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The issuer used an information technology ('IT') application to initiate process and record transactions related to certain significant accounts. The firm tested IT general controls ('ITGCs') over and application controls within this IT application. The firm identified multiple control deficiencies related to controls over logical access and program changes. The firm concluded that none of the deficiencies rose to the level of a significant deficiency or material weakness individually or in the aggregate. In reaching this conclusion the firm did not sufficiently evaluate the severity of the control deficiencies because it did not evaluate the effect of the deficiencies on the related IT-dependent manual controls and application controls. (AS 2201.62 and .65)

The firm did not identify and test controls over the accuracy and completeness of information used by the firm to test the ITGCs and application controls. (AS 2201.39)