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Nov 21, 2017 The Practice of History Essay,
No Action, Interpretive and/or Exemptive Letter: Weirton Steel Corporation. Response of the Office of Chief Counsel. Division of Essay, Corporation Finance. Incoming letters dated March 4, 2004 and Contemporary March 22, 2004. Based on the facts presented, the Division is The Practice of History, unable to gothic novels, provide the requested no-action relief regarding reports required to be filed with the Commission under Sections 13(a) or 15(d) of the Securities Exchange Act of The Practice of History, 1934. We note in this regard that an active trading market exists for the company's common stock. Specifically, despite the company's belief that there have been 5 market makers for the company's common stock, the Contemporary OTC Bulletin Board reports 17 active market makers for the company's common stock as of March 22, 2004. In addition, although not included in the company's letters, the trading volume for the company's common stock during the months preceding the letters generally ranged in the hundreds of thousands to millions of shares per day. The emphasis in The Practice of History Essay the company's letters on the minimal market value of trading rather than the extensive nature and social definition extent of trading noted above is The Practice of History Essay, inconsistent with the protection of investors, because it focuses solely on social market value rather than market interest. Any different facts or conditions might require the Division to Essay, reach a different conclusion.
Further, this response expresses the Division's position on enforcement action only and does not express any legal conclusion on the question presented. Jonathan A. Ingram. Attorney Counselor at Law. 26 Primrose Circle. Princeton, New Jersey 08540. (732) 274-9456 FAX. Office of Chief Counsel. Division of Corporation Finance.
Securities and Exchange Commission. 450 Fifth Street, N.W. Washington, D.C. 20549. Attn: David Lynn, Esq. Re: Weirton Steel Corporation, Commission File No. 001-10244.
Reference is made to Contemporary, the letter of the undersigned dated March 4, 2004 requesting from the staff, on behalf of the above registrant, no-action relief permitting modified, reduced reporting under the Securities Exchange Act of 1934 based on the circumstances described therein. After discussion, the registrant understands that its request will not be granted based on the staff's 1997 interpretation of minimal trading standards stemming from a Commission release issued almost 32 years ago. The registrant has been informed that the of History staff will not reconsider its interpretation in social definition light of the particular circumstances applicable to this case -- a minimal market value of trading in the registrant's equity securities coupled with certainty that the traded securities are valueless in the registrant's imminent bankruptcy liquidation. Essay. For its part, the registrant believes the staff's position elevates form over underlying economic substance and fails to balance costs and benefits in the best interests of all the social definition registrant's investors and other claimants. Accordingly, since it continues to believe relief is merited, the registrant has instructed me not to withdraw its request. Very truly yours, cc: William R. Kiefer, Esq. Attorney Counselor at Law. 26 Primrose Circle. Princeton, New Jersey 08540. (732) 274-9456 FAX. Office of Chief Counsel.
Division of Corporation Finance. Securities and The Practice Exchange Commission. 450 Fifth Street, N.W. Washington, D.C. 20549. Re: Weirton Steel Corporation, Commission File No. 001-10244. Ladies and Gentlemen:
On behalf of Weirton Steel Corporation, a Delaware corporation (Weirton or the Company), I hereby request, based upon the facts and circumstances discussed below, that the Staff indicate it will not recommend enforcement action to the Securities and Exchange Commission (the Commission) if the Company follows the modified reporting procedures set forth herein in lieu of social interactionism, continuing to file regular periodic reports specified under Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended (the Exchange Act), and the rules promulgated thereunder. The Company is a major integrated domestic steelmaker. It was incorporated in 1982, commenced business in The Practice of History Essay 1984 and operated as an entity wholly owned by its employees through an employee stock ownership plan until 1989. In June 1989, its Common Stock (par value $.01 per share) was registered under Section 12(b) of the designers Exchange Act and thereafter traded on the New York Stock Exchange (the NYSE). After being delisted from the NYSE, since September 2001, the Common Stock has remained registered under Section 12(g) of the Exchange Act and has traded on the OTC Bulletin Board.
As of Essay, July 31, 2003, Weirton had 42,077,327 shares of Common Stock outstanding held by approximately 3,900 stockholders (excluding participants holding stock through its ESOPs). 1. During the past three years, the domestic steel industry has been devastated by numerous adverse and Art Essays unprecedented economic developments. These have led to bankruptcies, closings, liquidations and reorganizations affecting most of the industry's productive capacity. Attempting to preserve its liquidity, solvency and long-term viability under these conditions, in 2001 and 2002, the The Practice of History Company, among other things, replaced and gothic revised its bank credit facilities, renegotiated its labor contracts, initiated force reduction, cost and vendor savings programs, restructured its publicly held debt through exchange offers and obtained pension funding relief. These events and developments were disclosed and reported, as they occurred, in the Company's regular, periodic and other filings made under the Exchange Act, as well as in its registration statements under the Securities Act of 1933 and press releases issued by The Practice Essay the Company from time to time which were not filed under the Exchange Act. In all these matters, and in fact since the time Weirton's Common Stock became registered under the interactionism definition Exchange Act, the Company has been timely in meeting its obligations to file periodic reports under the Exchange Act.
The voluntary measures taken by The Practice the Company and its employees, creditors, customers and vendors ultimately proved insufficient. On May 19, 2003, the Company filed a petition for relief under Chapter 11 of the United States Bankruptcy Code (the Bankruptcy Code) in the United States Bankruptcy Court for the Northern District of Contemporary, West Virginia (the Bankruptcy Court) (Bankruptcy No. 5:03-BK-1802) (the Bankruptcy Filing). The Bankruptcy Filing was reported in The Practice Weirton's Current Report on Form 8-K filed on May 19, 2003 and elaborated on in greater detail in its Quarterly Report on Form 10-Q for the period ended March 31, 2003 filed on May 21 2003 pursuant to The Similarities Between Islam Essay, a timely submitted Form 12b-25. Chapter 11 is the primary business reorganization resource under the Bankruptcy Code, and its fundamental objective is the consummation of a plan of reorganization looking to rehabilitate a debtor. In filing for protection under Chapter 11, it was the Company's intention to develop and implement a plan of reorganization and, upon confirmation and consummation of that plan, to of History Essay, emerge from bankruptcy as promptly as practicable. The commencement of a Chapter 11 case creates a bankruptcy estate, and the Bankruptcy Code allows a debtor to The Similarities Between and Christianity, continue to manage its business affairs and remain in possession of its property as a debtor-in-possession. In that capacity and according to orders of the The Practice of History Essay Bankruptcy Court issued from time to time, Weirton continued since the Bankruptcy Filing to operate its steelmaking and finishing business in substantially the t washington legacy same manner as before. To permit it to do so, on May 20, 2003, the Company obtained from institutional lenders (for whom Fleet Capital Corporation serves as agent) a combination revolving and term Debtor-in-Possession Credit Facility (the DIP Facility) of up to $225.0 million available for up to 18 months and secured by first liens on substantially all Weirton's assets. The DIP Facility contains significantly more stringent restrictions on The Practice Essay Weirton, including covenants requiring the attainment of improved financial performance and more numerous potential events of default, than the costume designers Company's pre-petition indebtedness, public or private. The occurrence of one or more events of default under the The Practice of History Essay DIP Facility, unless cured or waived, would permit the lenders to terminate that facility, thereby depriving Weirton of funding for working capital necessary to social interactionism, operate the business and, in all probability, causing liquidation of the debtor's assets.
Since the Bankruptcy Filing, Weirton continued making on of History Essay a timely basis all normal filings of periodic and The Similarities Between Islam current reports required under the Exchange Act, including the following: (i) Current Report on Form 8-K, May 19, 2003. (ii) Quarterly Report on The Practice of History Form 10-Q, May 21, 2003. (iii) Current Report on Form 8-K, July 8, 2003. (iv) Current Report on Form 8-K, July 21, 2003. (v) Current Report on Form 8-K, July 21, 2003. (vi) Current Report on Form 8-K, August 4, 2003. (vii) Quarterly Report on communication Form 10-Q, August 14, 2003. (viii) Current Report on Form 8-K, August 15, 2003. (ix) Current Report on Form 8-K, September 15, 2003. (x) Current Report on Form 8-K, October 16, 2003.
(xi) Current Report on Form 8-K, October 21, 2003. (xii) Current Report on Form 8-K, October 22, 2003. (xiii) Quarterly Report on Form 10-Q, November 14, 2003. (xiv) Current Report on Essay Form 8-K, November 18, 2003. (xv) Current Report on Form 8-K, December 15, 2003; (xvi) Current Report on Form 8-K, January 12, 2004; (xvii) Current Report on Form 8-K, February 3, 2004: (xviii) Current Report on Form 8-K, February 18, 2004; and. (xix) Current Report on Form 8-K, February 18, 2004. Each of the costume designers Company's periodic reports complied as to form with the Sarbanes-Oxley Act of 2002, including without limitation all certifications, which were given without exception. In addition to the periodic reports, the Current Reports on Form 8-K filed by the Company on a regular basis since August 15, 2003 have included as exhibits, where applicable, the Monthly Operating Reports (MORs) of the Company, as debtor, for each previous month required to be prepared under Bankruptcy Code rules and to be filed with the Bankruptcy Court and United States Trustee. The Practice Of History. As noted in the disclosures forming part of the current reports, although the MORs are not prepared in accordance with rules under the Exchange Act, they provide detailed financial information concerning the debtor's interim operations and other facts and gothic information related to The Practice of History, the business of interest to those with claims under the costume Bankruptcy Code. Believing that dissemination of the MORs is also in the interests of Essay, investors (who may or may not also be claimants), the Company has provided this information in Between Islam Essay connection with its Exchange Act filings. Furthermore, as matters have developed, the Company has disclosed the following material events and factors relating to the bankruptcy.
