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The firm did not test the completeness of certain liabilities. (AS 2301.08)

The firm did not test the fair value of certain assets. (AS 2502.15)

The firm did not evaluate an assumption in determining the fair value of certain other accounts. (AS 2502.26 and .28)

The firm's approach for substantively testing the estimate was to review and test management's process. The firm did not sufficiently evaluate the reasonableness of this estimate. Specifically the firm did not perform procedures to evaluate the relevance and reliability of certain external data the issuer used in determining its assumptions. (AS 1105.04 and .06; AS 2501.11) [The citations in this paragraph refer to AS 2501 Auditing Accounting Estimates which was in effect for this audit. This standard was replaced by AS 2501 Auditing Accounting Estimates Including Fair Value Measurements which became effective for audits of financial statements for fiscal years ending on or after December 15 2020.]

The firm's approach for substantively testing the estimate was to review and test management's process. The firm did not perform any substantive procedures to test or identify and test controls over the accuracy and completeness of internal data the issuer used in determining assumptions. (AS 1105.10; AS 2501.11) [The citations in this paragraph refer to AS 2501 Auditing Accounting Estimates which was in effect for this audit. This standard was replaced by AS 2501 Auditing Accounting Estimates Including Fair Value Measurements which became effective for audits of financial statements for fiscal years ending on or after December 15 2020.]

The firm's approach for substantively testing the estimate was to review and test management's process. The firm did not perform procedures to evaluate the reasonableness of certain assumptions used by the issuer to determine this estimate. (AS 2501.09 .10 and .11) [The citations in this paragraph refer to AS 2501 Auditing Accounting Estimates which was in effect for this audit. This standard was replaced by AS 2501 Auditing Accounting Estimates Including Fair Value Measurements which became effective for audits of financial statements for fiscal years ending on or after December 15 2020.]

The firm's approach to testing certain liabilities included reliance on controls. The following deficiencies were identified: · The issuer used a service organization to process and record transactions related to these liabilities. The firm did not perform procedures to test beyond inquiring of management certain complimentary user controls over these liabilities identified in the service auditor's report. (AS 2601.14)

The firm's approach to testing certain liabilities included reliance on controls. The following deficiencies were identified: · The firm did not test or in the alternative test any controls over the completeness of system-generated reports that it used to make its selections for testing controls over these liabilities. (AS 1105.10)

The sample sizes the firm used in its substantive procedures to test these liabilities 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 firm did not perform any substantive procedures to test or sufficiently test controls over the accuracy and completeness of certain reports that it used in its substantive testing of these liabilities. (AS 1105.10)

The firm identified journal entries that met certain criteria and haphazardly selected certain of those journal entries for testing without having a basis for its selection. Further for all but one of the journal entries selected for testing the firm did not examine the underlying support for the journal entries and instead limited its procedures to inspecting reviewer signatures or inquiring of management. (AS 2401.61)

The issuer reported investment securities. The firm sent a confirmation to the trustee and the response was returned by email. The following deficiencies were identified: · The firm did not perform any procedures to test the fair value of investment securities. (AS 2501.07)

The issuer reported investment securities. The firm sent a confirmation to the trustee and the response was returned by email. The following deficiencies were identified: · The firm did not evaluate whether the issuer's presentation of investment securities was in conformity with GAAP including consideration of contrary evidence included in the firm's work papers. (AS 2301.08; AS 2810.03)

The issuer reported investment securities. The firm sent a confirmation to the trustee and the response was returned by email. The following deficiencies were identified: · The firm did not identify and evaluate a GAAP departure related to the issuer's omission of certain required disclosures related to these securities. (AS 2810.30 and .31)

The issuer reported investment securities. The firm sent a confirmation to the trustee and the response was returned by email. The following deficiencies were identified: · The firm did not consider performing procedures to address the risks associated with the electronic response received from the trustee such as verifying the source and contents of the confirmation response. (AS 2310.29)

The issuer engaged an external specialist to determine the fair value of certain liabilities. The firm did not perform procedures to evaluate the reasonableness of a significant assumption developed and used by the company's specialist. (AS 1105.A8b)

