FORM 10-Q
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
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 reduced disclosure
format.
[x] QUARTERLY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE
SECURITIES EXCHANGE ACT OF 1934
For the quarterly period ended: September 30, 1997
OR
[ ] TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE
SECURITIES EXCHANGE ACT OF 1934
Commission file number: 33-47245
33-65381
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
(Exact name of registrant as specified in its charter)
NEW YORK 36-2608394
(State or other jurisdiction of (I.R.S. Employer
incorporation or organization) Identification No.)
One Allstate Drive
P.O. Box 9095
Farmingville, New York 11738
(Address of principal executive offices)
(Zip Code)
516/451-5300
(Registrant's telephone number, including area code)
Not Applicable
(Former name, former address and former fiscal year,
if changed since last report)
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
Indicate the number of shares of each of the issuer's classes of common
stock, as of September 30, 1997; there were 80,000 shares of common capital
stock outstanding, par value $25 per share all of which shares are held by
Allstate Life Insurance Company.
<PAGE>
PART I - FINANCIAL INFORMATION
Item 1. FINANCIAL STATEMENTS
Statements of Financial Position
September 30, 1997(Unaudited)and December 31, 1996................3
Statements of Operations
Three Months Ended September 30, 1997 and September 30, 1996 and
Nine Months Ended September 30, 1997 and September 30, 1996
(Unaudited).......................................................4
Statements of Cash Flows
Nine Months Ended September 30, 1997
and September 30, 1996 (Unaudited)................................5
Notes to Financial Statements(Unaudited)..........................6
Item 2. MANAGEMENT'S DISCUSSION AND ANALYSIS OF
FINANCIAL CONDITION AND RESULTS OF OPERATIONS......................7
Item 3. QUANTITATIVE AND QUALITATIVE DISCLOSURE ABOUT
MARKET RISK.*.................................................N/A
PART II - OTHER INFORMATION
Item 1. LEGAL PROCEEDINGS..................................................11
Item 2. CHANGES IN SECURITIES*............................................N/A
Item 3. DEFAULTS UPON SENIOR SECURITIES*..................................N/A
Item 4. SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS*..............N/A
Item 5. OTHER INFORMATION .................................................11
Item 6. EXHIBITS AND REPORTS ON FORM 8-K...................................11
SIGNATURE PAGE...............................................................13
*Omitted pursuant to General Instruction H(2) of Form 10-Q.
-2-
<PAGE>
PART I - FINANCIAL INFORMATION
Item 1. FINANCIAL STATEMENTS
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
STATEMENTS OF FINANCIAL POSITION
<TABLE>
<CAPTION>
September 30, December 31,
($ in thousands) 1997 1996
------- --------
(Unaudited)
<S> <C> <C>
ASSETS
Investments
Fixed income securities, at fair value
(amortized cost $1,481,444 and $1,378,155) $1,658,316 $1,500,783
Mortgage loans 101,343 84,657
Policy loans 26,971 25,359
Short-term 10,905 25,855
---------- ----------
Total investments 1,797,535 1,636,654
Deferred policy acquisition costs 68,546 61,559
Accrued investment income 19,110 20,321
Reinsurance recoverables 2,132 2,566
Cash 15,985 1,027
Income taxes receivable - 105
Other assets 4,491 7,384
Separate Accounts 308,716 260,668
---------- ----------
Total assets $2,216,515 $1,990,284
========== ==========
LIABILITIES
Reserve for life-contingent contract benefits $1,018,752 $ 911,457
Contractholder funds 593,829 572,480
Income taxes payable 2,861 -
Deferred income taxes 8,245 3,692
Other liabilities and accrued expenses 19,648 6,405
Net payable to affiliates 1,211 2,515
Separate Accounts 308,716 260,668
---------- ----------
Total liabilities 1,953,262 1,757,217
---------- ----------
SHAREHOLDER'S EQUITY
Common stock, $25 par value, 80,000 shares
authorized, issued and outstanding 2,000 2,000
Additional capital paid-in 45,787 45,787
Unrealized net capital gains 48,081 36,852
Retained income 167,385 148,428
---------- ----------
Total shareholder's equity 263,253 233,067
---------- ----------
Total liabilities and shareholder's equity $2,216,515 $1,990,284
========== ==========
</TABLE>
See notes to financial statements.
