Saturday, March 28, 2015

HTGZ: Partial Call/Bought Back 100 CSG at $7.74-REIT Basket Strategy (Trading Core Position)/ Bought 50 GJT at $17.97-Roth IRA and Sold 100 of 520+ BTZ at $13.65/Swiss Re Report: Cost of Financial Repression

Stable Vix Pattern (Bullish):
Links to SeekingAlpha Instablog, Articles and Comments:

South Gent's Instablog | Seeking Alpha

South Gent's Articles | Seeking Alpha

South Gent's Comments | Seeking Alpha

Recent Developments:

I suspect that the strong dollar and overall tepid overseas growth is adversely impacting orders for U.S. durable goods. New orders for durable goods declined by $3.2B in February of 1.4% to $231.2B. Excluding transportation, new orders decreased by .4%.

Swiss RE published a study that estimates savers have lost $470B in interest rate income (2008-2013) due to the FED's abnormal monetary policies. EU and U.S. insurers have lost about $400B in yield income, which constitutes in effect an annual "tax" of "roughly 0.8% of total financial assets on average, lowering long-term investor's capacity to channel funds to the real economy".  Swiss Re The full report can be downloaded at the preceding link.

A report from Deutsche Bank, reprinted in The Big Picture blog, contains data highlighting wage inflation when taking into account hourly earnings plus other forms of compensation.

The government's third estimate of 4th quarter real GDP remained unchanged at 2.2%. News Release: Gross Domestic Product Real personal consumption expenditures rose 4.4% in the 4th quarter, up from 3.2% in the third.

Realty Income (own) will be added to the S & P 500

S&P 500 2014 Buybacks Post 16.3% Increase 

Partial Issuer Call: Hercules Technology Growth Capital Inc. 7% Senior  Notes due 2019 (HTGZ )

Hercules Technology Growth Capital (HTGC) announced its intention to redeem $20M of its 7% unsecured senior note maturing in 2019, or about 24% of the outstanding principal amount. HTGC intends to make additional partial redemptions through 2015.

I own 200 HTGZ shares, with 100 shares owned in a Fidelity taxable account and another 100 shares owned in a Vanguard Roth IRA: Item # 3 Bought 100 HTGZ at $24.6-ROTH IRA (5/25/12 Post)Item # 4 Bought 100 HTGZ at $24.63 (5/4/12 Post)

When Fidelity receives a partial redemption notice, it will separate the position into shares subject to that redemption and the shares remaining after redemption:

Taxable Account: 24 out of 100 Shares

Vanguard also segregated the shares subject to redemption:

Roth IRA: 23 out of 100 Shares

While I have not ever tried to sell the "when issue money" shares, I suspect that I could not do so unless the shares were not redeemed for whatever reason and journaled back. Many years ago, before the shares subject to redemption were journaled, I sold an entire position unaware of the partial call and then had to buy back the shares subject to redemption.

I have no choice but to allow this happen. There is no reason for me to sell any shares, since I will be receiving par value, which will result in a small profit, plus accrued interest for any shares redeemed without having to incur a brokerage commission.

1. Bought Back 100 CSG at $7.74-Previously Sold at $8.76 (Equity REIT Common and Preferred Stock Basket Strategy)(see Disclaimer): 

This purchase brings me back up to 478+ CSG shares.

Snapshot of Trade:

CSG went ex dividend for its monthly distribution on 5/26/15, the day after my purchase.

CSG as a Trading Core Position in My REIT Basket:

Since this trade was an example of a trading system that I use, I wanted to explain that system in more detail.

In a recently published SA Instablog, I identified the securities that are presently "core" and "trading core" positions in my REIT sector basket strategy. Update For REIT Basket Strategy As Of 3/19/15 - South Gent | Seeking Alpha

For core positions, I am not likely to sell any shares without a major long term adverse event, since my initial purchase price is viewed favorably, and the stock is considered to be suitable for a long term hold {e.g. Item # 6 Bought100 Realty Income (O) at $36.96 (12/10/13 Post)Item # 2 Bought: 100 OHI at $29.85 (12/23/13 Post)}

For a "trading core position", I am unlikely to sell all shares, unless there is a fundamental adverse development that is likely to impact the company long term.

Instead, I will trade the position by selling my highest cost shares profitably into rallies and then wait for an opportunity to buy back the shares.