(i) On October 7, 2003 it filed an Essay, initial Plan of Reorganization with the Bankruptcy Court; (ii) On November 13, 2003, it filed a First Amended Plan of Reorganization (Reorganization Plan) with the The Similarities Between Islam and Christianity Essay Bankruptcy Court and The Practice of History Essay a Disclosure Statement to accompany the Reorganization Plan; 2. (iii) On November 13, 2003, the Emergency Steel Loan Guaranty Board (ESLGB), the federal agency which supervises a program of guaranteeing loans to qualified domestic steelmakers, conditionally approved the issuance of guarantees of indebtedness to be incurred by Weirton in connection with consummating the Reorganization Plan; (iv) On or about November 14, 2003, a group of lenders led by non therapeutic communication Fleet Capital Corporation had extended, and of History the Company had accepted, a commitment, subject to customary conditions, to provide a term and revolving financing facility (the Emergence Facility) to discharge Weirton's obligations under the DIP Facility, pay amounts required to consummate the Reorganization Plan and provide working capital for the Company following its emergence from bankruptcy as a stand alone entity; (v) That, pursuant to the orders of the Bankruptcy Court, December 12, 2003 had been established as the deadline for social interactionism impaired classes of claimants of Essay, record as of October 20, 2003 who were entitled to vote on accepting or rejecting the communication Reorganization Plan and that December 16, 2003 had been fixed by of History Essay the Bankruptcy Court as the date for the confirmation hearing on the issue of approving the Reorganization Plan 3 ; (vi) On December 8, 2003, the Company announced that the confirmation hearing before the Bankruptcy Court scheduled for December 16, 2003 would be postponed indefinitely in order to The Similarities Between Islam, permit the of History Company more time to horror novels, complete the elements necessary to consummate the Reorganization Plan, also citing favorable prospects for legislation extending the term of the ESLGB. 4. (vii) On December 10, 2003, the Company announced that it had reached an agreement with its principal union on certain temporary layoffs and The Practice of History Essay that it viewed this development as a significant step in achieving new union contracts which it regarded as necessary to consummate the Reorganization Plan and the Emergence Facility; and. As noted above, the Emergence Facility depended on obtaining ESLGB guarantees, which themselves were conditional on costume a number of factors, including reaching agreements with the Essay Company's principal union sufficient to The Similarities Between and Christianity, achieve projected labor cost savings. Weirton supplied its prospective lenders with forward-looking information, including a business plan and projections relating to its business operations and The Practice Essay financial performance. Entering into any definitive loan facility was conditioned, among other things, on substantially achieving those projections. In that regard, the projections took into account the need for Art Essays new labor agreements and other factors, including assumed levels of production, raw materials availability and costs, pricing, sales and the like. During December 2003 and January 2004, events transpired which led the Company to conclude that it could not obtain the Emergence Financing or consummate the Reorganization Plan. First, despite months of strenuous efforts on The Practice of History Essay the part of the Company to reach agreement with its principal union on new labor contracts consistent with the Between Islam and Christianity Essay projections necessary to obtain the Emergence Financing, the parties were unable to do so. Weirton's management came to The Practice of History, the conclusion that the leadership of Weirton's principal union preferred some other alternative to the stand alone Reorganization Plan.
Under those circumstances, management concluded it would not be possible for costume designers the Company to finalize the Emergence Facility (or the The Practice of History ESLGB guaranty for that matter) on the terms offered by the lenders in November 2003. Second, other factors led to a deterioration in interactionism definition the Company's business not contemplated when commitments for the Emergence Facility were issued in November 2003. On December 4, 2003, protective tariffs on steel were removed, raising substantial uncertainties concerning future import levels. Despite the concern over imports, a surging demand for steel in China appears to have dampened imports, and a significant pricing improvement has actually occurred over the past several months. However, only domestic producers who can maximize capability utilization at of History Essay reduced cost levels will benefit from non therapeutic communication techniques, that development. Unfortunately for the Company, improved costs from new labor contracts have not materialized, and, since December 2003, Weirton has faced a supply shortage of coke, an essential raw material, which has required it to reduce hot metal production for an indeterminate period of time and resort to reductions in manning and staffing levels.
5 Lack of production has translated into the inability to make sales, further eroding Weirton's customer base and adversely affecting liquidity. Based on discussions with its banks, Weirton's management concluded that the Company's business deterioration had undermined its ability to obtain the The Practice Essay Emergence Facility. Third, the Reorganization Plan required approval of the requisite classes of voting claimholders for confirmation. Weirton, at the time it postponed the scheduled confirmation hearing in the Bankruptcy Court, had not reached agreement with any of the classes of voting creditors regarding their approval of the Reorganization Plan. Thus, creditor approval remained problematic and gothic novels confirmation uncertain for reasons other than the Emergence Facility. Based on those developments, in December and January 2004, the Company's Board of Directors directed management to focus on alternative courses of action. Those consisted of disposing of the Company's assets, preferably as a whole to another steelmaker subject to the approval of the Bankruptcy Court, or otherwise in The Practice an orderly liquidation of Weirton's business.
Although not preferred, the costume possibility of these alternatives had been disclosed in Weirton's public filings. 6. On February 18, 2004, the The Practice of History Company announced that it had reached an agreement to sell substantially all its assets to social definition, a subsidiary of International Steel Group, Inc.(ISG) and entered into an Assets Purchase Agreement (the APA) to The Practice of History Essay, that effect. The event was reported by the Company publicly and a Form 8-K filed on the same date (February 18, 2004). Consistent with its obligations under the APA, the Company subsequently filed materials with the Bankruptcy Court setting in definition motion the sale process looking to consummate that agreement. Subject to of History, the operation of the booker legacy bankruptcy process, management believes the sale to ISG could be consummated sometime in April 2004. Among other things, the terms of the APA provide for reductions of employee staffing levels at of History Essay the Company prior to a closing of the transaction, and the process of non therapeutic techniques, reviewing and implementing those reductions is underway. The Company has been managing its assets as a debtor-in-possession pursuant to Sections 1107 and 1108 of the Bankruptcy Code. Of History. Beginning in December and January 2004, the definition Company shifted its efforts from reorganizing to selling its assets or otherwise liquidating its business. The APA represents the outcome of those efforts.
Therefore, the Company's bankruptcy proceeding under Chapter 11 of the Bankruptcy Code has now fundamentally changed in character. It is of History Essay, no longer the typical Chapter 11 reorganization that would result in the emergence of the gothic horror novels Company as a reorganized, ongoing operating entity. Rather, the Company effectively has become a liquidating debtor. Based on Exchange Act Release 9660 (June 30, 1972) (the 1972 Release) and Staff Legal Bulletin Number 2 (April 16, 1997) (the Bulletin), the Company proposes to discontinue filing with the Commission any further Annual Reports on Form 10-K or Quarterly Reports on Form 10-Q under Section 13(a) or 15(d) of the Exchange Act, but, in lieu thereof, to continue filing under cover of Form 8-K, copies of its MORs (including any final report) no later than 15 days after they are filed under the Bankruptcy Code and to make filings and disclosures of material events relating to the bankruptcy and otherwise as may be required from time to of History Essay, time on a current basis pursuant to Form 8-K. This modified reporting procedure would replace the periodic reports required under the Exchange Act until the liquidation of designers, Weirton is complete. At the time liquidation is being completed, the Company will (a) file a final Report on Form 8-K, (b) take appropriate steps to terminate the existence of the Company and (c) file a Form 15 to terminate its reporting obligations under the Exchange Act. In the now highly unlikely event Weirton reorganizes pursuant to Chapter 11, it will file a Form 8-K upon The Practice effectiveness of any plan of reorganization with such information (including financial statements if the annual and quarterly reports are not filed as proposed herein) as the Staff deems appropriate. Any reorganized Weirton, to the extent subject to the Exchange Act, would then comply fully with its reporting obligations for all periods commencing after release from proceedings under the Between Islam Essay Bankruptcy Code. Rationale for Requested Relief.
In the past, the Commission has agreed to the modification or suspension of the Exchange Act reporting requirements of certain issuers subject to proceedings under the Bankruptcy Code. The 1972 Release reflects the Commission's position that it will accept reports that differ in form or content from the Essay quarterly or annual reports required by the Exchange Act where the issuer is subject to communication, bankruptcy proceedings or has severely curtailed its operations so long as the The Practice modified reporting procedure provides adequate protection for investors and is not inconsistent with the public interest. The Bulletin indicates that issuers may request a no-action letter from the Staff that applies the positions in the 1972 Release to the issuer's facts. The Bulletin requires the issuer to present a clear demonstration of its inability to continue reporting, its efforts to inform its security holders and the market, and the absence of a market in its securities by responding to specific guidelines. The following paragraphs provide the required response. A. Information Regarding Disclosure of Financial Condition. 1. Whether the issuer complied with its Exchange Act reporting obligations before its Bankruptcy Code filing. The Bulletin requires that an issuer requesting relief be current in its Exchange Act reports for the 12 months before its bankruptcy filing. Weirton has been current in all its Exchange Act reports, not only for Contemporary all periods preceding the Bankruptcy Filing, but throughout the bankruptcy process itself (i.e. from The Practice Essay, May 19, 2003 to The Similarities Between Islam, date). 2. When the issuer filed its Form 8-K announcing its bankruptcy filing; whether the issuer made any other efforts to advise the Essay market of costume, its financial condition. The Bulletin requires that an Essay, issuer requesting relief timely file a Form 8-K announcing its bankruptcy.
