CONTROLS AND PROCEDURES
−Removed: of Disclosure Controls and Procedures
−Removed: Chief Executive Officer (our principal executive officer) and Chief Financial Officer (our
−Removed: principal financial officer and principal accounting officer) have concluded based on their evaluation as of December 31, 2023, that our
−Removed: “disclosure controls and procedures” (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934,
−Removed: as amended (“Exchange Act”)) are not effective due to a material weakness.
−Removed: The term “disclosure
−Removed: controls and procedures,” as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange
−Removed: Act, means controls and other procedures of a company
−Removed: that are designed to ensure that
−Removed: information required to be disclosed by the
−Removed: company in the reports it files or submits under the Exchange Act is recorded, processed,
−Removed: summarized and reported, within the time periods specified
+Added: Evaluation of Disclosure Controls
+Added: and Procedures
+Added: Our Chief Executive Officer and Chief Financial Officer (the principal
+Added: executive officer and principal financial officer, respectively) conducted an evaluation of the design and operation of our “disclosure
+Added: controls and procedures” (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (“Exchange
+Added: The term “disclosure controls and procedures,” as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange
+Added: Act means controls and other procedures of a company that are designed to ensure that information required to be disclosed by the Company
+Added: in the reports it files or submits under the Exchange Act is recorded, processed, summarized and reported, within the time periods specified
in the SEC’s rules and forms.
Disclosure controls and procedures also include, without limitation, controls and procedures designed
−Removed: to ensure that information required to be disclosed by a company
−Removed: in the reports that it files or submits under the Exchange Act
−Removed: is accumulated and communicated to the company’s management, including its principal
−Removed: executive officer and principal financial officer and principal accounting officer, or persons performing similar functions, as appropriate,
−Removed: to allow timely decisions regarding required disclosure.
−Removed: material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a
−Removed: reasonable possibility that a material misstatement of a company’s annual and interim financial statements will not be detected
−Removed: or prevented on a timely basis.
−Removed: A material weakness was discovered relating to the valuation and disclosure of level 3 investments during
−Removed: fiscal 2023 as well as level 2 investments for the three months ended December 31, 2023.
+Added: to ensure that information required to be disclosed by a company in the reports that it files or submits under the Exchange Act is accumulated
+Added: and communicated to the company’s management, including its principal executive and principal financial officers, or persons performing
+Added: similar functions, as appropriate, to allow timely decisions regarding required disclosure.
+Added: In accordance with SEC rules, an evaluation was performed under the supervision
+Added: and with the participation of our Principal Executive Officer and Principal Financial Officer of the effectiveness, as of March 31,
+Added: 2024, of the Company’s disclosure controls and procedures (as defined in Rule 13a-15(e) under the Exchange Act).
+Added: control over financial reporting” includes those policies and procedures that:
+Added: (1) pertain to the maintenance of records that in reasonable detail accurately
+Added: and fairly reflect the transactions and dispositions of the assets of the issuer;
+Added: (2) provide reasonable assurance that transactions are recorded as necessary
+Added: to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures
+Added: of the issuer are being made only in accordance with authorizations of management and directors of the issuer;
+Added: (3) provide reasonable assurance regarding prevention or timely detection of
+Added: unauthorized acquisition, use or disposition of the issuer’s assets that could have a material effect on the financial statements.
+Added: A material weakness
+Added: is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility
+Added: that a material misstatement of a company’s annual and interim financial statements will not be detected or prevented on a timely
+Added: A material weakness was discovered relating to the valuation and disclosure of level 3 investments during fiscal 2023 as well
+Added: as level 2 investments for the three months ended December 31, 2023.
We are continuing to remediate this weakness.
−Removed: While we no longer hold any level 3 investments, all of the investments in our portfolio continue to be considered level 2 investments
−Removed: because they are either thinly traded, or we own a substantial percentage of total outstanding shares.
−Removed: While we believe that our fair
−Removed: value assessment and disclosures at December 31, 2023, are appropriate, we are continuing to monitor our internal controls.
+Added: While we no longer
+Added: hold any level 3 investments, all of the investments in our portfolio continue to be considered level 2 investments because they are
+Added: either thinly traded, or we own a substantial percentage of total outstanding shares.
+Added: While we believe that our fair value assessment
+Added: and disclosures at March 31, 2024, are appropriate, we are continuing to monitor our internal controls.
+Added: Based on that evaluation as of March 31, 2024, our Chief Executive Officer
+Added: and Chief Financial Officer concluded that the disclosure controls and procedures are not effective.
Control Over Financial Reporting
−Removed: the three months ended December 31, 2023, there were no changes in our internal controls over financial reporting (as defined in Rule
−Removed: 13a-15(f) and 15d-15(f) under the Exchange Act) that have materially affected, or are reasonably likely to materially
−Removed: affect, our internal controls over financial reporting.
+Added: During the three months ended
+Added: March 31, 2024, there were no changes in our internal controls over financial reporting (as defined in Rule 13a-15(f) and 15d-15(f) under
+Added: the Exchange Act) that have materially affected, or are reasonably likely to materially affect, our internal controls over financial
Inherent Limitations
4 unchanged sentences
necessarily was required to apply its judgment in evaluating the cost-benefit relationship of possible controls and procedures.
−Removed: Because of its
−Removed: inherent limitations, internal control over financial reporting may not prevent or detect misstatements.
−Removed: Also, projections of any evaluation
−Removed: of effectiveness to future periods are subject to the risks that controls may become inadequate because of changes in conditions, or that
−Removed: the degree of compliance with the policies or procedures may deteriorate.
+Added: of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.
+Added: Also, projections of any
+Added: evaluation of effectiveness to future periods are subject to the risks that controls may become inadequate because of changes in conditions,
+Added: or that the degree of compliance with the policies or procedures may deteriorate.
II — OTHER INFORMATION
2 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.