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over time, controls may become inadequate because of changes in conditions, or the degree of compliance with the policies or procedures may deteriorate.
−Removed: An evaluation of the effectiveness of these disclosure controls and procedures as of March 31, 2024 was carried out under the supervision and with the participation of management, including the PEO and the PFO.
−Removed: Based on that evaluation, the Company’s management, including the PEO and the PFO, concluded that our disclosure controls and procedures were not effective at the reasonable assurance level at March 31, 2024 due to the material weakness in the Company’s internal control over financial reporting described below.
+Added: An evaluation of the effectiveness of these disclosure controls and procedures as of June 30, 2024 was carried out under the supervision and with the participation of management, including the PEO and the PFO.
+Added: Based on that evaluation, the Company’s management, including the PEO and the PFO, concluded that our disclosure controls and procedures were not effective at the reasonable assurance level at June 30, 2024 due to the material weakness in the Company’s internal control over financial reporting described below.
Material Weaknesses in Internal Control Over Financial Reporting
−Removed: Management assessed the Company’s system of internal control over financial reporting as of March 31, 2024.
−Removed: This assessment was conducted based on the Committee of Sponsoring Organizations (“COSO”) of the Treadway Commission “Internal Control – Integrated Framework (2013).” Based on this assessment, management has concluded that the Company’s internal control over financial reporting was not effective as of March 31, 2024 due to the material weaknesses identified below.
+Added: Management assessed the Company’s system of internal control over financial reporting as of June 30, 2024.
+Added: This assessment was conducted based on the Committee of Sponsoring Organizations (“COSO”) of the Treadway Commission “Internal Control – Integrated Framework (2013).” Based on this assessment, management has concluded that the Company’s internal control over financial reporting was not effective as of June 30, 2024 due to the material weaknesses identified below.
A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of our annual or interim financial statements will not be prevented or detected on a timely basis.
Management identified a material weakness caused by improperly designed preventative controls and insufficient monitoring controls of the online credit card account opening process, which resulted in a material fraud loss during the quarter-ended March 31, 2024.
−Removed: Management identified a previously disclosed material weakness associated with ineffective input review controls relating to specific aspects of the Company’s ACL model and a previously disclosed material weakness in relation to deferred income taxes discussed in Part II, Item 9A of the 2023 Annual Report.
−Removed: Management’s assessment concluded that the deferred income tax material weakness had been fully remediated as of March 31, 2024.
+Added: Management previously disclosed a material weakness in relation to deferred income taxes discussed in Part I, Item 4 of the Company’s Form 10-Q/A for the quarter ended September 30, 2023, which has been fully remediated as reported in Part I, Item 4 of the Company’s Form 10-Q for the quarter ended March 31, 2024.
+Added: Management previously disclosed another material weakness associated with ineffective input review controls relating to specific aspects of the Company’s ACL model discussed in Part II, Item 9A of the 2023 Annual Report.
Management continues to follow its remediation plan with respect to the review of controls related to the allowance for credit losses.
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In addition, management expects to conduct a detailed data audit to effectively ensure the completeness and accuracy of select inputs to the allowance for credit losses calculation.
−Removed: We expect that the allowance for credit losses material weakness will be fully remediated prior to the end of 2024.
+Added: We expect that the allowance for credit losses material weakness will be fully remediated by the end of 2024.
Management will consider the material weaknesses remediated once the applicable controls have operated for a sufficient period of time and management has concluded, through testing, that these controls are operating effectively.
Changes in Internal Control Over Financial Reporting
−Removed: Except as described above, there were no additional changes in the Company’s internal control over financial reporting (as such term is defined by Rules 13a-15(f) and 15d-15(f) of the Exchange Act) during the first quarter of 2024 that has materially affected, or is reasonably likely to materially affect, the Company’s internal control over financial reporting.
+Added: Except as described above, there were no additional changes in the Company’s internal control over financial reporting (as such term is defined by Rules 13a-15(f) and 15d-15(f) of the Exchange Act) during the second quarter of 2024 that has materially affected, or is reasonably likely to materially affect, the Company’s internal control over financial reporting.
PART II – OTHER INFORMATION
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At the present time, there are no proceedings which the Company believes will have a material adverse impact on the financial condition or earnings of the Company.
+Added: Item 1A – Risk Factors
+Added: There have been no material changes to the risk factors as previously disclosed under Item 1A in our 2023 Annual Report, our Quarterly Report on Form 10-Q for the first quarter of 2024 and those referenced in other reports on file with the SEC.
+Added: Item 2 – Unregistered Sales of Equity Securities and Use of Proceeds
+Added: There were no repurchases or unregistered sales of the Company’s common stock, par value $0.01 per share, during the quarter-to-date period ended June 30, 2024.
+Added: Item 3 – Defaults Upon Senior Securities
+Added: Item 4 – Mine Safety Disclosures
+Added: Not applicable
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.