-3-
<PAGE>
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
STATEMENTS OF OPERATIONS
<TABLE>
<CAPTION>
Three Months Ended Nine Months Ended
September 30, September 30,
------------------- ------------------
($ in thousands) 1997 1996 1997 1996
---- ---- ---- ----
(Unaudited)
<S> <C> <C> <C> <C>
REVENUES
Life and annuity premiums (net of
reinsurance ceded of $793 and $626;
$2,243 and $1,820) $ 21,075 $ 20,990 $ 67,882 $ 65,906
Contract charges 7,146 6,567 21,128 18,872
Net investment income 31,629 28,528 92,871 83,952
Realized capital gains and losses 817 (2,575) 742 (2,224)
-------- -------- -------- --------
60,667 53,510 182,623 166,506
-------- -------- -------- --------
COSTS AND EXPENSES
Life and annuity contract benefits (net of
reinsurance recoverable of $950 and
$523; $1,632 and $2,693) 43,081 40,298 132,946 125,687
Amortization of deferred policy acquisition
costs 746 1,498 4,565 4,463
Operating costs and expenses 5,237 4,265 15,493 12,679
--------- --------- -------- --------
49,064 46,061 153,004 142,829
--------- --------- -------- --------
INCOME BEFORE INCOME TAX
EXPENSE 11,603 7,449 29,619 23,677
INCOME TAX EXPENSE 4,207 2,609 10,662 8,599
--------- --------- --------- ---------
NET INCOME $ 7,396 $ 4,840 $ 18,957 $ 15,078
========= ========= ========= =========
</TABLE>
See notes to financial statements.
-4-
<PAGE>
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
STATEMENTS OF CASH FLOWS
<TABLE>
<CAPTION>
Nine Months Ended
September 30,
-----------------
1997 1996
---- ----
($ in thousands) (Unaudited)
<S> <C> <C>
CASH FLOWS FROM OPERATING ACTIVITIES
Net income $ 18,957 $ 15,078
Adjustments to reconcile net income to net cash
provided by operating activities
Depreciation, amortization and other non-cash items (23,167) (19,375)
Realized capital gains and losses (742) 2,224
Interest credited to contractholder funds 22,862 18,178
Increase in reserve for life-contingent contract
benefits and contractholder funds 52,221 53,962
Increase in deferred policy acquisition costs (7,222) (4,957)
Decrease in accrued investment income 1,211 1,580
Change in deferred income taxes (1,492) (3,212)
Change in other operating assets and liabilities 18,840 1,879
--------- ---------
Net cash provided by operating activities 81,468 65,357
--------- ---------
CASH FLOWS FROM INVESTING ACTIVITIES
Proceeds from sales of fixed income securities 14,776 20,810
Investment collections
Fixed income securities 80,621 50,223
Mortgage loans 1,899 7,702
Investment purchases
Fixed income securities (175,460) (122,232)
Mortgage loans (18,500) (1,825)
Change in short-term investments, net 14,950 (32,032)
Change in policy loans, net (1,612) (1,772)
--------- ----------
Net cash used in investing activities (83,326) (79,126)
--------- ----------
CASH FLOWS FROM FINANCING ACTIVITIES
Contractholder fund deposits 54,965 49,254
Contractholder fund withdrawals (38,149) (34,695)
--------- ----------
Net cash provided by financing activities 16,816 14,559
--------- ----------
NET INCREASE IN CASH 14,958 790
CASH AT BEGINNING OF PERIOD 1,027 1,472
--------- ----------
CASH AT END OF PERIOD $ 15,985 $ 2,262
========= ==========
</TABLE>
See notes to financial statements.
-5-
<PAGE>
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
NOTES TO FINANCIAL STATEMENTS
(Unaudited)
1. Basis of Presentation
Allstate Life Insurance Company of New York (the "Company") is
wholly owned by a wholly owned subsidiary of Allstate Insurance Company,
a wholly owned subsidiary of The Allstate Corporation.
