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The firm's internal inspection program inspected this audit and reviewed these areas but did not identify the deficiencies below. The firm did not perform substantive procedures to test the valuation of certain investment securities held within various investment funds beyond comparing their net asset value to pricing information obtained from the respective investment fund's website. (AS 2501.07)

The firm's internal inspection program inspected this audit and reviewed these areas but did not identify the deficiencies below. The firm's approach to testing participant and employer contributions included reliance on controls and the use of data and reports from two service organizations which (1) processed and recorded participant and employer contributions and (2) processed payroll and record-related participant data. The following deficiencies were identified: · The firm did not test the design and operating effectiveness of certain complementary user controls related to the processing and recording of participant and employer contributions as identified in the service auditor's reports beyond inquiry of management. Further the firm did not evaluate whether certain other complementary user controls as identified in the service auditor's reports were relevant in addressing the risks of material misstatement related to participant and employer contributions. (AS 2601.14)

The firm's internal inspection program inspected this audit and reviewed these areas but did not identify the deficiencies below. The firm's approach to testing participant and employer contributions included reliance on controls and the use of data and reports from two service organizations which (1) processed and recorded participant and employer contributions and (2) processed payroll and record-related participant data. The following deficiencies were identified: · The sample size the firm used in certain of its substantive procedures to test participant and employer contributions was 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 deficiencies in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The firm's internal inspection program inspected this audit and reviewed these areas but did not identify the deficiencies below. The firm's approach to testing participant and employer contributions included reliance on controls and the use of data and reports from two service organizations which (1) processed and recorded participant and employer contributions and (2) processed payroll and record-related participant data. The following deficiencies were identified: · The firm used certain data produced by one of the plan sponsor's service organizations in testing participant and employer contributions. The firm did not perform any procedures that addressed the accuracy and completeness of this data. (AS 2301.08)

The firm's internal inspection program inspected this audit and reviewed this area but did not identify the deficiencies below. To test the valuation of a certain type of investment securities the firm selected a sample of investments for testing. The sample size the firm used in its substantive test of details was too small to provide sufficient appropriate audit evidence because the firm did not take into account the characteristics of the population in determining its sample size. (AS 2315.16 .23 and .23A)

The firm's internal inspection program inspected this audit and reviewed this area but did not identify the deficiencies below. The firm did not perform substantive procedures to test the valuation of certain other types of investment securities held within various investment funds beyond (1) for certain securities comparing their net asset value to pricing information obtained from the respective investment fund's website and (2) for other securities comparing their fair value or net asset value to the trustee or custodian statements. (AS 2501.07)

The firm's internal inspection program inspected this audit and reviewed this area but did not identify the deficiency below. The firm did not perform substantive procedures to test the valuation of certain investment securities held within various investment funds beyond comparing their fair value or net asset value to the trustee statements. (AS 2501.07)

The firm's internal inspection program inspected this audit and reviewed this area but did not identify the deficiency below. The firm did not perform substantive procedures to test the valuation of certain investment securities held within various investment funds beyond comparing their net asset value to pricing information obtained from the respective investment fund's website. (AS 2501.07)

During the year the issuer identified events indicating that the carrying value of one of its long-lived assets may not be recoverable and performed an impairment analysis. The firm selected for testing a control that included the issuer's review of the impairment calculation. The firm did not evaluate the specific review procedures that the control owners performed to assess the completeness of the asset's carrying value used in the impairment calculation. (AS 2201.42 and .44)

The firm did not evaluate the reasonableness of significant assumptions used to determine the fair value of derivative liabilities. (AS 2502.26 and .28)

The firm did not perform any substantive procedures to test or in the alternative identify and test controls over the accuracy and completeness of data used in this determination. (AS 2502.39)

During the year the issuer entered into an agreement to acquire all of the assets and liabilities of another entity. The firm did not evaluate the accounting treatment for the initial recognition of the transaction as either a business combination or asset acquisition in conformity with IFRS 3 Business Combinations. (AS 2810.30)

During the year the issuer entered into a settlement agreement ('Settlement Agreement') with a related party ('Related Party A') in which the issuer returned rights related to software to Related Party A and Related Party A cancelled the issuer's remaining debt for the issuer's initial purchase of the software. Subsequent to this Settlement Agreement and after the issuer returned its rights to the software the issuer sold the software to another related party ('Related Party B') in exchange for other assets and a loan receivable. Subsequent to this transaction the issuer engaged in another transaction with Related Party A ('Subsequent Transaction') in which the issuer paid Related Party A other assets in exchange for cancellation of debt. The following deficiency was identified: · The firm did not evaluate whether the terms and other information about the transactions were consistent with inquiries and other audit evidence about the business purpose (or lack thereof) of the transactions. (AS 2410.12a)

