UNITED STATES OF AMERICA

before the 

SECURITIES AND EXCHANGE COMMISSION

SECURITIES ACT OF 1933

Release No. 11276 / March 12, 2024

SECURITIES EXCHANGE ACT OF 1934

Release No. 99716 / March 12, 2024

ACCOUNTING AND AUDITING ENFORCEMENT

Release No. 4492 / March 12, 2024

Admin. Proc. File No. 3-21831

In the Matter of

EDWARD F. HACKERT, CPA

ORDER GRANTING MOTION TO AMEND THE ORDER INSTITUTING PROCEEDINGS

On January 18, 2024, the Securities and Exchange Commission issued an order 

instituting proceedings (“OIP”) against Edward F. Hackert, CPA, pursuant to Section 8A of the 

Securities Act of 1933, Sections 4C and 21C of the Securities Exchange Act of 1934, and 

Commission Rule of Practice 102(e).1 

On February 5, 2024, the Division filed a motion to amend the OIP to correct certain 

factual errors. In its motion, the Division explained that, shortly after issuance of the OIP,

Division staff discovered errors in how the staff had calculated the number of times that Hackert

allegedly failed to sign-off on audit work papers and document his review by the audit report 

release date. The Division stated that the errors were inadvertent and due to miscommunication 

between staff members. Upon discovering these errors, the Division explained, the staff 

reviewed and double-checked Hackert’s sign-off and balance sheet and report release date

information for the audits at issue in the case. 

Based on the errors it discovered, the Division seeks to amend the OIP to: (1) reduce the 

number of audits for which Hackert allegedly failed to sign-off on audit work papers and 

document his review by the report release date (from 204 audits to 187 audits); and (2) reduce 

1 Edward F. Hackert, CPA, Exchange Act Release No. 99384, 2024 WL 212152 (Jan. 18, 

2024).
2

the number of audits for which Hackert allegedly failed to assemble complete and final audit 

documentation by the audit completion date (from 126 audits to 123 audits). 

Hackert filed a response to the Division’s motion, noting that while he “takes no position 

on the Division’s motion,” he maintains that both the original and amended OIP “lack[] merit.” 

Hackert also expressly reserves “his right to challenge the sufficiency of the operative OIP,” as 

well as the legality and constitutionality of this proceeding.

Rule of Practice 200(d)(1) provides that, “[u]pon motion by a party, the Commission 

may, at any time, amend an order instituting proceedings to include new matters of fact or law.”2 

Such amendments to OIPs, including amendments that correct errors in an OIP,

3

“should be 

freely granted, subject only to the consideration that other parties should not be surprised nor 

their rights prejudiced.”4 

Amending the OIP to correct factual errors about the number of Hackert’s alleged 

auditing failures should not surprise or prejudice him. The proposed amendments narrow the 

scope of the allegations against Hackert, and because this proceeding is still in its earliest stages,

he will be able to file an answer to the amended OIP and challenge its allegations.5

Accordingly, IT IS ORDERED that the Division’s motion to amend the OIP is granted. 

The amended OIP is attached to this order. Service of this order and the amended OIP shall be 

made consistent with Rule of Practice 141(a).6 After the service of the amended OIP, the 

Division shall promptly file with the Office of the Secretary a record of service consistent with 

Rule of Practice 141(a)(3).7 Hackert shall file an answer to the allegations contained in the 

amended OIP within 20 days of service of the amended OIP.

2

17 C.F.R. § 201.200(d)(1).

3

See Steven Wise, Exchange Act Release No. 48850, 2003 WL 22827675, at *1 (Nov. 26, 

2003) (explaining that the Commission has authority to amend an OIP “where an amendment is 

intended to correct an error and is within the scope of the original order”).

4 Robert David Beauchene, Exchange Act Release No. 68974, 2013 WL 661619, at *2 

(Feb. 25, 2013)).

5

See James S. Tagliaferri, Exchange Act Release No. 75820, 2015 WL 5139389, at *2 

(Sept. 2, 2015) (“The OIP does not establish facts, it alleges them; [the respondent] will have an 

opportunity to contest these allegations and their legal effect.”); Wise, 2003 WL 22827675, at *1 

(holding that amending factual errors in the OIP at an early stage of the proceeding when “no 

hearing ha[d] been set” would “not result in surprise or prejudice to other parties”).

6

17 C.F.R. § 201.141(a).

7

17 C.F.R. § 201.141(a)(3).
3

The parties’ attention is directed to the e-filing requirements in the Rules of Practice.8 

By the Commission.

Vanessa A. Countryman

 Secretary

8

See Rules of Practice 151, 152(a), 17 C.F.R. §§ 201.151, .152(a) (providing procedure for 

filing papers with the Commission and mandating electronic filing in the form and manner 

posted on the Commission’s website); Instructions for Electronic Filing and Service of 

Documents in SEC Administrative Proceedings and Technical Specifications, 

https://www.sec.gov/efapdocs/instructions.pdf. Parties generally also must certify that they have 

redacted or omitted sensitive personal information from any filing. Rule of Practice 151(e), 17 

C.F.R. § 201.151(e).
UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

ADMINISTRATIVE PROCEEDING 

File No. 3-21831 

In the Matter of

Edward F. Hackert, CPA, 

Respondent.

AMENDED ORDER INSTITUTING 

ADMINISTRATIVE AND CEASEAND-DESIST PROCEEDINGS 

PURSUANT TO SECTION 8A OF 

THE SECURITIES ACT OF 1933, 

SECTIONS 4C AND 21C OF THE 

SECURITIES EXCHANGE ACT OF 

1934, AND RULE 102(e) OF THE 

COMMISSION’S RULES OF 

PRACTICE, AND NOTICE OF 

HEARING

I.

The Securities and Exchange Commission (“Commission”) deems it appropriate 

and in the public interest that public administrative and cease-and-desist proceedings be, 

and hereby are, instituted pursuant Section 8A of the Securities Act of 1933 (“Securities 

Act”), Sections 4C1 and 21C of the Securities Exchange Act of 1934 (“Exchange Act”), 

1 Section 4C provides, in relevant part, that: 

The Commission may censure any person, or deny, temporarily or permanently, to any person the 

privilege of appearing or practicing before the Commission in any way, if that person is found . . . 

(1) not to possess the requisite qualifications to represent others; (2) to be lacking in character or

integrity, or to have engaged in unethical or improper professional conduct; or (3) to have willfully

violated, or willfully aided and abetted the violation of, any provision of the securities laws or the

rules and regulations issued thereunder.
2

and Rule 102(e)(1)(ii) of the Commission’s Rules of Practice2 against Edward F. Hackert

(“Respondent” or “Hackert”).

II.

After an investigation, the Division of Enforcement alleges the following: 

SUMMARY

1. Edward F. Hackert, a certified public accountant (“CPA”), engaged in

improper professional conduct, within the meaning of Section 4C of the Exchange Act 

and Rule 102(e) of the Commission’s Rules of Practice, due to his numerous violations of 

the Public Company Accounting Oversight Board’s (“PCAOB”) auditing standards 

relating to, among other things, audit supervision and audit documentation. 

2. From approximately July 2006 to the present, Hackert worked as an

engagement partner at the public accounting firm Marcum LLP (“Marcum”). As an 

engagement partner, Hackert was responsible for the Marcum audit engagements to 

which he was assigned, including proper supervision of the engagement team and 

compliance with PCAOB auditing standards. During his time as an engagement partner, 

Hackert was responsible for hundreds of audits. 

3. Under PCAOB auditing standards, the date on which an audit firm grants

permission to use its audit report in connection with the issuance of its client’s financial 

statements is called the “report release date.” Before releasing the audit report (on the 

report release date), the auditor must perform necessary audit procedures and conclude 

that sufficient evidence has been obtained to support the representations in the audit 

report. Then, once the audit report is released, the auditor’s client includes the audit 

report in its filing(s) with the Commission and those filings become public and available 

to investors. 

4. From 2012 through 2022 (the “relevant period”), Hackert failed to

properly supervise numerous audit engagements and to ensure that the engagements were 

performed in compliance with PCAOB auditing standards. Among other things, Hackert 

repeatedly failed to review the work of the engagement team members and to document 

that review prior to the report release date. 

5. During the relevant period, Hackert served as the engagement partner for

at least 239 audits of public companies, and he approved the release of Marcum’s audit 

reports for those audits. Those audits included 88 audits of operating public companies 

and 151 audits of special purpose acquisition companies (“SPACs”). For 187 of those 

audit engagements (or approximately 78%), Hackert failed to supervise the work of the 

engagement team as shown by, among other things, Hackert’s failure to review the work 

2 Rule 102(e)(1)(ii) provides, in relevant part, that “the Commission may . . . deny, temporarily or

permanently, the privilege of appearing or practicing before it . . . to any person who is found . . . to have 

engaged in unethical or improper professional conduct.” 
3

of the engagement team and to document his review by the report release date. 

6. Under PCAOB auditing standards, the auditor should assemble a complete

and final set of audit documentation for retention by 45 days after the report release date, 

which is called the “documentation completion date.” 

7. During the relevant period, Hackert repeatedly failed to assemble

complete and final audit documentation by the documentation completion date. For 123 

of the audit engagements during the relevant period (or approximately 51%), Hackert 

failed to ensure that a complete and final set of audit documentation was assembled by

the documentation completion date. 

8. Proper audit documentation in accordance with the PCAOB auditing

standards is not merely a technical requirement. It is essential to demonstrate that the 

required audit work was performed and reviewed by the report release date, and to 

support the conclusions reached by the auditor and the representations contained in the 

audit report. As Marcum’s internal training slides instructed its auditors in August 2021: 

“If you didn’t document it, you didn’t do it!”3

9. Hackert’s failure to properly supervise audit engagements and to review

the work of his engagement team members resulted in multiple deficient audits. As 

explained below, those failures independently violated PCAOB auditing standards. 

