Is Model N A Transparency Violation?

As many of you might suspect, this grumpy old accountant is not a big fan of last year’s JOBS Act.  As so eloquently communicated by Andrew Ross Sorkin in “JOBS Act Jeopardizes Safety Net for Investors,” my primary concern is the decreased amount of time that investors now have to analyze critical corporate information.  Three weeks is simply not enough to evaluate the financial viability of a company before it goes public.  As Mr. Sorkin suggests, the Act:

“dismantles some of the most basic protections for the most susceptible investors apt to be drawn into get-rich-quick scams and too-good-to-be-true investment ‘opportunities’.”

So, when Model N founder and CEO Zack Rinat told Maxwell Murphy at the CFO Journal recently that the Company believes in “complete transparency,” and won’t use the JOBS Act to hide material information from investors, I just had to take a look.  Now I can’t promise the Company that it would have avoided my scrutiny had it gone through the normal IPO filing process, but it sure would have gotten some good comments that would truly have helped the CEO honor his transparency pledge to investors.  My review of Model N’s Amendment  No. 4 to Form S-1 Registration Statement filed on March 15, 2013 (S-1), did not disappoint.

Two things immediately tipped me off that this was going to be an interesting read.  First, there was the unlabeled circular graphic presumably depicting the life cycle of revenue management using the Company’s solutions that preceded the table of contents.  Not until page 86 of the S-1 does the Company actually attempt to explain this illustration.  Then, there was the Company’s motto, “More Revenue, Made Simple.”  I found this marketing hype particularly annoying since it challenges the intelligence of experienced business professionals who recognize there is nothing easy about creating customer value.  So, right out of the gate we have transparency issues.

Next, there is the issue of what the Company actually does.  The reader must wade through page after page of MBA speak (85 pages in fact) to learn what the Company’s strategy and business model is.  Why mystify us with such terms as “revenue management solutions, strategic end-to-end process, application suites, and domain expertise” when the Company is nothing more than another software provider attempting to remedy the age old problems of transaction processing, reporting, and system integration.  Why all the marketing spin, legalese, and accounting verbosity?  All of this detracts from transparency. 

Then, there are the numerous questions raised by the Company’ s historical operations.  We learn early on that an investment in Model N is quite risky (S-1, page 4).  Recent operating losses, dependence on a few key customers (75 percent of revenues come from 15 customers), reliance on a single product, and a single industry focus all make this grumpy old accountant wonder what makes this Company “worthy” of an IPO.  

And then you have the declining margin issue masked in the Summary Consolidated Financial Data (S-1, page 8).  Margins on license and implementation products have decreased from almost 62 percent in 2010 to 54.81 percent at the end of the most recent fiscal year end. Why is this? Wouldn’t it be more transparent to explicitly report this very troubling trend in the introductory summary table?  

Instead, we don’t even see these negative margin trends until page 59 of the S-1.  Sure, Model N provides exhaustive detail of revenue and cost of goods sold changes, but it does so without answering the million dollar question: why the margin erosion?  Excuse me, but this is a pretty significant transparency deficiency.

And of course, as with so many IPO’s today, the Company feels compelled to spin its losses into profits via non-GAAP performance metrics (i.e., adjusted EBITDA).  When we get to the EBITDA reconciliation (S-1, page 10), we learn that the biggest reconciling item is for something called “LeapFrogRx compensation charges,” but the LeapFrogRx transaction has not been detailed up to this point in the S-1.  Again, is this what transparency is all about? And this is significant.  If not for the LeapFrogRx compensation charges and stock-based compensation, there would have been no need for “adjusted EBITDA” at all!  By the way, the LeapFrogRx transaction is not even mentioned until page 49 of the S-1, and we don’t get any of the specifics until much later in the actual financial statements (S-1, F-21 and F-22).  

As an aside, I particularly got a kick out of the Company’s justification for paying an excess purchase premium for LeapFrogRx: synergies in skill-sets, operations, customer base and organizational cultures.  Goodwill impairment can’t be far behind, can it?  And, oh by the way, why is stock-based compensation going up as the Company begins to lose money (S-1, page 9)?  Another transparency issue?

