What changed in this filing

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Item 4. Controls and Procedures

2016-08-10 compared with 2016-02-11 · 52 added, 46 removed, 11 unchanged (90% of the section changed)

2 unchanged sentences

Controls and Procedures.

maintain “disclosure controls and procedures,”

as the Securities and Exchange Commission (“SEC”) defines

We have designed these controls and procedures to reasonably assure that information required to be disclosed in our

reports filed under the Exchange Act, such as this Form 10-Q, is recorded, processed, summarized, and reported within the periods

specified in the SEC’s rules and forms.

We have also designed our disclosure controls to provide reasonable assurance that

such information is accumulated and communicated to the Chief Executive Officer, Executive Vice President and Vice President/Controller,

as appropriate, to allow them to make timely decisions regarding our required disclosures.

management has evaluated the effectiveness of our disclosure controls and procedures (as defined in Rule 13a-15(e) of the Exchange

Act) as of December 31, 2015.

Based on this evaluation, the Chief Executive Officer and Executive Vice President, as co-principal

executive officers, and Vice President/Controller acting as principal financial officer, concluded that our Company’s disclosure

controls and procedures, including the accumulation and communication of disclosures to the Chief Executive Officer, Executive

Vice President, and Vice President/Controller, as appropriate to allow timely decisions regarding required disclosure, were effective

as of this date to provide reasonable assurance that information required to be disclosed by us in the reports that we file or

submit under the Exchange Act is recorded, processed, summarized and reported within the time periods specified by the SEC’s

rules and forms.

Based on this evaluation, we have concluded that there are no material weaknesses in our disclosure controls

and procedures and they were effective.

Company maintains “disclosure controls and procedures,”

as the SEC defines such terms.

We have designed these controls

and procedures to reasonably assure that information required to be disclosed in our reports filed under the Exchange Act, such

as this Quarterly Report, is recorded, processed, summarized, and reported within the periods specified in the SEC’s rules

We have also designed our disclosure controls to provide reasonable assurance that such information is accumulated

and communicated to the Chief Executive Officer, Executive Vice President, and Vice President/Treasurer, as appropriate, to allow

them to make timely decisions regarding our required disclosures.

Management has evaluated the effectiveness

of our disclosure controls and procedures (as defined in Rule 13a-15(e) of the Exchange Act as of June 30, 2016.

on this evaluation, the Chief Executive Officer, Executive Vice President, and the Vice President/Treasurer, acting as principal

financial officer, concluded that the Company’s disclosure controls and procedures, including the accumulation and communication

of disclosures to the Company’s Chief Executive Officer, Executive Vice President, and Vice President/Treasurer, as

appropriate to allow timely decisions regarding required disclosure, were not effective as of this date to provide reasonable

assurance that information required to be disclosed by the Company in the reports filed or submitted under the Exchange Act is

recorded, processed, summarized and reported within the time periods specified by the SEC’s rules and forms.

The Company’s

quarter-end closing process did not adequately ensure that all transactions were accounted for in accordance with GAAP and that

required adjustments were made to the financial statements to prevent them from being materially misstated.

Management acknowledges

that as a smaller reporting entity, it is difficult to have adequate accounting staff to perform appropriate additional reviews

of the financial statements.

Management’s

3 unchanged sentences

Our internal control over financial reporting is a process designed to provide reasonable assurance

regarding the reliability of financial reporting and the preparation of financial statements for external purposes.

regarding the reliability of financial reporting and the preparatio n

of financial statements for external purposes.

of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.

1 unchanged sentence

those systems determined to be effective can provide only reasonable assurance of achieving their control objectives.

Our management,

including our Chief Executive Officer and Executive Vice President, as co-principal executive officers, and Vice President/Controller

acting as principal financial officer, does not expect that our disclosure controls and procedures or our internal controls will

prevent all error or fraud.

A control system, no matter how well conceived and operated, can provide only reasonable, not absolute,

assurance that the objectives of the control system are met.

Further, the design of a control system must reflect the fact that

there are resource constraints and the benefits of controls must be considered relative to their costs.

Due to the inherent limitations

in all control systems, no evaluation of controls can provide absolute assurance that all control issues and instances of fraud,

if any, have been detected.

Management believes that the financial statements included in this report fairly present in all material

respects our financial condition, results of operations and cash flows for the periods presented.

management, with the participation of the Chief Executive Officer and Executive Vice President, as co-principal executive officers,

and Vice President/Controller acting as principal financial officer, evaluated the effectiveness of the Company’s internal

control over financial reporting as of December 31, 2015.

In making this assessment, our management used the criteria set forth

by the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”) in Internal Control –

As a result of its review, management identified a material weakness in the internal control over financial reporting

as described in our annual report on Form 10-K for the year ended March 31, 2015.

Based on this evaluation, our management concluded

that, as of December 31, 2015, our internal control over financial reporting was not comprehensive.

Management acknowledges that

as a smaller reporting entity, it is difficult to have adequate accounting staff to perform appropriate additional reviews of

the financial statements.

OTHER INFORMATION

including our Chief Executive Officer, Executive Vice President, and our Vice President/Treasurer, acting as principal financial

officer, does not expect that our disclosure controls and procedures or our internal controls will prevent all error or fraud.

A control system, no matter how well conceived and operated, can provide only reasonable, not absolute, assurance that the objectives

of the control system are met.

Further, the design of a control system must reflect the fact that there are resource constraints

and the benefits of controls must be considered relative to their costs.

Due to the inherent limitations in all control systems,

no evaluation of controls can provide absolute assurance that all control issues and instances of fraud, if any, have been detected.

Management believes that the financial statements included in this report fairly present in all material respects our financial

condition, results of operations and cash flows for the periods presented.

with the participation of the Chief Executive Officer, as principal executive officer, Executive Vice President, and the Vice

President/Treasurer, acting as principal financial officer, evaluated the effectiveness of the Company’s internal control

over financial reporting as of June 30, 2016.

In making this assessment, management used the criteria set forth by the Committee

of Sponsoring Organizations of the Treadway Commission (“COSO”) in Internal Control –

Integrated Framework.

Consistent with its review for the year ending March 31, 2016, when management identified a material weakness in the internal

control over financial reporting, management concluded that, as of June 30, 2016, the Company’s internal control over financial

reporting was not comprehensive.

material weakness was evidenced through the Company’s year-end closing process, which did not adequately ensure that all

transactions were accounted for in accordance with GAAP and that required adjustments were made to the financial statements to

prevent them from being materially misstated.

Based on this evaluation, our management, with the participation of the Chief Executive

Officer, Executive Vice President and Principal Financial Officer, in this case, our Vice President/Controller, concluded, as

of March 31, 2016, our internal control over financial reporting was not effective.

Management acknowledges that as a smaller

reporting entity, it is difficult to have adequate accounting staff to perform appropriate additional reviews of the financial

II - 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