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The issuer recorded the fair values of certain of its available-for-sale (AFS) securities based on broker quotes. The following deficiencies were identified: · The firm did not identify and test any controls over the observability of the pricing inputs at the individual instrument level that the issuer used to determine the categorization of these securities within the fair value hierarchy as set forth in FASB ASC Topic 820. (AS 2201.39)

The issuer recorded the fair values of certain of its available-for-sale (AFS) securities based on broker quotes. The following deficiencies were identified: · 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 beyond tracing the balances that were disclosed for each category to issuer-prepared schedules. (AS 2301.08)

The firm did not identify and evaluate that the issuer's presentation of certain debt as long term was not in conformity with FASB ASC Topic 470 Debt. (AS 2810.30 and .31)

The issuer recorded the fair values of certain of its available-for-sale (AFS) securities based on broker quotes. The following deficiencies were identified: · The sample size the firm used in its substantive procedures to test the valuation of these investment securities 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 issuer disclosed (1) the lowest available credit rating by security type for its held-to-maturity securities and (2) the size and maturity date of certain deposit liabilities. The following deficiencies were identified: · The firm did not identify and test any controls over the accuracy and completeness of the issuer-prepared schedules used to develop these disclosures. (AS 2201.39)

The issuer disclosed (1) the lowest available credit rating by security type for its held-to-maturity securities and (2) the size and maturity date of certain deposit liabilities. The following deficiencies were identified: · The firm used these issuer-prepared schedules in its testing of these disclosures but did not perform any procedures to test or test controls over the accuracy and completeness of these schedules. (AS 1105.10)

The issuer reduced the number of its reporting units in the current year and reallocated the goodwill balance to the remaining reporting units based on their relative fair values. The following deficiencies were identified: · The firm did not identify and evaluate that this reallocation was not in conformity with FASB ASC Topic 350 Intangibles – Goodwill and Other. (AS 2810.30 and .31) In connection with our review the issuer reevaluated its allocation of goodwill to its reporting units and determined that an error existed that had not been previously identified. The issuer did not file an amended Form 10-K or Form 8-K indicating that its previously issued financial statements should not be relied on. Instead the issuer adjusted this allocation in a subsequent filing.

The issuer reduced the number of its reporting units in the current year and reallocated the goodwill balance to the remaining reporting units based on their relative fair values. The following deficiencies were identified: · The firm did not perform sufficient procedures to evaluate whether the goodwill associated with any of the previous reporting units may have been impaired at the time of the issuer's reduction in the number of reporting units because its procedures were limited to reading an issuer-prepared memorandum and inquiring of management. (AS 2301.08) In connection with our review the issuer reevaluated its allocation of goodwill to its reporting units and determined that an error existed that had not been previously identified. The issuer did not file an amended Form 10-K or Form 8-K indicating that its previously issued financial statements should not be relied on. Instead the issuer adjusted this allocation in a subsequent filing.

The issuer used an internally developed model to estimate the quantitative component of the ACL for loans collectively evaluated for impairment. The following deficiencies were identified: · The firm selected for testing a control that consisted of the issuer's annual validation of this model as of an interim date. The firm did not evaluate whether this control's operation six months prior to year end was sufficient to address the risks of material misstatement at year end. (AS 2201.42)

The issuer used an internally developed model to estimate the quantitative component of the ACL for loans collectively evaluated for impairment. The following deficiencies were identified: · The firm's approach for substantively testing the quantitative component of the ACL for loans collectively evaluated for impairment was to test the issuer's process and the firm used an auditor-employed specialist to evaluate the methods and significant assumptions used by the issuer. The firm did not sufficiently evaluate whether the methods used by the issuer were appropriate because the firm did not identify that the auditor-employed specialist did not perform any procedures to test the issuer's model at year end. (AS 1201.C6 and .C7; AS 2501.10)

The firm identified a control deficiency related to the review of the prices the issuer used to recognize revenue for certain locations. The firm identified compensating controls that it believed would mitigate this deficiency but did not test these controls. (AS 2201.68)

The firm did not identify and test any controls related to certain revenue disclosures. (AS 2201.39)

The firm did not perform any substantive procedures to test these revenue disclosures. (AS 2301.08)

The firm did not identify and evaluate a misstatement in the issuer's disclosures under FASB ASC Subtopic 860-30 Transfers and Servicing – Secured Borrowing and Collateral related to the carrying amount of its assets pledged as collateral. (AS 2810.30 and .31)

