Florida Hurricane
Catastrophe Fund
12th Annual Participating Insurers Workshop
May 15-16, 2012
Orlando, Florida
Opening Comments & Introductions
Jack Nicholson, Chief Operating Officer, Florida Hurricane
Catastrophe Fund
Hurricane Andrew
2
Agenda
May 16, 2012
9:00 Welcome
9:05 How Does the Claims Process Work Today Given
Current Technology?
9:30 Florida Hurricane Catastrophe Fund Update
9:50 2012 FHCF Premium Formula: Rates, Retention
Multiples, and Payout Multiples
10:30 BREAK
10:45 2012 Reimbursement Contract and Data Call Changes
10:55 Reporting Issues
11:30 Closing Remarks
3
How Does the Claims Process Work
Today Given Current Technology?
4
Hurricane Earl
Florida Hurricane Catastrophe Fund
Update
Leonard Schulte, Director of Legal Analysis and Risk Evaluation, FHCF
5
Hurricane Earl
Key Data: Coverage and Retention for
the 2012 Contract Year





$17 billion aggregate coverage limit for mandatory
coverage
$4 billion aggregate limit of available TICL coverage,
with approximately $317 million of TICL coverage
actually purchased
Maximum FHCF liability: $17.317 billion (projected)
No “LAC coverage” below the industry retention
Aggregate industry retention: $7.389 billion (projected)
6
Key Data: Premium for the 2012
Contract Year

Total projected premium:




Statutory “cash build-up factor” is now at 20%



Was 15% for the 2011 contract year
Will rise to 25% for 2013 (the last year of the phase-in)
Aggregate rate change for 2012 over 2011 is 14.79%


Mandatory coverage: $1.314 billion
TICL: $47 million
Total: $1.361 billion
10.01% before application of the cash build-up factor
Year-end projected cash balance: $8.56 billion
7
Return Times and Loss Probabilities


8.7 years, 11.5% probability to reach industry retention
of $7.4 billion
19.1 years, 5.24% probability to exhaust the cash
balance of $8.6 billion


33.8 years, 2.96% probability to reach the mandatory
coverage limit of $17 billion


$16.5 billion ground-up loss
$25.4 billion ground-up loss
42.6 years, 2.35% probability to reach the theoretical
TICL limit of $4 billion

$29.6 billion ground-up loss
8
2012/2013 Initial Season
Projection Based on Data Available as of May 2012
ESTIMATED TOTAL COVERAGE SELECTED: $17.317 billion
42.6 Years –
2.35%
$29.6B
$3.863B Available TICL Coverage Not Selected
33.8 Years –
2.96%
$0.033B
$17B Mandatory Coverage Limit
(Includes loss reimbursement and the 5% allowance for
loss adjustment expenses)
Bonding potential: $8.757B
Pre-event financing: ?
$8.560B Projected 2012 Year-End Cash
Balance
Mandatory Coverage
$16.5B
$1.816B Industry
Co-Payments
8.7 Years –
11.5%
$0.317B TICL Coverage Selected
$25.4B
Return Times,
Probabilities, &
Ground-Up Losses
19.1 Years –
5.24%
Not Drawn to Scale
Not Official
For Illustrative Purposes
Only
$7.389B
$7.389B Industry Retention
9
2012 FHCF Premium Formula: Rates,
Retention Multiples, and Payout Multiples
Andy Rapoport, Managing Director and Actuary, Paragon
10
FHCF Ratemaking
Overview




What’s New?
Balance: Funds Needed vs. Funds Sources
Ratemaking Process
Summary of Premium & Rate Changes
12
What’s New?