The firm did not perform any procedures to identify and select journal entries and other adjustments for testing. (AS 2401.58)

The firm did not perform procedures to evaluate whether the issuer's accounting for and disclosure of certain liabilities were in conformity with GAAP. (AS 2301.08)

The firm did not perform any procedures to test or in the alternative identify and test any controls over the accuracy and completeness of information produced by the issuer that the firm used in its substantive procedures to test certain revenue. (AS 1105.10)

The firm did not identify and evaluate a departure from GAAP related to the issuer's omission of certain disclosures related to revenue. (AS 2810.30 and .31)

The firm did not perform any substantive procedures to evaluate the appropriateness of the issuer's recognition of revenue. (AS 2301.08 and .13)

The firm did not perform procedures to evaluate the relevance and/or reliability of certain information it used as audit evidence in testing revenue. (AS 1105.04 and .06)

The firm did not evaluate the business purpose (or lack thereof) of the revenue transactions including whether they may have been entered into to engage in fraudulent financial reporting or conceal misappropriation of assets given certain facts regarding the transactions. (AS 2401.67)

The firm did not perform substantive procedures beyond comparing the account balance to the amount reported in the prior year to test the completeness and valuation of a significant account. (AS 2301.08 and .11; AS 2501.07)

The firm did not identify and select journal entries and other adjustments for testing to address the risk of management override. (AS 2401.58)

The firm's approach for substantively testing an intangible asset for impairment was to develop an independent expectation of the fair value of the asset. The firm did not take into account the requirements of the applicable financial framework so that the firm's independent expectation considered the factors relevant to the estimate. (AS 2501.21)

The firm did not identify and select journal entries and other adjustments for testing to address the risk of management override. (AS 2401.58)

The firm did not identify and select journal entries and other adjustments for testing to address the risk of management override. (AS 2401.58)

The sample size the firm used in certain of its substantive procedures to test revenue was too small to provide sufficient appropriate audit evidence because it used a methodology for determining the sample size that was not designed to test an account balance or a transaction class. As a result the firm did not consider factors relevant to determining sample size for substantive testing. (AS 2315.16 .23 and .23A)

The issuer entered into contracts with certain customers which included terms and conditions specific to (1) minimum delivery amounts (2) pricing based on a market or index rate and/or (3) payment provisions in the event of default. The issuer recognized revenue from those contracts in accordance with FASB ASC Topic 606 Revenue from Contracts with Customers. The firm did not perform any procedures to evaluate whether these contracts should have instead been accounted for as derivative instruments in conformity with FASB ASC Topic 815 Derivatives and Hedging. (AS 2301.08 and .13; AS 2810.03)

The issuer identified certain impairment indicators during the year and prepared an undiscounted cash flow analysis to evaluate its long-lived assets for impairment. The firm did not perform procedures to test the issuer's evaluation of long-lived assets for impairment beyond obtaining and reading the issuer's undiscounted cash flow analysis and a memorandum prepared by the issuer related to its impairment assessment. (AS 2501.07)

The following deficiencies were identified with respect to the firm's testing of revenue: · The firm did not perform sufficient procedures to evaluate whether the issuer appropriately recognized revenue in conformity with FASB ASC Topic 606 Revenue from Contracts with Customers because the firm did not evaluate whether the transactions were an exchange for a good or service that was an output of the issuer's ordinary activities. (AS 2301.08 and .13)

The following deficiencies were identified with respect to the firm's testing of revenue: · With respect to revenue disclosures the firm did not evaluate whether the disclosures about the issuer's agreements under which they recorded revenue were an accurate description of the nature of the contractual arrangements entered into by the issuer and the counterparties to the contracts. (AS 2301.08 and .13)

With respect to certain finite-lived intangible assets the firm did not perform sufficient procedures to evaluate whether the assets were appropriately accounted for in conformity with FASB ASC Topic 350 Intangibles—Goodwill and Other. Specifically the firm did not evaluate the appropriateness of (1) the classification of the assets as finite-lived intangible assets and (2) the useful lives assigned to the assets when no contractual term was present including the amortization expense recorded thereafter. (AS 2301.08 and .11; AS 2810.03)