The firm did not identify and test any controls over sales allowances. (AS 2201.39)

The firm did not perform any substantive procedures to test sales allowances. (AS 2301.08)

The firm did not identify and test any controls over the issuer's evaluation of the lower of cost or net realizable value for certain inventory. (AS 2201.39)

The firm did not perform any substantive procedures to test whether this inventory was recorded at the lower of cost or net realizable value. (AS 2301.08)

The firm did not identify and test any controls over the issuer's allocation of labor and overhead costs to inventory. (AS 2201.39)

The firm did not perform any substantive procedures to test whether the labor and overhead costs the issuer capitalized to inventory were appropriate. (AS 2301.08)

The firm identified various control deficiencies related to inventory. The firm identified and tested compensating controls that it believed would mitigate certain of these deficiencies but did not identify that these controls were dependent on the operating effectiveness of the deficient controls. (AS 2201.68)

The issuer recognized revenue from certain contracts as single performance obligations satisfied over time. With respect to the issuer's revenue recognition: The firm did not identify and test any controls over the issuer's identification and evaluation of contract terms with its customers that could affect revenue recognition. (AS 2201.39)

The issuer recognized revenue from certain contracts as single performance obligations satisfied over time. With respect to the issuer's revenue recognition: The firm did not perform any substantive procedures to evaluate the issuer's contract terms with its customers to determine whether the issuer recognized this revenue in conformity with FASB ASC Topic 606 Revenue from Contracts with Customers. (AS 2301.08)

The issuer recognized revenue from certain contracts as single performance obligations satisfied over time. With respect to the issuer's disclosures of its unsatisfied performance obligations: The firm did not identify and test any controls over the issuer's identification and evaluation of contracts that could be cancelled by the customer which could affect the issuer's disclosures of unsatisfied performance obligations. (AS 2201.39)

The firm did not perform any substantive procedures to test the issuer's presentation and disclosure of its unused financing arrangements. (AS 2301.08)

The issuer recognized revenue from certain contracts as single performance obligations satisfied over time. With respect to the issuer's disclosures of its unsatisfied performance obligations: The firm did not perform any substantive procedures to identify whether the issuer's contracts could be cancelled by the customer and evaluate the effect of those contract terms to determine whether the issuer's disclosures of unsatisfied performance obligations were in conformity with FASB ASC Topic 606. (AS 2301.08)

The firm selected for testing a control that included the issuer's review of its segment disclosures but did not test the aspect of the control that addressed the accuracy and completeness of the issuer-prepared schedules used to prepare these disclosures. (AS 2201.42 and .44)

The firm did not identify and evaluate certain misstatements in a required disclosure under FASB ASC Topic 280 Segment Reporting. (AS 2810.30 and .31)

The issuer used an information-technology (IT) system to process transactions related to revenue that automatically assigned predefined codes to each transaction. These codes were used by the issuer's system to determine revenue and certain related adjustments. The following deficiencies were identified: · The firm did not identify and test any controls that addressed whether certain of these codes were appropriately assigned by the IT system. (AS 2201.39)

The issuer used an information-technology (IT) system to process transactions related to revenue that automatically assigned predefined codes to each transaction. These codes were used by the issuer's system to determine revenue and certain related adjustments. The following deficiencies were identified: · The firm selected for testing a control that included the issuer's review of revenue transactions that exceeded a monetary threshold but did not evaluate whether this threshold was sufficiently precise to detect misstatements that could be material. (AS 2201.42)

The issuer used an information-technology (IT) system to process transactions related to revenue that automatically assigned predefined codes to each transaction. These codes were used by the issuer's system to determine revenue and certain related adjustments. The following deficiencies were identified: · The firm did not evaluate the specific review procedures that the control owners performed to determine whether the amount to be recorded as revenue was appropriate. (AS 2201.42 and .44)

The sample sizes the firm used in certain of its substantive procedures to test revenue and accounts receivable 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 identify and test any controls over the accounts receivable allowance and bad debt expense. (AS 2201.39)

The firm did not perform any substantive procedures to test the accounts receivable allowance and bad debt expense. (AS 2301.08)

The issuer disclosed various information about its investment securities that were in unrealized loss positions at year end. The following deficiencies were identified: · The firm did not identify and test any controls over the accuracy and completeness of the issuer-prepared schedules used to develop this disclosure. (AS 2201.39)