As I navigated the Company’s risk factor section (S-1, page 15), I was stunned to see accounting policies listed as a risk factor!  Essentially, Model N is “warning” potential investors that its reported revenues may be lower than they “really” are because of accounting.  Specifically: 

“Our revenue recognition model for our cloud-based solutions and maintenance and support agreements also makes it difficult for us to rapidly increase our revenues through additional sales in any period, as a significant amount of our revenues are recognized over the applicable agreement term.”

Does the Company require a specific type of accounting to report profitability? Unbelievable! Such disclosure does little to enhance transparency.

And the Company continues to imply that accounting will somehow “hurt” the business (S-1, page 31) in the following risk disclosures:

“Our financial results may be adversely affected by changes in accounting principles generally accepted in the United States...If our estimates or judgments relating to our critical accounting policies are based on assumptions that change or prove to be incorrect, our operating results could fall below expectations of securities analysts and investors, resulting in a decline in our stock price.”

Why is the Company warning us so much about the accounting?  Is there a problem?  Should we even be relying on the S-1?  Again, transparency sure seems to be an issue.

And if Model N is so transparent, why did it take advantage of certain exemptions from reporting requirements that public companies make, including not complying with auditor attestation requirements of Section 404 of Sarbanes-Oxley, reduced disclosure of executive compensation, etc. (S-1, page 32).  And then there is the issue of how Model N management intends to use the funds received in the IPO.  Surely, a Company wouldn’t do an IPO if it didn’t have some idea of how the proceeds would be used.  Yet, once again, Model N fails the transparency test by not telling us its plans for the monies raised (S-1, pages 36 and 41).

And then there are the bookkeeping errors (S-1, page F-18).  Is it really transparent to label accounting mistakes as “out-of-period adjustments?”  You make the call.

Finally, it is noteworthy that Model N reported income tax expense in 2012 even though it reported a pre-tax loss for the period.  The reason: a significant increase in its valuation allowance for deferred tax assets suggesting poor future operating performance prospects even with an IPO (S-1, F-32).  Then there is the issue of whether the IPO will trigger Section 382 limitations on the Company’s net operating loss carryovers.  While the Company does identify this as a risk (S-1, page 34), it seems to suggest that this “might” occur when in reality the likelihood is significantly greater than might.  This disclosure clearly plays down the loss of this asset, and again causes one to question the Company’s transparency.

Sujan Jain, Model N’s CFO, in the aforementioned CFO Journal indicated that filing offering plans confidentially with the SEC allowed the Company to avoid distractions of early IPO publicity.  You tell me…are the issues I raised “distractions?”  I think not…and to take a page from the beloved radio announcer Paul Harvey, “and now you know the rest of the story.”
But there’s more.  Earlier this week, Model N issued a press release to report its second quarter fiscal year 2013 results.  And once again, the Company disappointed us with its lack of transparency by introducing new non-GAAP metrics: non-GAAP gross profit, non-GAAP research and development expenses, non-GAAP sales and marketing expenses, and non-GAAP general and administrative expenses. Clearly, Model N is learning the new IPO game. But is this accounting-conflicted, non-GAAP focused, JOBS Act loving Company transparent?

This essay reflects the opinion of the author and not necessarily that of The American College, or Villanova University.

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AuthorAnthony Catanach
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Insider Trading or Lack of Transparency: Which is the Bigger Sin?

“Those who extol the virtues of U.S. capital markets are quick to tout their transparency. In this case, it is sadly and needlessly lacking.”
— David Reilly, Heard on the Street, Wall Street Journal, April 9, 2013

In making this statement, Mr. Reilly was referring to the paucity of information which investors and markets have regarding the accounting firm partners responsible for auditing today’s large global companies.  In “Looking for KPMG’s Mystery Man” he discusses several benefits of disclosing the name of the engagement partner which may improve audit quality.  But while knowing who the responsible partner is would be interesting, many would agree that this information alone probably wouldn’t have prevented KPMG’s recent independence fiasco.  This grumpy old accountant would like much, much more information about the large accounting firms who are supposed to be the “gatekeepers” of the public securities markets.

After half a century of blown audits (that’s as far back as this old bean counter can remember), these firms and their partners have somehow garnered “too few to fail status,” and continue to disappoint us.  And as Michael Rapoport reports, these firms have given us such accounting highlights as the financial crisis of 2007, and just last year, a Deloitte partner’s insider trading.  And now we have a 29-year, life-long KPMG audit veteran, with responsibilities for more than 50 other audit partners and over 500 employees, caught accepting envelops of cash for passing along privileged information.  And David Reilly’s call for more transparency (opening quote), prompts one major question…what do we really know about these firms who are supposed to be protecting the investing public?

