2 unchanged sentences
and Procedures
−Removed: As of September 30, 2015, the company carried
−Removed: out an evaluation, under the supervision of and with the participation of management, including our Company’s chief executive
−Removed: officer and chief financial officer, of the effectiveness of the design and operation of our Company’s disclosure controls
−Removed: and procedures under the 2013 COSO framework.
−Removed: Based on the foregoing, the chief executive officer and chief financial officer
−Removed: concluded that our Company’s disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities
−Removed: Exchange Act of 1934) were ineffective in timely alerting them to information required to be included in the Company’s periodic
−Removed: Securities and Exchange Commission filings.
+Added: As of December 31,
+Added: 2015, the company carried out an evaluation, under the supervision of and with the participation of management, including our Company’s
+Added: chief executive officer and chief financial officer, of the effectiveness of the design and operation of our Company’s disclosure
+Added: controls and procedures under the 2013 COSO framework.
+Added: Based on the foregoing, the chief executive officer and chief financial
+Added: officer concluded that our Company’s disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under
+Added: the Securities Exchange Act of 1934) were ineffective in timely alerting them to information required to be included in the Company’s
+Added: periodic Securities and Exchange Commission filings.
Changes in Internal
2 unchanged sentences
to focus on internal control over financial reporting.
−Removed: As of September 30, 2015, the Company has completed the necessary
−Removed: documentation of our internal controls and will further implement the following remedial initiatives:
−Removed: Improved design and documentation related to multiple levels of review over financial statements included
−Removed: in our SEC filings;
−Removed: Expanded design and assessment test work over the monitoring function of entity level controls;
−Removed: documentation retention policies over test work related to continuous management assessments of internal control effectiveness;
−Removed: documentation practices and policies related to various key controls to provide support and audit trails for both internal management
−Removed: assessment as well as external auditor testing.
−Removed: There were no changes in the Company’s
−Removed: internal control over financial reporting (as defined in Rule 13a-15(f) of the Securities Exchange Act of 1934) during the three
−Removed: months ended September 30, 2015 that have materially affected, or are reasonably likely to materially affect, the Company’s
−Removed: internal control over financial reporting, except as disclosed above.
+Added: As of December 31, 2015, the Company intends to further implement
+Added: the following remedial initiatives:
+Added: Improve the design and documentation related
+Added: to multiple levels of review over financial statements included in our SEC filings;
+Added: Expand the design and assessment test
+Added: work over the monitoring function of entity level controls;
+Added: Enhance documentation retention policies
+Added: over test work related to continuous management assessments of internal control effectiveness;
+Added: Expand documentation practices and policies
+Added: related to various key controls to provide support and audit trials for both internal management assessment as well as external
+Added: auditor testing.
+Added: There were no changes in the Company’s internal control
+Added: over financial reporting (as defined in Rule 13a-15(f) of the Securities Exchange Act of 1934) during the six months ended December
+Added: 31, 2015 that have materially affected, or are reasonably likely to materially affect, the Company’s internal control over
+Added: financial reporting, except as disclosed above.
Part II Other Information
2 unchanged sentences
Not applicable.
−Removed: Unregistered Sales of Equity Securities and Use
+Added: 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.