The firm did not identify and test any controls over the issuer's amortization of premiums and accretion of discounts on its investment securities. (AS 2201.39)

The issuer disclosed various information about its investment securities that were in unrealized loss positions at year end. The following deficiencies were identified: · The firm used these issuer-prepared schedules in its testing of this disclosure but did not perform any procedures to test or test controls over the accuracy and completeness of these schedules. (AS 1105.10)

The issuer disclosed various information about its investment securities that were in unrealized loss positions at year end. The following deficiencies were identified: · The firm did not identify and evaluate a misstatement in this disclosure. (AS 2810.30 and .31)

The issuer recorded most of its AFS securities at fair value based on prices including broker quotes it obtained from external pricing services. The following deficiencies were identified: · The firm selected for testing a control that consisted of the issuer's evaluation of the appropriateness of the methods and assumptions used by the external pricing services. The firm did not evaluate the specific review procedures that the control owner performed to assess the reasonableness of the methods and assumptions underlying broker quotes obtained from the pricing services. (AS 2201.42 and .44)

The issuer recorded most of its AFS securities at fair value based on prices including broker quotes it obtained from external pricing services. The following deficiencies were identified: · The firm did not identify and test any controls over the observability of the pricing inputs related to broker-priced AFS securities at the individual instrument level that the issuer used to determine the categorization of these AFS securities within the fair value hierarchy as set forth in FASB ASC Topic 820. (AS 2201.39)

The issuer recorded most of its AFS securities at fair value based on prices including broker quotes it obtained from external pricing services. The following deficiencies were identified: · The firm did not perform any substantive procedures to evaluate the appropriateness of the issuer's categorization of these AFS securities within the fair value hierarchy beyond tracing the balances that were disclosed for each category to issuer-prepared schedules. (AS 2301.08)

For AFS securities for which prices could not be obtained the issuer used the original purchase price to approximate fair value. The firm did not identify and test any controls that addressed whether the issuer's use of purchase price was an appropriate approximation of fair value for these AFS securities. (AS 2201.39)

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 valued inventory for one of its segments using the last-in first-out (LIFO) method and determined its quarterly LIFO adjustments based on the LIFO inventory balances for each of its inventory categories. The following deficiencies were identified: · The firm identified a control deficiency related to the issuer's quarterly review of the LIFO adjustment for each inventory category. The firm identified and tested a compensating control that it believed mitigated this deficiency but did not identify that this compensating control did not operate at the inventory-category level and involved the review of gross margins before they were adjusted for LIFO. (AS 2201.68)

The issuer valued inventory for one of its segments using the last-in first-out (LIFO) method and determined its quarterly LIFO adjustments based on the LIFO inventory balances for each of its inventory categories. The following deficiencies were identified: · The firm's substantive procedures to test the issuer's year-end LIFO adjustment consisted of performing substantive analytical procedures. The firm did not determine whether the expectations it used in these analytical procedures were based on predictable relationships. (AS 2305.13 and .14)

The firm did not perform any substantive procedures to test the issuer's amortization of premiums and accretion of discounts on these investment securities. (AS 2301.08)

The issuer valued inventory for one of its segments using the last-in first-out (LIFO) method and determined its quarterly LIFO adjustments based on the LIFO inventory balances for each of its inventory categories. The following deficiencies were identified: · The firm's substantive procedures to test the issuer's year-end LIFO adjustment consisted of performing substantive analytical procedures. The expectations the firm used were not sufficiently precise to identify differences that could be potential material misstatements individually or in the aggregate because the data used to develop the expectations did not address the issuer's determination of LIFO adjustments at the inventory-category level. (AS 2305.17)

The issuer disclosed the aggregate amount of transaction prices allocated to unsatisfied performance obligations and during the year made modifications to certain existing contracts that resulted in a change in the time frame for a performance obligation to be satisfied. The following deficiencies were identified: · The firm did not identify and test any controls over the accuracy and completeness of the issuer-prepared schedules used to develop the disclosure of unsatisfied performance obligations. (AS 2201.39)

The issuer disclosed the aggregate amount of transaction prices allocated to unsatisfied performance obligations and during the year made modifications to certain existing contracts that resulted in a change in the time frame for a performance obligation to be satisfied. The following deficiencies were identified: · The firm used these issuer-prepared schedules in its testing of this disclosure but did not perform any procedures to test or test any controls over the accuracy and completeness of these schedules. (AS 1105.10)