The statements of financial position as of September 30, 1997, the
statements of operations for the three-month and nine-month periods
ended September 30, 1997 and 1996, and the statements of cash flows for
the nine-month periods ended September 30, 1997 and 1996 are unaudited.
The interim financial statements reflect all adjustments (consisting
only of normal recurring accruals) which are, in the opinion of
management, necessary for the fair presentation of the financial
position, results of operations and cash flows for the interim periods.
These financial statements should be read in conjunction with the
financial statements and notes thereto included in the Allstate Life
Insurance Company of New York Annual Report on Form 10K for 1996. The
results of operations for the interim periods should not be considered
indicative of results to be expected for the full year.
To conform with the 1997 presentation, certain items in the prior
year's financial statements have been reclassified.
-6-
<PAGE>
Item 2. MANAGEMENT'S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND
RESULTS OF OPERATIONS
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
MANAGEMENT'S DISCUSSION AND ANALYSIS
AND RESULTS OF OPERATIONS
OF FINANCIAL CONDITION
The following discussion highlights significant factors influencing results
of operations and changes in financial position of Allstate Life Insurance
Company of New York (the "Company"). It should be read in conjunction with the
discussion and analysis and financial statements and notes thereto found under
Items 7 and 8 of Part II of the Allstate Life Insurance Company of New York
Annual Report on Form 10-K.
The Company is wholly owned by a wholly owned subsidiary of Allstate
Insurance Company. The Company markets a broad line of life insurance and
annuity products in the state of New York. Life insurance includes traditional
products such as whole life and term life insurance, as well as universal life
and other interest-sensitive life products. Annuities include deferred
annuities, such as variable annuities and fixed rate single and flexible premium
annuities, and immediate annuities such as structured settlement annuities. The
Company distributes its products using a combination of Allstate agents,
including life specialists, banks and other financial institutions, brokers and
direct response marketing.
RESULTS OF OPERATIONS
<TABLE>
<CAPTION>
Three Months Ended Nine Months Ended
September 30, September 30,
------------------- ------------------
($ in thousands) 1997 1996 1997 1996
---- ---- ---- ----
<S> <C> <C> <C> <C>
Statutory premiums and deposits $ 45,682 $ 44,523 $ 149,446 $ 133,882
========== ========== ========== ==========
Investments $1,797,535 $1,508,587 $1,797,535 $1,508,587
Separate Account assets 308,716 243,863 308,716 243,863
---------- ---------- ---------- ----------
Investments including Separate
Account assets $2,106,251 $1,752,450 $2,106,251 $1,752,450
========== ========== ========== ==========
Premiums and contract charges (net
of reinsurance) $ 28,221 $ 27,557 $ 89,010 $ 84,778
Net investment income 31,629 28,528 92,871 83,952
Life and annuity contract benefits 43,081 40,298 132,946 125,687
Operating costs and expenses 5,983 5,763 20,058 17,142
------------ ------------ ----------- -----------
Income from operations 10,786 10,024 28,877 25,901
Income tax expense on operations 3,921 3,510 10,402 9,377
------------ ------------ ----------- -----------
Net Operating income 6,865 6,514 18,475 16,524
Realized capital gains and losses,
after tax 531 (1,674) 482 (1,446)
------------ ------------- ----------- -----------
Net income $ 7,396 $ 4,840 $ 18,957 $ 15,078
============ ============= =========== ===========
</TABLE>
-7-
<PAGE>
Premium, deposits and contract charges
Statutory premiums and deposits, which include premiums and deposits for
all products, increased $1.2 million or 2.6% and $15.6 million or 11.6% for the
third quarter and the nine-month period ending September 30, 1997, respectively,
compared to the same periods in 1996. The increase for the quarter is primarily
due to increased sales of variable annuities and interest-sensitive life
insurance products partially offset by lower sales of structured settlement
annuities. The increase for the nine-month period is due to increased renewal
premiums on life insurance products, increased sales of structured settlement
annuities and increased sales of variable annuities.