Who are the Big Four and how did they become so powerful?  It’s been almost 30 years since Mark Stevens gave us a glimpse of these firms in The Big Eight and The Accounting Wars, so we really don’t know what they look like on the inside today.  And because of their operating structure, they are not required to disclose any of the information that we have been accustomed to in the 10-K annual reports filed by publicly traded firms.  We have no idea what their strategies are, the full extent of the risks to these strategies, or what their business models are.  Most importantly, we are clueless as to their financial condition and who their senior leaders are, or even what the governance structure looks like, much less its effectiveness.  Given the increasingly routine subpar performance of these large accounting firms, why do the regulators continue to let these firms get away with selling a clearly defective product.  What’s going on here?  Shouldn’t we know more about our “gatekeepers,” particularly since they appear to have left the gate wide open?

I am also somewhat troubled by the market’s recent reaction to KPMG’s recent partner scandal.  This is much, much more than simply another insider trading story.  I agree with James D. Cox, who called the case a “Bombshell that has the industry circling the wagons on training.”

There is simply no getting around it…this is a watershed event…this is a once in a generation occurrence…this is much worse than Deloitte’s insider trading problem.  Why?  This is about a major accounting firm violating the bedrock independence standards upon which the auditing profession is founded.  Mind you…this is not just another accounting restatement (although those are problematic as well).  So serious is the situation that KPMG actually withdrew its audit reports on multiple client financial statements for several years.  

The current KPMG debacle also highlights the failure of legislators and regulators to adequately address the independence issue last decade.  Although Section 201 of the Sarbanes-Oxley Act of 2002 created significant independence rules for non-audit (consulting) activities, they did little to beef up the actual policing of independence at accounting firms.  The limitations on consulting activities were largely a band-aid to address blatant independence violations during the Enron era.  Current professional standards largely require accounting firms to implement policies and procedures to provide reasonable assurance that personnel maintain independence.  And these can be quite “stringent” for KPMG and other accounting firms.  So, what’s the problem here?  The independence control procedures are largely self-reporting in nature.  That means that self-disclosure of independence violations is fundamental to most of the firm internal controls.  So, is it any wonder that KPMG was blindsided by its partner’s behavior. It appears that the firm actually was notified by federal investigators of the “rogue” behavior!  Shouldn’t the firm be ashamed that its own internal controls don’t work?  And we haven’t even discussed possible “failure to supervise” issues at KPMG, a topic that the Public Company Accounting Oversight Board will surely examine.

Given that independence, self-reporting, and firm culture all seem to be somewhat related, does this “rogue” KPMG partner’s behavior tell us anything about the firm’s culture?  Or about our society in general?  Here are a couple of examples from the recent press related to this 29-year veteran that concern me greatly:

This KPMG partner regrets his actions (now that he has been caught) after engaging in behavior that was “wrong” for a period of several years.  In fact, in his own words he felt guilty about it regularly, can’t explain it, and attributes it to “humans make mistakes.”

This KPMG partner tells us that he divulged “no real significant information,” and that his “take” was a watch discount, a couple of dinners, and a couple of thousand dollars in cash.  But instead we find out that he provided advance notices of earnings releases and merger plans, and in exchange “reaped more than $50,000 in cash and gifts, including a $12000 Rolex watch.”

Clearly, the “rogue” is trying to minimize his jail time, but I have yet another question.  Why does a senior, 29-year partner, with significant supervisory authority in one of KPMG’s largest offices behave this way?  Surely he didn’t need the money…the “why” is really nagging at me, and prompts me to question the firm’s culture. Shouldn’t we be concerned that this partner might actually reflect the system into which he was hired, trained, and promoted over almost 30 years?  Also, what about the effectiveness of ethics training at this firm and others, particularly at the senior level…and again what about leadership?

KPMG’s current catastrophe and PricewaterhouseCoopers’ recent quality control issues (which I discussed in “Is FASB Killing the Auditing Profession?”) reminded me of Marianne Jennings’ book titled “The Seven Signs of Ethical Collapse.”  As I reread Chapter One, I began wondering how many of the seven warning signs could apply to  the big accounting and auditing firms.  Three signals particularly jumped out at me:

Pressure to maintain those numbers – Given their size, one can only imagine what Big Four performance pressures might be.  After all they continue to protest regulatory attempts to improve audit quality, citing costs and pricing as issues.

