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Based on that evaluation, under the supervision and with the participation of the Hamilton Company, Inc.
−Removed: (the “Management Company”), Management concluded that IT control and related procedures that support financial reporting were not effective as of September 30, 2022 due to the material weaknesses described below that prevented the recording, processing, summarizing and reporting, on a timely basis, information required to be disclosed by the Partnership in the reports that it files or submits under the Exchange Act.
+Added: (the “Management Company”), Management concluded that IT control and related procedures that support financial reporting were not effective as of March 31, 2023 due to the material weaknesses described below that prevented the recording, processing, summarizing and reporting, on a timely basis, information required to be disclosed by the Partnership in the reports that it files or submits under the Exchange Act.
Management Report on Internal Control over Financial Reporting.
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However, Management determined that the inordinate amount of time to recover this data and rebuild the financial reporting system prevented the Partnership from filing this Quarterly Report on a timely basis.
−Removed: The Partnership is committed to remediating the material weaknesses in a timely manner.
−Removed: With the assistance of cybersecurity specialists, the Partnership and the Management Company have added additional security features designed to protect its systems and data from future attacks including multifactor authentication for domain sign-on, restricted server access, enhanced security awareness training, and updated multi-location secure backup with regular recovery testing.
−Removed: In addition to these steps already taken, remediation will also include the documentation and testing of the additional IT procedures implemented.
+Added: The Partnership is committed to maintaining a strong internal control environment.
+Added: Management has evaluated the material weakness described above and designed a remediation plan to address the material weakness and enhance our internal controls.
+Added: Management is in the process of executing this remediation plan.
+Added: We have updated our internal controls to remediate our control deficiencies by designing and implementing controls to mitigate the risks previously not addressed in our control environment.
+Added: These remediation measures include designing and implementing controls over least privileged access, inclusive of enhanced security configurations and monitoring.
+Added: We believe these enhancements will allow us to remediate our control deficiencies in a sustained manner.
+Added: Management is committed to successfully implementing the remediation plan and has begun testing the operating effectiveness of the controls designed and implemented to remediate the material weakness.
+Added: Based on procedures performed through the date of this filing, we expect the material weakness to be remediated as of June 30, 2023.
Limitations on Effectiveness of Controls.
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Changes in Internal Control over Financial Reporting.
−Removed: Except for the above noted material weaknesses and the remediation activities that have already begun, there were no other changes in the Management Company’s internal control over financial reporting identified in connection with the evaluation required by paragraph (d) of Exchange Act Rule 13a-15 that occurred during the quarter ended September 30, 2022 that have materially affected or are reasonably likely to materially affect, the Management Company’s internal control over financial reporting.
+Added: Except for the above noted material weaknesses and the remediation activities that have already begun, there were no other changes in the Management Company’s internal control over financial reporting identified in connection with the evaluation required by paragraph (d) of Exchange Act
+Added: Rule 13a-15 that occurred during the quarter ended March 31, 2023 that have materially affected or are reasonably likely to materially affect, the Management Company’s internal control over financial reporting.
PART II — OTHER INFORMATION
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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.