IDS LIFE INSURANCE CO /MN
10-Q, 1995-11-13
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<PAGE>
PAGE 1
                          FORM 10-Q
                              
             SECURITIES AND EXCHANGE COMMISSION
                   WASHINGTON, D.C.  20549
                              
Quarterly Report Under Section 13 or 15(d) of the Securities
Exchange Act of 1934
                              
(Mark one)
[ X ]  QUARTERLY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE
       SECURITIES EXCHANGE ACT OF 1934

For the quarterly period ended September 30, 1995

                             OR
                              
[   ]  TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE
       SECURITIES EXCHANGE ACT OF 1934

For the transition period from                to

               Commission file number 33-28976

                      IDS LIFE INSURANCE COMPANY               
         (Exact name of registrant as specified in its charter)
                              
                   MINNESOTA                      41-0823832    
        (State or other jurisdiction of       (I.R.S. Employer
         incorporation or organization)      Identification No.)

     IDS TOWER 10, MINNEAPOLIS, MINNESOTA         55440-0010
   (Address of principal executive offices)       (Zip Code)

(Registrant's telephone number, including area code) (612) 671-1257
                              
Indicate by check mark whether the registrant (1) has filed all
reports required to be filed by Section 13 or 15(d) of the
Securities Exchange Act of 1934 during the preceding 12 months (or
for such shorter period that the registrant was required to file
such reports), and (2) has been subject to such filing requirements
for the past 90 days.  Yes  X   No ___

THE REGISTRANT MEETS THE CONDITIONS SET FORTH IN GENERAL
INSTRUCTION H(1)(a) AND (b) OF FORM 10-Q AND IS THEREFORE FILING
THIS FORM WITH THE PERMITTED ABBREVIATED NARRATIVE DISCLOSURE.
<PAGE>
PAGE 2
                 IDS LIFE INSURANCE COMPANY
                              
                          FORM 10-Q
                              
          For the Quarter Ended September 30, 1995
                              
                      Table of Contents

PART I - FINANCIAL INFORMATION                                Page

  Item 1. Financial Statements

          Consolidated Balance Sheets as of
          September 30, 1995 (unaudited) and
          December 31, 1994                                  3 - 4

          Consolidated Statements of Income for the
          three months ended September 30, 1995 and 1994
          (unaudited)                                          5

          Consolidated Statements of Income for the
          nine months ended September 30, 1995 and 1994
          (unaudited)                                          6

          Consolidated Statements of Cash Flows for the
          nine months ended September 30, 1995 and 1994
          (unaudited)                                        7 - 8

          Notes to Consolidated Financial Statements
          (unaudited)                                        9 - 10

  Item 2. Management's Discussion and Analysis of
          Consolidated Financial Condition and
          Results of Operations                             11 - 13

PART II - OTHER INFORMATION                                    14

SIGNATURES                                                     15
<PAGE>
PAGE 3
                                   IDS LIFE INSURANCE COMPANY
                                   CONSOLIDATED BALANCE SHEETS
                             ($ thousands, except per share amount)

<TABLE>
<CAPTION>
                                                               September 30,         December 31,
ASSETS                                                             1995                  1994    
                                                                (unaudited)
<S>                                                              <C>                   <C>
Investments:
   Fixed Maturities:
      Held to maturity, at amortized cost (Fair value:
         1995, $11,393,021; 1994, $10,694,800)                   $11,036,382           $11,269,861
      Available for sale, at fair value (Amortized cost:
         1995, $9,723,978; 1994, $8,459,128)                       9,907,299             8,017,555
                                    
                                                                  20,943,681            19,287,416
                                    
   Mortgage loans on real estate
     (Fair value: 1995, $2,847,560; 1994, $2,342,520)              2,694,957             2,400,514
   Policy loans                                                      414,139               381,912
   Other investments                                                 116,849                51,795
                                    
          Total investments                                       24,169,626            22,121,637
                                    
Cash and cash equivalents                                              5,190               267,774
                                    
Receivables:                                    
   Reinsurance                                                       105,409                80,304
   Amounts due from brokers                                           10,605                 7,933
   Other accounts receivable                                          26,092                49,745
   Premiums due                                                        4,779                 1,594
                                    
         Total receivables                                           146,885               139,576
                                    