20% Cash Build-Up Factor included in rates


Quintuple TICL Premium



4x in 2011
TICL Limit reduced to $4 billion


15% in 2011
$6 billion in 2011
Investment rate assumption reduced from 1.5% to 0.0%
Pre-event notes expire 10/15/2012
13
Balance: Where Does the FHCF Get Its
Funds? Where Do They Go?
Loss &
Investment
Income
Financial
Post event
Assessments
Products
Premium
Operating
Expense
Mitigation
Funding
Loss
Expense
(5%)
Balance
Premiums are derived from the Ratemaking Formula
Page 14
Balance:
2004 & 2005 Hurricane Payments
Premium
and
Investment
Income
73%
Bonds
27%
15
Balance: What does the FHCF Premium
Pay For?
Expenses
2%
Mitigation
0%
Losses & LAE
98%
16
Ratemaking Process:
Overview of Steps
Step 1
Step 2
Step 3
Determine FHCF
Coverage
Trend
Exposure
Data
Simulate FHCF
Hurricane Losses
Step 5
Mandatory
FHCF
Premium
Step 4
Load Losses for Loss
Expenses, Operating
Expenses, Mitigation &
Adjust for Investment Income
17
Ratemaking Process:
Overview of Steps
Step 5
Mandatory FHCF Premium
Step 6
Allocate Premium to: Type of Business,
Deductible, Territory, Construction
Divide by Exposure
Recommended Rates
18
Ratemaking Process: Step 1 – Industry
Mandatory FHCF Coverage

Limit


Set by CS for SB 1460 at $17 billion until there are
sufficient resources for two seasons, limited to annual
growth in the cash balance
Industry Retention

Based on growth in reported exposures, projected to be
$7.389 billion for current Contract Year
19
Ratemaking Process:
Step 1 – Industry FHCF Coverage
($B)
Retention
Mandatory
TICL Limit
2005
4.667
15.000
0.000
2006
5.627
15.000
0.000
2007
5.785
15.845
12.000
2008
6.377
16.530
12.000
2009
7.204
17.175
10.000
2010
6.881
17.000
8.000
2011
7.143
17.000
6.000
2010
2011
Proj. 2012
7.389
17.000
4.000
FHCF Coverage
$40
$35
TICL Limit
Mandatory Limit
$30
Billlions
Retention
$25
$20
$15
$10
$5
$0
2005
2006
2007
2008
2009
Proj. 2012
20
Temporary Increase in Coverage Limit
(TICL)
Return Time
Return Time
40.9 yrs
FHCF
+
$4B TICL
$26.295B
32.6 yrs
$30.744B
FHCF
8.7 yrs
$7.389B
8.7 yrs
$7.389B
Mandatory FHCF Coverage
Mandatory Coverage Plus $4 Billion TICL Option
89.917% of $18.905B xs $7.389B
89.917% of $23.355B xs $7.389B
21
Ratemaking Process: Step 1 – Industry
Traditional FHCF Coverage
2012 Exposure Distribution
0.9%
4.0% 1.6%
9.6%
Residential
Exposure Drives
FHCF Totals
Residential
Tenants
Condominium
83.9%
Mobile Home
Commercial Habitational
22
Ratemaking Process:
Step 1 – Company FHCF Coverage
FHCF Premium
Payout Multiple
Retention Multiple
Used to
Calculate
Individual
Company’s
FHCF Coverage
23
Ratemaking Process:
Step 1 – Company FHCF Coverage
FHCF Industry Coverage: $17.000B xs $7.389B

Retention drops to 33% on 3rd largest event
Company Limit =
FHCF Premium x Payout Multiple
i.e., $100M x 12.9351
FHCF Coverage
at 90% Level
Company Retention =
FHCF Premium x Retention Multiple
i.e., $100M x 5.6170
24
Ratemaking Process:
Step 2 – Trend Exposure Data
Type of Business
Commercial
Residential
Mobile Home
Tenants
Condominium Unit Owners
Total
Assumed
Trends
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
Sent to Catastrophe Modelers
Projected
2011
Exposure
($B)
203.68
1,777.12
33.77
18.72
84.61
2,117.90
25
Ratemaking Process:
Step 2 – Trend Exposure Data

5 Accepted Hurricane Models





AIR Worldwide Corporation (AIR)
Applied Research Associates (ARA)
EQECAT (EQE)
Florida Public Hurricane Loss Model (FPM)
Risk Management Solutions (RMS)
New in 2008
26
Ratemaking Process:
Step 3 – Simulate FHCF Hurricane Losses
(Modeling Overview)
The Hurricane
Model
Stochastic
Event Set
(the storms)
Vulnerabilities
(damage functions)
Financial Model
(convert to
insured losses)
Insurance
Exposure
Information
Model Output
(AALs, PMLs)
27
Modeled Events Require Many
Parameters