10. Through his conduct described herein, Hackert engaged in improper

professional conduct within the meaning of Section 4C(a)(2) of the Exchange Act and 

Rule 102(e)(1)(ii) of the Commission’s Rules of Practice by engaging in repeated 

instances of unreasonable conduct, each resulting in violation of applicable professional 

standards. In connection with each of the audit engagements described herein on which 

Hackert failed to comply with applicable PCAOB auditing standards, he acted 

negligently, unreasonably, and without due professional care. 

11. In October 2021, in a video presentation for Marcum personnel, Hackert

admitted that Marcum’s audit work fell short of the PCAOB auditing standards, stating: 

“the standard of how we carry out our work, and document it, according to the auditing 

standards, . . . we’re still coming up short.” (Emphasis added.) 

Hackert’s conduct also caused Marcum to repeatedly violate Rule 2-02(b)(1) of 

Regulation S-X.4

 In connection with each of the audits described herein, Marcum issued 

an audit report stating that the audit was performed in accordance with PCAOB auditing 

standards. In fact, due to Hackert’s actions, those audits were not performed in 

3 Similarly, the PCAOB has stated that “if audit documentation does not exist for a particular procedure or 

conclusion related to a significant matter, its absence casts doubt as to whether the necessary work was 

done.” Audit Documentation and Amendment to Interim Auditing Standards, PCAOB Release No. 2004-

006 at 3 (June 9, 2004).

4 Marcum is not a respondent in this proceeding. The Commission brought a separate proceeding against 

Marcum. See infra ¶ 14. 
4

accordance with PCAOB standards. Marcum therefore violated Rule 2-02(b)(1) of 

Regulation S-X. Hackert caused Marcum’s violations of Rule 2-02(b)(1) because his 

actions as the engagement partner contributed to Marcum’s violations and Hackert knew 

or should have known that his conduct would contribute to a violation. 

RESPONDENT

13. Hackert, age 62, resides in East Meadow, New York. From approximately

July 2006 to the present, Hackert has been an engagement partner at Marcum. From June 

2004 through July 2006, Hackert was a senior manager at Marcum. Hackert is licensed as 

a CPA in the State of New York.

OTHER RELEVANT ENTITIES

14. Marcum, a New York limited liability partnership headquartered in New

York, New York, is a public accounting firm in the United States. Marcum has more than 40 

offices in cities across the United States and additional offices in other countries. Marcum 

has been registered with the PCAOB since October 2003. In June 2023, the Commission 

charged Marcum with systemic quality control failures and violations of audit standards in 

connection with audit work for hundreds of SPAC clients. See In the Matter of Marcum 

LLP, Exchange Act Rel. No. 97773 (June 21, 2023).

15. Ault Alliance, Inc. (“AAI”) is a Delaware corporation with its principal

place of business in Las Vegas, Nevada.5 AAI is a holding company that, since 2016, has 

engaged in operating businesses that include, among others, power products and systems, 

digital asset mining of Bitcoin, the manufacture and sale of textile technology machinery, 

and commercial lending. AAI’s stock is registered under Section 12(b) of the Exchange 

Act, and its common stock trades on NYSE American. Marcum issued audit reports for 

AAI from 2016 to the present. Hackert served as the engagement partner on audits of AAI 

from 2016 through 2020. In August 2023, the Commission charged AAI for financial 

disclosure failures, improper accounting, and reporting, internal controls, and books and 

records violations from 2017 through 2023. See In the Matter of Ault Alliance, Inc., et al., 

Exchange Act Rel. No. 98131 (August 15, 2023).

16. Avalanche International Corp. (“Avalanche”), a holding company, is a

Nevada corporation with its principal place of business in Las Vegas, Nevada. AAI has 

disclosed Avalanche as a related party since 2017. AAI invested over $17 million in 

Avalanche from 2016 to 2021. In June 2022, AAI acquired over 90% of Avalanche’s stock 

and began consolidating Avalanche’s financial results with AAI’s results. Avalanche’s 

common stock was publicly traded until September 2021. 

5 AAI has had several different names: AAI (from January 3, 2023, to present); BitNile Holdings, Inc. 

(from December 13, 2021, to January 2, 2023); Ault Global Holdings, Inc. (January 19, 2021, to December 

12, 2021); DPW Holdings, Inc. (September 19, 2017, to January 18, 2021); and Digital Power Corporation 

(prior to September 19, 2017).
5

FACTS

Relevant PCAOB Auditing Standards

17. The PCAOB was created as part of the Sarbanes-Oxley Act of 2002. The

PCAOB oversees audits of public companies that are subject to the securities laws in order 

to protect the interests of investors and further the public interest in the preparation of 

informative, accurate, and independent audit reports. The PCAOB established Auditing

Standards (“AS”) for registered public accounting firms to follow in the preparation of 

audit reports for public companies, other issuers, and broker-dealers. Certain of the 

standards relevant to this proceeding are summarized below.6 

Due Professional Care

18. Due professional care is to be exercised in the planning and performance of

an audit and preparation of the audit report. AS 1015.01. Due professional care requires an 

auditor to exercise “professional skepticism,” which includes “a questioning mind and a 

critical assessment of audit evidence.” AS 1015.07. Negligent conduct by an auditor violates 

the duty of due care. See AS 1015.03.

19. The engagement partner should know, at a minimum, the relevant

professional accounting and auditing standards and should be knowledgeable about the 

client. The engagement partner is responsible for the assignment of tasks to, and supervision 

of, members of the engagement team. AS 1015.06.

Supervision of the Audit

20. The audit engagement partner is responsible for the audit engagement and its

performance. The engagement partner is thus responsible for, among other things, proper 

supervision of the work of the engagement team and compliance with PCAOB standards, 

including standards regarding using the work of specialists. AS 1201.03.

21. In supervising an audit, the engagement partner should, among other things,

(a) inform engagement team members of their responsibilities; (b) direct engagement team

members to bring significant accounting and auditing issues to the attention of the

engagement partner or other supervisors; and (c) review the work of the engagement team

members. AS 1201.05. The engagement partner should review the work of the engagement

team to evaluate whether (1) the work was performed and documented; (2) the objectives of

the procedures were achieved; and (3) the results of the work support the conclusions

reached. AS 1201.05.c.

6 PCAOB Rule 3101 discusses the meaning of certain terms used in the PCAOB auditing standards. The 

rule provides that the words “must,” “shall,” and “is required” indicate unconditional responsibilities. The 

word “should” indicates responsibilities that are presumptively mandatory. Additionally, under Rule 

3101(a)(2) the “[f]ailure to discharge a presumptively mandatory responsibility is a violation of the relevant 

standard . . . unless the auditor demonstrates that, in the circumstances, compliance with the specified 

responsibility was not necessary to achieve the objectives of the standard.”
6

22. While the engagement partner may seek assistance from appropriate

engagement team members, the engagement partner’s supervision of the audit work cannot 

be eliminated and “higher risk areas of the audit require more supervisory attention from 

the engagement partner.” Auditing Standards Related to the Auditor’s Assessment of and 

Response to Risk and Related Amendments to PCAOB Standards, PCAOB Release No. 

2010-004 at A10-17 to A10-18 (Aug. 5, 2010). 

Audit Documentation

23. Audit documentation (the “work papers”) provides the written record of the

basis for the auditor’s conclusions. Audit documentation also facilitates the planning, 

performance, and supervision of the audit engagement. AS 1215.02.

24. An auditor must prepare audit documentation in connection with each audit

engagement conducted pursuant to PCAOB auditing standards. AS 1215.04. The audit 

documentation should demonstrate, among other things, that the engagement complied with 

the standards of the PCAOB. AS 1215.05.a.

25. “Audit documentation must clearly demonstrate that the work was in fact

performed.” AS 1215.06. Further, “[a]udit documentation must contain sufficient 

information to enable an experienced auditor, having no previous connection with the 

engagement” to determine (1) who performed the work, (2) the date such work was 

completed, (3) who reviewed the work, and (4) the date of such review. AS 1215.06.b. 

26. “Oral explanation alone does not constitute persuasive other evidence, but it

may be used to clarify other written evidence.” AS 1215.09.

27. Before the report release date, the auditor must complete all necessary audit

procedures and obtain sufficient evidence to support the representations in the auditor’s 

report. AS 1215.15. Additionally, a “complete and final set of audit documentation should 

be assembled for retention as of a date not more than 45 days after the report release date” – 

i.e., by the documentation completion date. Id.

28. Audit documentation must not be deleted or discarded after the

documentation completion date. AS 1215.16. Any documentation added after the 

documentation completion date must indicate (1) the date the information was added, (2) the 

name of the person who prepared the additional documentation, and (3) the reason for 

adding it. Id. 

29. “Documentation added to the working papers well after completion of the

audit or other engagement is likely to be of a lesser quality than that produced 

contemporaneously when the procedures were performed. It is very difficult to reconstruct 

and recall specific activities related to gathering audit evidence months, and perhaps years, 

after the work was actually performed.” PCAOB Release No. 2004-006 at 7.
7

Training and Proficiency

30. An auditor must study, understand, and apply new pronouncements on

accounting principles and auditing procedures as they are developed by authoritative bodies 

within the accounting profession. AS 1010.04.

Audit Evidence

31. An auditor must plan and perform audit procedures to obtain sufficient

appropriate audit evidence to provide a reasonable basis for the auditor’s opinion. AS 

1105.04. And appropriate audit evidence “must be both relevant and reliable in providing 

support for the conclusions on which the auditor’s opinion is based.” AS 1105.06.

32. When using information produced by an audited company as audit evidence,

an auditor should evaluate whether the information is sufficient and appropriate for purposes 

of the audit by performing procedures to: “[t]est the accuracy and completeness of the 

information, or test the controls over the accuracy and completeness of that information; 

and [e]valuate whether the information is sufficiently precise and detailed for purposes of 

the audit.” AS 1105.10. 

Evaluating Audit Results

33. When evaluating the results of the audit, the auditor should evaluate whether

the accumulated results of auditing procedures and other observations affect the assessment 

of the fraud risks made throughout the audit and whether the audit procedures need to be 

modified to respond to those risks. AS 2810.28. 