Weirton complied with this obligation by reporting the Bankruptcy Filing in its Report on Form 8-K filed on the same day (May 19, 2003) as the Bankruptcy Filing. The Bulletin also requires a discussion of any efforts other than the filing of the Form 8-K that the social interactionism definition issuer made to inform its security holders and The Practice of History Essay the market of its financial condition. Weirton's reports and Islam Essay proxy materials filed under the Exchange Act in of History Essay 2001-2003 preceding the Bankruptcy Filing and non therapeutic its registration statements and of History Essay amendments filed under the social definition Securities Act of 1933 in 2001 and 2002 in The Practice Essay connection with exchange offers covering publicly traded debt are replete with disclosures regarding unprecedented recessionary conditions affecting the domestic steel industry, the Company's deteriorating financial condition stemming from them, the steps the t washington Company was taking or proposing to take to address such matters, and possible consequences and outcomes that could arise from alternative courses of action. These disclosures appeared regularly and multiple times in the Company's filed disclosure documents under topics ranging from Description of Business and of History Essay Risk Factors to Management's Discussion and Analysis. 7 These disclosures demonstrate that the Company has made additional substantial and continuous efforts besides giving notice of the gothic novels Bankruptcy Filing to inform its investors and the market of its financial condition and its relationship to making the Bankruptcy Filing. 3. Whether the issuer is able to continue Exchange Act reporting; whether the The Practice of History information in modified reports is adequate to protect investors. The Bulletin requires a discussion of the booker reasons why an issuer requesting relief cannot continue to comply with Exchange Act reporting, including (a) whether the issuer has ceased its operations, (b) why filing periodic reports would present an undue hardship to The Practice of History, the issuer, (c) why the issuer cannot comply with the disclosure requirements and (d) why the issuer believes granting the request is consistent with the protection of investors.
Weirton's steelmaking and finishing operations are conducted at a single site in West Virginia. Costume Designers. Substantially all the Company's facilities operating at the date of the The Practice Essay Bankruptcy Filing remain operational at present, with, however, curtailed hot metal production and reduced manning and and Christianity Essay staffing as noted. In order to pursue the alternative of The Practice of History Essay, a going concern asset sale, it was important to maintain as many of Weirton's ordinary business operations as possible and interactionism definition as its financial condition permitted. Under the of History Essay APA, Weirton is now required to horror novels, continue to operate its commercial business in the normal course until the assets are sold to ISG. Of History. The fact that Weirton's operations remain intact for social those purposes, however, does not supply a reason why the Company should be required to continue with its previous level of Exchange Act reporting. The importance is not in the temporary normality of the operations, but in the fast approaching end to which they relate. Under the bankruptcy process, Weirton will cease to operate in the short-term, possibly within weeks after its next ordinary Exchange Act periodic report is due. Moreover, while the APA focuses on operational continuity, it will also result in additional permanent staff reductions, including among the of History Company's staff normally involved with reporting and compliance.
B. Information Regarding the Market for Contemporary Art Essays the Issuer's Securities. The Bulletin requires the issuer requesting relief to discuss in detail the market for its securities. The more active the market, the less likely that relief will be granted. If the issuer's securities are traded on a national securities exchange or the NASDAQ Stock Market, the Bulletin indicates that the Commission is The Practice Essay, unlikely to grant the requested relief. Between And Christianity. The information must demonstrate that there is minimal trading in the issuer's securities. The Bulletin also requires the issuer to provide the of History Essay number of social definition, market makers for its securities and the number of trades per month for The Practice of History Essay each of the three months before the issuer's Bankruptcy Code filing and each month after the filing. The Company's Common Stock is not listed on non therapeutic techniques a national securities exchange or the NASDAQ Stock Market.
Trading in the Company's Common Stock has been available on the OTC Electronic Bulletin Board since September 2001. The Company believes there have been five market makers listed for its Common Stock, but has had no recent contact with them. Trading in the Common Stock while on the OTC Bulletin Board had been generally at volumes less than on The Practice Essay the NYSE. Gothic Horror Novels. For all of 2002, according to the Company, average daily trading volume in the Common Stock was approximately 84,500 shares. For 2003, according to information maintained by of History Essay the Company, average daily trading volumes and booker average trading prices of the Common Stock in the first four months preceding the Bankruptcy Filing were: (i) January -16,862 shares @ $0.29; (ii) February- 38,711 shares @ $0.26; (iii) March- 40,548 shares @ $0.24; and. (iv) April- 36,355 shares @ $0.17. Following the month of the Bankruptcy Filing (May), average daily volume and price for the succeeding months was as follows: (i) June- 97,010 shares @ $0.06; (ii) July- 52,741 shares @ $0.05; (iii) August- 120,343 shares @ $0.05; (iv) September- 93,857 shares @ $0.11; (v) October- 84,187 shares @ $0.08; (vi) November- 211,663 shares @ $0.07; and.
(vii) December- 386,845 shares @ $0.05. 11. While the of History above volumes for 2003 were not insignificant measured in numbers of shares traded, the penny stock levels of their prices mean that the costume designers dollar value of trading has been in fact de minimis. The Practice. For example, the average daily dollar value of trading during the balance of 2003 (June-December) was only $13,665. Excluding the artificially high peak months of costume designers, November and December 2003, the The Practice daily dollar value was a mere $9,802. At such levels, the costs of compliance with full periodic reporting, even if the Company could pay for them, seem grossly disproportionate to costume designers, any benefit. The Company maintains no records regarding trading of its Series C Preferred Stock which was issued as partial consideration in a 2002 exchange offer for senior notes. Trading in that security is believed to be minimal and sporadic. The Company believes that continued full periodic reporting will provide no protective benefit to equity investors and, as discussed below, no incremental benefit to debtholders. The Practice. As previously disclosed by gothic novels the Company, the impaired classes of claimants against the estate consisting of all holders of The Practice Essay, equity (Class 8- Preferred Stock Interests and non therapeutic techniques Class 9- Common Stock Interests) would have received no distribution under the Reorganization Plan and of History were deemed to have rejected it.
The Company has concluded that such holders will fare no better under the sale and liquidation alternative. As a result, two of the principal classes of non therapeutic communication techniques, investors whom the disclosure structure under the Exchange Act was designed to The Practice of History Essay, protect not only booker account for minimal value of trading of the most speculative nature, but are certain to The Practice of History Essay, receive nothing as a result of the bankruptcy proceeding. Under those circumstances, the Company believes it makes no sense to expend more of its scarce resources providing the same full disclosure protections (as it has for the nine ensuing months of its bankruptcy) where it furnishes no meaningful protection to investors. As noted, additionally, three issues of debt are also listed for trading on the OTC Bulletin Board. The Company maintains no records concerning their trading levels or volumes and receives only sporadic contacts from firms which are trading, or purport to be trading, such instruments.
C. The Timing of the Issuer's Request for Modification of Reporting. The Bulletin indicates that an issuer should submit its request promptly after it has entered bankruptcy. Weirton has submitted its request promptly after the change in direction of its bankruptcy case indicated to the Company that the relief it is now seeking is both necessary and merited. Prior to this point, the non therapeutic techniques Company's bankruptcy proceedings were directed primarily at restructuring and, accepting the view that disclosure could serve some useful purpose for investors and the Company's available financial resources could support its efforts, it provided full and complete Exchange Act reporting since the Bankruptcy Filing. With the need to resort to an asset sale under the of History APA and communication the current intention to liquidate, those circumstances no longer exist. In view of (a) the fact that the Company is no longer pursuing restructuring and has agreed to sell its assets, becoming a liquidating Chapter 11 debtor, (b) the enormity of the task facing the Company's limited staff in preparing MORs and other filings and pleadings with the of History Bankruptcy Court directed at obtaining approval of the sale and continuing to deal with the non therapeutic prospective acquirer and creditor representatives, (c) the limited and tenuous financial resources available to the Company, (d) the de mininmis trading values reflected in the market for the Company's Common Stock and the certitude that equity holders will not receive value from the disposition of the Company's assets from Essay, one bankruptcy alternative or another, (e) the procedural and gothic horror substantive protections through the Bankruptcy Court and The Practice Bankruptcy Code available to holders of the Contemporary Company's publicly held debt who may receive value from the bankruptcy, and of History Essay (e) the abundance of public information concerning the Company that otherwise will be available to interested parties through Bankruptcy Court filings and the modified, reduced reporting procedures proposed herein, the Company believes that the modified procedures are appropriate to its condition. Granting the relief requested herein would be consistent with the 1972 Release, the Bulletin and the Staff's prior no-action correspondence, where, as here, full compliance with the reporting requirements of the Exchange Act would pose an undue hardship, such compliance was not needed to protect and inform investors and the public, and the modified reporting procedures proposed were not inconsistent with the public interest.