I will frequently use a two year chart when making the decision to pare or to buy back shares. CSG Interactive Stock Chart That chart revealed that a price over $8.5 was a decent exit point for a pare, and I sold 100 of my highest cost shares at $8.76 during the early February 2015 price spurt. I would then set a price target for a possible repurchase.

In retrospect, I was not satisfied with my initial CSG purchase price, one reason for placing it in the trading core category, and started to average down soon after my initial 150 lot purchase at $8.4 (11/19/13 Post).

I forgot that I owned 150 shares in that highest cost lot and instead sold 100 CSG at $8.76 (2/28/15 Post). That was an Old Geezer type breakdown in this trading system. I placed a limit order to buy back that 100 share lot at $7.74, which was filled on 3/26/14. In that account, I now own 371+ shares, with the balance owned in a Roth IRA account. At Fidelity, I can enter an All or None GTC order for a 100 share lot.

Other purchases in this account are discussed in Item # 5 Added 100 CSG at $7.85-Average Down (8/29/14 Post) and in Item # 3 Bought  100 CSG at $7.73 (April 2014).

My average cost per share in the taxable account is now $7.89. I will be able to reduce it some by unloading the remaining 50 shares bought at $8.4, but I am in no hurry to do so.

When I decide to unload that 50 share lot at a profit, I will probably include my highest cost shares purchased with dividends, provided their disposition will lower my average cost per share and can be sold at a profit which would increase the value of the original dividend.

For taxable accounts, I am also reducing my tax obligation by selling the highest cost shares. The primary goals for a trading core position are to use the stock's volatility to lower my average cost over a long period of time while realizing some profits along the way including the harvesting of dividends used to purchase shares.

Company Description: As of 12/31/14 Chambers Street Properties (CSG) is an internally managed REIT that owns or has majority interests in 128 industrial and office properties located in 19 states and western Europe.

Of those properties, 29 are owned by non-consolidated joint ventures:

Property Portfolio: Pictures of the properties can be found at Chambers' website.

About 76.2% of the portfolio is subject to triple net leases, where the lessee is responsible for property taxes, insurance and maintenance costs that would normally be paid by the lessor.

Total rentable square feet for the 128 properties was 37,740,832 as of 12/31/14.

CSG has been moving toward a higher concentration of industrial properties and has eliminated its retail exposure. Occupancy was at 98.3% as of 12/31/14.

Map of Industrial Properties: CSG makes a point in its investor presentation that the industrial properties are located near major logistics corridors, as shown in this map:

About 10.2% of the total portfolio is located in the U.K. and western Europe. Those properties are 100% triple net leased (12 industrial; 1 Office). The one office property is located in London.

Sourced: SEC Filed Investor Presentation February 2015

Major Tenants as of 12/31/2014 (sourced: page 29, 2014 10-K):

Amazon has a 9.9% weighting.
Major Tenants Page 29, 2014 10-K

Investment grade tenants accounted for 55.4% of annualized base rent, with 8.7% provided by non-investment grade tenants. The remaining percentage originates from unrated tenants. Page 16-Supplemental Information Package

CSG's corporate issuer rating is Baa3 by Moody's and BBB- by S & P. Both of those ratings are investment grade, but only one notch above junk.

Moody's Report-Baa3

ALL SEC Filings for CSG

Dividends: Chambers is currently paying a monthly dividend of $.0425 per share, up from .042 effective for the distribution paid last February. Dividends

At that monthly penny rate, the dividend yield would be about 6.59% at a total cost of $7.74 per share.

As with other pass through entities where no federal income tax is paid at the corporate level, CSG's 2014 distributions were not classified as qualified dividends. Chambers Street Properties Announces 2014 Tax Treatment of Distributions

2014 Dividends=$.504 Per Share
Qualified: Zero
Ordinary Dividends: $.32004
Capital Gains: $.06444
Unrecaptured 1250 Gain: $.02496
Return of Capital: $.11952

During 2014, CSG realized a gain of $21.2M related to the sale of properties.

The $.11952 per share classified as ROC will reduce the cost basis by an equivalent amount. If the shares are held in a taxable account for over a year, and are sold for a long term capital gain, then that is the only meaningful way to achieve a 15% maximum tax rate on distributions made by REITs.