Audit Sampling

34. When an auditor is unable to examine samples that have been chosen for

testing, the auditor “should evaluate whether the reasons for his or her inability to examine 

the items have (a) implications in relation to his or her risk assessments (including the 

assessment of fraud risk), (b) implications regarding the integrity of management or 

employees, and (c) possible effects on other aspects of the audit.” AS 2315.25. 

Consideration of Fraud

35. An auditor must exercise professional skepticism when considering fraud

risks and “conduct the engagement with a mindset that recognizes the possibility that a 

material misstatement due to fraud could be present, regardless of any past experience with 

the entity and regardless of the auditor’s belief about management's honesty and integrity 

.... In exercising professional skepticism in gathering and evaluating evidence, the auditor 

should not be satisfied with less-than-persuasive evidence because of a belief that 

management is honest.” AS 2401.13. 
8

36. Further, “[w]henever the auditor has determined that there is evidence that

fraud may exist, that matter should be brought to the attention of an appropriate level of 

management. This is appropriate even if the matter might be considered inconsequential.” 

AS 2401.79. Fraud involving senior management should be reported directly to the audit 

committee in a timely manner and prior to issuance of the auditor’s report. Id. 

Use of Specialists

37. If using a specialist engaged by the auditor’s firm, the auditor should (a)

obtain an understanding of the methods and assumptions used by the specialist, (b) make 

appropriate tests of data provided to the specialist, taking into account the auditor's 

assessment of control risk, and (c) evaluate whether the specialist's findings support the 

related assertions in the financial statements. AS 1210.12.

Auditing Estimates

38. In evaluating reasonableness, the auditor should obtain an understanding of

how management developed an estimate. Based on that understanding, the auditor should 

use one or a combination of the following approaches: (a) review and test the process used 

by management to develop the estimate; (b) develop an independent expectation of the 

estimate to corroborate the reasonableness of management's estimate; and/or (c) review 

subsequent events or transactions occurring prior to the date of the auditor's report. AS 

2501.10.

Hackert Failed to Properly Supervise and Document Audits

39. In the accounting industry, the generally accepted method for engagement

partners to document their supervision of an audit in compliance with the PCAOB auditing 

standards, and their review of the work performed by engagement team members, is by 

signing and dating (or “signing off”) on work papers when they perform or review work. 

Historically, sign offs occurred on hard copies of work papers but, in recent years, many 

audit firms, including Marcum, moved to electronic sign offs. Whether a sign off occurs in 

hard copy or electronic form, it provides evidence of who performed or reviewed audit 

work and the date on which such work or review occurred. By signing off on work papers, 

an engagement partner documents his or her supervision of the audit. 

40. During the relevant period, Hackert failed to appropriately supervise audits

for which he was the engagement partner by (a) failing to review the work of the 

engagement team members and to document that review prior to the report release date, 

and/or (b) failing to ensure that audit documentation was assembled for retention by the 

documentation completion date. Hackert’s conduct demonstrated a lack of due professional 

care and resulted in deficiencies in some of the audit work performed.

41. As noted above, during the relevant period, Hackert served as the

engagement partner for at least 239 audits, which included 88 audits of operating public 

companies and 151 audits of SPACs. 
9

42. As the engagement partner, Hackert was responsible for sending (or

authorizing a member of the engagement team to send) an email authorizing Marcum’s 

audit report to be filed with the Commission by the relevant issuer. The email authorizations 

contained a representation that the audits were conducted in accordance with PCAOB 

standards. But because of his actions on the audits, Hackert knew or should have known that 

those representations were not accurate.

43. Marcum issued audit reports in connection with each of the audits referenced

herein, and each of the audit reports stated that the audits were performed in accordance 

with PCAOB auditing standards. In fact, because of Hackert’s actions, the audits were not 

performed in accordance with PCAOB standards. Nevertheless, Marcum’s clients included 

Marcum’s audit reports in their filings with the Commission, including, among others, 

Forms 10-K and S-1.

44. Hackert repeatedly failed to review the work of the engagement team

members and to document that review prior to the report release date. In 187 of the 239

audits on which Hackert was the engagement partner during the relevant period (or about 

78%), Hackert did not review significant portions of the audit work performed or 

conclusions reached prior to the report release date. 

45. For two audit engagements, the audit of Operating Company 14 for 2015

and the audit of Operating Company 18 for 2016, Hackert did not review and sign off on 

any work papers containing substantive audit work by the engagement team.7

46. In 2017, in response to findings made by the PCAOB after an inspection,

Marcum changed its policy to require engagement partners and engagement quality review 

(“EQR”) partners to sign off on certain specific work papers in every audit binder, as well 

as work papers related to other significant risk areas. This policy became effective for 

audits with fiscal years ended December 31, 2016, or later. 

47. But even after Marcum’s policy changed, Hackert’s review and sign off

practices did not improve. In at least 14 audit engagements to which this policy applied, 

Hackert failed to review the work of the engagement team on significant audit areas and key 

work papers and to evidence his review before the report release date. 

48. For example, in the audit of Operating Company 12 for 2017, the

engagement team identified related party transactions as an area of the audit that had 

significant and fraud risks. Nevertheless, for the related party section of the audit, Hackert 

did not review the work of the engagement team and evidence his review prior to the report 

release date. 

49. Likewise, in the audit of Operating Company 22 for 2017, Hackert did not

review the work of the engagement team and evidence his review prior to the report release 

date on the Risk Assessment Summary Form, a key document requiring an engagement 

7 Except for AAI, the relevant issuers that Hackert and Marcum audited – both operating companies and 

SPACs – have been anonymized herein and in the attached Appendices A and B.
10

partner signature under Marcum policy. Hackert also failed to review the work of the 

engagement team and evidence his review prior to the report release date on significant risk 

areas in the audit identified by the engagement team, including accounts receivable and 

sales and inventory and cost of sales. In the same engagement, Hackert did not review the 

work of the engagement team and evidence his review on the Summary of Unadjusted 

Misstatements (“SUAM”), a key audit document that requires an engagement partner sign

off under Marcum policy and that should be included as part of the auditor’s evaluation of 

audit results in accordance with PCAOB auditing standards.

50. In the AAI 2018 audit engagement, Hackert failed to review the work of the

engagement team and evidence his review of work papers in significant areas of the audit, as 

identified by the engagement team, including areas involving crypto asset miners and 

goodwill or intangibles valuation. He also failed to review the work of the engagement team 

and evidence his review of certain key documents before the report release date, including 

the summary memorandum, work papers related to communications with the audit 

committee, and the SUAM.

51. In the AAI 2019 audit engagement, Hackert never reviewed the work of the

engagement team and evidenced his review on certain key documents that required an 

engagement partner to sign off under Marcum policy, including the work papers related to 

planning the audit, engagement team discussion and risk identification, and the auditor’s 

report. Hackert also did not review the work of the engagement team and evidence his 

review before the report release date on work papers related to communications to the audit 

committee and the summary memorandum, which were key documents for the audit under 

Marcum policy and PCAOB auditing standards. 

52. In 2020, Hackert’s practice shifted mostly to auditing SPACs. Between 2020

and 2022, Hackert served as the engagement partner for at least 151 audits of SPACs. In 122 

of those audits, Hackert did not review the work of the engagement team and document his 

review of at least some of the audit documentation prior to the report release date. In one of 

the SPAC audits, Hackert did not review the substantive work of the engagement team and 

document his review of any work papers before or after the report release date. 

53. Beginning with audits for the fiscal year that ended on December 31, 2016,

and continuing to the present, Marcum policy required Hackert to sign a “routing slip” 

work paper before the report release date for every audit on which he was the engagement 

partner. At Marcum, a routing slip is the work paper that engagement partners, engagement 

managers, and EQR partners sign to attest and document that their procedures and review 

are complete, and that they authorize release of the audit report. 

54. Hackert sometimes failed to sign the required routing slips prior to the

report release date and then backdated his signature to make it appear that the routing slip 

had been timely signed. For example, on the audit of Operating Company 14 for 2015, the 

2016 and 2017 audits of AAI, and the audit of Operating Company 22 for 2017, Hackert 

dated his signature as of the report release date, but the electronic metadata in the routing 

slip indicates that the document was not created until weeks after the purported date of 
11

Hackert’s signature. Hackert knew or should have known that backdating documentation 

violates, at a minimum, his duties under AS 1015, 1201, and 1215. 

55. On at least 37 of the SPAC audits, Hackert failed to sign the routing slips,

which were important audit documentation, prior to the report release date.

56. Hackert’s supervision failures extended to the PCAOB requirement to

assemble a “complete and final set of audit documentation” within 45 days after the report 

release date (i.e., by the documentation completion date), as required by AS 1215.15. 

Marcum’s policies referred to this requirement as “Finalizing and Locking Engagement 

Binders.” During the relevant period, on 123 of the audit engagements for which Hackert 

was the engagement partner, he failed to ensure that a complete and final set of audit 

documentation was assembled for retention by the documentation completion date. 

57. Marcum required engagement teams to prepare a so-called “AS 3 memo”

for any engagement where documentation was added to the work papers after the 

documentation completion date. The AS 3 memo was a quality control document

ostensibly intended to meet the requirements of AS 1215.16 that any audit documentation 

added after the report release date “must indicate the date the information was added, the 

name of the person who prepared the additional documentation, and the reason for adding 

it.” But for 21 audits on which Hackert was the engagement partner, he added sign offs to 

the work papers after the documentation completion date and the required documentation 

under AS 1215.16 was not added, whether through an AS 3 memo or otherwise.

58. Accordingly, Hackert violated AS 1015, 1201, and 1215 in connection with

at least 193 audits. Attached hereto and incorporated herein are Appendix A, which 

summarizes Hackert’s failures to evidence his supervision by the report release date, and

Appendix B, which summarizes Hackert’s failures to assemble a complete and final set of 

audit documentation by the documentation completion date.8 Additionally, in connection 

with the audits listed on Appendices A and B, Hackert caused Marcum to violate Rule 2-

02(b)(1) of Regulation S-X.

Additional Deficiencies in Hackert’s Audits of AAI

59. Hackert’s conduct also demonstrated a lack of due professional care and

violated PCAOB auditing standards in connection with multiple audits of AAI, from 2018 

through 2020, on which Hackert was the engagement partner. 