See, e.g. Hauser, Inc. (July 17, 2003); Insilico Holding Co. (March 18, 2003); Laclede Steel Company (July 25, 2002); Opticon Medical, Inc. (June 28, 2002); Brazos Sportswear, Inc. (November 22, 1999); Roberds, Inc. (October 4, 2000); LA Gear, Inc. (February 27, 1998); Martin Lawrence Limited Editions (July 3, 1997); Comptronix Corporation (April 4, 1997); and Cray Computer Corporation (May 16, 1996). For the foregoing reasons, I respectfully request that the definition Staff confirm that it will not recommend enforcement action to the Commission if the of History Essay Company proceeds to modify its reporting under the Exchange Act as specified under the caption Requested Relief. The Company has advised me that it undertakes to report and perform such actions in the manner so specified. If you have any questions regarding this matter or if you need additional information, please do not hesitate to contact me at the numbers/addresses indicated above or William R. Kiefer, Esq., Secretary and General Counsel of Weirton, 400 Three Springs Drive, Weirton, WV 26062 who may be reached at (304) 797-2111 [email protected] If the Staff believes that it will be unable to respond affirmatively to definition, this request, we would like the of History Essay opportunity to costume designers, discuss with you, in advance of The Practice Essay, any formal written response, possible alternative courses of costume designers, action that the Company might pursue. Very truly yours, cc: William R. The Practice Essay. Kiefer, Esq. 1 The Company also has the following debt and equity securities registered under Section 12(g) of the The Similarities and Christianity Exchange Act: (i) 11 3/8% Senior Notes due 2004; (ii) 10 ? % Senior Notes due 2005; (iii) 10% Senior Secured Notes due 2008); and (iv) Convertible, Redeemable Preferred Stock, Series C (par value $.10 per The Practice share). All are available for Art Essays trading on the OTC Bulletin Board.
2 Among other things, the Reorganization Plan provided for cancellation of the Common Stock and all other existing equity interests in Weirton without any payment or other consideration therefor. The Disclosure Statement, which was distributed to all claimants of record in the bankruptcy, contained a detailed and The Practice of History comprehensive discussion and review of factors relating to the bankruptcy and costume the Reorganization Plan. 3 The timing of the filing of the Reorganization Plan, the The Practice Essay circulation of its related Disclosure Statement and accompanying ballots, as well as the Bankruptcy Court hearing and the emergence financing had been structured to communication techniques, accommodate the of History anticipated expiration of the authority of the ESLGB to issue guarantees on December 31, 2003 and, accordingly, to satisfy all necessary conditions to an emergence by Contemporary Art Essays that date. 4 The relevant bill became law as of January 23, 2004. 5 As the Company has disclosed in Essay its filings and reports, it is an integrated producer in communication techniques that it makes steel from raw materials (principally iron ore/pellets, coke, limestone and other minerals), but it does not own or control raw material production sources, as do several of its larger competitors. The Practice. In December 2003, a coal mine fire affecting Weirton's primary coke supplier (which is also its primary competitor in tin mill products) led that supplier to social, declare force majeure conditions and to The Practice of History Essay, put the costume Company on allocation of coke at of History Essay levels significantly below promised contract volumes. Given the worldwide shortage of coke, the cancellation of a secondary supply contract and its weak finances, the Company has been unable to replace the lost volumes. 6 According to the Disclosure Statement: The Debtor is non therapeutic techniques, also simultaneously pursuing other options with respect to its reorganization, which may include, but are not limited to, the sale of some or all of Weirton's operating assets. Of History Essay. Weirton's ability to sell some or all its assets could impact [sic] Weirton's decision to pursue its reorganization in accordance with the [Reorganization] Plan. The Company's Form 10-Q filed on November 14, 2003 also indicated this alternative possibility.
7 In the non therapeutic interest of The Practice of History Essay, conciseness, these disclosures have been characterized without a detailed listing. If the Staff requires such a listing quoting actual language, it can be furnished supplementally. 8 Continued normal periodic reporting would require retention of third party professionals for the 2003 Annual Report on Form 10-K, the next periodic report, due on March 30, 2004, at an estimated $60,000-$100,000 (presuming the Company has the internal workforce to manage such a third party process considering the headcount reductions described above and in footnote 10) beyond the t washington ordinary costs for producing, filing and disseminating such report. 9 The revolver under the DIP Facility utilizes all collections to pay down indebtedness on a daily basis and permits the of History Company, if an adequate borrowing base of gothic horror novels, inventory and receivables exists at the time and there is no default, to The Practice of History, reborrow sums for working capital purposes. Defaults under the Contemporary Art Essays DIP Facility can arise from, among other things, failure to maintain specified financial ratios and other measurements. Expenses for continued reporting, particularly where they involve costs for The Practice of History outside professionals, adversely affect such measurements and can contribute to a DIP Facility default.
10 Since the social definition Bankruptcy Filing and to The Practice of History Essay, date, the number of salaried exempt employees has been reduced approximately 24% through departures and The Similarities Islam and Christianity Essay terminations. These have included employees involved in the preparation of periodic reporting documents as well as supporting their preparation. Only two management employees regularly involved with periodic reporting documentation preparation remain at present and Essay they are heavily occupied in non therapeutic communication techniques the sale. The Company estimates that preparation of its Form 10-K in prior years has involved, on the average, several hundred hours of internal time. 11 The significant rise in trading activity in the last two months of 2003 coincided with the filing of the Reorganization Plan, the circulation of the Disclosure Statement and The Practice Essay ballots for approval of the The Similarities Between Islam plan and the securing of of History, commitments related to the Emergence Facility, during all of which time the Company was providing full Exchange Act reporting. 12 The secured pollution control bond claims arise from debt instruments issued in a 2002 exchange offer by booker t washington the City of Weirton, WV for an earlier series of unsecured pollution control bonds. The 2002 issue was secured by Company facilities on a shared lien basis with the Company's 10% Senior Secured Notes due 2008 issued in a simultaneous 2002 exchange offer made by Weirton. The latter issue is a security of the Company registered under Section 12(g) of the Exchange Act and referred to under Background.
13 The general unsecured claims include the two remaining unsecured issues of the Company's Senior Notes due 2004 and The Practice Essay 2005 registered under Section 12(g) of the Exchange Act and referred to under Background.
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analyses essay How to develop and write an analytic essay. Argument : Writing an of History Essay analytic essay requires that you make some sort of argument. The core of this argument is Contemporary Art Essays called a thesis. It is your claim, succinctly stated in a single sentence. What do budding literary critics such as yourselves argue about? You make a pervasive, persistent case that a certain thing is true about a piece of literature. The Practice? This thing should not be readily obvious to the casual reader of the literature in question. It is gothic horror what you draw out of the book or essay, how you interpret it. It is of History a claim that must be supported by Art Essays, specific evidence from the The Practice Essay text. Between Islam Essay? Thesis statement: At least once during the course of writing your essay, isolate what you consider to be your thesis. The Practice? Is your proposition both arguable and reasonable?
If it is obvious (i.e. Mary Rowlandson used the Bible for Between Essay, comfort during her captivity) you don’t have an The Practice argument. Argument requires analysis (i.e. Horror? taking things apart and explaining them). One test that may help is asking yourself what the opposite The Practice, side of Contemporary your argument would be. A good, complicated thesis (which was proposed by one of your classmates) is that Although Mary Rowlandson says she often used the Bible as a source of comfort during her captivity, a closer reading of of History her narrative suggests her faith may have been more troubled by her experience than she lets on. One useful structure for Between, writing thesis statements is the The Practice although form used above: Although x seems to t washington legacy, be true about this piece of literature, y is in fact more true (or makes our thinking about The Practice of History x more complex). In this form you present both sides of your argument at techniques once and show which side you’re on. The Practice Of History? Your job in the paper is to costume designers, convince your reader to join you. Another way to write an effective thesis statement is to use the form If we look closely at x (e.g. how Bradford defines freedom) we discover y (that ). The Practice Of History Essay? In order to find something to argue: Look for images or metaphors that the author uses consistently. What other sort of pattern can you identify in the text?
How do you interpret this pattern so that your reader will understand the definition book, essay, poem, speech, etc. The Practice Of History Essay? better? What philosophical, moral, ethical, etc. ideas is the author advocating or opposing? What are the consequences of horror accepting the author's argument? Explain how the work functions as a piece of rhetoric-- how does the author attempt to The Practice of History, convince his or her reader of something? For instance, what widely held beliefs do they use to support their argument? How do they appeal to emotions, logic… Re-examine something that the text or most readers take for granted (that Thoreau’s book Walden represents his attempt to escape from society).
Question this major premise and see where it takes you. Ask yourself if an author’s literary argument is inconsistent with itself or is in gothic horror some way philosophically dangerous, inadequate, unethical, or misleading. Examine how characters are presented in a story. How do they help the main character to develop? Which characters are trustworthy? Which are not? Why are they presented this way?
What counts as evidence: Structure : How the The Practice of History parts of the book or essay follow one another; how the parts are assembled to make a whole? Why does the author start where they start, end where they end? What is the logical progression of thought? How might that progression be intended to affect the reader What effect might this progression of ideas have on a generic reader or on a reader from the The Similarities Between Islam and Christianity Essay time period in The Practice of History which the work was written? Does the piece move from the general to the specific or vice versa? If you could divide the designers book/essay into sections, units of meaning, what would those sections be? How are they related to each other?
Note that chapters, while they form obvious sections can themselves be grouped. Referring to Essay, the text : In writing analytic papers that address any kind of literature, it is necessary to refer to the text (the specific words on the page of the book) in order to support your argument. This means that you must quote and interpret passages that demonstrate or support your argument. Quotation is Contemporary Art Essays usually stronger than paraphrase. Remember also that your purpose in writing an essay is not merely to paraphrase or summarize (repeat) what the author has said, but to make an argument about how the make their point, or how they have said what they have said. Language : includes the way an author phrases his or her sentences, the The Practice of History key metaphors used (it’s up to horror novels, you to Essay, explain how these metaphors are used, why these metaphors are appropriate, effective, ineffective, or ambiguous).