Since I am retired with no pension other than social security and have no earned income anymore, I am consequently in a lower tax bracket than when I had earned income. I am no longer concerned about making a distinction between qualified and non-qualified dividends when selecting securities for purchase in taxable accounts for that reason and others. Instead, I am more focused on income generation and capital preservation. Even if I exceed a 15% marginal rate now, the taxes associated with REIT distributions are reduced by ROC and capital gains classifications, and neither of those classifications are relevant in an IRA.

Chart: The company was formed in 2004 following a private placement of shares. CSG started to trade as a public company in May 2013.

On the first day of trading, the shares opened and closed at $10 and thereafter cratered to $7.21 (8/21/13). CSG Interactive Stock Chart

The shares started to trade at a difficult period for REITs in general, as interest rates started to spike in early May 2013. The ten year rose from 1.66% (5/2/13) to 3.04% by 12/31/13. Daily Treasury Yield Curve Rates

The shares then spiked up to $9.5, but that rally was short circuited in late October 2013, with the shares falling again. Subsequent to that last spike down which formed multiple bottoms in the $7.5 to $7.65 range, the shares have mostly traded in a whipsaw $7.5 to $8.5 channel.

Last Earnings Report: For the 2014 4th quarter, CSG reported CORE FFO of $.18 per share, up 6.3% from the 2013 4th quarter. The core FFO number for 2014 increased 3.4% to $.69 per share.

FFO for the quarter was $.14, negatively impacted by a $5.2M severance expense related to the CEO's planned retirement.

I view it as important for valuation purposes and to determine the appropriate payout ratios and dividend growth potential to see exactly how the company calculates FFO, Core FFO, and AFFO. The AFFO number will frequently be a cash available for distribution number and will consequently be more relevant than FFO for those purposes. The following table shows how CSG arrives at those three numbers:

The AFFO calculation takes the Core FFO number, which excludes the CEO's severance package costs, acquisition related costs and costs related to the early extinguishment of debt, and then makes a number of positive and negative adjustments to that number. The most important deductions involve $4.306M for "recurring capital expenditures" and $.785M for the pro-rata share of "recurring capital expenditures" made in the joint ventures. There is also a deduction for straight line rent, a difficult concept to understand for those without any training in accounting and whose careers did not relate to real estate.

Page 8 Supplemental Package

I am willing to make the adjustment to FFO for the CEO's severance package costs. That item is non-recurring.

To arrive at an appropriate cash flow number, I would not exclude acquisition related and debt refinancing charges, since those costs are recurring IMO.

I certainly would exclude recurring capital expenditures from FFO.

I would exclude straight line rent based on my understanding of that accounting concept.

A back of the envelope computation leaves me with $38.433M in Core Funds from Operations, rather than the $41.528M shown by the company and consequently a lower in AFFO number of $34.307.

That gives me about  a $.1448 per share AFFO number for the 4th quarter rather than the $.15 shown by the company. This difference is simply based on my opinion about what I personally consider to be the appropriate free cash flow number, and is not a criticism of CSG's accounting.

Through the preceding adjustments, I reduced the 2014 AFFO number from $151.343M to $148.594M by deducting acquisition related and debt extinguishment expenses for the year. That reduces 2014 AFFO per share to $.6273 from $.64.

Using the $.6273 number, the TTM P/AFFO is about 12.339 based on a total cost of $7.74. For those inclined to use the 2014 $.69 core FFO per share number, and I am not going to use that one for the reasons explained above, the TTM P/FFO would be about 11.22. Either number suggests a reasonable valuation at the $7.74 price.

The funds available for distribution number in relation to the dividend gives the investor a better number to judge the sustainability of the current dividend and the REIT's ability to increase it.

I noted in a recent comment here at SA that a dividend payment in excess of FAD will often lead to a dividend cut, which was the case for Washington REIT (WRE) and Commonwealth REIT. Many investors insist on using FFO rather than FAD, even though the former number will often provide a misleading or inaccurate picture of cash flow available for distribution which is the sine qua non of why REIT investors focus on cash flow rather than GAAP net income. FAD is sometimes referred to as CAD or just AFFO  (see e.g. my discussion in an October 2012 blog: Commonwealth REIT: FFO and CAD Distinction)

Sourced:  SEC Filed Press Release
SEC Filed 4th Quarter Supplemental Package

Q4 2014 Results - Earnings Call Transcript | Seeking Alpha

Guidance for 2015: The company estimated 2015 core FFO of $.68 to $.71, close to flat compared to 2014. That guidance does not include the effect of unannounced property additions and dispositions. This lackluster guidance was included in the earnings release that was published before the market opened on 2/25/15. The shares closed at C$8.3 on 2/25.

