Item 4. Controls and Procedures
Item 4. Controls and Procedures.
Disclosure Controls
and Procedures
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
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;
¨ 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 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.
18
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.