What changed in this filing

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Item 4. Controls and Procedures

2013-11-14 compared with 2013-05-13 · 13 added, 40 removed, 8 unchanged (87% of the section changed)

Controls and Procedures.

Disclosure Controls

and Procedures

As of March 31, 2013, the company carried

out an evaluation, under the supervision of and with the participation of management, including our Company’s chief executive

officer and chief financial officer, of the effectiveness of the design and operation of our Company’s disclosure controls

and procedures.

Based on the foregoing, the chief executive officer and chief financial officer concluded that our Company’s

disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934) were

ineffective in timely alerting them to information required to be included in the Company’s periodic Securities and Exchange

Commission filings.

Changes in Internal

Control over Financial Reporting

The Company, with the assistance

of a third party internal control consultant, has developed a specific plan to address our control deficiencies.

During the nine

months ended March 31, 2013, the Company has completed the necessary documentation of our internal controls and implemented the

following remedial initiatives:

the design and documentation related to the multiple levels of review over our financial statements included in our SEC filings;

the design and assessment test work over the monitoring function of entity level controls;

documentation retention policies over test work related to continuous management assessments of internal control effectiveness;

internal control policy implementation by hiring an experienced reporting consultant and strengthening the training of our financial

staff on US GAAP matters.

However, the Company’s internal control over

financial reporting is not effective because of the following:

The Company has not completed

the expanded documentation practices and policies related to various key controls to provide support and audit trails for both

internal management assessment as well as external auditor testing;

The Company lacks sufficient

personnel with appropriate levels of accounting knowledge and experience to address complex U.S.

GAAP accounting issues and to

prepare and review financial statements and related disclosures under U.S.

Specifically, our controls did not operate effectively

to ensure the appropriate and timely analysis of and accounting for unusual and non-routine transactions and certain financial

statement accounts.

There were no other changes in the Company’s

internal control over financial reporting (as defined in Rule 13a-15(f) of the Securities Exchange Act of 1934) during the three

months ended March 31, 2013 that have materially affected, or are reasonably likely to materially affect, the Company’s internal

control over financial reporting, except as disclosed above.

Disclosure Controls and Procedures

As of September 30, 2013, the company carried out an evaluation, under the supervision of and with the participation of management, including our Company’s chief executive officer and chief financial officer, of the effectiveness of the design and operation of our Company’s disclosure controls and procedures.

Based on the foregoing, the chief executive officer and chief financial officer concluded that our Company’s disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934) were ineffective in timely alerting them to information required to be included in the Company’s periodic Securities and Exchange Commission filings.

Changes in Internal Control over Financial Reporting

The Company, with the assistance of an independent internal controls consultant, has developed a specific plan to address our control deficiencies.

As of September 30, 2013, the Company has completed the necessary documentation of our internal controls and implemented the following remedial initiatives:

· Improved the design and documentation related to multiple levels of review over financial statements included in our SEC filings;

· Expanded the design and assessment test work over the monitoring function of entity level controls;

· Enhanced documentation retention policies over test work related to continuous management assessments of internal control effectiveness;

· Expanded documentation practices and policies related to various key controls to provide support and audit trails for both internal management assessment as well as external auditor testing;

· Enhanced internal control policy implementation by hiring experienced reporting consultant and strengthening training financial staffs of US GAAP.

There were no changes in the Company’s internal control over financial reporting (as defined in Rule 13a-15(f) of the Securities Exchange Act of 1934) during the three months ended September 30, 2013 that have materially affected, or are reasonably likely to materially affect, the Company’s internal control over financial reporting, except as disclosed above.

Part II Other Information

2 unchanged sentences

Not applicable.

Unregistered Sales of Equity Securities

and Use of Proceeds.

Unregistered Sales of Equity Securities and Use of Proceeds.

Defaults upon Senior Securities.

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.

What changed 10-Q

Item 4. Controls and Procedures