What changed in this filing

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Item 4. Controls and Procedures

2015-11-13 compared with 2015-05-15 · 20 added, 19 removed, 15 unchanged (72% of the section changed)

2 unchanged sentences

and Procedures

As of March 31, 2015, 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 under the 1992 COSO framework.

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.

As of September 30, 2015, 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 under the 2013 COSO framework.

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

continues to focus on internal control over financial reporting.

As of March 31, 2015, the Company has completed the necessary documentation of our internal controls and will further implement

the following remedial initiatives:

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

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

Management continues

to focus on internal control over financial reporting.

As of September 30, 2015, the Company has completed the necessary

documentation of our internal controls and will further implement the following remedial initiatives:

Improved design and documentation related to multiple levels of review over financial statements included

in our SEC filings;

Expanded 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;

1 unchanged sentence

assessment as well as external auditor testing.

and update the internal controls to be in compliance with the 2013 COSO framework.

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 March 31, 2015 that have materially affected, or are reasonably likely to materially affect,

the Company’s internal control over financial reporting, except as disclosed above.

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, 2015 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

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