Rationale: I am trying to keep this section simple and to focus just on the core reasons supporting a purchase.

For CSG, the valuation is reasonable and the current dividend yield is good in a world without any risk free yield. The dividend yield, coupled with immaterial dividend growth, would not look so hot when and if a FDIC insured savings account yields 4%, at least for an investor with my risk profile, overall financial condition and age.

I hope to increase my total returns over time by opportunistic trades.

I may buy another 100 shares on a price dip close to $7.25. I will sell the highest cost 50 share along with some higher cost shares purchased with dividends at or above $8.75.  Most likely, I would sell the reinvested dividend shares bought at over $8 which can be done profitably at that target price.

Risks/Issues: The company discusses risks incident to its operations starting at page 5 of its recently filed 2014 Annual Report: 2014 10-K I believe that an investor needs to review that kind of material, which is too lengthy to summarize here anyway.

Chambers will need to grow AFFO at a faster pace that will increase its ability to grow the dividend. With lackluster growth anticipated for 2015, I would not anticipate a material dividend increase and would expect a range bound stock price that will be more influenced by interest rate movements than the company's reports, assuming they are in line with that lackluster forward guidance mentioned above.

Lexington REIT has the same fundamental problem which explains in my opinion its low P/AFFO ratio.  Added To LXP At $9.85-Roth IRA - South Gent | Seeking Alpha I also have that stock in my "trading core position". The purchase at $9.85 replaced 50 of the 54+ shares sold at $11.44 Vanguard Roth IRA.

The European properties create some currency risks.

There is some concentration risk as well (e.g. Amazon).

With short term interest rates going up, the cost of CSG's sizable floating rate debt obligations will increase in tandem with the federal funds rate:

Page 56 2014 10-K

2. Sold 100 BTZ at $13.65 Roth IRA (see Disclaimer): I still own 420+ shares in another Roth IRA, but I quit reinvesting the dividend after the January 2015 payment.

Snapshot of Trade:

Snapshot of Profit:

2015 Roth IRA 100 BTZ  +$23.77
Item # 1 Added 100 of the Bond CEF BTZ at $13.25-Roth IRA (12/9/14 Post)

Dividends: $32.21

Total Return: $55.98 or 4.2% (holding period 3+months)

Prior Trades: I was just using this fund to generate cash flow in a taxable account, and I successfully exited the position profitably. Item # 4 Sold 361+BTZ at $13.45-Taxable Account (10/21/14 Post)(profit snapshot=+116.91). Snapshots of earlier profits, totaling $413.8, can be found in Item # 3t Added 50 BTZ at $12.35 (8/31/13 Post)

I also sold some higher cost shares held in the regular IRA earlier this year: Item # 8 Sold IRA: 210+BTZ at $13.62 (3/17/14 Post)

Trading Profits: $554.48 (excludes dividends)

Security Description: The BlackRock Credit Allocation Income Trust (BTZ) is a closed end leveraged bond fund that is weighted in investment grade bonds, though the fund has a significant weighting in junk rated bonds.

Data on Day of Sell (3/24/15):
Closing Net Asset Value Per Share: $15.3
Closing Market Price: $13.63
Discount: -10.92
Average Discounts:
1 Yr.: -12.24%
3 Yr:  -10.91%
5 Yr:  -11.2%

Sourced: CEFConnect Page for BTZ

Sponsor's Website: Credit Allocation Income Trust-BTZ  

According to the sponsor, the effective duration was 6.08 years as of 2/27/15, with a leverage ratio of 29.81%.  

A duration of 6.08 years provides the investor with a rule of thumb about the potential impact of interest rate changes on the bond fund's portfolio. A 1% rise in rates would likely cause a 6.08% decline in value, while a 2% rise in rates would generate close to a 12% decline in value. Conversely, a 1% decline in rates would result in about a a 6.08% increase in value, as more fully explained in the previous two links.