Storm Landfall
Frequency
Track
Minimum Central
Pressure
Radius to
Maximum Winds
Parameters are
correlated, but not
perfectly so
28
04
)
Hazard: Hurricane Tracks
(2
0
19
E(
85
)
)
RLEY
Tallahassee
) Tallahassee
(2004
))
Pensacola
) Pensacola
Jacksonville
Jacksonville
)
L (1
OP
A
Ocala
)) Ocala
(1
ERI N
)
(199
5
Deltona
) Deltona
)
Orlando
) Orlando
Lakeland
) Lakeland
IS
NN
DE
E
EL
NA
5
98
Sarasota
) Sarasota
(20
)
KA
TR
I NA
( 20
)
RG
ES
05)
AND
(1
99
8
REW
(1992
)
) Palm
Palm Bay
Bay
)
West
West Palm
Palm
Beach
Beach
)
05
GE
O
(1999)
995
Gainesville
) Gainesville
FLOYD
FRANCES (2004)
Irene (1999)
)) Panam
Panamaa City
City
CHA
IV
A
N
T
KA
JEANNE (2004)
Naples
)) Naples
ILM
W
A
(20
)
05
Miam
Miamii
)
29
Damage: Data Required

Policy Structure



Limits by coverages
Deductibles
Individual Risk Characteristics



Type of Business
ZIP Code
Construction
30
Sources of Damage


Wind
Projectiles





Roof tiles
Gravel from
tops of
buildings
Wind-driven rain
Falling trees
Storm surge
31
Damage: Calculation
Damage
Roof Covering
Roof Decking
Roof Framing
Roof-Wall Connection
Lateral Bracing
Opening in Structure
Cladding of Structure
Frame-Foundation Connection
Foundation Failure
Structure
Loss Determined by Hazard and Policy Data
Wind Speed
32
Modeling Results
$ in billions
33
Gross Losses
Gross Single Event Severity Distribution
(100% Coverage, no LAE)
$60
$55
TICL
FHCF
$50
$45
$40
Loss ($B)
$35
$30
$25
2012
$20
2011
2010
$15
$10
$5
$0
0
5
10
15
20
25
30
35
40
45
50
55
Return Time (Years)
60
65
70
75
80
85
90
95
100
34
Ratemaking Process:
Step 4 – Loadings






Post-Model Adjustments +$51.1 million
Operating Expenses +$7.8 million
2007A Notes Expense +$14.2 million
Investment Income Credit -$0.0 million
Mitigation Funding $0 million (Now paid out of investments)
20% Cash Build-Up Factor +$219.0 million
35
Post-Model Adjustments
& Operating Expenses

Post-Model Adjustments



Used to account for special insurance coverages and
other factors not projected by models
2012 Selection 5% or $51.1 million
Operating Expenses

Day to day costs of FHCF

2012 Selection $7.8 million
36
2007A Notes Expense

Additional expense incurred in 2007 to increase liquidity
(cash) for the FHCF

Difference between interest payments to note holders and
investment income on note proceeds

Lost investment income

Expires 10/15/2012

2012 Charge $14.2 million
37
Investment Income Credit

FHCF generally holds funds several years before payout

Historically, investment income reduced the premium
required

2012 Investment Income Credit = $0.0 million
Interest Rate
Assumption
Return Time
Investment
Credit
2008 Rating Year
3.50%
4 yrs
11.04%
2009 Rating Year
3.00%
4 yrs
8.40%
2010 Rating Year
2.50%
4 yrs
7.38%
2011 Rating Year
1.50%
4 yrs
4.48%
2012 Rating Year
0.00%
4 yrs
0.00%
38
Mitigation Funding

Rates produced assuming all mitigation paid from
investment income

No Charge to premium

Funding can range from $10 million to 35% of prior
year’s investment income
39
Cash Build-Up Factor