Crypto Asset Miners

60. In 2018, AAI purchased approximately $9 million worth of computer

equipment known as crypto asset miners. During Marcum’s audit of AAI for 2018, 

8 Appendix A shows 187 audits on which Hackert failed to evidence his supervision by the report release 

date. Additionally, for 6 of the audits shown on Appendix B (and not on Appendix A), Hackert signed off 

by the report release date, but he failed to ensure that complete documentation was assembled by the 

documentation completion date.
12

Hackert’s engagement team identified the existence and valuation of the crypto asset 

mining equipment as a significant risk area. Because the value of the miners was material 

to AAI’s balance sheet (approximately 15% of total assets), the engagement team identified 

this as a significant audit area along with risks that the equipment (a) did not exist due to 

accounting error or misappropriation, (b) did not belong to the company, (c) was recorded 

at “incorrect values,” and/or (d) was impaired and not adjusted to net realizable value. 

61. Despite identifying the foregoing risks related to the existence and valuation

of the miners, the only work paper that contained evidence of Hackert’s review in this 

section of the audit binder was the “Audit Program for Property,” which listed audit 

procedures performed and referenced the work papers documenting those procedures. The 

audit program indicated that all the procedures were performed by, and the underlying 

work papers were prepared by, a junior member of Hackert’s team. Hackert, however, did 

not review and document his review of any underlying work papers to determine whether 

the audit work in this significant area was appropriate and complete. 

62. The only supporting documents reviewed by the engagement team to

evidence the existence of the miners were several invoices purporting to show purchased 

miners. Those invoices, however, did not provide sufficient and appropriate audit evidence 

to demonstrate that the miners existed, that the miners were delivered to AAI, and that title 

to the miners passed to AAI.

63. Further, the engagement team did not perform and document any audit

procedures to assess the valuation and impairment of the miners. 

64. Accordingly, Hackert’s conduct with respect to the crypto asset miners

violated AS 1015, 1105, 1201, and 2501. 

Goodwill Valuation

65. AAI’s balance sheet for 2018 included Goodwill of $8.5 million related to

four acquisitions. Goodwill arises when the purchase price of an acquired entity exceeds 

the combined fair value of the identifiable assets and liabilities. Goodwill represents 

intangible assets such as the value of brand reputation, among other things. 

66. In its audit of AAI’s 2018 financial results, Hackert’s engagement team

identified AAI’s goodwill valuation as a significant risk area. The engagement team wrote

in a work paper that in response to this risk, it “obtained third party valuation reports and 

utilized [a] Marcum Valuation team to perform analysis on the company’s conclusions.”

But the work papers related to goodwill valuation show that Hackert’s team did not 

conduct sufficient audit work in this significant area.

67. The only goodwill analysis in the work papers was for one (of the four) AAI

acquisitions, and its goodwill was valued at $265,000 (or 3% of total goodwill). There was 

no goodwill analysis in the work papers for the other three acquisitions, which accounted 

for about 97% of the goodwill value. 
13

68. Additionally, while conducting the 2018 audit, Hackert received a thirdparty valuation report via email related to another AAI acquisition (not the acquisition with 

goodwill valued at $265,000). The report indicated that AAI should record a $2.5 million 

impairment of goodwill, meaning that the value of goodwill related to the acquisition had 

fallen by $2.5 million. However, the analysis in the third-party valuation report was not 

included in the AAI work papers for 2018, and no goodwill impairment was recorded in 

AAI’s financial statements for 2018. Hackert claimed that he reviewed with Marcum’s 

valuation expert the report indicating that a $2.5 million impairment should be recorded, 

but the work papers do not reflect Hackert’s analysis of the report or why he believed the 

$2.5 million impairment was not warranted. 

69. The next year, when auditing AAI’s 2019 results, Hackert’s engagement

team did not identify goodwill valuation as a significant risk area, as it had in 2018. 

Although goodwill still comprised a material amount of AAI’s total assets (about 26%), the 

engagement team provided no explanation in the work papers for why the assessed risk 

level was downgraded. 

70. In the 2019 AAI audit, Hackert signed off on multiple work papers citing as

audit evidence certain valuation reports prepared by third parties about AAI’s goodwill 

valuations. Despite these citations, however, the work papers did not include the referenced 

valuation reports. 

71. Although the valuation reports were not included in the work papers, they

purportedly were reviewed by Marcum’s valuation expert, who identified multiple issues 

with these reports and their valuations of goodwill. But there is no documentation in the 

work papers of whether or how these issues were addressed or resolved. For example, the 

expert advised the team that they should perform a market cap reconciliation by comparing 

the sum of the fair values in the reports with certain other data, and that his “back of the 

envelope” calculations did “not line up.” However, there is no evidence in the work papers 

that any market cap reconciliation was performed. In addition, the expert wrote in an email 

on which Hackert was copied that he would rely on the audit team “to test all projected 

financial information” included in the goodwill third party valuation reports. Yet there is no 

evidence in the work papers that the team tested any of the projected financial information. 

72. Accordingly, Hackert’s conduct with respect to goodwill valuation violated

AS 1015, 1105, 1201, 1210, and 2501. 

Investments in Related Party

73. In 2018, the Marcum audit team identified AAI’s transactions with related

parties as a significant and fraud risk area. AAI’s relevant related party transactions 

included its investment in the warrants of Avalanche, which AAI identified in its filings 

with the Commission as a related party to AAI. As background, Avalanche had issued 

AAI warrants to purchase 35.6 million shares of Avalanche common stock between 2017 
14

and 2020.9 From 2018 through 2020, AAI’s investments in Avalanche (including the 

warrants, common stock, and loans) ranged from 18-22% of AAI’s total assets, 

representing a material amount of AAI’s assets.

74. GAAP that became effective for fiscal years beginning after December 15,

2017 – specifically, Accounting Standards Codification Topic 321, Investments – Equity 

Securities (“ASC 321”) – eliminated an issuer’s ability to record changes in the fair value 

of certain investments in equity securities (including warrants) in other comprehensive 

income on the issuer’s financial statements. Instead, under the new ASC 321, such changes 

had to be recorded in net income/loss on the financial statements. 

75. Although ASC 321 was effective for AAI’s fiscal year 2018, and AAI

applied that provision to certain equity investments in a private company on its Form 10-K 

for 2018, AAI did not apply ASC 321 to its Avalanche warrants. The failure to apply ASC 

321 to the Avalanche warrants was a material accounting error.

76. During his audits of AAI for the fiscal years 2018 through 2020, however,

Hackert concurred with AAI’s incorrect accounting treatment of the Avalanche warrants. 

Hackert knew or should have known that AAI’s accounting treatment was incorrect 

because it did not apply ASC 321. 

77. Hackert’s failure to recognize or correct AAI’s improper accounting

resulted in AAI materially understating its net loss by 24.34% in 2018 and 6% in 2019, and 

overstating its net loss by 10% in 2020. Because of that materially improper accounting, 

AAI restated its financial results in 2023. 

78. Accordingly, Hackert’s conduct with respect to related party investments

violated AS 1010, 1015, and 1201.

Expense Testing

79. During the audit of AAI for 2019, as in other audits, Hackert’s engagement

team was required to sample and test expenses (to confirm that the expenses were 

substantiated and accounted for correctly). The engagement team used an electronic 

sampling program to select certain AAI expenses for testing. One of the expenses selected 

was for $65,000, which purportedly was a payment to a third-party for consulting services. 

80. Email communications between a junior member of Hackert’s audit team

and AAI’s then-CFO, in or around May 2020, indicated that AAI could not locate 

supporting documents for the expense, such as an executed consulting agreement, an 

invoice from the consultant, or other documentation. But instead of insisting that AAI 

provide supporting documentation for the $65,000 expense, the engagement team simply 

stopped seeking support for this sample item and chose another item to test. 

9 A stock warrant gives the holder the right to purchase a company’s stock at a specific price and within a 

specific time frame. 
15

81. In fact, the third party provided little or no consulting services to AAI, and

certainly not services worth $65,000. Additionally, contemporaneous correspondence 

between AAI’s then-CEO and the third-party indicated that AAI’s payment of $65,000 was 

to satisfy a personal debt from the then-CEO to the third party. But so far as the work 

papers show, neither Hackert nor anyone on the engagement team reviewed or analyzed 

any documentation related to the $65,000 payment to ensure that it was evaluated properly. 

82. As a result, during the 2019 audit of AAI, Hackert failed to exercise due

professional care. Because of Hackert’s insufficient supervision, the engagement team failed 

to perform appropriate procedures when they were unable to examine a sample chosen for 

testing; they failed to consider the impact of the client being unable to provide sufficient 

evidentiary support; and they failed to appropriately evaluate potential fraud on the part of 

senior management. Additionally, so far as the work papers show, the team did not consider 

whether the inability to obtain sufficient appropriate evidential matter for the potentially 

fraudulent expense item constituted a scope limitation or whether the auditor’s opinion 

should have been qualified or disclaimed.

83. Accordingly, Hackert’s conduct with respect to expense testing violated AS

1015, 1201, 2315, 2401, and 2810. 

VIOLATIONS

84. As a result of the conduct described above, Hackert engaged in improper

professional conduct within the meaning of Section 4C(a)(2) of the Exchange Act and Rule 

102(e)(1)(ii) of the Commission’s Rules of Practice. Section 4C(a)(2) and Rule 

102(e)(1)(ii) provide, in pertinent part, that the Commission may censure or deny, 

temporarily or permanently, the privilege of appearing or practicing before the Commission 

to any person who is found by the Commission to have engaged in improper professional 

conduct. With respect to persons licensed to practice as accountants, “improper 

professional conduct” includes “[r]epeated instances of unreasonable conduct, each 

resulting in a violation of applicable professional standards, that indicate a lack of 

competence to practice before the Commission.” Exchange Act Section 4C(b)(2)(B) and 

Rule 102(e)(1)(iv)(B)(2). As discussed above, Hackert engaged in repeated instances of 

unreasonable conduct, each resulting in a violation of applicable professional standards. 