Premiums and contract charges under generally accepted accounting
principles ("GAAP") increased $664 thousand or 2.4% and $4.2 million or 5.0% for
the three-month and nine-month periods ending September 30, 1997, respectively
when compared to the same periods last year. Under GAAP, revenues exclude
deposits on most annuities and premiums on universal life insurance policies.
GAAP premium and contract charges will vary with the mix of products sold during
the period. The increase for the quarter was due to a higher level of renewal
premiums on life products offset in part by lower sales of structured
settlement annuities with life contingencies. The increase for the nine-month
period is due to increased renewal premiums on life insurance products, higher
sales of structured settlement annuities and increased contract charges
associated with increased sales of variable annuities.
Net operating income
Pretax net investment income increased 10.9% and 10.6% for the
three-month and nine-month periods ended September 30, 1997, respectively,
compared with the same periods in 1996 primarily due to the investment of
positive cash flows from operations.
Operating expenses, which includes the amortization of deferred policy
acquisition costs, increased $220 thousand or 3.8% and $2.9 million or 17.0%
for the three-month and nine-month periods ended September 30, 1997.
The increase for the three-month period ended September 30, 1997 in operating
expenses was due to increased general expenses and was offset in part by
decreased amortization of deferred policy acquisition costs. The increase in
operating expenses for the nine-month period ended September 30, 1997 is
related to growth in the number of customer policies and increased general
expenses. In both the three and nine month period ended September 30, 1997, the
amortization of the deferred acquisition costs was reduced due to the revised
estimates of future gross profits on interest sensitive life products.
Net operating income increased 5.4% for the third quarter and 11.9% for
the nine-month period ending September 30, 1997 compared with the same periods
in 1996. Net operating income for the three-month period increased primarily due
to higher investment margins. Net operating income for the nine-month period
increased primarily due to favorable mortality margins on the structured
settlement annuity business and higher investment margins due to additional
sales of structured settlement annuities.
Realized capital gains and losses
Net realized capital gains after tax were $531 thousand and $482
thousand for the three-month and the nine-month periods, respectively. During
both periods ended September 30, 1997, gains realized from the sales of fixed
income securities were partially offset by losses on mortgage loans. Net
realized capital losses after tax were $1,674 and $1,446 for the three-month and
the nine-month periods, respectively. During both periods ended September 30,
1996, losses were realized on mortgage loans and fixed income securities.
-8-
<PAGE>
INVESTMENTS
The composition of the investment portfolio at September 30, 1997
is presented at carrying value in the table below.
<TABLE>
<CAPTION>
Percentage
($ in thousands) of portfolio
<S> <C> <C>
Fixed income securities $1,658,316 92.3%
Mortgage loans 101,343 5.6
Policy loans 26,971 1.5
Short-term 10,905 0.6
---------- ------
Total $1,797,535 100.0%
========== ======
</TABLE>
The Company's fixed income securities portfolio consists of tax-exempt
municipal bonds, publicly traded corporate bonds, privately-placed securities,
mortgage-backed securities, asset-backed securities, and U.S. government bonds.
The Company generally holds its fixed income securities for the long term, but
has classified all of these securities as available for sale to allow maximum
flexibility in portfolio management. Total investments increased to $1.80
billion at September 30, 1997 from $1.64 billion at December 31, 1996 due to the
investment of positive cash flows generated from operating activities and a
$54.3 million increase in unrealized gains on the fixed income securities
portfolio. The increase in the unrealized gain position is primarily
attributable to lower interest rates.
The Company's fixed income securities portfolio is 99.4% rated
investment grade. Investment grade is defined by the Company as a security
having a National Association of Insurance Commissioners rating of 1 or 2, a
Moody's rating of Aaa, Aa, A or Baa, or a comparable Company internal rating.
LIQUIDITY AND CAPITAL RESOURCES
Liquidity
Cash provided by operating activities, investment collections and part
of the short term investment balance was used to purchase fixed income
securities and mortgage loans.