Rationale: The discount had narrowed almost 2% from my purchase which gave me a profit after harvesting 4 monthly dividend payments. I am also anticipating a rise in interest rates that will hopefully give me a more advantageous entry point than my last purchase.

3. Bought 50 GJT at $17.97-Roth IRA (see Disclaimer): I paired this security with the potentially long term first mortgage bond, ELB, discussed in the last post: 

Snapshot of Trade:

This security is thinly traded and typically has a large bid/ask spread. Limit orders have to be used. Since I was just buying a 50 share lot, I simply hit the ask price with a limit order rather than fooling with multiple attempts to secure a lower price with an odd lot limit order that can have some unfortunate results when the security is so thinly traded (e.g. a fill of 1 share which has happened to me when I tried a limit order at the bid price).

Fidelity does not allow its customers to purchase this type of security. Fidelity Brokerage Extends Denial of Trading Opportunities to Synthetic Floaters I am not aware of another brokerage firm that prevents customers from buying synthetic floaters. That is only one of several categories of exchange traded bonds that are off limits to Fidelity customers.

GJT is one unusual exchange traded bond and is probably an inappropriate for most individual investors. The name itself reeks of complexity.

Security Description: Synthetic Fixed-Income Securities Inc. STRATS Trust for Allstate Corp. Securities, Series 2006 (GJT) is a Synthetic Floater in the Trust Certificate form of legal ownership.

This security makes monthly interest payments at a .8% float over the 3 month treasury bill on a $25 par value, up to a maximum rate of 8%.

The maximum yield would consequently be hit with a three month treasury bill rate of 7.2%. At a $17.97 total cost per trust certificate, the maximum yield would be 11.13% (.08% x. $25 par value=$2 ÷$17.97=11.13%). At a zero 3 month T Bill, the yield would be about 1.11%, which is close to where it is now. Until maturity, the actual yield will move up and down between 1.11% to 11.13%, but the yield is not going to increase until the FED starts to raise the FF rate.  

Since the Federal Reserve launched its Jihad against Savers back in 2008, the 3 month treasury bill has hovered just a tiny faction above zero. This long term chart does have a line starting in late 2008 for the 3 month T bill yield but it is indistinguishable from the box line:

3-Month Treasury Constant Maturity Rate-St. Louis Fed

So, for the past six years or so, this security has in effect paid a .8% float over a barely detectable slither above zero.

The underlying security owned by the trust is a 5.95% senior unsecured Allstate bond maturing on 4/1/36. According to FINRA, that bond is currently rated A3 by Moody's and A- by S & P. On 3/25/15, that bond closed at a 33.57% premium to its par value.

If Allstate pays the principal amount on 4/1/36, the trustee would then redeem the trust certificates at their $25 par values with the proceeds. In that eventuality, there would be a built in profit for an owner buying at $17.97 and holding the security until that date.

If I assumed that GJT never paid 1% from now until the underlying bond's maturity date, and further assumed a total cost per trust certificate  of $17.95, the harvesting of the discount at maturity would at least raise the YTM to 2.81% using the Morningstar Bond Yield to Maturity Calculator The underlying bond at the 133.57 price only has a 3.81% YTM.

If I changed the average annual current yield of GJT to 2% (hit with the three month treasury bill at just 1.2% due to the .8% spread), that brings the YTM up to 4.07% and to 6.68% at an average annual yield of 4% (hit at 3.2%)

The owners of GJT do not currently, and have not in the past, received the 5.95% fixed coupon payment.  Instead, the trust owns those Allstate bonds and receives those interest payments and then swaps that payment with the brokerage firm that created the trust and who also acts as the "swap counterparty".  The brokerage firm then pays the trustee the amount due to the owners of GJT.


I recently explained how this works in Item # 1 Bought Back 50 of the Synthetic Floater GYC at $21.67. I would also refer to that posts, and the citations contained therein, for a more complete discussion of the risks relating to synthetic floaters.

The reason that the underlying bond is trading at such a premium now is due to a "make whole" provision that would make it punitive for Allstate to redeem this bond.

Without going into detail explaining a make whole provision, it basically requires the issuer to pay the bond owners the sum of the present values of all remaining interest payments and the principal payment (par value) discounted to the redemption date using a treasury rate for a similar maturity plus 20 basis points. The sum of the remaining interest payments and the principal amount is a very large number and the current discount rate is very low. Thus, no one expects Allstate to redeem this bond early, and that is why a 5.95% coupon bond is now selling at such a large premium to its par value.