85. Rule 2-02(b)(1) of Regulation S-X requires an accountant’s report to state

“the applicable professional standards under which the audit was conducted.” 17 C.F.R. § 

210.2-02(b)(1). For audits of fiscal years 2016 and 2017, Rule 2-02(b)(1) similarly 

mandated that an accountant’s report “state whether the audit was made in accordance with 

accepted auditing standards....” An auditor violates Rule 2-02(b)(1) if it issues a report 

stating it has conducted its audit in accordance with the PCAOB standards when it has not. 

As a result of the conduct described above, Marcum violated Rule 2-02(b)(1) of Regulation 

S-X and Hackert caused those violations.

III.
16

In view of the allegations made by the Division of Enforcement, the Commission 

deems it necessary and appropriate in the public interest that public administrative and 

cease-and-desist proceedings be instituted to determine:

A. Whether the allegations set forth in Section II hereof are true and, in

connection therewith, to afford Respondent an opportunity to establish any defenses to such 

allegations; 

B. What, if any, remedial action is appropriate in the public interest against

Respondent pursuant to Section 8A of the Securities Act, Section 4C(a) of the Exchange 

Act, and Rule 102(e) of the Commission’s Rules of Practice; and 

C. Whether, pursuant to Section 8A of the Securities Act and Section 21C of

the Exchange Act, Respondent should be ordered to cease and desist from committing or 

causing violations of and any future violations of Rule 2-02(b)(1) of Regulation S-X.

IV.

IT IS ORDERED that a public hearing before the Commission for the purposes of 

taking evidence on the questions set forth in Section III hereof shall be convened not earlier 

than 30 days and not later than 60 days from service of this Order at a time and place to be 

fixed by further order of the Commission, pursuant to Rule 110 of the Commission’s Rules 

of Practice, 17 C.F.R. § 201.110.

IT IS FURTHER ORDERED that Respondent shall file an Answer to the allegations 

contained in this Order within twenty (20) days after service of this Order, as provided by 

Rule 220(b) of the Commission’s Rules of Practice, 17 C.F.R. § 201.220(b). 

IT IS FURTHER ORDERED that the Division of Enforcement and Respondent 

shall conduct a prehearing conference pursuant to Rule 221 of the Commission’s Rules of 

Practice, 17 C.F.R. § 201.221, within fourteen (14) days of service of the Answer. The 

parties may meet in person or participate by telephone or other remote means; following 

the conference, they shall file a statement with the Office of the Secretary advising the 

Commission of any agreements reached at said conference. If a prehearing conference was 

not held, a statement shall be filed with the Office of the Secretary advising the 

Commission of that fact and of the efforts made to meet and confer.

If any Respondent fails to file the directed Answer, or fails to appear at a hearing or 

conference after being duly notified, the Respondent may be deemed in default and the 

proceedings may be determined against him upon consideration of this Order, the 

allegations of which may be deemed to be true as provided by Rules 155(a), 220(f), 221(f) 

and 310 of the Commission’s Rules of Practice, 17 C.F.R. §§ 201.155(a), 201.220(f), 

201.221(f), and 201.310.

This Order shall be served forthwith upon Respondent by any means permitted by 

the Commission’s Rules of Practice.
17

The Commission finds that it would serve the interests of justice and not result in 

prejudice to any party to provide, pursuant to Rule 100(c) of the Commission’s Rules of 

Practice, 17 C.F.R. § 201.100(c), that notwithstanding any contrary reference in the Rules 

of Practice to service of paper copies, service to the Division of Enforcement of all 

opinions, orders, and decisions described in Rule 141, 17 C.F.R. § 201.141, and all papers 

described in Rule 150(a), 17 C.F.R. § 201.150(a), in these proceedings shall be by email to 

the attorneys who enter an appearance on behalf of the Division, and not by paper 

service. 

Attention is called to Rule 151(a), (b) and (c) of the Commission’s Rules of 

Practice, 17 C.F.R. § 201.151(a), (b) and (c), providing that when, as here, a proceeding is 

set before the Commission, all papers (including those listed in the following paragraph) 

shall be filed electronically in administrative proceedings using the Commission’s 

Electronic Filings in Administrative Proceedings (eFAP) system access through the 

Commission’s website, www.sec.gov, at http://www.sec.gov/eFAP. Respondent also must 

serve and accept service of documents electronically. All motions, objections, or 

applications will be decided by the Commission.

The Commission finds that it would serve the interests of justice and not result in 

prejudice to any party to provide, pursuant to Rule 100(c) of the Commission’s Rules of

Practice, 17 C.F.R. § 201.100(c), that notwithstanding any contrary reference in the Rules 

of Practice to filing with or disposition by a hearing officer, all filings, including those 

under Rules 210, 221, 222, 230, 231, 232, 233, and 250 of the Commission’s Rules of 

Practice, 17 C.F.R. §§ 201.210, 221, 222, 230, 231, 232, 233, and 250, shall be directed to 

and, as appropriate, decided by the Commission. This proceeding shall be deemed to be 

one under the 120-day timeframe specified in Rule of Practice 360(a)(2)(i), 17 C.F.R. § 

201.360(a)(2)(i), for the purposes of applying Rules of Practice 233 and 250, 17 C.F.R. §§ 

201.233 and 250.

The Commission finds that it would serve the interests of justice and not result in 

prejudice to any party to provide, pursuant to Rule 100(c) of the Commission’s Rules of

Practice, 17 C.F.R. § 201.100(c), that the Commission shall issue a decision on the basis of 

the record in this proceeding, which shall consist of the items listed at Rule 350(a) of the 

Commission’s Rules of Practice, 17 C.F.R. § 201.350(a), and any other document or item 

filed with the Office of the Secretary and accepted into the record by the Commission. The 

provisions of Rule 351 of the Commission’s Rules of Practice, 17 C.F.R. § 201.351, 

relating to preparation and certification of a record index by the Office of the Secretary or 

the hearing officer are not applicable to this proceeding.

The Commission will issue a final order resolving the proceeding after one of the 

following: (A) The completion of post-hearing briefing in a proceeding where the public 

hearing has been completed; (B) The completion of briefing on a motion for a ruling on the 

pleadings or a motion for summary disposition pursuant to Rule 250 of the Commission’s 

Rules of Practice, 17 C.F.R. § 201.250, where the Commission has determined that no 

public hearing is necessary; or (C) The determination that a party is deemed to be in default 
18

under Rule 155 of the Commission’s Rules of Practice, 17 C.F.R. § 201.155, and no public 

hearing is necessary. 

In the absence of an appropriate waiver, no officer or employee of the Commission 

engaged in the performance of investigative or prosecuting functions in this or any factually 

related proceeding will be permitted to participate or advise in the decision of this matter, 

except as witness or counsel in proceedings held pursuant to notice. Since this proceeding is 

not “rule making” within the meaning of Section 551 of the Administrative Procedure Act, it 

is not deemed subject to the provisions of Section 553 delaying the effective date of any 

final Commission action.
Client Name Balance

Sheet Date

Report

Release

Date

("RRD")

SEC Filing Hackert

Sign‐offs

within 45

Days after

RRD

Hackert

Sign‐offs

more than

45 Days

after RRD

Total

Hackert

Sign‐offs

after RRD

T

Ha

Sign

A

1 Operating Co. 1 Dec‐31‐11 Apr‐16‐12 S‐1 45 0 45 

2 Operating Co. 2 Jun‐30‐12 Sep‐28‐12 10‐K 22 14 36 

3 Operating Co. 3 Dec‐31‐12 Apr‐05‐13 10‐K 0 22 22 4 Operating Co. 4 Dec‐31‐12 Aug‐02‐13 8‐K/A 9 0 9 

5 Operating Co. 5 Dec‐31‐13 Apr‐01‐14 10‐K 39 6 45 6 Operating Co. 6 Dec‐31‐13 May‐01‐14 S‐1 0 34 34 

7 Operating Co. 7 Dec‐28‐13 Mar‐27‐14 10‐K 0 31 31 8 Operating Co. 8 Dec‐31‐13 Mar‐28‐14 10‐K 13 0 13 

9 Operating Co. 9 Dec‐31‐13 Mar‐31‐14 10‐K 10 0 10 

10 Operating Co. 3 Dec‐31‐13 Apr‐15‐14 10‐K 4 0 4 11 Operating Co. 10 Dec‐31‐13 Apr‐15‐14 10‐K3 0 3 12 Operating Co. 5 Dec‐31‐14 Mar‐17‐15 10‐K 80 0 80 13 Operating Co. 11 Dec‐31‐14 Mar‐31‐15 10‐K 76 0 76 14 Operating Co. 12 Dec‐31‐14 Dec‐07‐15 10‐K 0 43 43 15 Operating Co. 13 Dec‐31‐14 Mar‐11‐15 10‐K 41 0 41 

16 Operating Co. 1 Dec‐31‐14 Mar‐31‐15 10‐K 29 4 33 17 Operating Co. 8 Dec‐31‐14 Apr‐15‐15 10‐K 28 0 28 18 Operating Co. 9 Dec‐31‐14 Mar‐30‐15 10‐K 7 0 7 

19 Operating Co. 14 Dec‐31‐14 Apr‐14‐15 S‐4 3 0 3 

20 Operating Co. 15 Dec‐31‐14 Mar‐12‐15 10‐K 0 3 3 

21 Operating Co. 7 Jan‐03‐15 Mar‐19‐15 10‐K 0 7 7 

22 Operating Co. 11 Dec‐31‐15 Mar‐30‐16 10‐K 0 83 83 

23 Operating Co. 12 Dec‐31‐15 Jul‐29‐16 10‐K 19 4 23 24 Operating Co. 1 Dec‐31‐15 Mar‐30‐16 10‐K 0 32 32 25 Operating Co. 16 Dec‐31‐15 Feb‐18‐16 10‐K 24 0 24 26 Operating Co. 17 Dec‐31‐15 Dec‐04‐16 8‐K 16 0 16 27 Operating Co. 5 Dec‐31‐15 Mar‐15‐16 10‐K 0 5 5 28 Operating Co. 14 Dec‐31‐15 Mar‐10‐16 10‐K0 0 0 