The passage of CS/CS/CS/HB 1495 in 2009 by the
Florida Legislature imposed an escalating Cash BuildUp Factor on the mandatory premium
Year
Cash Build-Up Factor
Amount
2009
5%
$51.3M
2010
10%
$101.0M
2011
15%
$154.1M
2012
20%
$219.0M
2013
25%
40
Ratemaking Process:
Step 5 – Overall FHCF Premium
FHCF
TICL ($4B)
FHCF + TICL
2011 Premium
(Actual)
$1,145M
$90M
$1,235M
2012 Premium
(Projected)
$1,314M
$47M
$1,361M
% Change
+14.8%
-47.8%
+10.2%
Notes:
FHCF premiums include Cash Build-Up Factor (15% for 2011, 20% for 2012)
TICL premiums include TICL Factor (4x for 2011, 5x for 2012)
41
Ratemaking Process:
Step 6 – Allocating Loss
Proposed 2012
Rating Territories
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Not Rated
2012 Rating
Regions
32
Ratemaking Process:
Step 6 – Allocating Loss
100%
90%
80%
70%
60%
Tenants
Mobile Home
50%
Condominium-Owners
40%
Commercial
Residential
30%
20%
10%
0%
Total
Exposure
Terr 1-5
(40%)
Terr 6-10 Terr 11-15 Terr 16-20 Terr 21-25 Modeled
(22%)
(24%)
(9%)
(5%)
Loss
43
Recap of Ratemaking Steps
Step 1
Determine FHCF
Coverage
Step 5
Mandatory
FHCF
Premium
Step 2
Step 3
Trend
Exposure
Data
Simulate FHCF
Hurricane Losses
Step 4
Load Losses for Loss
Expenses, Operating
Expenses, Mitigation &
Adjust for Investment Income
44
Recap of Ratemaking Steps
Step 5
Mandatory FHCF Premium
Step 6
Allocate Premium to: Type of Business,
Deductible, Territory, Construction
Divide by Exposure
Recommended Rates
45
Summary: Overall Mandatory FHCF
Premium
FHCF Premium ($ Millions)
Components of 2012 Mandatory Premium Change
(+14.79%)
$1,350
$1,300
$1,314.3
$1,250
$1,259.5
$1,200
$1,215.7
$1,150
$1,144.9
$1,100
$1,144.9
$1,050
2011 Premium
Adjusted for
Adjusted for
Adjusted for
Adjusted for
Exposure
Modeled Losses Investment
Cash Build Up
Growth (0.00%) and Expenses Income (1.5% to Factor (15% to
(6.18%)
0.0%)
20%)
46
Summary: Overall Mandatory FHCF
Premium
Rate Change Component Impact
32%
42%
Modeled Losses and
Expenses (+6.2%)
Investment
Income/Mitigation (+3.6%)
Statutory Cash Build Up
(4.4%)
26%
47
Summary: Overall Indications
Rate Changes by Type of Business
FHCF Layer
(No change to
Cash Build-up*)
(Per Statute*)
Residential
Tenants
Condominiums
Mobile Home
Commercial Habitational
9.99%
11.59%
12.03%
1.09%
11.94%
14.77%
16.44%
16.90%
5.49%
16.81%
Total Rate Change
10.01%
14.79%
Type of Business
* Cash Build-up Factor for 2011 was 15%; for 2012 it is 20%
48
Windstorm Mitigation Construction Factors

FHCF member companies are required to adjust primary
rates for mitigation

Hurricane models show significant differentiation in risk for
exposures with these features

Classifications first used with FHCF rates in 2009




Capped at +/-10% in 2009
Capped at +/-20% in 2010 and 2011
Recommend: Maintain Cap at +/-20% in 2012
Revised rating factors to match Data Call revisions


