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The issuer evaluated certain of its intangible assets for possible impairment using forecasted cash flows that it developed using various assumptions including when and at what amounts the issuer would be able to begin recognizing revenue. The firm did not evaluate beyond inquiry of management whether the issuer had a reasonable basis for the significant assumptions the issuer used including taking into account the issuer's ability to carry out its planned course of action for certain of these assumptions. (AS 2501.16 and .17)

During the year the issuer acquired a business and engaged a specialist to assist it in determining the fair values of certain acquired intangible assets using various assumptions including forecasted revenue customer attrition rate and useful lives. Forecasted revenue included revenue for current contracts as well as projected revenue for contract renewals and expansions. The following deficiencies were identified: · The firm did not perform sufficient procedures to evaluate the reasonableness of the useful lives the issuer assigned to these intangible assets because it did not evaluate significant differences between the useful lives assigned to these assets and 1) the cash-flow forecast periods used to determine their fair values and/or 2) the remaining lives of the contracts. (AS 2501.16)

During the year the issuer acquired a business and engaged a specialist to assist it in determining the fair values of certain acquired intangible assets using various assumptions including forecasted revenue customer attrition rate and useful lives. Forecasted revenue included revenue for current contracts as well as projected revenue for contract renewals and expansions. The following deficiencies were identified: · The firm did not identify and evaluate the issuer's omission of certain disclosures required under FASB ASC Topic 820 Fair Value Measurement. (AS 2810.30 and .31)

The issuer used multiple information-technology (IT) systems to initiate process and record transactions related to revenue and outsourced certain aspects of the IT function including change management to an external party. The following deficiencies were identified: · The firm did not evaluate the reliability of the information it obtained from the external party and used to select its sample for testing a control over change management for one of these systems. (AS 1105.04 and .06)

The issuer used multiple information-technology (IT) systems to initiate process and record transactions related to revenue and outsourced certain aspects of the IT function including change management to an external party. The following deficiencies were identified: · The firm selected for testing various controls over revenue but did not test or test any controls over the completeness of the system-generated reports that it used to select its samples for testing these controls. (AS 1105.10)

The issuer used multiple information-technology (IT) systems to initiate process and record transactions related to revenue and outsourced certain aspects of the IT function including change management to an external party. The following deficiencies were identified: · The firm used system-generated reports in its substantive testing of certain revenue transactions but did not perform any procedures to test or test any controls over the accuracy and completeness of these reports. (AS 1105.10)

The issuer used multiple information-technology (IT) systems to initiate process and record transactions related to revenue and outsourced certain aspects of the IT function including change management to an external party. The following deficiencies were identified: · The firm's substantive procedures to test contract assets consisted of the preparation and testing of a roll-forward of contract assets from the prior year. The firm did not perform sufficient procedures to test this roll-forward because its procedures were limited to testing additions to contract assets during the year. (AS 2301.08)

The issuer used multiple information-technology (IT) systems to initiate process and record transactions related to revenue and outsourced certain aspects of the IT function including change management to an external party. The following deficiencies were identified: · The firm did not identify and evaluate the issuer's omission of a disclosure related to the change in the balance of contract assets required under FASB ASC Topic 606 Revenue from Contracts with Customers. (AS 2810.30 and .31)

The issuer used a service organization to initiate and process transactions related to revenue that are then recorded in the issuer's information-technology (IT) system. In its testing of controls over revenue the firm tested certain automated and IT-dependent manual controls that used data and reports generated by this service organization. The firm obtained a service auditor's report and identified complementary user controls that the service auditor's report described as necessary. As a result of the deficiencies in the firm's testing of the complementary user controls discussed below the firm's testing of these automated and IT-dependent manual controls was not sufficient. (AS 2201.46)

The firm selected for testing a complementary user control that consisted of the issuer's reviews of user access to the service organization's IT system. The firm did not evaluate the specific review procedures that the control owners performed to determine whether previously granted access continued to be appropriate. (AS 2201.42 .44 and .B22)

The firm selected for testing a complementary user control that consisted of the issuer's reviews of user access to the service organization's IT system. The firm did not perform any procedures to evaluate whether the issuer had implemented any complementary user controls related to change management. (AS 2201.39 and .B22)

The firm did not identify and evaluate the issuer's omission of certain disclosures required under FASB ASC Topic 820 Fair Value Measurement. (AS 2810.30 and .31) In connection with our review the issuer reevaluated its disclosures related to these intangible assets and determined that certain disclosures were omitted. The issuer corrected these omissions in the amended filing discussed below.