Accrued investment income                                            329,436               317,510
                                    
Deferred policy acquisition costs                                  1,961,532             1,865,324
                                    
Deferred income taxes                                                      -               124,061
                                    
Other assets                                                          61,662                30,426
                                    
Assets held in segregated asset accounts,
  primarily common stocks at market                               14,120,026            10,881,235
                                    
        Total assets                                             $40,794,357           $35,747,543

See accompanying notes.
<PAGE>
PAGE 4
                                   IDS LIFE INSURANCE COMPANY
                                   CONSOLIDATED BALANCE SHEETS
                             ($ thousands, except per share amount)
                                           (continued)
                                    
                                    
                                                               September 30,         December 31,
LIABILITIES AND STOCKHOLDER'S EQUITY                               1995                  1994    
                                                                (unaudited)
Liabilities:
   Future policy benefits:
      Fixed annuities                                            $20,472,909           $19,361,979
      Universal life-type insurance                                3,025,137             2,896,100
      Traditional life insurance                                     208,667               206,754
      Disability income, health and
        long-term care insurance                                     306,748               244,077
   Policy claims and other                         
      policyholders' funds                                            77,143                50,068
   Amounts due to brokers                                            166,933               226,737
   Deferred income taxes                                              53,331                     -
   Other liabilities                                                 242,749               291,902
   Liabilities related to segregated                           
      asset accounts                                              14,120,026            10,881,235
                                    
         Total liabilities                                        38,673,643            34,158,852
                                    
Stockholder's equity:                                 
   Capital Stock, $30 par value per share;                             3,000                 3,000
      100,000 shares authorized, issued and outstanding
   Additional paid-in capital                                        237,384               222,000
   Net unrealized gain (loss) on investments                         113,751              (275,708)
   Retained earnings                                               1,766,579             1,639,399
                                    
         Total stockholder's equity                                2,120,714             1,588,691
                                    
Total liabilities and stockholder's equity                       $40,794,357           $35,747,543
                                    
See accompanying notes.

</TABLE>
<PAGE>
PAGE 5
            
                                   IDS LIFE INSURANCE COMPANY
                                CONSOLIDATED STATEMENTS OF INCOME
                                          ($ thousands)
                                           (unaudited)

<TABLE>
<CAPTION>

                                                               Three months ended
                                                                  September 30,
                                                             1995              1994    
<S>                                                      <C>               <C>
Revenues:
   Premiums:
      Traditional life insurance                         $   12,213        $   11,881
      Disability income, health and
       long-term care insurance                              28,343            23,678

           Total premiums                                    40,556            35,559

   Policyholder and contractholder charges                   63,768            55,499
   Management and other fees                                 55,634            43,492
   Net Investment Income                                    477,997           437,689
   Net realized gain (loss) on investments                      145            (1,023)

           Total revenues                                   638,100           571,216

Benefits and expenses:
   Death and other benefits:                                               
      Traditional life insurance                              6,769             5,770
      Universal life-type insurance                                     
          and investment contracts                           17,532            13,258
      Disability income, health and
          long-term care insurance                            4,578             3,819
   Increase (decrease) in liabilities for                                  
      future policy benefits:                                           
          Traditional life insurance                              7              (436)
          Disability income, health and
           long-term care insurance                          12,956            12,745
   Interest credited on universal life-type                                
      insurance and investment contracts                    333,159           292,978
   Amortization of deferred policy                                         
      acquisition costs                                      86,622            64,935
   Other insurance and operating expenses                    46,478            42,414

          Total benefits and expenses                       508,101           435,483

Income before income taxes                                  129,999           135,733

Income taxes                                                 45,180            45,665

Net income                                               $   84,819        $   90,068

See accompanying notes.
<PAGE>
PAGE 6

                                   IDS LIFE INSURANCE COMPANY
                                CONSOLIDATED STATEMENTS OF INCOME
                                          ($ thousands)
                                           (unaudited)

                                                               Nine months ended
                                                                  September 30,
                                                             1995              1994    

Revenues:
   Premiums:
      Traditional life insurance                         $   37,668        $   35,770
      Disability income, health and
       long-term care insurance                              81,655            68,248

