1 unchanged sentence
Disclosure Controls and Procedures.
−Removed: The effectiveness of the Partnership’s disclosure controls and procedures (as such term is defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”)) have been evaluated as of the end of the period covered by this report.
−Removed: 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 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.
−Removed: Management Report on Internal Control over Financial Reporting.
−Removed: On October 3, 2022, the Management Company was the target of a ransomware attack.
−Removed: The Partnership did not incur any monetary damage nor any loss of financial data due to the incident.
−Removed: After becoming aware of the incident, the Management Company conducted an internal investigation into their digital environment and discovered that all on premise computer systems were encrypted by an outside party.
−Removed: The Partnership, along with the Management Company, worked with independent third-party cybersecurity specialists to help with the restoration of the environment and to return operations securely.
−Removed: Off-site data backups, which were verified to have not been compromised by the ransomware attack, were utilized to restore the data that had been encrypted.
−Removed: The Partnership, along with the Management Company, has successfully recovered the impacted files and rebuilt its computer systems.
−Removed: 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 maintaining a strong internal control environment.
−Removed: Management has evaluated the material weakness described above and designed a remediation plan to address the material weakness and enhance our internal controls.
−Removed: Management is in the process of executing this remediation plan.
−Removed: 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.
−Removed: These remediation measures include designing and implementing controls over least privileged access, inclusive of enhanced security configurations and monitoring.
−Removed: We believe these enhancements will allow us to remediate our control deficiencies in a sustained manner.
−Removed: 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.
−Removed: Based on procedures performed through the date of this filing, we expect the material weakness to be remediated as of June 30, 2023.
+Added: The Partnership’s management, with the participation of the Partnership’s principal executive officer and principal financial officer, has evaluated the effectiveness of the Partnership’s disclosure controls and procedures (as such term is defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”)) as of the end of the period covered by this report.
+Added: Based on such evaluation, the Partnership’s principal executive officer and principal financial officer have concluded that, as of the end of such period, the Partnership’s disclosure controls and procedures were effective in 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: We previously identified material weaknesses in our IT control and related procedures that support financial reporting as of December 31, 2022, due to control deficiencies related to a threat actor ransomware attack that delayed the filing of our 3rd quarter 10-Q.
+Added: We 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 included redesigning and enhancing controls over the monitoring of user access rights, implementation of least privileged access and implementation of enhanced security configuration software.
+Added: We completed our testing and evaluation of our internal control over financial reporting as of June 30, 2023 and determined that as of June 30, 2023, our internal control over financial reporting was designed and operating effectively for a sufficient period for management to conclude that the material weaknesses have been remediated.
Limitations on Effectiveness of Controls.
3 unchanged sentences
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
−Removed: 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.
+Added: , There were no other changes in the Management Company’s internal control over financial reporting identified in connection with the evaluation required by paragraph
+Added: (d) of Exchange Act Rule 13a-15 that occurred during the quarter ended June 30, 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
3 unchanged sentences
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.