Is the way a sentence is phrased particularly revealing of the author’s meaning? Practical Essay-writing Hints: Please title your paper and make the title apt and enticing--I LOVE a good title. It puts me in a good mood before I start reading. Be clear about whether you’re writing about a book, an essay (non-fiction, short prose), a story (short fiction) a poem, a novel (book-length fiction), an autobiography, a narrative (as in Captivity Narratives) etc. Walden is a book comprised of chapters. Each of social definition these chapters could also be called an essay. Within these essays, Thoreau sometimes tells stories.
The book itself is not a story, but closer to Essay, a narrative, which is non-fiction. Always go through at least two drafts of you paper . Communication? Let your paper sit, preferably for of History Essay, 24 hours between drafts sometime during the gothic process of your writing. Eliminate first person pronoun (I) in your final draft (it’s OK for rough drafts and may help you write). If your paragraphs are more a full page or more in length it is more than likely that they are tooooooo long . Probably you have too many ideas in the air at once. Consider breaking the paragraph in half--into two smaller, but related arguments. Your reader needs a break, needs more structure in order to be able to follow your meaning. If several of your paragraphs are exceedingly short (4-5 lines), it is likely that you are not developing your ideas thoroughly enough--that you are writing notes rather than analysis. Short paragraphs are usually used as transitional paragraphs, not as content paragraphs. (Short paragraphs can be used in the rhetorical devise of reversal where you lead your reader down a certain path (to show them one side of the argument, the one you are going to oppose) and then turn away from that argument to state the true argument of your paper.) Employ quotation often. One quotation per argumentative paragraph is usually necessary. Depending upon the length and complexity of the passage or topic you're dealing with, more quotations may be useful to prevent you from The Practice Essay getting too far away from the text.
Your quotations combined with your interpretations are your proof. Be sure that you show your reader how they should interpret these quotations in order to follow your argument. (Almost every quotation should be followed by Contemporary, an interpretation, a deeper reading of what is being said and how its being said. Essay? This interpretation demonstrates how the quotation supports the claim you're making about Contemporary Art Essays it). Pay attention to The Practice of History Essay, metaphor, phrasing, tone, alliteration, etc. How is the author saying what they are saying--what does that teach us about the text? Remember to write directive (sometimes called topic) sentences for your paragraphs . Designers? The first sentence of of History any paragraph should give your reader an idea of what the paragraph is going to say and how the paragraph will connect to the larger argument.
It should have more to do with what you have to say about the materials than what the author him or herself has said. Transitions between paragraphs : try to t washington, get away from using The next, First of all Another thing. to connect your paragraphs. The Practice Of History Essay? This is the list method of structuring a paper--not an integrated, logical approach. A really strong transition makes the logical connection between paragraphs or sections of Contemporary a paper and gives the reader a sense that you’re building an argument. To make sure you are making a well-connected argument, ask yourself how the last sentence of each paragraph and the first sentence of the next are connected. Each of the sentences within your paragraphs should be related somehow (follow from, refer to, etc.) the one that precedes it, and Essay the one which follows it. This will help the The Similarities and Christianity Essay reader follow the flow of your ideas.
The order of your paragraphs should reveal a developing argument. On the most basic level, you should be able to consciously justify the presence and placement of every word in The Practice of History Essay every sentence, every sentence in every paragraph, every paragraph in every essay . To repeat: in revising your papers after the first draft (which is always, inevitably to some degree confused because you are involved in the process of working your ideas out), you should be highly conscious of what you are doing and social definition why you are doing it.
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Nov 21, 2017 The Practice of History Essay,
Auditing advantages and limitations. The review of saving money organizations assumes an imperative part in India as it manage the saving money organizations in right way. In review of banks incorporates different sorts of review which are ordinarily completed in The Practice of History, saving money organizations, for example, statutory review, income/wage use review, simultaneous review, PC and framework review and so on the above review is social definition, principally directed by the banks own staff or outside reviewer. Be that as it may, the tenets and the regulation identifying with the behavior of different sorts of review or assessments vary from a bank to bank expect the statutory review for which the RBI rules is pertinent. In this, I have given more significance on the general bank review framework. In today’s focused world review is all that much vital and in of History, addition obligatory , in light of the fact that speculator contributing choice is rely on upon that specific idea if evaluator has communicating his perspective about specific association is costume designers, genuine and reasonable then financial specialist can get his thoughts regarding the amount he ought to The Practice put resources into specific organizations. ORIGIN AND EVOLUATION OF AUDITING. 1) Origin of term : The term review is gotten from the Latin expression “audire” intend to listen. In right on time days, an evaluator used to leaning to the record read out by the bookkeeper keeping in mind the end goal to check them.
2) Ancient origin : Examining is as old as bookkeeping. Art Essays! It was being used in every single old countrie, for example, Mesopotamia, Egypt, Greece, Rome, U.K., and India. The Vedas,Ramayana, Mahabharata contain references to bookkeeping and inspecting. Arthashasastra by Kautilya gives nitty gritty principles for bookkeeping and evaluating of of History open accounts. The Mauryas, the Guptas and the Mughals had created and bookkeeping and evaluating framework to control state accounts. In this manner, fundamentally, bookkeeping and examining had their starting point in the requirement for the legislature to control the wage and consumption of the state and the armed force.
The first question of reviewing was to distinguish and avoid mistakes and cheats. 3) Compulsory audits of companies: With expanding number of organizations, the organizations’ demonstrations in diverse nations started accommodating mandatory review of records of organizations. Accordingly U.K. review of records of restricted organizations got to be obligatory in 1900. Art Essays! In India, the of History Essay organizations demonstration, 1913 made review of organization records mandatory. Non Therapeutic Communication Techniques! With expansion in size of organizations, the object of review likewise moved to of History Essay discovering whether the records were “genuine and Between Islam and Christianity Essay reasonable” as opposed to “genuine and right”. In this manner, the accentuation was not arithmetical precision but rather on reasonable representation of The Practice of History budgetary undertakings. 4) Development of accounting and auditing standard: The global bookkeeping measures advisory group and the bookkeeping guidelines leading body of foundation of contracted bookkeeper of India have created standard bookkeeping and examining practices to direct the bookkeepers and reviewer in their everyday work. 5) Computer technology: The most recent improvement in evaluating relates to the utilization of PCs in bookkeeping and in addition reviewing.
Truly, reviewing has make some amazing progress from “listening to” the records in the antiquated day to utilizing PCs to legacy inspect mechanized records of today. DEFINITION OF AUDITING. ‘ Different persons, for example, the proprietors, shareholders, financial specialists, loan bosses, moneylenders, government and so on The Practice of History Essay utilize the novels last record of The Practice of History Essay business sympathy toward diverse purposes. Every one of these clients should make certain that the last records arranged by booker t washington, the administration are dependable. An inspector is an autonomous master who looks at the records of a business concern and reports whether the last records are dependable or not.
Diverse powers have characterized inspecting as takes after. ‘ Mautz characterize the inspecting as “reviewing is worried with the check of bookkeeping information, with deciding the exactness and dependability of bookkeeping explanation and reports”. ‘ International auditing guidelines characterizes the inspecting as “evaluating is an autonomous examination of budgetary data of any substance with a perspective to communicating a sentiment consequently”. ‘ BASIC PRINCIPAL OF AUDITING: 1) Integrity, objectivity and independence: The examiner ought to of History be straightforward and earnest in his review work. He must be reasonable and objective. He ought to additionally be free.
2) Confidentiality: The evaluator ought to keep the social data acquired amid review, private. He ought not reveal such data to of History Essay any outsider. He ought to, keep his eyes and ears open yet his mouth close. 3) Skill and competence: The auditor should have adequate training, experience and competence in communication techniques, Auditing. He should have a professional qualification ( i.e. be a Chartered Accountant) and practical experience. He should be aware of recent developments in the field of auditing such as statement of ICAI, changes in company law, decisions of courts etc. 4) Working papers: The evaluator ought to keep up working papers of vital matters to of History demonstrate that review was led with due consideration as indicated by the fundamental standards. 5) Planning: The inspector ought to The Similarities Between and Christianity arrange for his review work. He ought to set up a review modified to finish the review productively and in time.
6) Audit evidence: The report of the The Practice of History Essay reviewer ought to be base on confirmation got over the span of review. The proof may be acquired through vouching of exchanges, check of advantages and liabilities, proportion investigation and so forth. 7) Evaluation of accounting system and internal control: The inspector ought to guarantee that the bookkeeping framework is satisfactory. He ought to see that all the exchange have been appropriately recorded. Contemporary Art Essays! He ought to think about and assess the Essay inner controls.
8) Opinion and report: The examiner ought to touch base at his sentiment on the record in light of the review prove and present his report. The feeling may be inadequate, qualified or unfavorable. The review report ought to obviously express his sentiment. Law ought to require the substance and type of The Similarities Islam Essay review report. One of the elements of this board of trustees is to The Practice of History Essay give guidance and Contemporary manages the operations of the aggregate review capacity in the bank.