          Total premiums                                    119,323           104,018
                                    
   Policyholder and contractholder charges                  188,939           162,189
   Management and other fees                                153,064           120,598
   Net Investment Income                                  1,414,616         1,330,950
   Net realized loss on investments                          (2,605)           (1,837)

          Total revenues                                  1,873,337         1,715,918
                                    
Benefits and expenses:                                
   Death and other benefits:                             
      Traditional life insurance                             22,124            21,534
      Universal life-type insurance                   
          and investment contracts                           51,555            50,554
      Disability income, health and
          long-term care insurance                           13,091             9,756
   Increase (decrease) in liabilities for                            
      future policy benefits:                   
          Traditional life insurance                         (1,714)           (1,734)
          Disability income, health and
           long-term care insurance                          38,228            30,667
   Interest credited on universal life-type                          
      insurance and investment contracts                    975,033           871,081
   Amortization of deferred policy                             
      acquisition costs                                     211,239           207,927
   Other insurance and operating expenses                   156,771           142,466

          Total benefits and expenses                     1,466,327         1,332,251
                                    
Income before income taxes                                  407,010           383,667
                                    
Income taxes                                                141,560           131,403

Net income                                               $  265,450        $  252,264
                                    
See accompanying notes.

</TABLE>
<PAGE>
PAGE 7
                                   IDS LIFE INSURANCE COMPANY
                              CONSOLIDATED STATEMENTS OF CASH FLOWS
                                          ($ thousands)
                                           (unaudited)
<TABLE>
<CAPTION>

                                                               Nine months ended
                                                                  September 30,
                                                              1995            1994  
<S>                                                     <C>             <C>
Cash flows from operating activities:
  Net income                                             $   265,450     $   252,264
  Adjustments to reconcile net income to                                  
     net cash provided by operating activities:                        
         Policy loans, excluding universal
            life-type insurance:                                  
                 Issuance                                    (35,332)        (28,037)
                 Repayment                                    26,993          24,913
         Change in reinsurance receivable                    (25,305)        (16,538)
         Change in other accounts receivable                  23,653          (5,723)
         Change in accrued investment income                 (11,926)         (1,857)
         Change in deferred policy                                   
            acquisition costs, net                          (124,744)       (127,804)
         Change in liabilities for future policy                     
            benefits for traditional life,
            disability income, health and
            long-term care insurance                          64,584          44,007
         Change in policy claims and other                           
            policyholders' funds                              27,075          53,260
         Change in deferred income taxes                     (32,318)        (29,718)
         Change in other liabilities                         (49,153)          4,222
         Amortization of premium                                     
            (accretion of discount), net                     (19,620)          8,280
         Net loss on investments                               2,605           1,837
         Activity related to universal                               
            life-type insurance:                                  
                 Premiums                                    339,747         299,172
                 Surrenders and death benefits              (228,266)       (218,766)
                 Interest credited to account balances       121,324         112,289
         Policyholder and contractholder charges,
            non-cash                                        (103,768)        (93,979)
         Other, net                                            3,300          (3,541)

           Net cash provided by operating activities     $   244,299     $   274,281

See accompanying notes.
<PAGE>
PAGE 8

                                   IDS LIFE INSURANCE COMPANY
                              CONSOLIDATED STATEMENTS OF CASH FLOWS
                                          ($ thousands)
                                           (unaudited)
                                           (continued)


                                                               Nine months ended
                                                                  September 30,
                                                              1995            1994  
Cash flows from investing activities:
   Fixed maturities held to maturity:                                      
      Purchases                                         ($   443,661)   ($   809,541)
      Maturities, sinking fund payments and calls            485,070       1,385,948
      Sales                                                  175,616          42,762
   Fixed maturities available for sale:                                    
      Purchases                                           (1,831,133)     (1,827,901)
      Maturities, sinking fund payments and calls            553,582         968,698
      Sales                                                   50,031         179,117
   Other investments, excluding policy loans:                            
      Purchases                                             (505,182)       (440,592)
      Sales                                                  124,229         222,664
   Change in amounts due from broker                          (2,672)          4,119
   Change in amounts due to broker                           (59,805)       (156,621)

            Net cash used in investing activities         (1,453,925)       (431,347)

Cash flows from financing activities:                                         
   Activity related to investment contracts:                               
      Considerations received                              2,338,090       2,250,745
      Surrenders and death benefits                       (2,080,869)     (2,702,747)
      Interest credited to account balances                  853,709         758,793
   Universal life-type insurance policy loans:                             
      Issuance                                               (63,768)        (56,182)
      Repayment                                               39,880          38,047
   Cash dividends to parent                                 (140,000)       (105,000)

            Net cash provided by financing activities        947,042         183,656

Net increase (decrease) in cash and cash equivalents        (262,584)         26,590

Cash and cash equivalents at beginning of period             267,774         146,281

Cash and cash equivalents at end of period               $     5,190     $   172,871

See accompanying notes.