Cash at the end of the period increased as cash from operations and
financing activities were partially offset by the purchase of investments. Cash
from operations increased due to increased sales and lower federal income tax
payments offset in part by higher benefits and expenses.
-9-
<PAGE>
PENDING ACCOUNTING STANDARDS
In January 1997, the Securities and Exchange Commission issued Financial
Reporting Release No. 48 ("FRR 48") "Disclosure of Accounting Policies for
Derivative Financial Instruments and Derivative Commodity Instruments and
Disclosure of Quantitative and Qualitative Information about Market Risk
Inherent in Derivative Financial Instruments, Other Financial Instruments, and
Derivative Commodity Instruments."
Among other things, FRR 48 requires annual disclosure of quantitative
and qualitative information about the market risk inherent in the Company's
market risk sensitive instruments, including but not limited to, the Company's
fixed income securities. The quantitative and qualitative disclosures are
effective for the Company's year-end 1998 reporting, but recent Congressional
events may ultimately impact the nature and effective date of FRR 48.
Effective in the second quarter of 1997, FRR 48 requires additional
disclosures in the footnotes to the financial statements about the Company's
accounting policies for derivative financial instruments. The Company
substantially adopted this requirement at December 31, 1996. In addition, FRR 48
requires annual disclosure of quantitative and qualitative information about the
market risk inherent in the Company's market risk sensitive instruments,
including but not limited to, equity and fixed income securities and derivative
financial instruments. The quantitative and qualitative disclosures are
effective for the Company's year-end 1997 reporting.
In June 1997, the Financial Accounting Standards Board issued
Statement of Financial Accounting Standards "SFAS" No. 130 "Reporting
Comprehensive Income" and SFAS No. 131 "Disclosures About Segments of an
Enterprise and Related Information."
SFAS No. 130 requires the presentation of comprehensive income in the
financial statements. Comprehensive income is a measurement of all changes in
equity that result from transactions and other economic events other than
transactions with stockholders. The requirements of this statement will be
adopted in January 1998.
SFAS No. 131 redefines how segments are determined and requires
additional segment disclosures for both annual and quarterly reporting. Under
this statement, segments are determined using the management approach for
financial statement reporting. The management approach is how an enterprise
makes operating decisions and assesses performance of its businesses. The
requirements of this statement will be adopted in December 1998.
FORWARD-LOOKING STATEMENTS
The statements contained in this Management's Discussion and Analysis
that are not historical information are forward-looking statements that are
based on management's estimates, assumptions and projections. The Private
Securities Litigation Reform Act of 1995 provides a safe harbor under The
Securities Act of 1933 and The Securities Exchange Act of 1934 for
forward-looking statements.
-10-
<PAGE>
PART II - OTHER INFORMATION
ITEM 1. LEGAL PROCEEDINGS
The Company and its Board of Directors know of no material legal
proceedings pending to which the Company is a party or which would
materially affect the Company. The Company is involved in pending and
threatened litigation in the normal course of its business in which claims
for monetary damages are asserted. Management, after consultation with
legal counsel, does not anticipate the ultimate liability arising from such
pending or threatened litigation to have a material effect on the financial
condition of the Company.
ITEM 5. OTHER INFORMATION
Not applicable.
ITEM 6. EXHIBITS AND REPORTS ON FORM 8-K
(a) Exhibits required by Item 601 of Regulation S-K
(2) None
(3)(i) Articles of Incorporation*
(ii) By-laws*
(4)(i) Allstate Life Insurance Company of New York
Single Premium Deferred Annuity Contract**
(ii) Allstate Life Insurance Company of New York Flexible
Premium Deferred Annuity Contract*
(10) None
(11) None
(15) None
(18) None
(19) None
(22) None
(23)(a)Consent of Independent Public Accountants***
(b)Consent of Attorneys****
(24) None
(27) Financial Data Schedule
(99) None
(b) Reports on 8-K
No reports on Form 8-K were filed during the third quarter of 1997.
* Previously filed in Form N-4 Registration Statement No.33-65381 dated
September 20, 1996 and incorporated by reference.