For certain customer contracts the firm did not perform any substantive procedures to test whether the performance obligations had been satisfied before revenue was recognized. (AS 2301.08 and .13)

During the year the issuer completed a business combination. The firm used issuer-prepared schedules in its substantive testing of this transaction but did not perform any procedures to test or test any controls over the accuracy of certain of these schedules. (AS 1105.10)

The firm did not evaluate the relevance and reliability of information it obtained from external sources that it used to test certain assets. (AS 1105.04 and .06)

The issuer recorded interest payable on certain liabilities. The firm did not evaluate the appropriateness of the interest rate that the issuer used to determine the amount of this liability. (AS 2301.08 and .13)

The issuer recognized certain revenue over time based on costs incurred to date relative to total estimated costs to complete the contract. The firm did not perform any substantive procedures to evaluate the reasonableness of a significant assumption that the issuer used to develop the estimated total costs to complete the contracts. (AS 2501.16)

The firm did not perform procedures beyond reading an issuer-prepared memorandum to evaluate whether the issuer's accounting for warrants as equity was in conformity with FASB ASC Topic 815 Derivatives and Hedging. (AS 2301.08)

The firm did not perform procedures to evaluate whether the issuer's accounting for redeemable stock as temporary equity was in conformity with FASB ASC Topic 480 Distinguishing Liabilities from Equity. (AS 2301.08 and .11)

During the year the issuer engaged a specialist to assist it in determining the fair value of certain shares of its stock. The firm did not perform any procedures to evaluate the reasonableness of a significant assumption developed by the company's specialist. (AS 1105.A8b)

During the year the issuer entered into certain transactions related to convertible debt and warrants. The following deficiencies were identified: · The firm did not perform sufficient procedures to evaluate whether the issuer's accounting for and presentation of convertible debt including warrants were in conformity with relevant GAAP because for certain transactions its procedures were limited to reading an issuer-prepared memorandum without evaluating certain terms within the debt and warrant agreements. (AS 2301.08 and .11) In connection with our review the issuer reevaluated its accounting for these convertible debt and warrant transactions 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.

During the year the issuer entered into certain transactions related to convertible debt and warrants. The following deficiencies were identified: · The firm did not identify and evaluate that the method the issuer used to allocate fair value between certain warrants and convertible debt was not in conformity with FASB ASC Topic 470 Debt. (AS 2810.30 and .31) In connection with our review the issuer reevaluated its accounting for these convertible debt and warrant transactions 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.

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 perform sufficient procedures to evaluate the reliability of certain interim financial results it used to estimate the fair value of these investments because it did not perform procedures beyond (1) comparing the interim financial results to year-end financial results and (2) confirming for certain underlying investments operating results with related parties. Further for one of these investments the firm did not evaluate certain evidence that indicated lower revenue than it used to develop its independent expectation. (AS 1105.04 and .06; AS 2810.03) 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.

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: · For one of these investments the firm did not perform sufficient procedures to evaluate the reliability of other data it used to estimate the fair value of the investment because its procedures were limited to recalculation. Further the firm did not evaluate certain evidence that indicated a higher amount than the data it used to develop its independent expectation. (AS 1105.04 and .06; AS 2810.03) 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.

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.

During the year the issuer acquired a business and engaged a specialist to assist it in determining the fair values of certain acquired intangible assets using various assumptions including forecasted revenue customer attrition rate and useful lives. Forecasted revenue included revenue for current contracts as well as projected revenue for contract renewals and expansions. The following deficiencies were identified: · The firm did not sufficiently evaluate the reasonableness of the forecasted revenue because its procedures were limited to agreeing the total contract value for current contracts to customer contracts without testing projected revenue for contract renewals or expansions. (AS 2501.16)

During the year the issuer acquired a business and engaged a specialist to assist it in determining the fair values of certain acquired intangible assets using various assumptions including forecasted revenue customer attrition rate and useful lives. Forecasted revenue included revenue for current contracts as well as projected revenue for contract renewals and expansions. The following deficiencies were identified: · The firm did not sufficiently evaluate the reasonableness of the customer attrition rate because its procedures were limited to consideration of the issuer's pre-existing relationships with customers and certain qualitative industry factors. (AS 2501.16)

The firm did not evaluate the terms and conditions of agreements related to certain revenue to determine if the revenue was recognized in conformity with FASB ASC Topic 606 Revenue from Contracts with Customers. (AS 2301.08 and .13)

The firm did not perform any procedures to evaluate whether the issuer's revenue was recognized in conformity with FASB ASC Topic 606. (AS 2301.08 and .13)

The firm did not perform any procedures to evaluate the reliability of external information it used to test revenue. (AS 1105.04 and .06)

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 606. (AS 2810.30 and .31

The firm did not perform procedures beyond inquiry and reading the issuer's analysis to evaluate the reasonableness of the significant assumptions the issuer used to determine the valuation of deferred income taxes including evaluating a significant difference between one of the significant assumptions and a similar projection in the issuer's budget. (AS 2501.16)