During the year the issuer acquired other assets from Related Party B ('Other Assets A') and recorded them as non-current intangible assets. The issuer subsequently disposed of the majority of Other Assets A in exchange primarily for the settlement of related party debt. The issuer presented this disposal as revenue and cost of sales. In addition the issuer acquired additional other assets ('Other Assets B') from a customer for services rendered and recorded them as current intangible assets. The following deficiency was identified: · The firm did not perform any substantive procedures to evaluate the reliability of information from a related party and data from an external provider that it used to test the existence of these other assets. (AS 1105.04 and .06) In connection with our review the issuer reevaluated the accounting for the transfer of Other Assets A as revenue and cost of sales and determined that a misstatement existed that had not been previously identified. The issuer did not file an amended Form 10-K or a Form 8-K indicating that its previously issued financial statements should not be relied on. Instead the issuer corrected this misstatement in a subsequent filing by revising the accounting.

During the year the issuer acquired other assets from Related Party B ('Other Assets A') and recorded them as non-current intangible assets. The issuer subsequently disposed of the majority of Other Assets A in exchange primarily for the settlement of related party debt. The issuer presented this disposal as revenue and cost of sales. In addition the issuer acquired additional other assets ('Other Assets B') from a customer for services rendered and recorded them as current intangible assets. The following deficiency was identified: · The firm did not perform any substantive procedures to evaluate the reliability of pricing information that it used to test the valuation of these other assets. (AS 1105.04 and .06) In connection with our review the issuer reevaluated the accounting for the transfer of Other Assets A as revenue and cost of sales and determined that a misstatement existed that had not been previously identified. The issuer did not file an amended Form 10-K or a Form 8-K indicating that its previously issued financial statements should not be relied on. Instead the issuer corrected this misstatement in a subsequent filing by revising the accounting.

During the year the issuer acquired other assets from Related Party B ('Other Assets A') and recorded them as non-current intangible assets. The issuer subsequently disposed of the majority of Other Assets A in exchange primarily for the settlement of related party debt. The issuer presented this disposal as revenue and cost of sales. In addition the issuer acquired additional other assets ('Other Assets B') from a customer for services rendered and recorded them as current intangible assets. The following deficiency was identified: · The firm did not identify and evaluate a GAAP departure related to the issuer presenting Other Assets B as indefinite lived intangible assets while also carrying them at fair value. (AS 2810.30) In connection with our review the issuer reevaluated the accounting for the transfer of Other Assets A as revenue and cost of sales and determined that a misstatement existed that had not been previously identified. The issuer did not file an amended Form 10-K or a Form 8-K indicating that its previously issued financial statements should not be relied on. Instead the issuer corrected this misstatement in a subsequent filing by revising the accounting.

During the year the issuer acquired other assets from Related Party B ('Other Assets A') and recorded them as non-current intangible assets. The issuer subsequently disposed of the majority of Other Assets A in exchange primarily for the settlement of related party debt. The issuer presented this disposal as revenue and cost of sales. In addition the issuer acquired additional other assets ('Other Assets B') from a customer for services rendered and recorded them as current intangible assets. The following deficiency was identified: · The firm did not evaluate whether the issuer's accounting for its other assets as (1) intangible assets and (2) as current or non-current assets was appropriate and in conformity with GAAP. (AS 2301.08 and .11) In connection with our review the issuer reevaluated the accounting for the transfer of Other Assets A as revenue and cost of sales and determined that a misstatement existed that had not been previously identified. The issuer did not file an amended Form 10-K or a Form 8-K indicating that its previously issued financial statements should not be relied on. Instead the issuer corrected this misstatement in a subsequent filing by revising the accounting.

During the year the issuer acquired other assets from Related Party B ('Other Assets A') and recorded them as non-current intangible assets. The issuer subsequently disposed of the majority of Other Assets A in exchange primarily for the settlement of related party debt. The issuer presented this disposal as revenue and cost of sales. In addition the issuer acquired additional other assets ('Other Assets B') from a customer for services rendered and recorded them as current intangible assets. The following deficiency was identified: · The firm did not evaluate whether the issuer's recording of revenue for the transfer of Other Assets A to a related party qualified as a transaction with a customer in conformity with FASB ASC Topic 606 Revenue from Contracts with Customers. (AS 2410.17; AS 2810.03) In connection with our review the issuer reevaluated the accounting for the transfer of Other Assets A as revenue and cost of sales and determined that a misstatement existed that had not been previously identified. The issuer did not file an amended Form 10-K or a Form 8-K indicating that its previously issued financial statements should not be relied on. Instead the issuer corrected this misstatement in a subsequent filing by revising the accounting.

