used in certain of its substantive procedures to test the valuation of the AFS securities were too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiency in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

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 firm did not perform any substantive procedures to evaluate the appropriateness of the issuer's categorization of these securities within the fair value hierarchy. (AS 2502.43)

The firm did not perform procedures to evaluate the issuer's qualitative assessments to evaluate whether certain of its investments were impaired. (AS 2301.08 and .11)

The firm did not test the fair values of certain investments. (AS 2502.15)

The issuer did not consider unrealized losses on certain investments to be other-than-temporary due to its ability to hold these investments until the recovery of fair values. The firm did not evaluate the issuer's ability to hold the investments for a period of time sufficient to allow for the anticipated recovery in fair value. (AS 2503.48)

The issuer engaged a specialist to determine the fair value of an equity investment. The firm's approach for substantively testing the fair value of the investment was to test the issuer's process and the firm used an auditor-engaged specialist to evaluate certain significant assumptions the company's specialist used. The following deficiency was identified. • The firm did not evaluate whether this was an investment in a variable interest entity that should have been consolidated by the issuer in accordance with FASB ASC Topic 810 Consolidation. (AS 2301.08 and .11)

The issuer engaged a specialist to determine the fair value of an equity investment. The firm's approach for substantively testing the fair value of the investment was to test the issuer's process and the firm used an auditor-engaged specialist to evaluate certain significant assumptions the company's specialist used. The following deficiency was identified. • The firm did not evaluate whether a certain related asset was properly classified as a current asset in accordance with FASB ASC Topic 210 Balance Sheet. (AS 2301.08 and .11)

The issuer engaged a specialist to determine the fair value of an equity investment. The firm's approach for substantively testing the fair value of the investment was to test the issuer's process and the firm used an auditor-engaged specialist to evaluate certain significant assumptions the company's specialist used. The following deficiency was identified. • The firm did not perform procedures to test the issuer's conclusion that no allowance was necessary for the related asset. (AS 2501.07)

The firm's approach for substantively testing the issuer's impairment analysis for certain investments was to develop an independent expectation. The following deficiency was identified. • The firm did not perform procedures to demonstrate that it had a reasonable basis for the method and assumptions it used including taking into account (1) the requirements of certain elements of the applicable financial reporting framework and (2) its understanding of the issuer's process including the issuer's use of a flat rate for impairment so that its independent expectation considered the factors relevant to the estimate. (AS 2501.21 and .22)

The firm's approach for substantively testing the issuer's impairment analysis for certain investments was to develop an independent expectation. The following deficiency was identified. • The firm did not evaluate the significant difference between its independent expectation and the issuer's recorded impairment beyond concluding that the issuer's recorded impairment was more conservative. (AS 2501.26; AS 2810.13)

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.

The issuer engaged a specialist to determine the fair value of an equity investment. The firm's approach for substantively testing the fair value of the investment was to test the issuer's process and the firm used an auditor-engaged specialist to evaluate certain significant assumptions the company's specialist used. The following deficiency was identified. • The firm did not evaluate the reasonableness of a certain significant assumption developed by the company's specialist. (AS 1105.A8b)

To test the valuation of certain investments the firm selected specific investments for testing. The firm did not perform any substantive procedures to test the remaining portion of these certain investments. (AS 1105.27; AS 2301.08)

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 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 sample sizes the firm used in certain of its substantive procedures to test the valuation of these investments were too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiencies in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The issuer held investments in multiple unconsolidated entities including certain entities that were managed by the issuer. The following deficiencies were identified: · The firm selected for testing a control over the issuer's disclosure of these investments. The firm did not identify and test any controls over the accuracy and completeness of an issuer-prepared schedule that the control owner used in the operation of this control. (AS 2201.39)

The issuer held investments in multiple unconsolidated entities including certain entities that were managed by the issuer. The following deficiencies were identified: · The firm selected for testing a control over the valuation of the investments in unconsolidated entities managed by the issuer. The firm did not identify and test any controls over the accuracy and completeness of the unconsolidated entities' financial statements that the control owners used in the operation of this control. (AS 2201.39)

The issuer held investments in multiple unconsolidated entities including certain entities that were managed by the issuer. The following deficiencies were identified: · The firm used the unconsolidated entities' financial statements and the issuer-prepared schedule in its substantive testing of these investments but did not perform any procedures to test or test any controls over the accuracy and completeness of this information. (AS 1105.10)

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)

In addition the firm did not identify and test any controls over the valuation of investments. (AS 2201.39)

To evaluate an investment for potential impairment the firm used information related to transactions involving the investee's stock. The firm did not perform any procedures beyond inquiring of management of the investee to test whether this information was reliable and accurate. Further when determining whether the issuer's conclusion that the investment was not impaired was reasonable the firm did not evaluate potential impairment indicators including (1) the investee's negative operating results unsuccessful attempt to raise capital and workforce reduction shortly after year end and (2) a significant decline in the value of certain assets that were important to the issuer's and the investee's operations. (AS 2301.08; AS 2810.03)