The council additionally needs to audit the inward examination capacity in the bank, with extraordinary accentuation on the framework, its quality and adequacy as far as postliminary. The board needs to survey the The Practice of History arrangement of arrangement and compensation of Between and Christianity simultaneous examiners. The review board of trustees is, in The Practice Essay, this way, joined with the working of the arrangement of simultaneous review. The technique for arrangement of evaluators, their compensation and the nature of their work is to be checked on by the Audit Committee. It is in this connection that periodical meeting by horror, the individuals from the review board of trustees with the simultaneous examiners help the review advisory group to manage the operations of the aggregate review capacity in the bank. ADVANTAGES OF AUDITING. 1) Assurance of true and fair accounts: Review gives a certification to the different clients of conclusive records, for example, proprietors, administration, leasers, moneylenders, financial specialists, government’s and so on The Practice of History that the records are genuine and reasonable. 2) True and Fair balance sheet: The client records can make sure that the advantages and liabilities appeared in the examined monetary record demonstrate the worry, as it is i.e. neither more nor less. 3) True and gothic novels fair profit and loss account:
The client can be sure that the inspected benefit and misfortune record demonstrates the genuine measure of benefit or misfortune as it is i.e. neither more nor less. 4) Tally with books: The reviewed last record can be brought to The Practice count with the books of records. In this way, the wage assessment officer can begin with the figure of examined books benefit, make modification and register the assessable salary. An outside client need not experience the whole books. 5) As per standard accounting and t washington legacy auditing practices: The examined last records take after the standard bookkeeping and evaluating standards set around expert bodies. Subsequently, inspected records depend on goals standard and not on individual impulses and fancies of a specific bookkeeper or inspector.
6) Detection and prevention of errors and frauds: Examined records can be accepted sensibly free from blunders and fakes. The evaluator with his master learning would take due consideration to see that Errors and cheats are identified so that the records shoe a genuine and reasonable perspective. 7) Advice on Essay system, taxation, finance: The evaluator can likewise prompt the customer about the bookkeeping framework, inside control, interior check, inner review, tax assessment, accounts and so on. LIMITATIONS OF AUDITING. 1.An examiner can’t check every last exchange he needs to check just the chose zones and exchange on an example premise. 2.Audit proof is not convincing in gothic novels, nature accordingly affirmation by The Practice Essay, an indebted person is not definitive confirmation that the Contemporary Art Essays sum will be gathered. Of History! It is said proof is Essay, instead of convincing in nature. 3.An examiner can’t be relied upon to find profoundly laid cheats as a rule includes acts intended to cover them, for example, imitation , chaste inability to record exchanges, false clarification and thus are hard to recognize. 4.Audit can’t guarantee the clients of record about the future gainfulness, prospects or the productivity of the of History Essay administration.
5.An examiner needs to depend upon master inspector may need to depend on master in related field, for Contemporary example, legal counselors, architects, esteem’s and so on for evaluating unforeseen liabilities, valuation of settled resources and Essay so forth. INTERNAL CONTROL IN CERTAIN SELECTED AREAS. ‘The staff and officer of a bank ought to lift structure one position to another often and without earlier notice. ‘The work of one individual ought to dependably be checked by someone else in the ordinary course of business. ‘All arithmetical precision of the book ought to be demonstrated autonomously consistently. ‘The mark book of the telegraphic codebook ought to be kept with capable officers, utilized, and seen by approved officers just. ‘The bank ought to take out protection strategies against misfortune and representatives unfaithfulness. ‘Cash ought to be kept in the joint authority of interactionism definition two capable individuals.
Bill of The Practice of History collection: ‘All archives going with the bill ought to be gotten and entered in the register by costume designers, a mindful officer. All the season of dispatch, the officer ought to likewise see that all archive sent alongside the bills. ‘The record of clients or principals ought to be credited when bills have been gathered or an exhortation to that impact got structure the branch or operators to of History Essay which they were sent for accumulation. ‘It ought to be guaranteed that bills sent by one, branch for accumulation to another branch of the bank, are not in the gathering twice in communication techniques, the amalgamated monetary record of the bank. For this reason, the accepting branch ought to The Practice of History Essay switch the passages, for example, bills toward the end of the getting branch toward the end of the year fir shutting pur.
‘At the season of obtained of bill, an officer ought to check that all the archive of costume designers titles are legitimately doled out to the bank. ‘Sufficient edge ought to The Practice Essay be kept while obtained or reducing a bill to The Similarities Between Islam Essay cover any decrease in Essay, the estimation of the security and techniques so on. ‘If the bank is not able to gather a bill on the due date, promptly step ought to be taken to recuperations the sum shape the drawer against the security gave. ‘All sporadic remarkable record ought to of History be accounted for to the head office. ‘In the instance of non therapeutic communication techniques obtained exceptional at the end of the year rebate got subsequently ought to consequently ought to be appropriately allocated betw. Loan and advances: ‘The bank ought to make propels strictly when fulfilling itself as to the financial soundness of the borrowers and subsequent to getting assent from the correct powers of bank. ‘Sufficient edge ought to be kept against securities taken to cover any decrease in the quality thereof furthermore to The Practice of History agree to legitimate powers of mandates.
Such edge ought to be dictated by the correct powers of the bank as a general approach or for communication specific recor. ‘All the securities ought to be gotten and returned by mindful officer. They ought to be kept in the joint authority of two such officer. ‘In the of History instance of good possessing the bank, substance of the bundle ought to be test checked at the season of receipt. ‘Surprise check ought to be made in admiration of hypothecated merchandise not in the ownership of the legacy bank. ‘Market estimation of good ought to be checked by The Practice Essay, officer of the bank by individual enquiry notwithstanding the receipt to the receipt quality given by the borrowers. ‘All record ought to be kept inside both the designers drawing force and The Practice of History as far as possible at all times.
‘ The signature on demand draft should be checked by an officer with signature book. ‘ All the social interactionism definition best demand draft sold by should be immediately confirmed by of History Essay, the advice to the branches concerned. Inter branch account: ‘The record ought to be balanced just on the premise of utilization with sensibly great credit evaluation. ‘Prompt move ought to be made ideally by focal powers, if any passages are not sensibly time. ‘There ought to be compelling screening of utilization with sensibly great credit appraisal.
‘There ought to be strict control over capacity and issues of card. ‘There ought to Contemporary be arrangement of brief reporting by the vendor of all settlement acknowledged by them through Visas. ‘Reimbursement to vendors ought to be made strictly when check of the legitimacy of dealer acknowledgment of card. ‘All the repayment ought to The Practice Essay be made promptly charged to designers the clients account. ‘There ought to be a framework to screen and catch up client installment. STAGES IN AUDITING.
1) Preliminary work: a) The auditor should acquire knowledge of the Essay regulatory environment in which the bank operates. Thus, the auditor should familiarize himself with the relevant provisions of non therapeutic communication applicable laws and ascertain the scope of his duties and Essay responsibilities in accordance with such laws. He should be well acquainted with the provisions of the Banking Regulation act, 1956 in Between and Christianity, the case of audit of a banking company as far as they relate of The Practice of History preparation and presentation of financial statements and their audit. b) The auditor should also acquire knowledge of the economic environment in which the bank operates. Similarly, the auditor needs to t washington acquire good working knowledge of the services offered by the bank. The Practice Of History Essay! In acquiring such knowledge, the auditor needs to be aware of the many variation in the basic deposit, loan and treasury services that are offered and communication techniques continue to be developed by The Practice of History Essay, banks in response to market conditions. To do so, the auditor needs to understand the nature of services rendered through instruments such as letters of interactionism definition credit, acceptances, forward contracts and other similar instruments. I. Obtaining internal audit reports, inspection reports, inspection reports and concurrent audit reports pertaining to the bank/branch. II.
Obtaining the latest report of The Practice of History Essay revenue or income and expenditure audits, where available. III. Gothic! In the case of branch auditors, obtaining the report given by the outgoing branch manager to the incoming branch in the case of change in incumbent at the branch during the year under audit, to the extent the same is relevant for the audit. c) RBI has introduced and offsite surveillance system for commercial banks on various aspects of The Practice of History Essay operations including solvency, liquidity, asset quality, earnings, performance, insider trading etc., and has indicated that such reports shall be submitted at periodic intervals from the year commencing 1-04-1995. Islam And Christianity Essay! It will be appropriate to be familiar with the reports submitted and to review them to the event that they are relevant for of History Essay the purpose of audit. d) One set of tests that the Contemporary Art Essays auditor at both the branch level and The Practice Essay head office level may apply for audit of booker t washington banks in analytical procedure. 2) Evaluation of internal control system:
It might be noticed that exchange in banks are voluminous and dreary, and fall into constrained classes/heads of record. It might, in this manner, be more proper that the assessment of the inward control is made for every class/classification of exchange. On the off chance that the activity of interior control assessment is legitimately done, it help the evaluator to The Practice decide the adequacy or generally of the Art Essays control frameworks and in like manner empower him to reinforce his review methodology, and lay fitting accentuation on the danger inclined ranges. Interior control would incorporate bookkeeping control regulatory controls. Bookkeeping controls spread regions straightforwardly worried with recording of monetary exchanges and upkeep of such registers/records as to The Practice of History guarantee their unwavering quality. Inward bookkeeping controls are additionally visualizing such systems as would decide obligation and fix responsibility as to protecting of the advantages of the bank. It would not be strange of notice that there is a qualification between bookkeeping framework and social definition inside bookkeeping controls. Bookkeeping framework conceives the preparing of the Essay exchange and occasions, their acknowledgment, and fitting recording.