During the year the issuer issued preferred shares and recorded them within stockholder's equity. The firm did not evaluate whether the issuer's accounting for and presentation of the issuance of these preferred shares was in conformity with FASB ASC Topic 480 Distinguishing Liabilities from Equity and FASB ASC Topic 820 Fair Value Measurement. (AS 2301.08)

The issuer engaged an external specialist to determine the fair value of the preferred shares. The following deficiency was identified: · The firm did not evaluate the reasonableness of the significant assumptions developed by the company's specialist. (AS 1105.A8b)

The issuer engaged an external specialist to determine the fair value of the preferred shares. The following deficiency was identified: · The firm did not evaluate the appropriateness of the methods the company's specialist used to determine the fair value. (AS 1105.A8c)

The issuer engaged an external specialist to determine the fair value of the preferred shares. The following deficiency was identified: · The firm did not identify and evaluate the effect on the fair value determination of certain inconsistencies related to the rights of the preferred shares between the company's specialist report the disclosures in the financial statements and the issuer's Amended Articles of Incorporation. (AS 1105.A9c and .A10)

The firm did not perform any procedures to test the issuer's financial statement disclosures regarding certain of the rights related to the preferred shares including consideration of the differences between the company's specialist's report the disclosures and the issuer's Amended Articles of Incorporation. (AS 2301.08; AS 2810.03)

During the year the issuer entered into a settlement agreement ('Settlement Agreement') with a related party ('Related Party A') in which the issuer returned rights related to software to Related Party A and Related Party A cancelled the issuer's remaining debt for the issuer's initial purchase of the software. Subsequent to this Settlement Agreement and after the issuer returned its rights to the software the issuer sold the software to another related party ('Related Party B') in exchange for other assets and a loan receivable. Subsequent to this transaction the issuer engaged in another transaction with Related Party A ('Subsequent Transaction') in which the issuer paid Related Party A other assets in exchange for cancellation of debt. The following deficiency was identified: · The firm did not evaluate whether the business purpose (or lack thereof) indicated that the transactions may have been entered into to engage in fraudulent financial reporting or conceal misappropriation of assets. (AS 2401.67)

During the year the issuer issued convertible notes with warrants. The issuer engaged an external specialist to determine the standalone fair values of the convertible notes and warrants to determine the allocation of proceeds and recording of debt and equity associated with the transaction. The following deficiency was identified: · The firm did not evaluate whether the issuer's accounting for the convertible notes was in conformity with GAAP including whether (1) the conversion options should have been bifurcated and accounted for as derivatives in conformity with FASB ASC Topic 815 Derivatives and Hedging or (2) the convertible notes should have been separated into a liability component and the embedded conversion option in conformity with FASB ASC Topic 470 Debt. (AS 2301.08)

During the year the issuer issued convertible notes with warrants. The issuer engaged an external specialist to determine the standalone fair values of the convertible notes and warrants to determine the allocation of proceeds and recording of debt and equity associated with the transaction. The following deficiency was identified: · The firm did not perform any substantive procedures to evaluate the reasonableness of the significant assumptions developed by the company's specialist to determine the fair values of the convertible notes and warrants. (AS 1105.A8b)

During the year the issuer issued convertible notes with warrants. The issuer engaged an external specialist to determine the standalone fair values of the convertible notes and warrants to determine the allocation of proceeds and recording of debt and equity associated with the transaction. The following deficiency was identified: · The firm did not perform any substantive procedures to evaluate whether the method used by the company's specialist to determine the fair values of the convertible notes and warrants was appropriate in the circumstances taking into account the requirements of the applicable financial reporting framework. (AS 1105.A8c)

Subsequent to the issuance of the convertible notes with warrants the issuer also issued shares of common stock to the noteholder. The following deficiency was identified: · The firm did not perform substantive procedures beyond obtaining a copy of the securities purchase agreement to test the issuance of the shares to the noteholder. (AS 2301.08)