Removed Florida Building Code
Removed BCEG
49
Mitigation Construction Factor Relativities
20% cap in 2012
50
Temporary Increase in Coverage Limit
(TICL)
Multiply published FHCF rates by the premium
adjustment factor for the selected TICL limit level
51
FHCF Reserving
Contract Years Comparison:
FHCF Loss Development
FHCF: 2004 and 2005 Losses by Age of Report
6.000
5.000
$ Billions
4.000
3.000
Year 1
2.000
1.000
0.000
2004
2005
53
Contract Years Comparison:
FHCF Loss Development
FHCF: 2004 and 2005 Losses by Age of Report
6.000
5.000
$ Billions
4.000
Year 2
3.000
Year 1
2.000
1.000
0.000
2004
2005
54
Contract Years Comparison:
FHCF Loss Development
FHCF: 2004 and 2005 Losses by Age of Report
6.000
5.000
$ Billions
4.000
Year 3
3.000
Year 2
Year 1
2.000
1.000
0.000
2004
2005
55
Contract Years Comparison:
FHCF Loss Development
FHCF: 2004 and 2005 Losses by Age of Report
6.000
5.000
$ Billions
4.000
Year 4
Year 3
3.000
Year 2
Year 1
2.000
1.000
0.000
2004
2005
56
Contract Years Comparison:
FHCF Loss Development
FHCF: 2004 and 2005 Losses by Age of Report
6.000
5.000
4.000
$ Billions
Year 5
Year 4
3.000
Year 3
Year 2
Year 1
2.000
1.000
0.000
2004
2005
57
Contract Years Comparison:
FHCF Loss Development
FHCF: 2004 and 2005 Losses by Age of Report
6.000
5.000
4.000
$ Billions
Year 6
Year 5
Year 4
3.000
Year 3
Year 2
Year 1
2.000
1.000
0.000
2004
2005
58
Contract Years Comparison:
FHCF Loss Development
FHCF: 2004 and 2005 Losses by Age of Report
6.000
5.000
4.000
Year 7
$ Billions
Year 6
Year 5
3.000
Year 4
Year 3
Year 2
Year 1
2.000
1.000
0.000
2004
2005
59
Contract Years Comparison:
FHCF Loss Development
FHCF: 2004 and 2005 Losses by Age of Report
6.000
5.000
4.000
Year 8
$ Billions
Year 7
Year 6
Year 5
3.000
Year 4
Year 3
Year 2
Year 1
2.000
1.000
0.000
2004
2005
60
Contract Year 2004-2005:
FHCF Loss Development
FHCF Loss Development
4.500
4.000
3.500
$ Billions
3.000
2.500
2.000
FHCF IBNR
Reported Outstanding
1.500
FHCF Paid
1.000
0.500
0.000
2004
2005
2006
2007
2008
2009
2010
2011
2012
As of 12/31/YY *
61
Contract Year 2005-2006:
FHCF Loss Development
FHCF Loss Development
6.000
$ Billions
5.000
4.000
3.000
FHCF IBNR
2.000
Reported Outstanding
FHCF Paid
1.000
0.000
2005
2006
2007
2008
2009
2010
2011
2012
As of 12/31/YY *
62
Questions?
63
BREAK
Sponsored by:
2012 Reimbursement Contract and Data
Call Changes
Martin Helgestad, Managing Director, Paragon
Kathy Mackenthun, Director, Paragon
Gina Wilson, Director of Examinations, FHCF
65
Contract (Article I)

Scope of Agreement

Clarification that the SBA shall reimburse for Ultimate Net
Loss on Covered Policies in force and in effect at the time
of the Covered Event causing the loss…
66
Contract (Article X)

Commutations

Following submission to a panel of three actuaries, the
parties are prohibited from providing further information
or other communication unless requested by the panel

Responses to the panel must be in writing,
simultaneously provided to the other party and all
members of the panel

Panel may require response be provided in a meeting or
teleconference attended by both parties and all members
of panel
67
Contract (Article XIII)

Inspection of Records – Examination Procedures

Exposure Exam


Clarification that once SBA has accepted a
resubmission as a sufficient response to the
examiner’s findings, the exam is closed
Claims Exam

Clarification that once the SBA has accepted a
corrected Proof of Loss Report as a sufficient
response to the examiner’s findings, the exam is
closed
68
Addenda to the Contract

Addendum No. 1: Temporary Increase in Coverage
Limit Option (TICL)

Company’s coverage equals its share of one of four
layers of TICL coverage from $1B to $4B

TICL premium increased by a factor of 5 (factor of 4 for
2011 Contract Year)
69
Amendment to the Contract

Optional Amendment to Change Prior Elections

Allows a company to change its elections prior to June 1,
2012

If used, requires re-affirmation of all elections previously
made

There were no changes to this form
70
Data Call

Florida Building Code Indicator (FBCI) Code field
eliminated

Building Code Effectiveness Grading (BCEG) Code
field eliminated

Both fields in the record layout are reserved for future use
71
Reporting Issues
Martin Helgestad, Managing Director, Paragon
Kathy Mackenthun, Director, Paragon
Steve Szypula, Manager of Financial Operations, FHCF
Marcie Vernon, Senior Examiner Analyst, FHCF
Gina Wilson, Director of Examinations, FHCF
72
Construction Code Mappings

When is a construction code mapping required to be
submitted?


