What changed in this filing

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Item 4. Controls and Procedures

2021-05-12 compared with 2021-02-16 · 23 added, 25 removed, 4 unchanged (92% of the section changed)

1 unchanged sentence

of disclosure controls and procedures

management is responsible for establishing and maintaining a system of disclosure controls and procedures (as defined in Rule

13a-15(e)) under the Exchange Act) that is designed to ensure that information required to be disclosed by our Company in the

reports that we file or submit under the Exchange Act is recorded, processed, summarized and reported, within the time specified

in the Commission’s rules and forms.

Disclosure controls and procedures include, without limitation, controls and procedures

designed to ensure that information required to be disclosed by an issuer in the reports that it files or submits under the Exchange

Act is accumulated and communicated to the issuer’s management, including its principal executive officer or officers and

principal financial officer or officers, or persons performing similar functions, as appropriate to allow timely decisions regarding

required disclosure.

to Rule 13a-15(b) under the Exchange Act, our Company carried out an evaluation with the participation of our Company’s

management, including our Company’s Chief Executive Officer (“CEO”) and our Company’s Chief Financial

Officer (“CFO”), of the effectiveness of our Company’s disclosure controls and procedures (as defined under

Rule 13a-15(e) under the Exchange Act) as of December 31, 2020.

Based upon that evaluation, our Company’s CEO and

CFO concluded that our Company’s disclosure controls and procedures were not effective as of December 31, 2020 due

to our Company’s limited internal resources and lack of ability to have multiple levels of transaction review.

management is responsible for establishing and maintaining a system of disclosure controls and procedures (as defined in Rule 13a-15(e))

under the Exchange Act) that is designed to ensure that information required to be disclosed by our Company in the reports that we file

or submit under the Exchange Act is recorded, processed, summarized and reported, within the time specified in the Commission’s

rules and forms.

Disclosure controls and procedures include, without limitation, controls and procedures designed to ensure that information

required to be disclosed by an issuer in the reports that it files or submits under the Exchange Act is accumulated and communicated

to the issuer’s management, including its principal executive officer or officers and principal financial officer or officers,

or persons performing similar functions, as appropriate to allow timely decisions regarding required disclosure.

to Rule 13a-15(b) under the Exchange Act, our Company carried out an evaluation with the participation of our Company’s management,

including our Company’s Chief Executive Officer (“CEO”) and our Company’s Chief Financial Officer (“CFO”),

of the effectiveness of our Company’s disclosure controls and procedures (as defined under Rule 13a-15(e) under the Exchange Act)

as of March 31, 2021.

Based upon that evaluation, our Company’s CEO and CFO concluded that our Company’s disclosure controls

and procedures were not effective as of March 31, 2021 due to our Company’s limited internal resources and lack of ability to have

multiple levels of transaction review.

is in the process of determining how best to change our current system and implement a more effective system to insure that information

required to be disclosed in the reports that we file or submit under the Exchange Act have been recorded, processed, summarized

and reported accurately.

Our management intends to develop procedures to address the current deficiencies to the extent possible

given limitations in financial and personnel resources.

While management is working on a plan, no assurance can be made at this

point that the implementation of such controls and procedures will be completed in a timely manner or that they will be adequate

once implemented.

required to be disclosed in the reports that we file or submit under the Exchange Act have been recorded, processed, summarized and reported

Our management intends to develop procedures to address the current deficiencies to the extent possible given limitations

in financial and personnel resources.

While management is working on a plan, no assurance can be made at this point that the implementation

of such controls and procedures will be completed in a timely manner or that they will be adequate once implemented.

in internal control over financial reporting

have been no changes in our internal control over financial reporting during the period ended December 31, 2020 that have materially

affected, or are reasonably likely to materially affect, our internal controls over financial reporting.

have been no changes in our internal control over financial reporting during the period ended March 31, 2021 that have materially affected,

or are reasonably likely to materially affect, our internal controls over financial reporting.

OTHER INFORMATION

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.

What changed 10-Q

Item 4. Controls and Procedures