Inward controls are strategies, technique and methods so outlined and normally incorporated with frameworks, as would empower aversion and in addition location of blunders, oversights or abnormalities during the time spent execution and recording of exchange/occasions. The inside bookkeeping controls as would guarantee aversion of blunders, exclusions and inconsistencies would incorporate after: I. No exchange can be enrolled/recorded unless it is authorized/affirmed by booker, the assigned power. II. Built-in double control/supervisory systems guarantee that there is an autonomous programmed keep an eye on information/vouchers. III. No single individual has power to start exchange and record through all stages to the general record. Every day exchanges are precisely and instantly recorded, and the control and The Practice of History Essay auxiliary records are kept adjusted through staff autonomous of one another. The reviewer would be all around encouraged to investigate different zones may prompt location of mistakes, oversights and anomalies, entomb false name in interactionism, the accompanying: I. Missing/loss of security paper, stationery shapes. II.
Accumulation of exchanges/equalizations in ostensible heads of records like anticipation, sundries, between branch accounts, or other ostensible head of records especially if there records especially if these records are broadly used to adjust books, in spite of accessibility of data. III. Accumulation of old/vast unexplained/unverified sections in records with Reserve Bank of India and The Practice of History different banks and organizations. IV. Transaction spoke to by minor book conformities not prove/substantiated or upon non-respecting of horror agreements/responsibilities. V. Origination charges I head office records/between branch accounts.
VI. Analytical audit methodology. VII. Serious inconsistencies pointer out in inward review/assessment/exceptional review. VIII. The Practice Essay! Complaints/matters pending in the cautiousness/grievances cell, as respects inconsistencies in records of constituents, and so on. IX. Results of occasional scientific survey, if saw as antagonistic. a) Administrative control:
These are extensively worried with the choice making process and setting down of power/designation of forces by the administration. It might be noticed that in the typical course, the head office utilize the zonal/territorial workplaces don’t direct any saving money business. They are for the most part in charge of authoritative and approach choices which are executed at the branch level. 3) Preparation of review system for substantive testing and its execution. Having acquainted him the necessities of review, the reviewer ought to set up a review program for substantive testing which ought to sufficiently cover the extent of his work.
In surrounding the social definition review program, due weightage ought to be given by the evaluator to territories where, in his perspective, there are shortcomings in the inward controls. The review program for the statutory inspectors would be not the same as that of the branch reviewer. At the branch level, essential keeping money operation are to be secured by the review. Then again, the Essay statutory evaluators at the head office (procurements for tip, official records, and so on.). The extent of the work of the statutory inspectors would likewise include managing different bookkeeping angles and exposure necessities emerging out of the branch returns. 4) Preparation and accommodation of review report. The branch reviewer advances his report to the statutory inspectors who need to manage the same in such way, as they considered vital. It is attractive that the branch evaluators’ reports are satisfactorily in unambiguous terms. Beyond what many would consider possible, the money related effect of all capability or unfriendly remarks on the branch records ought to be obviously gotten out the branch review report. It would help the statutory reviewers if a standard example of reporting, say, head savvy, starting with resources, then liabilities and from that point things identified with pay and use, is taken after. In setting up the review report, the evaluator ought to remember the idea of materiality.
In this way, things which don’t really influence the perspective introduced by the monetary articulations may be overlooked. Be that as it may, in the judgment of the inspector, a thing however not material, is in gothic horror novels, opposition to bookkeeping standards or any declarations of the Institute of Chartered Accountants of India or in, for example, would require a survey of the important technique, it would be suitable for him to draw the consideration of the administration to this angle in his long shape review report. BOOKS OF ACCOUNTS OF BANKS. A managing an account organization is required to The Practice keep up the books of records as per techniques sec.209 of the organizations demonstration. There are, in any case, certain goals in saving money business they are the prerequisites to keep up precise and dependably a la mode account. The Practice Of History Essay! Banks, in this manner, gadget their bookkeeping framework to suit these prerequisites. The fundamental attributes of a banks arrangement of accounting are as per the following: passages in the individual records are made specifically from vouchers as opposed to designers being posted from the books of prime section. A.The vouchers went into distinctive individual records every day are condensed on summery sheet; the sums of each are presented on the control accounts in the general record.
B. The general record trail equalization is extricated and concurred each day. C. A trial equalization of the nitty gritty individual records is arranged intermittently, normally at regular intervals, and concurred with the general record control accounts. PRINCIPAL BOOKS OF ACCOUNT. It contains control records of every single individual record, the benefit and of History Essay misfortune account and distinctive resources and liabilities accounts. There are sure extra records known as contra records, which is novel element of bank bookkeeping. These contra records are kept up with a perspective to keeping control over exchanges, which have no immediate impact on the banks positions. For e.g. letter of credit opened, bills got for legacy accumulation, certification is given and so forth. ‘ Profit and Loss ledgers; A few banks keep one record for benefit and misfortune in this general record and kept up particular books for the definite records. These are columnar books having separate segments for every income receipt and cost head.
Different banks keep separate books for charges and attributes presented are entered in on the benefit and misfortune account in of History Essay, the general record. SUBSIDIARY BOOKS OF ACCOUNTS. Separate records are kept up by banks for costume designers distinctive sorts of records, i.e. current record, sparing record, and so on. As has been looked after before, these records are posted straightforwardly from vouchers and the whole voucher entered in every record in a day are compressed into Voucher Summary Sheets. Subtle elements of diverse sorts of bills are kept in particular registers, which have suitable sections. For e.g. bill acquired, internal bill for accumulation, outward bills for of History gathering and so forth are entered serially everyday in isolated registers. Sections in these registers are made by reference to the first archives. ‘ Other subsidiary registers: There are diverse registers for different sorts of exchange.
Their number, volume and subtle elements, which vary as indicated by costume designers, the individual needs of every bank. Of History! For instance, there will be registers for: A. Demand drafts, telegraphic and mail exchanges issued on branches or organizations. B. Demand drafts, telegraphic and mail exchanges got from branches and organizations. C. Letters of credit.
D. T Washington Legacy! Letter of surety. Every division of bank keeps up a diary to take note of the The Practice exchange sections went by it. Definition! These diaries are memoranda book just, as every one of the passages made there are likewise made in the daybook, through voucher synopsis sheets. The reason for existing is to keep up a record of all exchange passages started by every division. ‘ Other memoranda books: ‘ Besides the Essay book specified above, different divisions of a bank need to say various memoranda books to encourage their work. A percentage of the critical books are depicted beneath: o Receiving clerks money book. o Paying clerks money book. o Main money book. A man checks the vouchers and rundown with the clearing checks got books. The voucher are then sent to proper offices, where clients record are instantly credited. Ordinarily no drawings are permitted against clearing checks stored that day however special cases are regularly made by the director on non therapeutic techniques account of set up client.
Checks got are check with the going with rundown. These are then disseminated to varied division and number of checks given to every office is noted in a notice book. At the point when the checks are passed and presented in on record, there number is autonomously concurred with the of History notice book. On the off chance that the The Similarities Between Islam checks are discovered unpayable, they are come back to clearing house. ‘ Loans and overdrafts departments: a) Registers for shares and different securities hung in the interest of its client. b) Summary books of securities give in points of interest of of History Essay government securities. c) Godown registers kept up by techniques, the Godown managers of bank. d) Overdraft approval register.
e) Drawing force book. f) Delivery request books. g) Storage books. a) Account opening and shutting registers. b) Fixed stores rate register. c) Due date dairy. d) Specimen mark book. a) Salary and partnered registers. b) Register of Essay altered resources. c) Stationary registers.
d) Old record registers. a) Signature books of bank officers. b) Private telegraphic code and figures. In a few circumstances, the inspector may find that sure bookkeeping and different records are not up and coming. In such a circumstances, the booker examiner ought to first determine the degree of unpaid debts in housekeeping and of History the territories in which bookkeeping and different records are not a la mode. Between Islam And Christianity Essay! It might likewise be noticed that in Long Form Audit Report (LFAR0), the examiner needs to mention point by point objective fact on such overdue. VERIFICATION OF ASSETS AND LIABILITES. Capital and Liabilities: The accompanying particulars must be given in appreciation of offer capital in a critical position sheet. ‘ For nationalized banks.
The capital claimed by focal government as on the date of accounting report including commitment from government, if any, for The Practice of History Essay support in world bank venture ought to be appeared. ‘ For banks incorporated outside India. Capital (the sum got by banks by method for start up capital as endorsed by RBI appeared under this head) Measure of store kept with RBI under segment 11(2) of the managing an account regulation act, 1949. The inspector ought to check the opening equalization of capital with reference to the evaluated asset report of the earlier year. On the off chance that there has been expansion in capital amid the year, the evaluator ought to look at the pertinent reports supporting the increment. For instance, in the event of a build an approved capital of a managing an account organization, the evaluator ought to Between analyze the extraordinary determination of shareholders and the reminder of affiliation. 2) Reserves and surplus:
The accompanying are required to be unveiled in a critical position sheet under the head ‘Stores and Surplus’. a) Statutory holds. b) Capital holds. c) Share premium. d) Revenue and different stores. e) Balance in benefit and misfortune account. The evaluator ought to The Practice confirm the Between Islam opening equalizations of different stores with reference to the examined asset report of the earlier year. Expansion to or reasonings from stores ought to additionally be confirmed in the typical way, e.g. with reference to board determination.
On account of statutory saves and share premium, consistence with lawful necessities ought to additionally be analyzed. Stores are required to be grouped in a critical position sheet under the accompanying heads. A. I. Interest Deposits. II. Sparing Bank Deposits. I. The Practice! Term Deposits. B. Interactionism Definition! I. Stores of Branches in India. II.
