What changed in this filing

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Item 1B. Unresolved Staff Comments

2026-04-15 compared with 2025-04-10 · 60 added, 46 removed, 4 unchanged (96% of the section changed)

1 unchanged sentence

Cybersecurity.

Company employs internal resources and third-party service providers to manage, operate and administer our day-to-day operations, business

and affairs, subject to the direction and supervision of the Board.

The Board recognizes the critical importance of maintaining the trust

and confidence of our business partners.

The Board plays an active role in overseeing management of our risks, and cybersecurity represents

an important component of the Company’s overall approach to risk management and oversight.

The Company and its management are committed

to protecting the confidentiality of all non-public information related to the Company’s clients, shareholders and their personnel.

Management and Strategy

Company relies on its Management and employees to execute its comprehensive cybersecurity program, and has adopted a written information

security program, which is designed to address applicable requirements under Regulation S-P and the FTC Safeguards Rule .

Consequently,

the Company also relies on the processes for assessing, identifying, and managing material risks from cybersecurity threats.

The processes

include, among other things, maintaining secure digital or physical access to information assets, using manual and automated detection

methods for malicious code, due diligence of third-party vendors, and engaging a leading provider of cybersecurity services to assess

and manage cybersecurity risk.

For third-party service vendors that perform a variety of important functions for our business, we seek

to engage reliable, reputable service vendors that maintain cybersecurity programs.

of the Company’s officers and employees are subject to its policies and procedures.

The Company utilizes both internal and third-party

cybersecurity services, including threat detection and response, vulnerability assessment and monitoring, security incident response

and recovery and general cybersecurity education and awareness.

We engage in periodic assessment and training regarding the policies,

standards and practices designed to address cybersecurity threats and incidents.

Our cybersecurity risk management is integrated into

our overall enterprise risk management and shares common methodologies, reporting channels and governance processes that apply across

our enterprise risk management.

date, we have not experienced any cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially

affected the Company and we are not aware of any cybersecurity threats that are reasonably likely to affect the Company, including its

Company has implemented a written information security program designed to address the confidentiality, integrity, and availability of

information systems and the non-public personal information the Company holds on behalf of its clients and business partners.

is designed to comply with applicable requirements under Regulation S-P and the Federal Trade Commission Safeguards Rule.

Company’s cybersecurity risk management program includes the following key elements:

Detection and Response:

The Company uses a combination of automated tools and manual procedures to detect, contain, and respond

to cybersecurity threats, including malicious code detection, network monitoring, and security incident response protocols

Vulnerability

The Company engages a third-party cybersecurity service provider it believes is qualified to conduct periodic vulnerability

assessments, penetration testing, and risk evaluations of the Company’s information systems.

Vendor Risk Management:

Before engaging service providers that will access, transmit, or store Company or client data, management

performs due diligence to evaluate their cybersecurity practices.

The Company seeks to engage vendors that maintain cybersecurity

programs reasonably consistent with the Company’s own standards.

Training and Awareness:

All officers and employees are subject to the Company’s information security policies and procedures

and are required to participate in periodic cybersecurity education and awareness training.

with Enterprise Risk Management:

The Company’s cybersecurity risk management program

is integrated into its broader enterprise risk management framework and utilizes the same

common reporting channels and governance processes and the broader framework.

● Third-Party

The Company engages an external cybersecurity services provider to assist

in assessing and managing cybersecurity risks.

This provider supports threat monitoring,

incident response planning, and periodic assessments of the effectiveness of the Company’s

security controls.

Cybersecurity Incidents.

To date, the Company has not experienced any cybersecurity incident

that has materially affected, or is reasonably likely to materially affect, the Company’s

business strategy, results of operations, or financial condition.

oversees the Company’s cybersecurity risk management process.

Management has adopted a charter that provides to periodically review

and discuss with the Board the guidelines and policies with respect to risk assessment and risk management of cybersecurity and other

risk exposures relevant to the Company’s computerized information system controls and security.

Management may receive additional

training in cybersecurity and data privacy matters to enable its oversight of such risks.

Management will report to the Board on the

substance of such reviews and discussions and, as necessary, recommend to the Board such actions as management deems appropriate.

noted above, the Company relies on our internal Information Systems in connection with the Company’s day-to-day operations.

Company relies on the internal processes for assessing, identifying, and managing material risks from cybersecurity threats.

Company’s Chief Financial Officer, Chief Legal Officer, and Head of IT work collaboratively with other employees of the Company

to ensure protection of the Company’s Information Systems from cybersecurity threats and to promptly respond to any cybersecurity

These members of the Company’s management team monitor the prevention, detection, mitigation and remediation of cybersecurity

threats and incidents and report such threats and incidents to the board when appropriate.

They have gained relevant knowledge, skills

and experience in information technology and cybersecurity risk management, including overseeing third-party vendors in such areas, over

their careers at the Company or other organizations.

However, we cannot guarantee

that future incidents will not occur or will not be material.

See Part I, Item 1A., “Risk

Factors––Risks Related to Legal Proceedings and Regulatory Compliance––An

interruption in, or breach of security of, our information systems could adversely affect

Board of Directors recognizes that cybersecurity is an important component of the Company’s overall risk management framework.

The Board has delegated primary oversight responsibility for cybersecurity risk to management, which periodically briefs the Board

on the status of the cybersecurity program, material developments, and the threat environment.

Management reviews and

discusses with the Board the guidelines and policies with respect to risk assessment and risk management of cybersecurity and other

relevant risks related to the Company’s information systems.

The Board receives updates from management on cybersecurity

matters as needed or when a significant incident or emerging risk warrants attention.

Responsibility

responsibility for the cybersecurity program is managed by Jeremy Robinson, the Company’s Vice President of Information Technology,

who oversees the design, implementation, and maintenance of the Company’s information security program , including:

the prevention, detection, mitigation, and remediation of cybersecurity threats and incidents;

relationships with third-party cybersecurity service providers;

material cybersecurity threats or incidents to the Chief Executive Officer and, where appropriate, to the Board.

Company believes that Mr.

Robinson has developed relevant knowledge, skills, and experience in information technology and cybersecurity

risk management through his career in the information technology sector, including his experience overseeing third-party vendors, evaluating

security controls, and responding to information security risks.

The Chief Executive Officer is responsible for ensuring that material

cybersecurity matters are escalated to the Board in a timely manner , although Mr.

Robinson may also report material cybersecurity threats

or incidents to the Board.

Company maintains cybersecurity incident response procedures that provide a framework for identifying, assessing, containing, and remediating

cybersecurity incidents, including procedures for timely reporting to the Board and, where required, to regulators and affected individuals

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-K

Item 1B. Unresolved Staff Comments