1 unchanged sentence
Evaluation of Disclosure Controls and Procedures
−Removed: Our management, with the participation of our Chief Executive Officer and Chief Financial Officer, evaluated the effectiveness of our disclosure controls and procedures (as defined in Rule 13a-15(e) of the Exchange Act) as of the end of the period covered by this report.
−Removed: Based on that evaluation, our Chief Executive Officer and Chief Financial Officer have concluded that as of December 31, 2020, our disclosure controls and procedures were effective at a reasonable assurance level.
+Added: Our management, with the participation of our principal executive officer and principal financial officer, evaluated the effectiveness of our disclosure controls and procedures (as defined in Rule 13a-15(e) of the Exchange Act) as of the end of the period covered by this report.
+Added: Based on that evaluation, our principal executive officer and principal financial officer have concluded that as of December 31, 2021, our disclosure controls and procedures were effective at a reasonable assurance level.
The Company’s disclosure controls and procedures are designed to provide reasonable assurance that information required to be disclosed by us in reports that we file or submit under the Exchange Act (i) is recorded, processed, summarized and reported within the time periods specified in the SEC’s rules and forms;
−Removed: and (ii) accumulated and communicated to management, including our Chief Executive Officer and Chief Financial Officer, as appropriate, to allow timely discussions regarding required disclosure.
+Added: and (ii) accumulated and communicated to management, including our principal executive officer and principal financial officer, as appropriate, to allow timely discussions regarding required disclosure.
We believe that a control system, no matter how well designed and operated, cannot provide absolute assurance that the objectives of the control system are met, and no evaluation of controls can provide absolute assurance that all control issues and instances of fraud, if any, within a company have been detected.
−Removed: Remediation of Previously Reported Material Weaknesses
−Removed: Our management previously determined that material weaknesses in our internal control over financial reporting existed related to the design and maintenance of internal controls commensurate with our financial reporting requirements.
−Removed: Specifically, we lacked a sufficient complement of professionals with an appropriate level of accounting knowledge, training and experience to appropriately analyze, record and disclose accounting matters timely and accurately and we did not design and maintain controls to ensure adequate segregation of duties within our financial reporting function including the preparation and review of journal entries.
−Removed: A material weakness is a deficiency or combination of deficiencies in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of a company’s annual and interim financial statements will not be detected or prevented on a timely basis.
−Removed: During 2019 and 2020, management implemented remediation initiatives in response to the previously identified material weakness.
−Removed: Specific remedial actions included:
−Removed: • hiring additional personnel in our finance department with experience commensurate with our financial accounting and reporting requirements;
−Removed: • strengthening our internal policies, processes and reviews, including creation of related documentation thereof;
−Removed: • implementing an enterprise resource planning system to support key financial processes and controls, including the segregation of duties around the preparation and review of journal entries;
−Removed: • completing the design and implementation of internal controls to address the relevant risks.
−Removed: Management believes that these actions have been implemented and have operated effectively for a sufficient period of time.
−Removed: As a result, we have concluded that our remediation efforts have been successful and that the previously identified material weaknesses were remediated as of December 31, 2020.
Management’s Report on Internal Control Over Financial Reporting
6 unchanged sentences
Changes in Internal Control Over Financial Reporting
−Removed: Other than the applicable remediation efforts described in “Remediation of Previously Reported Material Weaknesses” above, there have been no changes in our internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) of the Exchange Act) during the fiscal quarter ended December 31, 2020 that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
+Added: There were no changes in our internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) of the Exchange Act) during the fiscal year ended December 31, 2021, that has materially affected, or is reasonably likely to materially affect, our internal control over financial reporting.
Other Information
+Added: Disclosure Regarding Foreign Jurisdictions that Prevent Inspections
+Added: Not applicable.
Directors, Executive Officers and Corporate Governance
50 unchanged sentences
333-235789) filed on January 3, 2020)
−Removed: 10.11#* Employment Agreement between the Registrant and Rachel Humphrey
+Added: 10.11# Employment Agreement between the Registrant and Rachel Humphrey (incorporated by reference to Exhibit 10.11 of the Registrant’s Annual Report on Form 10-K (File No.
+Added: 001-39200) filed on March 25, 2021)
+Added: 10.12# Employment Agreement between the Registrant and Elizabeth Buck (incorporated by reference to Exhibit 10.1 of the Registrant’s Quarterly Report on Form 10-Q (File No.
+Added: 001-39200) filed on August 12, 2021 )
10.13+ Lease Agreement, dated as of July 24, 2020, by and between RREEF America REIT II Corp.
34 unchanged sentences
(Principal Executive Officer)
−Removed: /s/ Thomas Leggett Chief Financial Officer
+Added: /s/ Fang Ni Chief Business and Interim Chief Financial Officer
(Principal Financial Officer)
−Removed: Thomas Leggett
+Added: /s/ Erika Jones Vice President, Finance and Corporate Controller
+Added: (Principal Accounting Officer)
/s/ Robert A.
12 unchanged sentences
Kapil Dhingra
+Added: Velleca Director
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.