Deposits of The Practice Branches outside India. The reviewer may check sorts of stores in the accompanying way. I. Costume Designers! Current account: The inspector ought to check the equalizations in individual records on an examining premise. He ought to likewise look at whether the parities according to backup records count with the related control accounts in the general record. II. Saving bank deposits:
The evaluator ought to check the equalizations is individual record on an examining premise. He ought to likewise analyze whether the equalizations according to auxiliary records count mind the The Practice of History Essay related control accounts in the general record. III. Term deposits: Term deposits are deposits repayable after a specified period. They are considered time liabilities of the social definition bank.
The auditor should verify the The Practice of History deposits with reference to the relevant registers. The auditor should also examine, on a sampling basis, the registers with the counter-foils of the receipts issued and The Similarities with the discharged receipts returned to Essay the bank. IV. Deposits designated in Contemporary Art Essays, foreign currencies: On account of stores assigned in an outside money, for e.g. outside coin non-occupant stores, the inspector ought to look at Essay whether they have been changed over into Indian rupees at the rate told for his sake by the head office.
V. Interest accrued but not due: The inspector ought to analyze that hobby collected yet not due on costume designers stores is excluded under the kept but rather is appeared under the head ‘different liabilities commercial procurement’ Borrowings of a bank are required to be appeared in monetary record as takes after. I. Borrowing in India. a. Reserves Bank of India. c. Other establishment and The Practice organizations. II. Interactionism! Borrowing from RBI, different banks/budgetary foundation and The Practice Essay so forth ought to be checked by the inspectors with reference to affirmation certificated and other supporting record, for example, understandings, correspondence and so on. The examiner ought to likewise analyze whether a reasonable qualification has been made in the middle of “rediscount” and “renegotiate” for divulgence of the sum under the above head subsequent to rediscount does not figure under this head. Other current liabilities: The third calendar to the managing an account Regulation act, 1949, requires exposure of the booker legacy accompanying things under the Essay head ‘different liabilities and procurement’ ‘ Inter office changes.
‘ Other (counting procurements) The evaluator may check the different things under the head different liabilities and procurement in the accompany. Charges payable speak to instrument issued by the farm against cash got from clients, which are to be paid to the clients or according to his request. These incorporate Demand Draft, Telegraphic Transfer, and Mail exchange and Mail Transfer, Traveler checks, Pay request, Banker checks, and comparable instrument issued by the bank however not displayed for horror installment until the The Practice of History Essay asset report date. Inter office adjustment: The adjusted in t washington, official conformity account, if in The Practice, credit, is to be appeared under this head. As per the notes and booker t washington directions for The Practice of History Essay gathering of Art Essays monetary record and benefit and misfortune record, issued by the Reserve Bank of India, the accompanying things are to be incorporated under this head. ‘ Net procurement for money assessment and The Practice of History different expenses like premium duty, less advances installment and duty deducted at interactionism source. ‘ Surplus in total in procurement for terrible and The Practice of History dicey obligations procurement account. ‘ Proposed profit/exchange to govt.
Cash, bank balanced and money at call and short notice: The third calendar to the Banking Regulation act, 1949, requires taking after divulgence to the be made in the made to be determined sheet in costume designers, regards to money, parities with Reserve Bank of India., equalization with other bank, and cash at call and short notice. Cash and balance with Reserve Bank of India. I. Cash close by (counting remote coin notes) II. Balance with Reserve Bank of India. a) In current record. b) In other record.
Adjusted with banks cash at call and short notice. A) Balanced with banks. 1. In current record. 2. In different stores account. B) Money at call and short notice.
2. Of History! With different foundations. II Outside in India. 1. Booker Legacy! In current records. 2. The Practice Of History Essay! In different stores account. 3. Money at call and short notice.Cash Reserved: Deposits by foreign banking company: Area 11(2) of the demonstration requires the managing an account organizations joined outside India to store with RBI certain sum either in trade or out unrestricted securities or mostly in trade and somewhat out designers, such securities. The reviewer ought to check the speculation scripts physically at Essay the end of Between Islam business on the date of accounting report. In outstanding situations where physical check of speculation scripts on the accounting report date is unrealistic the inspector ought to complete the physical confirmation on an ought to take into thought any alteration for resulting exchange of procurement, deal and so forth he ought to take specific consideration to see that just bona fide venture are delivered before him. In completing of review of advances, the evaluator of advances, the reviewer is basically worried with getting proof about The Practice after. a) Amount incorporated into accounting report in appreciation of advances are exceptional at the date of monetary record.
b) Advances speak to sum because of the bank. c) There are no unrecorded advances. d) The inspector ought to audit the operation different advances accounts. In doing a review of altered resources, the evaluator is booker, concerned principally with getting confirmation about their presence and valuation. The branch reviewer ought to find out whether the records in The Practice of History, admiration of premises and/or other settled resources are kept up at the branch or halfway. Essentially, he ought to find out the gothic area of archives of title or different reports confirming responsibility for things of Essay altered resources.
The inspector ought to check the opening parity of premises with reference to gothic calendar of settled resources, record or altered resource register. The rule requires the banks to characterize their advances in four general classes as takes after:- 1. Standard resource:- A standard resource is one, which does not reveal any issues, and of History which does not convey more than typical danger joined to the business such resource is not a non-performing resource. 2. Sub-standard resource: It is one, which has been delegated N.P.A. for period not surpassing not over year and a half. 3. Doubtful resource: It is one, which remained has N.P.A for period surpassing year and horror a half. 4. Loss resource: It is one where the misfortune has been distinguished by the bank or the inner or outer evaluators or the RBI investigation, however the sum has not been composed off entirely or incompletely at the end of the day such resource is viewed as uncollectible and of such little esteem that its consistent as bankable resource is not justified through in spite of the fact that there may be some rescue or recuperation esteem. With the Essay perspective to moving towards worldwide based practices and to Contemporary Art Essays guarantee more prominent transference it has been chosen to receive the 90 days late standards for recognizable proof.
Of N.P.A. from the year finishing 31st March 2004, agreeing with impact from 31st walk 2004, a non-performing resource should be an advance or advances where, i. Interest and portion of The Practice of History standard stays past due for the time of over 90 days in appreciation of term credit. ii. Contemporary Art Essays! The record stays out of request for time of over Essay, 90 days. In appreciation of overdraft or money credit limit. iii. The bill stays past due for time of over 90 days on account of bills acquired and non therapeutic communication marked down.
iv. Interest and portion of guideline stays late for two harvest season however not surpassing 2.5 years on account of cutting edge allowed for The Practice of History horticulture reason. v. Horror Novels! Any add up to be gotten stays past due for a time of over 90 days in of other record. A portion of the Exemptions are their as takes after, i. Project money: On account of bank, money given for modern task or for farming status where ban period is The Practice, accessible for installment of premium, installment of premium gets to be expected after the ban period is over and not on techniques the date of The Practice of History charge of premium. ii. The Similarities Between And Christianity! Agricultural Advances Affected by Natural Calamities: As far as RBI direction where Natural cataclysms in fairs the reimbursement limit of farming borrower the bank can change over fleeting generation credit, into term advance or reschedule the reimbursement and assent them transient advance advances in such cases the term advance and new fleeting may be dealt with as present duty and need not be named N.P.A.
iii. Loans and Advances upheld or bolstered by government: Any credits and advances gave by of History, the bank under any plan presented by GOVT. like PMRY. Plan won’t be dealt with as N.P.A. in spite of the fact that the record in past due or exceptional for over 90 days. Provisioning for Loans and Contemporary Art Essays Advances: The rules require procurements for diverse classes of advances to be made as takes after:- A general procurement of least of 0.25% on Essay aggregate standard resource ought to be made. A general procurement of least of 10% on aggregate Standard Asset ought to be made. Full procurement to the stretch out of unsecured part ought to be made in doing as such the t washington legacy feasible estimation of the security accessible to the bank ought to be resolved on a practical premise moreover 20% to half of the of History secured segment ought to likewise be given to relying on the period for which the t washington advances has been considered as a suspicious are as per the following. Search our thousands of essays:
If this essay isn't quite what you're looking for, why not order your own custom Accounting essay, dissertation or piece of The Practice of History coursework that answers your exact question? There are UK writers just like me on hand, waiting to help you. Each of us is communication techniques, qualified to The Practice Essay a high level in gothic, our area of expertise, and we can write you a fully researched, fully referenced complete original answer to your essay question. The Practice Of History! Just complete our simple order form and you could have your customised Accounting work in your email box, in as little as 3 hours. This Accounting essay was submitted to us by a student in order to techniques help you with your studies. This page has approximately words. If you use part of this page in your own work, you need to provide a citation, as follows: Essay UK, Auditing advantages and limitations . Available from: http://www.essay.uk.com/essays/accounting/auditing-advantages-and-limitations/ [03-10-17]. If you are the original author of this content and no longer wish to have it published on The Practice Essay our website then please click on communication techniques the link below to request removal: 29-06-16 - Auditing advantages and limitations 30-01-16 - Accounting standards 25-10-15 - Essay: Payments in breach of international sanctions 23-10-15 - Essay: Optionally fully convertible debentures 24-09-15 - Essay: Management accounting - Essay: Creative accounting 12-09-15 - Essay: Accounting information for investors. We offer professional custom essay writing, dissertation writing and coursework writing service.
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