29 Operating Co. 7 Jan‐02‐16 Mar‐17‐16 10‐K 0 1 1 30 Operating Co. 18 Mar‐31‐16 Jun‐21‐16 10‐K0 0 0 

Appendix A
Client Name Balance

Sheet Date

Report

Release

Date

("RRD")

SEC Filing Hackert

Sign‐offs

within 45

Days after

RRD

Hackert

Sign‐offs

more than

45 Days

after RRD

Total

Hackert

Sign‐offs

after RRD

T

Ha

Sign

A

31 Operating Co. 11 Dec‐31‐16 Mar‐23‐17 10‐K 83 3 86 32 Operating Co. 19 Dec‐31‐16 Mar‐24‐17 10‐K 63 11 74 33 Operating Co. 20 Dec‐31‐16 Mar‐28‐17 10‐K 39 0 39 34 Operating Co. 21 Dec‐31‐16 Feb‐07‐17 10‐K 30 0 30 35 Operating Co. 12 Dec‐31‐16 Apr‐14‐17 10‐K 13 11 24 36 Ault Alliance, Inc. Dec‐31‐16 Apr‐10‐17 10‐K 4 4 8 

37 Operating Co. 9 Dec‐31‐16 Mar‐31‐17 10‐K 5 0 5 

38 Operating Co. 14 Dec‐31‐16 Mar‐10‐17 10‐K 4 0 4 39 Operating Co. 38 Dec‐31‐16 Mar‐15‐17 10‐K 3 0 3 40 Operating Co. 22 Dec‐31‐17 Apr‐02‐18 10‐K 102 4 106 41 Ault Alliance, Inc. Dec‐31‐17 Apr‐18‐18 10‐K 0 101 101 

42 Operating Co. 12 Dec‐31‐17 Apr‐17‐18 10‐K 0 73 73 43 Operating Co. 23 Dec‐31‐17 Apr‐10‐18 S‐4 0 71 71 44 Operating Co. 11 Dec‐31‐17 Mar‐15‐18 10‐K 0 47 47 

45 Operating Co. 20 Dec‐31‐17 Mar‐22‐18 10‐K 7 0 7 46 Operating Co. 24 Dec‐31‐18 Sep‐27‐19 S‐1 0 153 153 

47 Operating Co. 25 Dec‐31‐18 Sep‐27‐19 S‐1 8 75 83 

48 Operating Co. 26 Dec‐31‐18 Sep‐27‐19 S‐1 24 54 78 49 Ault Alliance, Inc. Dec‐31‐18 Apr‐16‐19 10‐K 0 68 68 

50 Operating Co. 27 Dec‐31‐18 Sep‐27‐19 S‐1 1 63 64 

51 Operating Co. 20 Dec‐31‐18 Mar‐22‐19 10‐K 58 0 58 

52 Operating Co. 28 Dec‐31‐18 Sep‐27‐19 S‐1 0 58 58 

53 Operating Co. 23 Dec‐31‐18 Mar‐19‐19 10‐K 52 0 52 54 Operating Co. 12 Dec‐31‐18 Apr‐01‐19 10‐K 0 37 37 55 Operating Co. 29 Dec‐31‐18 Sep‐27‐19 S‐1 28 3 31 

56 Operating Co. 30 Dec‐31‐18 Nov‐12‐19 S‐4 0 24 24 

57 Operating Co. 31 Dec‐31‐18 Nov‐12‐19 S‐4 0 22 22 

58 Operating Co. 32 Dec‐31‐18 Nov‐12‐19 S‐4 0 20 20 

59 Operating Co. 33 Dec‐31‐18 Sep‐27‐19 S‐1 2 10 12 

60 Operating Co. 34 Mar‐31‐19 Dec‐27‐19 20‐F 37 9 46 

61 Operating Co. 35 Oct‐31‐19 Jan‐29‐20 10‐K 26 0 26 
Client Name Balance

Sheet Date

Report

Release

Date

("RRD")

SEC Filing Hackert

Sign‐offs

within 45

Days after

RRD

Hackert

Sign‐offs

more than

45 Days

after RRD

Total

Hackert

Sign‐offs

after RRD

T

Ha

Sign

A

62 Operating Co. 36 Dec‐31‐19 Mar‐23‐20 10‐K 5 0 5 

63 Ault Alliance, Inc. Dec‐31‐19 May‐29‐20 10‐K 1 27 28 64 SPAC 1 Dec‐31‐19 Jan‐31‐20 S‐1 15 0 15 65 SPAC 2 Dec‐31‐19 Mar‐06‐20 S‐1 13 0 13 

66 SPAC 3 Dec‐31‐19 Mar‐10‐20 S‐1 11 0 11 

67 SPAC 4 Dec‐31‐19 Mar‐13‐20 S‐1 8 0 8 

68 SPAC 5 Dec‐31‐19 Mar‐26‐20 10‐K 8 0 8 

69 SPAC 6 Dec‐31‐19 Apr‐08‐20 S‐1 17 0 17 70 SPAC 7 Dec‐31‐19 Aug‐06‐20 S‐1 12 0 12 71 SPAC 8 Dec‐31‐19 Sep‐25‐20 S‐1 16 0 16 72 SPAC 9 Nov‐30‐20 Dec‐11‐20 S‐1 7 14 21 

73 SPAC 10 Feb‐04‐20 Feb‐12‐20 S‐1 10 0 10 74 SPAC 11 Feb‐14‐20 Mar‐02‐20 S‐1 13 0 13 

75 SPAC 12 Mar‐03‐20 Mar‐10‐20 S‐1 12 0 12 

76 SPAC 13 Mar‐05‐20 Mar‐18‐20 S‐1 13 0 13 

77 SPAC 14 May‐01‐20 May‐08‐20 S‐1 0 5 5 

78 SPAC 16 Jun‐01‐20 Jun‐08‐20 S‐1 0 7 7 

79 SPAC 17 Jun‐30‐20 Jul‐08‐20 S‐1 0 1 1 

80 SPAC 18 Jun‐30‐20 Jul‐17‐20 S‐1 5 0 5 

81 SPAC 19 Jul‐07‐20 Jul‐24‐20 S‐1 0 11 11 82 SPAC 20 Jul‐15‐20 Jul‐20‐20 S‐1 4 80 84 

83 SPAC 21 Jul‐20‐20 Jul‐27‐20 S‐1 7 0 7 

84 SPAC 22 Jul‐20‐20 Jul‐27‐20 S‐1 8 0 8 85 SPAC 23 Jul‐20‐20 Aug‐04‐20 S‐1 19 39 58 86 SPAC 24 Aug‐03‐20 Aug‐10‐20 S‐1 14 0 14 

87 SPAC 26 Aug‐17‐20 Sep‐04‐20 S‐1 0 12 12 88 SPAC 27 Aug‐19‐20 Sep‐18‐20 S‐1 9 0 9 

89 SPAC 28 Aug‐20‐20 Oct‐27‐20 S‐1 21 0 21 

90 SPAC 30 Aug‐24‐20 Aug‐31‐20 S‐1 0 16 16 

91 SPAC 32 Aug‐28‐20 Oct‐02‐20 S‐1 0 10 10 

92 SPAC 33 Aug‐31‐20 Sep‐04‐20 S‐1 0 12 12 
Client Name Balance

Sheet Date

Report

Release

Date

("RRD")

SEC Filing Hackert

Sign‐offs

within 45

Days after

RRD

Hackert

Sign‐offs

more than

45 Days

after RRD

Total

Hackert

Sign‐offs

after RRD

T

Ha

Sign

A

93 SPAC 34 Sep‐03‐20 Sep‐15‐20 S‐1 8 0 8 

94 SPAC 35 Sep‐04‐20 Sep‐11‐20 S‐1 19 42 61 95 SPAC 37 Sep‐04‐20 Sep‐21‐20 S‐1 12 0 12 96 SPAC 39 Sep‐11‐20 Oct‐09‐20 S‐1 8 0 8 

97 SPAC 40 Sep‐15‐20 Sep‐21‐20 S‐1 8 15 23 98 SPAC 41 Sep‐15‐20 Sep‐28‐20 S‐1 4 0 4 

99 SPAC 42 Aug‐17‐20 Sep‐10‐20 S‐1 0 27 27 

100 SPAC 43 Sep‐30‐20 Oct‐14‐20 S‐1 0 18 18 

101 SPAC 44 Sep‐30‐20 Oct‐13‐20 S‐1 0 46 46 102 SPAC 45 Sep‐30‐20 Dec‐23‐20 S‐1 0 12 12 103 SPAC 46 Oct‐02‐20 Oct‐13‐20 S‐1 0 12 12 

104 SPAC 47 Oct‐02‐20 Oct‐16‐20 S‐1 0 24 24 

105 SPAC 48 Oct‐09‐20 Oct‐22‐20 S‐1 11 0 11 

106 SPAC 49 Oct‐13‐20 Oct‐21‐20 S‐1 10 0 10 

107 SPAC 50 Oct‐13‐20 Oct‐22‐20 S‐1 11 0 11 

108 SPAC 51 Oct‐31‐20 Nov‐19‐20 S‐1 16 0 16 

109 SPAC 52 Oct‐23‐20 Nov‐19‐20 S‐1 0 36 36 

110 SPAC 53 Oct‐28‐20 Nov‐17‐20 S‐1 5 0 5 

111 Operating Co. 35 Oct‐31‐20 Feb‐16‐21 10‐K 1 31 32 

112 SPAC 56 Nov‐04‐20 Nov‐20‐20 S‐1 11 0 11 113 SPAC 57 Nov‐18‐20 Nov‐30‐20 S‐1 0 13 13 

114 SPAC 58 Nov‐20‐20 Dec‐28‐20 S‐1 0 15 15 

115 SPAC 59 Nov‐21‐20 Dec‐09‐20 S‐1 0 8 8 

116 SPAC 60 Nov‐24‐20 Dec‐09‐20 S‐1 0 15 15 

117 SPAC 61 Nov‐20‐20 Dec‐07‐20 S‐1 0 11 11 

118 SPAC 62 Dec‐04‐20 Dec‐18‐20 S‐1 0 11 11 119 SPAC 63 Dec‐11‐20 Dec‐23‐20 S‐1 0 14 14 

120 SPAC 64 Dec‐11‐20 Jan‐13‐21 S‐1 0 2 2 

121 SPAC 65 Dec‐17‐20 Dec‐23‐20 S‐1 0 1 1 122 SPAC 66 Dec‐17‐20 Dec‐30‐20 S‐1 20 0 20 123 SPAC 67 Dec‐18‐20 Dec‐23‐20 S‐1 0 9 9 
Client Name Balance