Subsequent to the issuance of the convertible notes with warrants the issuer also issued shares of common stock to the noteholder. The following deficiency was identified: · The firm did not evaluate an apparent discrepancy between the statement of stockholders' equity and the issuer's footnote disclosures regarding the issuance of these shares. (AS 2301.08)

During the year the issuer changed the accounting and presentation of an asset from one asset class to another. The firm did not perform procedures to evaluate whether this change was appropriate including consideration of contrary evidence that indicated that the asset may not have met the criteria for the new classification. (AS 2301.08 and .11; AS 2810.03)

During the year the issuer changed the accounting and presentation of an asset from one asset class to another. The firm did not perform procedures to evaluate whether this change in classification was appropriately presented and disclosed in conformity with FASB ASC Topic 205 Presentation of Financial Statements. (AS 2301.08 and .11)

During the year the issuer entered into a settlement agreement ('Settlement Agreement') with a related party ('Related Party A') in which the issuer returned rights related to software to Related Party A and Related Party A cancelled the issuer's remaining debt for the issuer's initial purchase of the software. Subsequent to this Settlement Agreement and after the issuer returned its rights to the software the issuer sold the software to another related party ('Related Party B') in exchange for other assets and a loan receivable. Subsequent to this transaction the issuer engaged in another transaction with Related Party A ('Subsequent Transaction') in which the issuer paid Related Party A other assets in exchange for cancellation of debt. The following deficiency was identified: · The firm did not perform any procedures to determine whether the issuer had ownership of or other rights to sell the software to Related Party B. (AS 2301.08; AS 2410.11)

During the year the issuer entered into a settlement agreement ('Settlement Agreement') with a related party ('Related Party A') in which the issuer returned rights related to software to Related Party A and Related Party A cancelled the issuer's remaining debt for the issuer's initial purchase of the software. Subsequent to this Settlement Agreement and after the issuer returned its rights to the software the issuer sold the software to another related party ('Related Party B') in exchange for other assets and a loan receivable. Subsequent to this transaction the issuer engaged in another transaction with Related Party A ('Subsequent Transaction') in which the issuer paid Related Party A other assets in exchange for cancellation of debt. The following deficiency was identified: · The firm did not perform any procedures to evaluate the financial capability of Related Party B with respect to the loan receivable. (AS 2410.12d)

During the year the issuer entered into a settlement agreement ('Settlement Agreement') with a related party ('Related Party A') in which the issuer returned rights related to software to Related Party A and Related Party A cancelled the issuer's remaining debt for the issuer's initial purchase of the software. Subsequent to this Settlement Agreement and after the issuer returned its rights to the software the issuer sold the software to another related party ('Related Party B') in exchange for other assets and a loan receivable. Subsequent to this transaction the issuer engaged in another transaction with Related Party A ('Subsequent Transaction') in which the issuer paid Related Party A other assets in exchange for cancellation of debt. The following deficiency was identified: · The firm did not perform any procedures to determine whether the debt cancellation in the Subsequent Transaction had been previously cancelled under the Settlement Agreement. (AS 2301.08; AS 2410.11)

During the prior year the issuer sold certain assets to Related Party A in return for the cancellation of debt. In addition in the prior year Related Party A transferred these assets to another related party ('Related Party C') as settlement of debt. During the current year the issuer repurchased these assets from Related Party C for the issuance of preferred shares which were recorded as an expense. The issuer did not assign a book value to these assets. The following deficiency was identified: · The firm did not evaluate whether the terms and other information about the transaction were consistent with inquiries and other audit evidence about the business purpose (or lack thereof) of the transactions. (AS 2410.12a)

During the prior year the issuer sold certain assets to Related Party A in return for the cancellation of debt. In addition in the prior year Related Party A transferred these assets to another related party ('Related Party C') as settlement of debt. During the current year the issuer repurchased these assets from Related Party C for the issuance of preferred shares which were recorded as an expense. The issuer did not assign a book value to these assets. The following deficiency was identified: · The firm did not evaluate whether the business purpose (or lack thereof) indicated that the transactions may have been entered into to engage in fraudulent financial reporting or conceal misappropriation of assets. (AS 2401.67)

During the prior year the issuer sold certain assets to Related Party A in return for the cancellation of debt. In addition in the prior year Related Party A transferred these assets to another related party ('Related Party C') as settlement of debt. During the current year the issuer repurchased these assets from Related Party C for the issuance of preferred shares which were recorded as an expense. The issuer did not assign a book value to these assets. The following deficiency was identified: · The firm did not perform any procedures to test the existence and valuation of the acquired assets. (AS 2301.08; AS 2410.11)