</TABLE>
<PAGE>
PAGE 9
                 IDS LIFE INSURANCE COMPANY
                              
         NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
                              
                     September 30, 1995
                      ($ in thousands)
                         (unaudited)

1.   General

In the opinion of the management of IDS Life Insurance Company (the
Company), the accompanying unaudited consolidated financial
statements contain all adjustments (consisting of normal recurring
adjustments) necessary to present fairly its balance sheet as of
September 30, 1995, statements of income for the three and nine
months ended September 30, 1995 and 1994 and statements of cash
flows for the nine months ended September 30, 1995 and 1994.

The Company is a wholly owned subsidiary of American Express
Financial Corporation which is a wholly owned subsidiary of
American Express Company.  The accompanying consolidated financial
statements include the accounts of the Company and its wholly owned
subsidiaries, IDS Life Insurance Company of New York, American
Enterprise Life Insurance Company, American Centurion Life
Assurance Company and American Partners Life Insurance Company. 
All material intercompany accounts and transactions have been
eliminated in consolidation.

2.   Nature of business

The Company is engaged in the life insurance and annuity business. 
The Company sells various forms of fixed and variable individual
life insurance, group life insurance, individual and group
disability income insurance, long-term care insurance, and single
and installment premium fixed and variable annuities.

3.   Statements of cash flows

The Company considers investments with a maturity at the date of
their acquisition of three months or less to be cash equivalents. 
These securities are carried principally at amortized cost which
approximates market value.

Cash paid for interest on borrowings totaled $4,568 and $1,382 for
the nine months ended September 30, 1995 and 1994, respectively. 
Cash paid for income taxes totaled $157,199 and $168,352 for the
nine months ended September 30, 1995 and 1994, respectively.

4.   Commitments and contingencies

Commitments for purchases of investments in the ordinary course of
business at September 30, 1995 aggregated $423,938.
<PAGE>
PAGE 10
                 IDS LIFE INSURANCE COMPANY
                              
         NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
                      ($ in thousands)
                         (unaudited)
                          (continued)
                              

The maximum amount of risk retained by the Company on any one life
is $750 of life and waiver of premium benefits plus $50 of
accidental death benefits.  The excesses are reinsured with other
life insurance companies on a yearly renewable term basis.

The Company is a defendant in various lawsuits, none of which, in
the opinion of the Company counsel, will result in a material
liability.
<PAGE>
PAGE 11
MANAGEMENT'S DISCUSSION AND ANALYSIS OF CONSOLIDATED FINANCIAL
CONDITION AND RESULTS OF OPERATIONS

Results of Operations

Nine Months Ended September 30, 1995 Compared to Nine Months
Ended September 30, 1994:

Consolidated net income increased 5.2 percent to $265 million for
the nine months ended September 30, 1995, compared to $252 million
in 1994.  Earnings growth resulted primarily from increases in
management fees and policyholder and contractholder charges,
partially offset by a decrease in investment margins.  The
increases reflect higher average insurance and annuities in force. 
Investment margins were below prior year levels primarily due to
the increase in interest rates credited.

Total premiums received decreased to $3.8 billion for the nine
months ended September 30, 1995, compared with $4.2 billion a year
ago.  This decrease is primarily due to decreased sales of variable
annuities.

Total revenues increased 10 percent to $1.9 billion for the nine
months ended September 30, 1995, compared with the corresponding
period in 1994.  The increase is primarily due to increases in net
investment income, policyholder and contractholder charges and
management fees.

Net investment income increased to $1.4 billion for the nine months
ended September 30, 1995, compared with $1.3 billion a year ago.
The increase reflects higher total investments which increased 11
percent from a year ago to $24 billion at September 30, 1995,
partially offset by lower yields.