Sheet Date

Report

Release

Date

("RRD")

SEC Filing Hackert

Sign‐offs

within 45

Days after

RRD

Hackert

Sign‐offs

more than

45 Days

after RRD

Total

Hackert

Sign‐offs

after RRD

T

Ha

Sign

A

124 SPAC 69 Dec‐31‐19 Jan‐31‐20 S‐1 9 0 9 

125 SPAC 70 Dec‐22‐20 Dec‐31‐20 S‐1 0 15 15 126 SPAC 71 Dec‐28‐20 Jan‐08‐21 S‐1 7 10 17 127 SPAC 18 Dec‐31‐20 Jan‐07‐21 S‐1 5 0 5 

128 SPAC 72 Dec‐31‐19 Feb‐18‐20 S‐10 0 0 

129 SPAC 73 Dec‐31‐20 Jan‐07‐21 S‐1 0 7 7 

130 SPAC 74 Dec‐31‐20 Jan‐07‐21 S‐1 0 13 13 

131 SPAC 75 Dec‐31‐20 Jan‐08‐21 S‐1 11 5 16 132 SPAC 76 Dec‐31‐20 Jan‐08‐21 S‐1 2 10 12 133 SPAC 27 Dec‐31‐20 Jan‐11‐21 S‐1 0 16 16 134 SPAC 32 Dec‐31‐20 Jan‐11‐21 S‐1 0 16 16 135 SPAC 78 Dec‐31‐20 Jan‐14‐21 S‐1 0 12 12 136 SPAC 79 Dec‐31‐20 Jan‐14‐21 S‐1 0 6 6 

137 SPAC 50 Dec‐31‐20 Jan‐15‐21 S‐1 0 14 14 

138 SPAC 80 Dec‐31‐20 Jan‐19‐21 S‐1 0 43 43 139 SPAC 81 Dec‐31‐20 Jan‐21‐21 S‐1 3 15 18 140 SPAC 82 Dec‐31‐20 Jan‐25‐21 S‐1 0 10 10 141 SPAC 83 Dec‐31‐20 Jan‐25‐21 S‐1 4 9 13 

142 SPAC 45 Dec‐31‐20 Jan‐26‐21 S‐1 0 8 8 

143 SPAC 68 Dec‐31‐20 Jan‐27‐21 S‐1 8 0 8 

144 SPAC 57 Dec‐31‐20 Feb‐05‐21 S‐1 0 15 15 

145 SPAC 84 Dec‐31‐20 Feb‐05‐21 S‐1 0 3 3 

146 SPAC 70 Dec‐31‐20 Feb‐10‐21 S‐1 0 11 11 147 SPAC 33 Dec‐31‐20 Feb‐19‐21 S‐1 0 6 6 

148 SPAC 3 Dec‐31‐20 Feb‐25‐21 S‐1 0 9 9 

149 SPAC 62 Dec‐31‐20 Feb‐25‐21 S‐1 0 5 5 

150 SPAC 7 Dec‐31‐20 Mar‐09‐21 S‐1 13 0 13 

151 SPAC 54 Dec‐31‐20 Mar‐25‐21 10‐K 1 0 1 

152 SPAC 86 Jan‐08‐21 Jan‐20‐21 S‐1 0 22 22 

153 SPAC 87 Jan‐15‐21 Feb‐03‐21 S‐1 0 20 20 

154 SPAC 88 Jan‐21‐21 Jan‐29‐21 S‐1 0 8 8 
Client Name Balance

Sheet Date

Report

Release

Date

("RRD")

SEC Filing Hackert

Sign‐offs

within 45

Days after

RRD

Hackert

Sign‐offs

more than

45 Days

after RRD

Total

Hackert

Sign‐offs

after RRD

T

Ha

Sign

A

155 SPAC 89 Jan‐21‐21 Jan‐29‐21 S‐1 0 21 21 

156 SPAC 90 Jan‐21‐21 Jan‐29‐21 S‐1 0 9 9 

157 SPAC 91 Jan‐25‐21 Feb‐01‐21 S‐1 9 12 21 

158 SPAC 92 Feb‐08‐21 Feb‐22‐21 S‐1 4 0 4 

159 SPAC 93 Feb‐15‐21 Feb‐16‐21 S‐1 25 21 46 160 SPAC 94 Feb‐23‐21 Mar‐15‐21 S‐1 0 8 8 

161 SPAC 95 Feb‐23‐21 Mar‐24‐21 S‐1 0 19 19 

162 SPAC 96 Feb‐25‐21 Mar‐12‐21 S‐1 3 0 3 

163 SPAC 97 Mar‐02‐21 Mar‐29‐21 S‐1 5 0 5 164 SPAC 98 Mar‐04‐21 Mar‐15‐21 S‐1 5 0 5 165 SPAC 100 Mar‐05‐21 Mar‐25‐21 S‐1 0 15 15 166 SPAC 101 Mar‐08‐21 Mar‐18‐21 S‐1 1 11 12 167 SPAC 103 Mar‐15‐21 May‐25‐21 S‐1 11 0 11 

168 SPAC 104 Mar‐22‐21 Aug‐03‐21 S‐1 16 0 16 

169 SPAC 105 Mar‐31‐21 Jun‐10‐21 S‐1 0 18 18 170 SPAC 102 Mar‐31‐21 Jun‐22‐21 S‐1 0 22 22 171 SPAC 106 Mar‐31‐21 Jun‐24‐21 S‐1 1 1 2 172 SPAC 107 Mar‐31‐21 Jul‐14‐21 S‐1 21 0 21 173 SPAC 108 Apr‐08‐21 Jul‐13‐21 S‐1 14 1 15 174 SPAC 109 Apr‐09‐21 Jul‐19‐21 S‐1 16 0 16 

175 SPAC 110 Apr‐19‐21 Jul‐02‐21 S‐1 0 19 19 

176 SPAC 111 May‐28‐21 Jul‐02‐21 S‐1 22 14 36 

177 SPAC 112 May‐17‐21 Jul‐14‐21 S‐1 0 4 4 

178 SPAC 114 Jun‐10‐21 Jul‐30‐21 S‐1 12 12 24 

179 SPAC 115 Jun‐20‐21 Jul‐09‐21 S‐1 13 0 13 

180 SPAC 117 Jun‐30‐21 Nov‐12‐21 S‐1 7 0 7 181 SPAC 17 Jun‐30‐21 Dec‐17‐21 S‐1 16 0 16 

182 SPAC 118 Jul‐31‐21 Oct‐13‐21 S‐1 0 13 13 

183 SPAC 119 Jul‐18‐21 Oct‐04‐21 S‐1 0 9 9 

184 SPAC 120 Aug‐18‐21 Oct‐11‐21 S‐1 0 12 12 185 SPAC 19 Dec‐31‐20 Feb‐19‐21 S‐1 0 11 11 
Client Name Balance

Sheet Date

Report

Release

Date

("RRD")

SEC Filing Hackert

Sign‐offs

within 45

Days after

RRD

Hackert

Sign‐offs

more than

45 Days

after RRD

Total

Hackert

Sign‐offs

after RRD

T

Ha

Sign

A

186 SPAC 3 Dec‐31‐21 Mar‐31‐22 10‐K 9 0 9 

187 Operating Co. 35 Oct‐31‐18 Jan‐28‐19 10‐K 10 0 10 
Client Name Balance

Sheet Date

Report

Release

Date

("RRD")

SEC Filing Hackert

Sign‐offs

more than

45 Days

after RRD

AS 3 Memo

1 Operating Co. 2 Jun‐30‐12 Sep‐28‐12 10‐K 14

2 Operating Co. 3 Dec‐31‐12 Apr‐05‐13 10‐K 22

3 Operating Co. 5 Dec‐31‐13 Apr‐01‐14 10‐K 6

4 Operating Co. 6 Dec‐31‐13 May‐01‐14 S‐1 34 X5 Operating Co. 7 Dec‐31‐13 Mar‐27‐14 10‐K 31

6 Operating Co. 12 Dec‐31‐14 Dec‐07‐15 10‐K 43 X

7 Operating Co. 1 Dec‐31‐14 Mar‐31‐15 10‐K4 X

8 Operating Co. 15 Dec‐31‐14 Mar‐12‐15 10‐K 3

9 Operating Co. 7 Jan‐03‐15 Mar‐19‐15 10‐K 7

10 Operating Co. 11 Dec‐31‐15 Mar‐30‐16 10‐K 83 X

11 Operating Co. 12 Dec‐31‐15 Jul‐29‐16 10‐K 4 X

12 Operating Co. 1 Dec‐31‐15 Mar‐30‐16 10‐K 32 X

13 Operating Co. 5 Dec‐31‐15 Mar‐15‐16 10‐K5 X

14 Operating Co. 9 Dec‐31‐15 Mar‐29‐16 10‐K0 X

15 Operating Co. 7 Jan‐02‐16 Mar‐17‐16 10‐K1 X

16 Operating Co. 11 Dec‐31‐16 Mar‐23‐17 10‐K 3

17 Operating Co. 19 Dec‐31‐16 Mar‐24‐17 10‐K 11 X

18 Operating Co. 12 Dec‐31‐16 Apr‐14‐17 10‐K 11

19 Ault Alliance, Inc. Dec‐31‐16 Apr‐10‐17 10‐K4 X

20 Operating Co. 22 Dec‐31‐17 Apr‐02‐18 10‐K4 X

21 Ault Alliance, Inc. Dec‐31‐17 Apr‐18‐18 10‐K 101 X

22 Operating Co. 12 Dec‐31‐17 Apr‐17‐18 10‐K 73 X

23 Operating Co. 23 Dec‐31‐17 Apr‐10‐18 S‐4 71 X24 Operating Co. 11 Dec‐31‐17 Mar‐15‐18 10‐K 47

25 Operating Co. 35 Oct‐31‐18 Jan‐28‐19 10‐K0 X

26 Operating Co. 24 Dec‐31‐18 Sep‐27‐19 S‐1 153 X

27 Operating Co. 25 Dec‐31‐18 Sep‐27‐19 S‐1 75 X

28 Operating Co. 26 Dec‐31‐18 Sep‐27‐19 S‐1 54 X

29 Ault Alliance, Inc. Dec‐31‐18 Apr‐16‐19 10‐K 68 X

30 Operating Co. 27 Dec‐31‐18 Sep‐27‐19 S‐1 63 X

Appendix B
Client Name Balance

Sheet Date

Report

Release

Date

("RRD")