Weak board – We have virtually little or no information on the governance of the large accounting firms.  But given their track record in protecting the public for the last half century, can’t we conclude that  there are some problems in this area?

Goodness in some areas atoning for evil in others – The big accounting firms deluge us (at least the academic community that is) with tales of their outstanding community and public service.  Could these actions be attempts to somehow make up for their “gatekeeper” failures?

In short, is there a festering cultural problem at these firms that makes them increasingly incapable of doing their duty to society?  After all, it was supposedly another “rogue” that took down Arthur Andersen in Houston, right?  I’m sorry…the “rogue” excuse is beginning to wear thin after all of the accounting and trading scandals we have witnessed recently.

Jennings in Chapter Ten also suggests that transparency may offer a solution to this “ethical collapse” issue.  She proposes clarity, honesty, and full disclosure.  Why can’t the large accounting and auditing firms “practice what they preach,” of their clients. Tell us more about who you are, what you do, and how you do it?  Admit your mistakes and tell us how you are going to fix it.  And then follow through and actually correct it!

Unfortunately, the spin to minimize legal exposure at KPMG has already begun. When this saga ends, we likely will conclude that we have seen this picture before.  A tale of weak and ineffective controls, missed signals, and greed…sound familiar?  Then, there is the standard “mea culpa” and promise to do better in the future. Shouldn’t the standard be higher for a firm of professionals?  One would think so…

And let’s not forget all the others that will use this case to promote their own policy initiatives.  Let’s try not to be blinded by the quick fix “solutions” (e.g., naming engagement auditors, audit rotation, etc.).  For example, while naming the auditors on an engagement sounds like a good idea, it might actually make things worse!  I would propose that good auditors (many of whom by nature are risk averse) might actually flee the large accounting firms if their names are disclosed, unwilling to put their limited wealth at risk for making an “honest” mistake in today’s litigious society.  This would leave the “rogue” risk takers to fill the engagement partner roles.  Just a thought…

The fundamental issues are, and have always been, independence and transparency.  Until we the investing public actually somehow become a contractual party to the audit with auditor hiring and firing authority (and I don’t mean via the board of directors), we are wasting our time.  We also need to know much, much more about the large accounting firms to better understand why their behaviors will likely never change in our lifetime (if ever).  Pretty grumpy, huh?

This essay reflects the opinion of the author and not necessarily that of The American College, or Villanova University.

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AuthorAnthony Catanach
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Groupon Revisited: New Mission, New Reporting Issues

It’s been over six months since the Grumpies’ last Groupon commentary.  Remember the financial restatements, revenue corrections , SEC criticism of the Company’s non-GAAP performance metrics, the internal control weaknesses over financial reporting, and public critiques of reported operating cash flows? Well, quite honestly, many of us had just tired of the Company’s story, until recently that is.  But two events during the past month, Andrew Mason’s “resignation” and the Company’s 2012 10-K securities filing, made it impossible for me to remain silent any longer.  As the marketing slogan suggests, Groupon is simply “the gift that keeps on giving.”

First, there’s Mr. Mason’s so-called “resignation” letter.  Let’s be clear here…according to Groupon’s Form 8-K filed on February 28th, “Andrew D. Mason was terminated as Chief Executive Officer.”  Unbelievable are those that actually praised Mr. Mason’s letter.  But what really troubles me is that at least one person found his memo to employees “geeky, hilarious, and touching,” and another titled it a “charming goodbye letter.” I think more appropriate descriptors might be immature and irresponsible.  Why am I being so grumpy about this?  Let’s not forget that the Company incurred a $9 billion loss in value (a decline from a $12.7 billion IPO valuation to an estimated $3 billion value on February 28th) during his tenure as CEO.  Phrases like “ I’m OK with having failed at this part of the journey,” or “maybe I’ll figure out how to channel this experience into something productive” are simply not acceptable. And for those that applaud his wisdom about having the “courage to start with the customer,” what about the investors?  How could Mr. Mason have forgotten about them in his letter? Those who invested $9 billion in his business education should be outraged!  His company’s loss in market capitalization makes today’s college tuition look amazingly affordable, if not downright cheap.  Okay, enough of Mr. Mason…let’s turn to Groupon’s most recently filed 10-K.