During the year the issuer acquired other assets from Related Party B ('Other Assets A') and recorded them as non-current intangible assets. The issuer subsequently disposed of the majority of Other Assets A in exchange primarily for the settlement of related party debt. The issuer presented this disposal as revenue and cost of sales. In addition the issuer acquired additional other assets ('Other Assets B') from a customer for services rendered and recorded them as current intangible assets. The following deficiency was identified: · The firm did not perform any substantive procedures to establish that the issuer had control over these other assets to support its rights and obligations. (AS 2301.08 and .11; AS 2410.11) In connection with our review the issuer reevaluated the accounting for the transfer of Other Assets A as revenue and cost of sales and determined that a misstatement existed that had not been previously identified. The issuer did not file an amended Form 10-K or a Form 8-K indicating that its previously issued financial statements should not be relied on. Instead the issuer corrected this misstatement in a subsequent filing by revising the accounting.

The firm did not perform any substantive procedures to test or in the alternative identify and test any controls over the accuracy and completeness of certain system-generated data used in the firm's testing of significant transactions. (AS 1105.10)

The issuer used certain information technology (IT) systems to initiate process and record transactions related to (1) fee and commission income and related receivables and (2) realized and unrealized gain and losses and interest income. The firm selected for testing certain IT change management controls over these IT systems that consisted of the review testing and approval of changes prior to their migration into production. The following deficiency was identified: · The firm did not perform procedures to test the design and operating effectiveness of a control related to user access beyond observation of one individual's attempt to log in to the production and development environments. (AS 2201.42 and .44)

For fee and commission income and related receivables the following additional deficiency related to the firm's testing of controls and substantive testing were identified: · The firm did not identify and evaluate the issuer's omission of certain disclosures related to fee and commission income required by FASB ASC Topic 606 Revenue from Contracts with Customers. (AS 2810.30 and .31)

For fee and commission income and related receivables the following additional deficiency related to the firm's testing of controls and substantive testing were identified: · The firm did not perform procedures to test receivables due from a related party beyond confirming the amount with an individual who was an executive officer of the issuer and an employee of the related party. (AS 2410.12)

For realized and unrealized gains and losses and interest income the following additional deficiency related to the firm's testing of controls and substantive testing were identified: · The firm selected for testing controls over the reconciliation and/or review of information related to realized and unrealized gains and losses and interest income. The firm did not evaluate the review procedures that the control owners 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)

For realized and unrealized gains and losses and interest income the following additional deficiency related to the firm's testing of controls and substantive testing were identified: · The firm did not perform sufficient procedures to test realized gains and losses because it limited its procedures to recalculating the gains or losses for a sample of transactions based on issuer-produced information or information obtained from external sources. (AS 2301.08 and .13)

For realized and unrealized gains and losses and interest income the following additional deficiency related to the firm's testing of controls and substantive testing were identified: · The firm did not perform any procedures to test the unrealized gains and losses at year end. (AS 2301.08 and .13)

For realized and unrealized gains and losses and interest income the following additional deficiency related to the firm's testing of controls and substantive testing were identified: · The firm did not perform sufficient procedures to test interest income because it limited its procedures to recalculating interest income for a sample of transactions and tracing data used in the recalculation to information obtained from external sources. (AS 2301.08 and .13)

For realized and unrealized gains and losses and interest income the following additional deficiency related to the firm's testing of controls and substantive testing were identified: · The firm did not perform procedures to evaluate the relevance and reliability of information it obtained from external sources that it used in its testing. (AS 1105.04 and .06)

For realized and unrealized gains and losses and interest income the following additional deficiency related to the firm's testing of controls and substantive testing were identified: · The firm did not perform procedures to test or identify and test any controls over the accuracy and completeness of certain system-generated data used in the firm's testing. (AS 1105.10)

The issuer planned to divest of its interest in certain subsidiaries. The firm did not identify and test a control that addressed whether the assets and liabilities of these subsidiaries met the held for sale criteria and should have been presented as discontinued operations in the financial statements in accordance with FASB ASC Topic 205 Presentation of Financial Statements. (AS 2201.39)

The issuer planned to divest of its interest in certain subsidiaries. The firm did not perform substantive procedures to evaluate whether the assets and liabilities of these subsidiaries met the held for sale criteria and should have been presented as discontinued operations in the financial statements in accordance with FASB ASC Topic 205. (AS 2301.08)