SEC Filing Hackert

Sign‐offs

more than

45 Days

after RRD

AS 3 Memo

31 Operating Co. 28 Dec‐31‐18 Sep‐27‐19 S‐1 58 X

32 Operating Co. 12 Dec‐31‐18 Apr‐01‐19 10‐K 37 X

33 Operating Co. 29 Dec‐31‐18 Sep‐27‐19 S‐13 X

34 Operating Co. 30 Dec‐31‐18 Nov‐12‐19 S‐4 24 X

35 Operating Co. 31 Dec‐31‐18 Nov‐12‐19 S‐4 22 X

36 Operating Co. 32 Dec‐31‐18 Nov‐12‐19 S‐4 20 X

37 Operating Co. 33 Dec‐31‐18 Sep‐27‐19 S‐1 10 X

38 Operating Co. 37 Dec‐31‐18 Feb‐05‐19 F‐40 X

39 Operating Co. 34 Mar‐31‐19 Dec‐27‐19 20‐F9 X

40 Operating Co. 18 Mar‐31‐19 Jul‐01‐19 10‐K0 X

41 Operating Co. 35 Oct‐31‐19 Jan‐29‐20 10‐K0 X

42 Ault Alliance, Inc. Dec‐31‐19 May‐29‐20 10‐K 27 X43 SPAC 9 Nov‐30‐20 Dec‐11‐20 S‐1 14 X

44 SPAC 14 May‐01‐20 May‐08‐20 S‐1 5

45 SPAC 15 Jun‐08‐20 Jun‐12‐20 S‐10 X46 SPAC 16 Jun‐01‐20 Jun‐08‐20 S‐17 X47 SPAC 17 Jun‐30‐20 Jul‐08‐20 S‐11 X48 SPAC 19 Jul‐07‐20 Jul‐24‐20 S‐1 11 X

49 SPAC 20 Jul‐15‐20 Jul‐20‐20 S‐1 80 X

50 SPAC 23 Jul‐20‐20 Aug‐04‐20 S‐1 3951 SPAC 26 Aug‐17‐20 Sep‐04‐20 S‐1 12

52 SPAC 30 Aug‐24‐20 Aug‐31‐20 S‐1 16 X53 SPAC 32 Aug‐28‐20 Oct‐02‐20 S‐1 10 X54 SPAC 33 Aug‐31‐20 Sep‐04‐20 S‐1 12

55 SPAC 35 Sep‐04‐20 Sep‐11‐20 S‐1 42

56 SPAC 40 Sep‐15‐20 Sep‐21‐20 S‐1 15 X57 SPAC 42 Aug‐17‐20 Sep‐10‐20 S‐1 27 X

58 SPAC 43 Sep‐30‐20 Oct‐14‐20 S‐1 18 X59 SPAC 44 Sep‐30‐20 Oct‐13‐20 S‐1 46 X60 SPAC 45 Sep‐30‐20 Dec‐23‐20 S‐1 12 X61 SPAC 46 Oct‐02‐20 Oct‐13‐20 S‐1 12 X
Client Name Balance

Sheet Date

Report

Release

Date

("RRD")

SEC Filing Hackert

Sign‐offs

more than

45 Days

after RRD

AS 3 Memo

62 SPAC 47 Oct‐02‐20 Oct‐16‐20 S‐1 24 X63 SPAC 52 Oct‐23‐20 Nov‐19‐20 S‐1 36 X64 Operating Co. 35 Oct‐31‐20 Feb‐16‐21 10‐K 31 X

65 SPAC 57 Nov‐18‐20 Nov‐30‐20 S‐1 13 X66 SPAC 58 Nov‐20‐20 Dec‐28‐20 S‐1 15 X

67 SPAC 59 Nov‐21‐20 Dec‐09‐20 S‐18 X

68 SPAC 60 Nov‐24‐20 Dec‐09‐20 S‐1 15 X

69 SPAC 61 Nov‐20‐20 Dec‐07‐20 S‐1 11

70 SPAC 62 Dec‐04‐20 Dec‐18‐20 S‐1 11 X

71 SPAC 64 Dec‐11‐20 Jan‐13‐21 S‐12 X72 SPAC 63 Dec‐11‐20 Dec‐23‐20 S‐1 14 X73 SPAC 65 Dec‐17‐20 Dec‐23‐20 S‐11 X74 SPAC 67 Dec‐18‐20 Dec‐23‐20 S‐19 X75 SPAC 70 Dec‐22‐20 Dec‐31‐20 S‐1 15 X

76 SPAC 71 Dec‐28‐20 Jan‐08‐21 S‐1 10 X77 Ault Alliance, Inc. Dec‐31‐20 Apr‐15‐21 10‐K0 X

78 SPAC 73 Dec‐31‐20 Jan‐07‐21 S‐17 X

79 SPAC 74 Dec‐31‐20 Jan‐07‐21 S‐1 13 X80 SPAC 75 Dec‐31‐20 Jan‐08‐21 S‐1 581 SPAC 76 Dec‐31‐20 Jan‐08‐21 S‐1 10 X

82 SPAC 27 Dec‐31‐20 Jan‐11‐21 S‐1 16

83 SPAC 32 Dec‐31‐20 Jan‐11‐21 S‐1 16 X

84 SPAC 78 Dec‐31‐20 Jan‐14‐21 S‐1 12 X85 SPAC 79 Dec‐31‐20 Jan‐14‐21 S‐16 X86 SPAC 50 Dec‐31‐20 Jan‐15‐21 S‐1 14 X87 SPAC 80 Dec‐31‐20 Jan‐19‐21 S‐1 43 X88 SPAC 81 Dec‐31‐20 Jan‐21‐21 S‐1 15 X

89 SPAC 82 Dec‐31‐20 Jan‐25‐21 S‐1 10 X

90 SPAC 83 Dec‐31‐20 Jan‐25‐21 S‐19 X91 SPAC 45 Dec‐31‐20 Jan‐26‐21 S‐18 X92 SPAC 57 Dec‐31‐20 Feb‐05‐21 S‐1 15 X
Client Name Balance

Sheet Date

Report

Release

Date

("RRD")

SEC Filing Hackert

Sign‐offs

more than

45 Days

after RRD

AS 3 Memo

93 SPAC 84 Dec‐31‐20 Feb‐05‐21 S‐13 X

94 SPAC 70 Dec‐31‐20 Feb‐10‐21 S‐1 11 X

95 SPAC 33 Dec‐31‐20 Feb‐19‐21 S‐16 X

96 SPAC 62 Dec‐31‐20 Feb‐25‐21 S‐15 X

97 SPAC 63 Dec‐31‐20 Jan‐25‐21 S‐10 X

98 SPAC 3 Dec‐31‐20 Feb‐25‐21 S‐19 X

99 SPAC 64 Dec‐31‐20 Feb‐26‐21 S‐10 X

100 SPAC 87 Jan‐15‐21 Feb‐03‐21 S‐1 20 X101 SPAC 88 Jan‐21‐21 Jan‐29‐21 S‐18 X102 SPAC 89 Jan‐21‐21 Jan‐29‐21 S‐1 21 X103 SPAC 90 Jan‐21‐21 Jan‐29‐21 S‐19 X104 SPAC 91 Jan‐25‐21 Feb‐01‐21 S‐1 12105 SPAC 93 Feb‐15‐21 Feb‐16‐21 S‐1 21 X106 SPAC 94 Feb‐23‐21 Mar‐15‐21 S‐18 X

107 SPAC 95 Feb‐23‐21 Mar‐24‐21 S‐1 19 X

108 SPAC 97 Mar‐02‐21 Mar‐29‐21 S‐10 X109 SPAC 100 Mar‐05‐21 Mar‐25‐21 S‐1 15 X

110 SPAC 101 Mar‐08‐21 Mar‐18‐21 S‐1 11 X

111 SPAC 105 Mar‐31‐21 Jun‐10‐21 S‐1 18 X

112 SPAC 102 Mar‐31‐21 Jun‐22‐21 S‐1 22 X

113 SPAC 106 Mar‐31‐21 Jun‐24‐21 S‐11 X

114 SPAC 108 Apr‐08‐21 Jul‐13‐21 S‐11 X115 SPAC 110 Apr‐19‐21 Jul‐02‐21 S‐1 19 X116 SPAC 111 May‐28‐21 Jul‐02‐21 S‐1 14 X

117 SPAC 112 May‐17‐21 Jul‐14‐21 S‐14 X

118 SPAC 114 Jun‐10‐21 Jul‐30‐21 S‐1 12 X119 SPAC 118 Jul‐31‐21 Oct‐13‐21 S‐1 13 X

120 SPAC 119 Jul‐18‐21 Oct‐04‐21 S‐1 9

121 SPAC 120 Aug‐18‐21 Oct‐11‐21 S‐1 12122 SPAC 19 Dec‐31‐20 Feb‐19‐21 S‐1 11 X123 SPAC 86 Jan‐08‐21 Jan‐20‐21 S‐1 22