Allstate Bond Prospectus

There are circumstances where the owners of the synthetic floater will receive the fixed coupon of the bond owned by the trust rather than the float amount. The only example so far occurred for JBK whose swap counterparty was Lehman Brothers. After Lehman filed for bankruptcy, the JBK independent trustee took the position that the BK filing terminated the swap agreement and consequently gave the JBK owners the right to receive the higher coupon paid by the underlying security owned by the trust. It took awhile for investors to figure that out, which allowed me at the time to take advantage of the JBK's significant mispricing.

Due to unique and impossible for me to even comprehend tax issues, I will only own synthetic floaters in a retirement account: Will Hold Synthetic Floaters In Retirement Account

Prior Trades: I have not bought this security since 2011. All of my trading activity is shown in the following snapshots from 2009 and 2013:
2009 Roth IRA 100 Shares (two 50 share lots): +$472.45
2009 Taxable Account GJT 100 Shares +$79.97
I quickly sold the shares bought in a taxable account after realizing that I had acquired a difficult to understand tax issue.

2013 Roth IRA GJT 50 Shares +$23.53

Bought 100 GJT at $8.3 (4/6/09 Post)-No Reference to Sell
Sold GJR 50 GJT at $13 (6/20/09 Post)-No Reference to Buy
Item # 4 Sold 50 GJT at $17.5-Some Details about Managing My Two IRA Accounts (12/31/2009 Post)-No Reference to Buy
Item # 3 Bought 50 GJT at $18.15-Roth IRA (7/22/11 Post)-ROTH IRA: SOLD 50 GJT at $18.9 (6/15/13 Post)

Total Profit: $575.95

I have not missed anything significant by selling the 50 shares owned in the Roth at $18.9 back in June 2013 and then buying those shares back at $17.97 in March 2015.

Rationale: I have not bothered with this security since the 50 share lot purchase in 2011 due to its paltry yield. Most of my purchases were made after this security had been shellacked in price.

How do you manage interest rate risk now?

GJT has some use in a Roth IRA when short term rates are rising.

I suspect, but do not know, that the FED is underestimating inflation pressures building in the economy and may end up having no choice other than to raise the federal funds rate at a faster pace and to a higher level than the market currently anticipates.

In that scenario, the three month T Bill rate will be rising with the federal funds rate which will cause this floater to increase its coupon. Fixed rate and longer term bonds could be going down in value with intermediate and long term rates rising due to a significant change in inflation and inflation expectations.

Hopefully, this type of security will be going up in value in that scenario and would thus act as a balance for fixed coupon bonds and bond funds owned in the Roth IRAs.

If this security is going to work long term, the three month T Bill will need to have an average annual yield much closer to its historical number than the near zero yield over the past 6+ years.

There is capital appreciation potential given the discount to par value. Back in early August 2007, there were a few trade above $21.5. The 3 month T Bill rate was close to 4.9% at that time and started to fall in the following months. The perception about the direction of short term rates may be important to the pricing of this security in addition to the current rate. At some point, probably years before maturity would be my best guess now, there will be a spike in short term rates and this security may rise close to par value thus giving its owner the opportunity to harvest the discount before the 4/1/36 maturity.

I used the same reasoning in a debate with Extreme Banker in the comment section to this SA Instablog: Equity Preferred Floating Rate Stocks: Added 50 GSPRC At $19.63-South Gent | Seeking Alpha

With a 50 share lot, I minimize the risks. I also took into consideration that the out of pocket costs was almost covered by my previous realized gains, so I am close to playing with the house's money.

Risks/Issues: I am not going to repeat my discussion about the risks inherent in synthetic floaters contained in the post discussing the GYC purchase. Item # 1 Bought Back 50 of the Synthetic Floater GYC at $21.67 (3/22/15 Post)

I view the main disadvantage to be the paltry coupon rate. This security is likely to be paying a paltry interest payment for awhile, needless to say. The three month T bill is now near zero. In part, this security is viewed as a hedge against unanticipated and problematic inflation that would likely pulverize long term bonds owned in the Roth IRA which are not sold for whatever reason, including but not limited to stupidity, when and if that scenario arises.

The risks are discussed in the prospectus starting at page S-11.

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