The first thing the 10-K does is confirm what Matthew Lynley reported in “Groupon Is No Longer a Daily Deals Business.”  It appears that the Company has a new mission.  According to last year’s 10-K:

“Groupon is a local commerce marketplace that connects merchants to consumers by offering goods and services at a discount…By bringing the brick and mortar world of local commerce onto the Internet, Groupon is creating a new way for local merchant partners to attract customers and sell goods and services.”
— 2011 10-K, page 3

But the recently filed 2012 10-K reveals a major change that has profound implications for Groupon’s business model and processes:

“Our mission is to become the operating system for local commerce. Groupon seeks to reinvent the traditional small business world by providing merchants with a suite of products and services, including customizable deal campaigns, credit card payments processing capabilities and point-of-sale solutions to help them attract more customers and run their operations more effectively.”
— 2012 10-K, page 3

Apparently, management finally realized that its original “daily deals” strategy just wasn’t creating much value or delivering on the differentiation dimension. So, now Groupon has decided to pursue a more Amazon-like approach.  While a dubious strategic shift, it does makes sense given Jason Child’s (Chief Financial Officer) tenure with Amazon from 1999 to 2010 (2012 10-K, page 11).  Also, don’t forget that Jeffrey Holden, Sr. Vice President of Product Management, also spent time at Amazon between 1997 and 2006 (2012 10-K, page 11).  When a plan is not working, it is not uncommon for some managers to fall back on what they know best.

But before we get to the financials, let’s reflect on what the Company’s redirection means for performance measurement (i.e., the numbers).  A new strategy means new processes, which in turn affect metrics and reported results. This means that traditional financial statement analysis (FSA) cannot be relied upon to provide its usual meaningful results.  FSA’s ratio and trend analyses are founded on the assumption of stable relationships, so when a company is transforming itself, the usefulness of these tools is somewhat limited.  Further complicating FSA is the Company’s decision to reclassify financial statement items from prior years (2012 10-K, page 69).  Does Groupon bother to tell us where the changes are?  Of course not.  Nevertheless, here are a few grumpy observations.

My biggest concern is the Company’s continuing struggle with estimates (and judgment).  Remember how the grumpies complained last August about Groupon’s “unusual” gain on an e-commerce transaction that created second quarter profitability (see Groupon: Still Accounting Challenged)?  This was a gain driven solely by the Company’s own estimates of fair value, the reasonableness of which we questioned at the time.  Well, guess what?  We were right again!  In the fourth quarter (literally at the eleventh hour), the Company revised its value estimate of its F-tuan investment downward by almost 40 percent resulting in a write-down of $50.6 million (2012 10-K, page 84). This turnabout almost completely reverses the pre-tax $56 million gain that Groupon reported in the second quarter of 2012. 

And while I’m on the topic of estimates and valuation, let’s not forget intangibles. Goodwill just keeps on growing from 9.4 percent of assets in 2011 to 10.17 percent in 2012.  With the Company’s new mission and related business models, one can’t help but wonder what the implications are for previously recorded goodwill, particularly since the Company couldn’t get F-tuan’s number right.  And a change in strategic direction clearly must impact intangibles.  In fact, cracks are beginning to appear in the goodwill numbers.  International segment revenue actually declined 15.9 percent in the final quarter of 2012 (2012 10-K, page 38) raising questions about reported international goodwill amounts.  More troubling is that liabilities exceed assets for the EMEA and LATAM reporting units, and that Groupon actually looked at possible impairment for these units this year (2012 10-K, page 53).  Ultimately, the Company decided that no write-down was necessary, but you have been warned again.  In fact, I suspect this year’s 10-K language may be signaling an impairment charge in the very near future.