The issuer reported certain assets that were held by an outside party. The firm did not perform sufficient procedures to test the issuer's rights to these assets because it limited its procedures to confirmation review of the issuer's transaction detail and observation of the issuer logging in to an account with the outside party. (AS 2301.08)

The firm selected for testing controls that consisted of the issuer's review of (1) risk ratings assigned to certain commercial loans (2) loans that were identified as having higher risk characteristics and (3) the reasonableness of the ALL general reserve. 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)

The firm selected for testing controls that consisted of the issuer's review of (1) risk ratings assigned to certain commercial loans (2) loans that were identified as having higher risk characteristics and (3) the reasonableness of the ALL general reserve. With respect to the review of risk ratings control the firm did not consider the complexity of the control and the significance of the judgments made by the control owners in determining the sample size used to test this control. (AS 2201.46)

The firm did not identify and test any controls over the determination of the risk ratings for the remaining loans that were not subject to the review controls discussed above. (AS 2201.39)

The sample size the firm used in certain of its substantive procedures to test the ALL 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 the deficiencies 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 controls that consisted of the issuer's review of (1) valuation reports and journal entries used to record the business combinations (2) reconciliations of valuation reports to the general ledger and (3) assumptions used to value assets acquired and liabilities assumed. 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)

The firm selected for testing controls that consisted of the issuer's review of (1) valuation reports and journal entries used to record the business combinations (2) reconciliations of valuation reports to the general ledger and (3) assumptions used to value assets acquired and liabilities assumed. The firm did not identify and test any controls over the accuracy and completeness of issuer-produced data that the control owners used in the performance of these controls. (AS 2201.39)

The firm did not identify and evaluate a departure from GAAP related to the issuer's omission of disclosures required by FASB ASC Topic 280 Segment Reporting related to revenue from certain customers. (AS 2810.30 and .31)

The issuer engaged a specialist to develop an accounting estimate that was used to determine the valuation of certain long-lived assets. The following deficiencies were identified: · The firm did not sufficiently evaluate a significant assumption developed by the issuer because it did not take into account the issuer's ability to carry out an action related to the assumption. (AS 2501.16 and .17)

The issuer engaged a specialist to develop an accounting estimate that was used to determine the valuation of certain long-lived assets. The following deficiencies were identified: · The firm did not perform any procedures to evaluate whether the methods used by the company's specialist were appropriate under the circumstances taking into account the requirements of the applicable financial reporting framework. (AS 1105.A8c)

The issuer engaged a specialist to develop an accounting estimate that was used to determine the valuation of certain long-lived assets. The following deficiencies were identified: · The firm did not perform any procedures to test or test controls over the accuracy and completeness of certain data produced by the issuer and used by the company's specialist. (AS 1105.A8a)

The issuer engaged a specialist to develop an accounting estimate that was used to determine the valuation of certain long-lived assets. The following deficiencies were identified: · The firm did not perform procedures to evaluate the relevance and reliability of external data that was used by the company's specialist. (AS 1105.A8a)

The issuer engaged a specialist to develop an accounting estimate that was used to determine the valuation of certain long-lived assets. The following deficiencies were identified: · The firm did not perform any procedures to evaluate certain other significant assumptions that were developed by the issuer. (AS 2501.16)

The firm did not perform any procedures beyond obtaining a memorandum to evaluate the issuer's conclusion that there were no impairment indicators related to certain other long-lived assets. (AS 2501.07)

The firm received a response to its cash confirmation request and included a scanned version of the response in the work papers. The firm did not maintain control over the confirmation response because the firm did not know how the response was received. (AS 2310.28)

The issuer capitalized expenditures related to the development of a long-lived asset. The firm did not perform substantive procedures beyond inquiry to determine whether the expenditures qualified for capitalization as a long-lived asset. (AS 2301.08)