The issuer determined the qualitative reserve component of the ALL for loans that were collectively evaluated for impairment. The following deficiencies were identified: · The firm selected for testing a control that included the issuer's review of (1) certain loans for potential impairment and (2) the qualitative component of the ALL. The firm did not evaluate the specific review procedures that the control owners performed to (1) determine whether all loans identified for potential impairment were reviewed and (2) assess the reasonableness of the qualitative component of the ALL. (AS 2201. 42 and .44)

The issuer determined the qualitative reserve component of the ALL for loans that were collectively evaluated for impairment. The following deficiencies were identified: · The firm's approach for substantively testing the ALL was to test the issuer's process. The firm did not sufficiently evaluate whether the issuer had a reasonable basis for the significant assumptions it used to determine the qualitative component of the ALL because the firm's procedures were limited to (1) reading the issuer's ALL analysis and (2) comparing the significant assumptions the issuer used at year end to those used in prior periods. (AS 2501.16)

The firm selected for testing a control over the existence of certain assets. The firm did not evaluate how the issuer determined how frequently asset items would be reviewed and whether the issuer reviewed those items as frequently as intended. (AS 2201.42 and .44)

The firm did not identify and test any controls over the accuracy and completeness of system-generated information used by the issuer in the operation of certain controls. (AS 2201.39)

The firm did not perform any substantive procedures to test or identify and test any controls over the accuracy and completeness of system-generated information used in its substantive testing of these assets. (AS 1105.10)

The sample sizes the firm used to test these assets 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 determined the qualitative component of the ALL by applying basis points to qualitative factors. The following deficiency was identified: · The firm selected for testing a review control over the qualitative component of the ALL. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the reasonableness of the basis points applied to each qualitative factor. (AS 2201.42 and .44)

The issuer engaged valuation specialists to determine the fair value of the collateral for impaired loans. The following deficiency was identified: · The firm did not perform any procedures to evaluate whether the issuer had a reasonable basis for the significant assumptions it developed related to the adjustments the issuer made to the valuation of collateral. (AS 2501.16)

The firm selected for testing a control that consisted of management's reviews of the ACL. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the reasonableness of the qualitative component of the ACL. (AS 2201.42 and .44)

The issuer used certain data to determine the quantitative component of the ACL. The firm did not identify and test any controls over the accuracy and/or completeness of this data. (AS 2201.39) In addition the firm used this data to substantively test the ACL. The firm did not perform any procedures to test or (as discussed above) identify and test any controls over the accuracy of this data. (AS 2301.08)

The issuer used certain data to determine the quantitative component of the ACL. In addition the firm used this data to substantively test the ACL. The firm did not perform any procedures to test or (as discussed above) identify and test any controls over the accuracy of this data. (AS 2301.08)

The firm did not perform any substantive procedures to test the valuation of certain investment securities including some accounted for at fair value. (AS 2301.08; AS 2501.07)

The issuer determined the qualitative component of the ALL by applying basis points to qualitative factors. The following deficiency was identified: · The firm's approach for substantively testing the qualitative component of the ALL was to test the issuer's process. The firm did not evaluate whether the issuer had a reasonable basis for the significant assumptions related to basis points applied to the qualitative factors. (AS 2501.16)

Loan risk ratings were an important input in estimating the issuer's ALL. The following deficiency was identified: · The firm selected for testing a review control to address the risk related to inaccurate loan risk ratings. The firm did not evaluate the specific review procedures that the control owners performed to evaluate whether the loan risk ratings reviews were occurring timely. (AS 2201.42 and .44)

Loan risk ratings were an important input in estimating the issuer's ALL. The following deficiency was identified: · The sample size the firm used in its substantive procedure to test the reasonableness of loan risk ratings was too small to provide sufficient appropriate audit evidence because the procedure was 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's ALL included reserves for impaired loans. The following deficiency was identified: · The firm selected for testing a control that included the review of impaired loans. The firm did not evaluate the specific review procedures that the control owners performed to evaluate whether impaired loans were appropriately reserved including the review of support for the collateral value of the loans. (AS 2201.42 and .44)

The issuer's ALL included reserves for impaired loans. The following deficiency was identified: · The sample size the firm used in its substantive procedure to test the valuation of impaired loans was too small to provide sufficient appropriate audit evidence because the procedure was 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 engaged valuation specialists to determine the fair value of the collateral for impaired loans. The following deficiency was identified: · The firm did not perform any procedures to evaluate the reasonableness of the significant assumptions developed and used by the company's specialists. (AS 1105.A8b)