Item 4. Controls and Procedures
Item 4. Controls and Procedures.
Disclosure Controls
and Procedures
As of December 31, 2014, 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
Management
continues to focus on internal control over financial reporting.
As of December 31, 2014, the Company has completed the necessary documentation of our internal controls and implemented the following
remedial initiatives:
· Improved
the documentation related to multiple levels of review over financial statements included in our SEC filings;
21
· 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;
and
· 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.
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 December 31, 2014 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
Item 1. Legal Proceedings.
None.
Item 1A. Risk Factors.
Not applicable.
Item 2. Unregistered Sales of Equity Securities and Use of Proceeds.
(a)
None
(b)
None
(c)
None
Item 3. Defaults upon Senior Securities.
None.
Item 4. Mine Safety Disclosures.
Not applicable.
Text extracted from the filing as submitted to EDGAR. Formatting, tables and exhibits are simplified for reading; the original document is authoritative for anything you rely on.