Policyholder and contractholder charges increased to $189 million
for the nine months ended September 30, 1995, compared with $162
million a year ago.  This increase is primarily due to higher life
insurance in force.

Management and other fees increased to $153 million for the nine
months ended September 30, 1995, compared with $121 million a year
ago.  This is primarily due to an increase in assets held in
segregated asset accounts, which grew 32 percent to $14 billion at
September 30, 1995 due to market appreciation and sales.  The
Company provides investment management services for the mutual
funds which are used as investment options for variable annuities
and variable life insurance.  The Company also receives a mortality
and expense risk fee from the segregated asset accounts.

Total benefits and expenses increased to $1.5 billion for the nine
months ended September 30, 1995, compared to $1.3 billion a year
ago.  The largest component of expenses, interest credited on 
universal life-type insurance and investment contracts, increased
to $975 million, compared with $871 million for the corresponding
period in 1994.  This is due to higher aggregate amounts in force 
<PAGE>
PAGE 12
and an increase in interest credited rates.  Amortization of
deferred policy acquisition costs increased to $211 million for the
nine months ended September 30, 1995, compared to $208 million a
year ago.  This increase reflects a higher deferred cost asset
base.

Risk Management

The Company primarily invests in fixed income securities, over a
broad range of maturities for the purpose of providing fixed
annuity clients with a competitive rate of return on their
investments while minimizing risk, and to provide a dependable and
consistent margin between the interest rate earned on investments
and the interest rate credited to clients' accounts.  The Company
does not invest in securities to generate trading profits.

The Company has an investment committee that holds regularly
scheduled meetings and, when necessary, special meetings.  At these
meetings, the committee reviews models projecting different
interest rate scenarios and their impact on profitability.  The
objective of the committee is to structure the investment security
portfolio based upon the type and behavior of products in the
liability portfolio so as to achieve targeted levels of
profitability.

Rates credited to clients' accounts are generally reset at shorter
intervals than the maturity of underlying investments.  Therefore,
margins may be negatively impacted by increases in the general
level of interest rates.  Part of the committee's strategy includes
the purchase of some types of derivatives, such as interest rate
caps, for hedging purposes.  These derivatives protect margins by
increasing investment returns if there is a sudden and severe rise
in interest rates, thereby mitigating the impact of an increase in
rates credited to clients' accounts.

Liquidity and Capital Resources

The liquidity requirements of the Company are met by funds provided
from operations and investment activity.  The primary components of
the funds provided are premiums, investment income, proceeds from
sales of investments as well as maturities and periodic repayments
of investment principal.

The primary uses of  funds are policy benefits, commissions and
operating expenses, policy loans, new investment purchases and
dividends to parent.

The Company has available lines of credit with three banks
aggregating $100 million, which are used strictly as short-term
sources of funds.  There were no outstanding borrowings under these
agreements at September 30, 1995.  The Company also uses reverse
repurchase agreements for short-term liquidity needs.  Outstanding
reverse repurchase agreements totaled $115 million at September 30,
1995.
<PAGE>
PAGE 13
At September 30, 1995, approximately 8.3 percent of the Company's
invested assets were below-investment-grade bonds, compared to 8.9
percent at December 31, 1994.  These investments may be subject to
a higher degree of risk than the more "traditional" issues because
of the borrowers' generally greater sensitivity to adverse economic
conditions, such as recession or increasing interest rates, and in
certain instances the lack of an active secondary market.  Expected
returns on below-investment-grade bonds reflect consideration of
such factors.  The Company has identified those fixed maturities
for which a decline in fair value is determined to be other than
temporary, and has written them down to fair value with a charge to
earnings.

At September 30, 1995, net unrealized appreciation on investments
in fixed maturities held to maturity totaled $357 million.  For the
nine months ended September 30, 1995, sales of fixed maturities
held for investment were due to either credit deterioration or
early extinguishment by the issuer.

At September 30, 1995, the Company had an allowance for losses on
mortgage loans of $34 million.

The Company paid $140 million in dividends to its parent during the
nine months ended September 30, 1995.