The issuer held certain investments in privately held companies that were categorized as level 3 within the fair value hierarchy as set forth in FASB ASC Topic 820 Fair Value Measurement. The following deficiencies were identified: · The firm's approach for substantively testing the valuation of certain of these investments was to review and test management's process. The firm did not perform any procedures to test the share price the issuer used to record the fair value of each investment beyond (1) obtaining for one investment an unexecuted consent of the investee company's board of directors regarding a possible equity transaction and (2) obtaining for the other investments an email that the issuer had received from a broker indicating the weighted-average share price for trades that the broker executed in the last quarter of the year under audit. (AS 2502.26 and .28)

The issuer held certain investments in privately held companies that were categorized as level 3 within the fair value hierarchy as set forth in FASB ASC Topic 820 Fair Value Measurement. The following deficiencies were identified: · The firm's approach for substantively testing the valuation of another investment was to develop an independent estimate. The firm did not evaluate the appropriateness of the peer companies determined by the issuer that the firm used in developing its fair value estimate of this investment. (AS 2502.40)

For certain investments the issuer held the firm performed confirmation procedures for a small number of these investments but did not perform any procedures to obtain evidence that the remaining population of these investments existed at year end. (AS 2503.21)

During the year the issuer invested in an entity. The following deficiency was identified: · The firm did not evaluate whether the business purpose (or lack thereof) of this investment indicated that it may have been entered into to engage in fraudulent financial reporting given certain facts regarding this investment. (AS 2401.67) 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.

During the year the issuer invested in an entity. The following deficiency was identified: · The firm did not evaluate whether the issuer's accounting for this investment was in conformity with certain requirements of GAAP. (AS 2301.08) 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.

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 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 firm's internal inspection program inspected this audit and reviewed the investments area but did not identify the deficiencies below. For certain investments the following additional deficiencies were identified: · For certain of these investments the firm did not perform any procedures to test the fair values. (AS 2501.07)

The firm's internal inspection program inspected this audit and reviewed the investments area but did not identify the deficiencies below. For certain investments the following additional deficiencies were identified: · For another investment the firm did not perform any procedures to evaluate the reasonableness of a significant assumption developed by the issuer. (AS 2501.16)

The firm's internal inspection program inspected this audit and reviewed the investments area but did not identify the deficiencies below. For certain investments the following additional deficiencies were identified: · For certain other investments the issuer used the investees' unaudited financial results in estimating the fair values. The firm did not sufficiently evaluate the investees' financial results it used as audit evidence because it did not apply or request that another auditor apply appropriate auditing procedures to the unaudited financial statements. (AS 1105.B3)

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)

To test the valuation of investments the firm selected for testing specific investments. The firm did not perform any substantive procedures to test the remaining population of investments. (AS 1105.27; AS 2301.08)

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 firm did not perform procedures to test the fair value of certain Level 2 investments beyond comparing the fair value to the pricing source used by the issuer. (AS 2502.26 and .28)

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 issuer recorded the fair values of available-for-sale (“AFS”) securities based on the prices it obtained from an external pricing service. The firm selected for testing a control that consisted of the comparison of these prices to prices obtained from another external pricing service; the securities and prices obtained from each external pricing service were manually entered by the issuer into a spreadsheet for this comparison. The firm did not identify and test any controls over whether the prices that were manually entered into this spreadsheet were accurate and complete. (AS 2201.39)

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 issuer determined the fair value of an investment using projected cash flows of the investee company. The following deficiencies were identified: · The issuer determined the revenue projections underlying these cash flows by multiplying for each of the investee company's two products the quantities of units projected to be sold by an estimated selling price. For one of these products the firm did not evaluate the reasonableness of the projected quantities of units to be sold beyond inquiring of the investee company's management and comparing the current-year projected revenue for the investee company to actual revenue. (AS 2502.26 .28 and .31)

The issuer recorded the fair value of its available-for-sale ('AFS') securities based on prices it obtained from an external pricing service. The firm selected for testing various controls over the valuation of these securities that included the issuer's comparison of these prices to prices obtained from another external pricing service. The securities and prices obtained from both pricing services were manually entered by the issuer into a spreadsheet for this comparison. The firm did not test the aspects of these controls that addressed whether the prices the issuer used in this comparison were derived from different sources. (AS 2201.42 and .44)

The issuer recorded the fair value of its available-for-sale ('AFS') securities based on prices it obtained from an external pricing service. The firm selected for testing various controls over the valuation of these securities that included the issuer's comparison of these prices to prices obtained from another external pricing service. The securities and prices obtained from both pricing services were manually entered by the issuer into a spreadsheet for this comparison. The firm did not identify and test any controls over the accuracy of the prices that were manually entered into the comparison spreadsheet. (AS 2201.39)

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)