-11-
<PAGE>
** Previously filed in Form S-1 Registration Statement No.33-47245 dated
November 13, 1992 and incorporated by reference.
*** Previously filed in Form S-1 Registration Statement No.33-47245 dated April
1, 1997 and incorporated by reference. Previously filed in Form S-1
Registration Statement No. 33-65355 dated April 1, 1997 and incorporated by
reference.
**** Previously filed in Form S-1 Registration Statement No.33-47245 dated
November 13, 1992 and incorporated by reference. Previously filed in Form S-1
Registration Statement No. 33-65355 dated September 20, 1996 and incorporated
by reference.
-12-
<PAGE>
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 on the 11th day of November 1997.
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
(Registrant)
/s/LOUIS G. LOWER, II CHAIRMAN OF THE BOARD OF DIRECTORS
- --------------------- and PRESIDENT
LOUIS G. LOWER, II (Principal Executive Officer)
/s/KEITH A. HAUSCHILDT ASSISTANT VICE PRESIDENT AND CONTROLLER
- ----------------------- (Chief Accounting Officer)
KEITH A. HAUSCHILDT
<TABLE> <S> <C>
<CAPTION>
<ARTICLE> 7
<LEGEND> THIS SCHEUDLE CONTAINS SUMMARY FINANCIAL INFORMATION EXTRACTED FROM
STATEMENTS OF FINANCIAL POSITION AT SEPTEMBER 30, 1997; STATEMENTS OF
OPERATIONS THREE MONTHS ENDED SEPTEMBER 3O, 1997 AND SEPTEMBER 30, 1996 AND
NINE MONTHS ENDED SEPTEMBER 30, 1997 AND SEPTEMBER 30, 1996; AND STATEMENTS
OF CASH FLOWS NINE MONTHS ENDED SEPTEMBER 30, 1997.
</LEGEND>
<CIK> 0000839759
<NAME> ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
<MULTIPLIER> 1,000
<CURRENCY> U.S. DOLLARS
<S> <C>
<PERIOD-TYPE> 9-MOS
<FISCAL-YEAR-END> DEC-31-1997
<PERIOD-START> JAN-01-1997
<PERIOD-END> SEP-30-1997
<EXCHANGE-RATE> 1
<DEBT-HELD-FOR-SALE> 1,658,316
<DEBT-CARRYING-VALUE> 0
<DEBT-MARKET-VALUE> 0
<EQUITIES> 0
<MORTGAGE> 101,343
<REAL-ESTATE> 0
<TOTAL-INVEST> 1,797,535
<CASH> 15,985
<RECOVER-REINSURE> 2,132
<DEFERRED-ACQUISITION> 68,546
<TOTAL-ASSETS> 2,216,515
<POLICY-LOSSES> 0
<UNEARNED-PREMIUMS> 0
<POLICY-OTHER> 1,018,752
<POLICY-HOLDER-FUNDS> 593,829
<NOTES-PAYABLE> 0
0
0
<COMMON> 2,000
<OTHER-SE> 261,223
<TOTAL-LIABILITY-AND-EQUITY> 2,216,515
67,882
<INVESTMENT-INCOME> 92,871
<INVESTMENT-GAINS> 742
<OTHER-INCOME> 21,128
<BENEFITS> 132,946
<UNDERWRITING-AMORTIZATION> 4,565
<UNDERWRITING-OTHER> 15,493
<INCOME-PRETAX> 29,619
<INCOME-TAX> 10,662
<INCOME-CONTINUING> 18,957
<DISCONTINUED> 0
<EXTRAORDINARY> 0
<CHANGES> 0
<NET-INCOME> 18,957
<EPS-PRIMARY> 0
<EPS-DILUTED> 0
<RESERVE-OPEN> 0
<PROVISION-CURRENT> 0
<PROVISION-PRIOR> 0
<PAYMENTS-CURRENT> 0
<PAYMENTS-PRIOR> 0
<RESERVE-CLOSE> 0
<CUMULATIVE-DEFICIENCY> 0
</TABLE>