And then there is the Company’s deferred tax asset (DTA) intangible.  As you may recall, the Grumpies first sounded the alarm on this intangible almost one year ago exactly in “Groupon’s First 10-K: Looking Under the Hood.” Well, guess what?  The Company is still reporting a loss because it FINALLY recorded an allowance for the DTAs which it likely will never (ever) be able to use.  It’s the increase in the DTA allowance (and several other tax factors) that drove the Groupon’s effective tax rate to an astronomical 153.7 percent in 2012 (see 2012 10-K, pages 46, 54, 104, and 114).  This is what we warned you would happen in our previous blog postings, and it has come to pass.  This is just more evidence of the Company’s struggle to make reliable estimates.  If I were the regulators, I would consider the Company’s F-tuan write-down, it’s delay in reserving for its DTAs, and its forthcoming goodwill impairment as evidence of a potential material weakness in controls over financial reporting as it relates to fair value estimation.  Heads up SEC…you too E&Y!

No review of Groupon would be complete without a discussion of non-GAAP performance metrics, and the Company does not disappoint us again.  Yes, Groupon still relies on non-GAAP metrics (2012 10-K, page 47), but there are changes. The Company has shed its infamous CSOI metric in favor of “operating income (loss) excluding stock-based compensation and acquisition-related expense (benefit), net.”  What would the acronym for this mouthful be?  OIESBCAEN?  I think I liked CSOI better…nevertheless, it’s still a curious metric that inflates operating performance.  And there’s more…last year, the gross billings metric was considered by the Company to be an “operating metric” (2011 10-K, page 41), while now it is reported as a financial metric (2012 10-K, page 31).  

What’s the big deal?  Gross billings is a total sales number that does not deduct the merchant’s share of transaction revenue.  Thus, gross billings is not a valid financial performance indicator…for goodness sakes, it doesn’t even appear in the financial statements. Moreover, to report gross billings as a financial performance metric actually decreases financial reporting transparency!  Why?  Well, Groupon reports growth rates in gross billings of 35 percent and 434.7 percent for 2012 and 2011, respectively (2012 10-K, page 35).  Yet gross profit (a “real” financial indicator) decreased from 83.9 percent in 2011 to 69.2 percent in 2012 (2012 10-K, page 41).  Now, you tell me…which sounds better, huge growth rates in gross billings or declines in gross profit?

While I’m on the topic of performance, despite the declines in gross profit percentage, income from operations has turned positive for the first time primarily due to reduced marketing expenses. The dramatic reversals in marketing and selling, general, and administrative (SG&A) expenses may reflect the Company’s changing business model, but given Groupon’s past reporting issues, one wonders if some of this expense volatility is due to the aforementioned decision to reclassify financial statement items.  Just a thought. And did you notice that the percentage of stock based compensation as a percent of operating expenses is increasing (2012 10-K, page 35)?  Why are managers continuing to reward themselves so highly despite continued losses, diminishing growth, and stock price declines?

Could there possibly be anything else you ask?  Well yes, there are a couple of lesser financial reporting issues that continue to irritate this grumpy old accountant.  Operating cash flows (OCF) have declined in 2012 despite accounts receivable liquidations, and the decrease is largely due to diminishing contributions of merchant payable flows to reported OCF.  We warned you about this in “Groupon’s First 10-K: Looking Under the Hood.”  

And why isn’t inventory reported separately as a current asset on the balance sheet?  Given the Company’s new retail strategy, the $40 million inventory amount reported in the notes (2012 10-K, page 89), and the existence of separate accounting policy note (2012 10-K, page 70), inventory has earned its own line item disclosure on the face of the balance sheet.

Then there is the Company’s segment disclosure. Groupon acknowledges having four reporting units: North America, Europe, Middle East and Africa (EMEA), Asia Pacific (APAC), and Latin America (LATAM) (2012 10-K, page 70). Yet, the Company only discloses two business segments, North America and International.  Oh, Groupon is probably GAAP compliant here basing their reporting on the size of the individual reporting units.  But why can’t the Company just report all four units, and why the need to deduct certain expenses in calculating segment operating income (see note (2) in 2012 10-K on page 106)?  Is this the 2012 version of last year’s CSOI?

So, where does all of this leave us? 

  • The Company is operating without a permanent CEO. 
  • The Company has abandoned its old mission in favor of a new one.
  • The Company is transitioning to an untested business model which raises serious balance sheet valuation questions, particularly given management’s recent estimation difficulties.
  • The Company continues to struggle with providing consistent and reliable financial reports, its efforts now further complicated by its current state of flux.
You tell me.  At my advancing age, I just can’t take any more April Fool’s Day surprises!

This essay reflects the opinion of the author and not necessarily that of The American College, or Villanova University.

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AuthorAnthony Catanach
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