The economy and other factors have caused an increase in the number
of insurance companies that are under regulatory supervision.  This
circumstance has resulted in an increase in assessments by state
guaranty associations to cover losses to policyholders of insolvent
or rehabilitated companies.  Some assessments can be partially
recovered through a reduction in future premium taxes in certain
states.  The Company established an asset for guaranty association
assessments from those states allowing a reduction in future
premium taxes over a reasonable period of time.  The asset will be
amortized as future premium taxes are reduced.  The Company has
also estimated the potential effect of future assessments on the
Company's financial position and results of operations and has
established a reserve for such potential assessments.
<PAGE>
PAGE 14
PART II - OTHER INFORMATION

Item 1.   LEGAL PROCEEDINGS

          Reference is made to Note 4 of the Notes to
          Consolidated Financial Statements (unaudited)
          contained in the Report filed on Form 10-Q for the
          quarterly period ended September 30, 1995.

Item 2.   CHANGES IN SECURITIES

          Not applicable.

Item 3.   DEFAULTS UPON SENIOR SECURITIES

          Not applicable.

Item 4.   SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS

          Not applicable.

Item 5.   OTHER INFORMATION

          Not applicable.

Item 6.   EXHIBITS AND REPORTS ON FORM 8-K

          Not applicable.

No reports on Form 8-K were required to be filed by the Company for
the nine months ended September 30, 1995.
<PAGE>
PAGE 15
SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of
1934, the registrant has duly caused this report to be signed on
its behalf by the undersigned thereunto duly authorized.

REGISTRANT                  IDS LIFE INSURANCE COMPANY


BY                          _______________________________

NAME AND TITLE              Melinda S. Urion
                            Executive Vice President and Controller

DATE                        November 9, 1995
<PAGE>
WARNING: THE EDGAR SYSTEM ENCOUNTERED ERROR(S) WHILE PROCESSING THIS SCHEDULE.

<TABLE> <S> <C>

<ARTICLE>         7
<CIK>          0000727892
<NAME>                          IDS Life Insurance Company
<MULTIPLIER>                    1000
<CURRENCY>                      U.S. DOLLAR
<FISCAL-YEAR-END>                      DEC-31-1995
<PERIOD-START>                         JAN-01-1995
<PERIOD-END>                          SEPT-30-1995
<PERIOD-TYPE>                                9-MOS
<EXCHANGE-RATE>                                  1
<DEBT-HELD-FOR-SALE>                       9907299
<DEBT-CARRYING-VALUE>                     11036382
<DEBT-MARKET-VALUE>                       11393021
<EQUITIES>                                   26573
<MORTGAGE>                                 2694957
<REAL-ESTATE>                                59922
<TOTAL-INVEST>                            24169626
<CASH>                                        5190
<RECOVER-REINSURE>                            1589
<DEFERRED-ACQUISITION>                     1961532
<TOTAL-ASSETS>                            40794357
<POLICY-LOSSES>                           24013461
<UNEARNED-PREMIUMS>                              0
<POLICY-OTHER>                                   0
<POLICY-HOLDER-FUNDS>                        77143
<NOTES-PAYABLE>                                  0
<COMMON>                                      3000
                            0
                                      0
<OTHER-SE>                                 1766579
<TOTAL-LIABILITY-AND-EQUITY>              40794357
                                  119323
<INVESTMENT-INCOME>                        1414616
<INVESTMENT-GAINS>                          (2605)
<OTHER-INCOME>                              342003
<BENEFITS>                                 1098317
<UNDERWRITING-AMORTIZATION>                 211239
<UNDERWRITING-OTHER>                        156771
<INCOME-PRETAX>                             407010
<INCOME-TAX>                                141560
<INCOME-CONTINUING>                         265450
<DISCONTINUED>                                   0
<EXTRAORDINARY>                                  0
<CHANGES>                                        0
<NET-INCOME>                                265450
<EPS-PRIMARY>                                    0
<EPS-DILUTED>                                    0
<RESERVE-OPEN>                               20636
<PROVISION-CURRENT>                          86770
<PROVISION-PRIOR>                                0
<PAYMENTS-CURRENT>                           82696
<PAYMENTS-PRIOR>                                 0
<RESERVE-CLOSE>                              24710
<CUMULATIVE-DEFICIENCY>                          0
<PAGE>
</TABLE>


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