When the company’s and the FHCF’s definitions do not
match
How often should my company submit a mapping for
approval?

Annually
73
Short Term Rentals

Are short term rentals covered by the FHCF?

Exclusion defined in Article VI of the FHCF
Reimbursement Contract

Applies to homes, condominium structures or
condominium units

What if my company does not know if a unit is a short
term rental?

How does the FHCF know if a unit is used as a short
term rental?

Reviewed during FHCF exams
74
Single Structures

What is a single structure?

How are single structures required to be reported to the
FHCF?

Predominantly residential – report the entire exposure

Predominantly commercial non-residential – report the
exposure based on your company’s carve out option in
the Reimbursement Contract
75
Single Structures

How does the FHCF define predominantly residential
versus predominantly commercial non-residential?

How does the FHCF know if a structure is
predominantly residential or predominantly commercial?
76
Impact of Data Call Resubmissions on
Reimbursements

Can have a large financial impact

Premium increase/decrease

Interest charge

Hold on reimbursements

Five-fold impact on retention at 90% coverage

Thirteen-fold impact on FHCF limit
77
Impact of Data Call Resubmissions on
Reimbursements

Example based on initial Data Call:

90% Coverage

Premium = $1 million

Retention = $5.617 million

Maximum Payout = $12.935 million
78
Calculation of Reimbursement
(not considering optional coverage options)
Example: Ultimate Net Loss (UNL) = $19.0M
90% Coverage Structure
10%
$12,935,100 Maximum
FHCF Payout
(90% coverage)
Retention
$5,617,000
Reimbursement Equals:
19,000,000 paid UNL
5,617,000 retention
x
90% coverage
+
5% LAE
Equals: $12,647,000
79
Impact of Data Call Resubmissions on
Reimbursements

Assume an exposure exam results in a new premium of
$900,000

Retention = $5.055 million

Maximum Payout = $11.642 million

Paid Ultimate Net Loss still $19.0 million
80
The Impact:
Original Reimbursement
$12,647,000
Recalculated Reimbursement
equals $13,178,000; BUT exceeds limit:
$11,641,600 Maximum
FHCF Payout
$12,935,100 Maximum
FHCF Payout
10%
10%
(90% coverage)
(90% coverage)
Retention
$5,617,000
Retention
$5,055,300
Excess Reimbursement Equals: $1,005,400
(prior paid against new maximum coverage)
81
Loss Reporting Changes Since 2005
82
Detailed Claims Listing (DCL) - 2007

Requirement added to include a DCL with the first Proof
of Loss Report (POL) that qualifies a company for
reimbursement for a specific hurricane

Provides a historical baseline

File layout and requirements provided in the Loss
Reimbursement Examination Advance Preparation
Instructions (LAP1)

Omitting the DCL could delay reimbursements

DCL should be prepared and retained for every POL filing
83
Loss Assessment - 2010

Losses attributable to Loss Assessment contractually
excluded from FHCF coverage

Legislatively excluded in 2011

Reporting losses attributable to Loss Assessment could
result in significant excess reimbursements
84
Proof of Loss Report “as of” Date - 2010

Requirement added to address the age of data reported
to the FHCF on quarterly or annual Proof of Loss
Reports

“As of” date may not be more than 60 days prior to the
applicable quarter-end or year-end date

Older data could result in delayed reimbursements
85
Policyholder Fees - 2011

Legislation changed the definition of FHCF losses to:

Include “amounts paid as fees on behalf of or inuring to
the benefit of a policyholder”

Specifically exclude amounts paid as:

Bad faith awards

Punitive damage awards

Other court-imposed fines, sanctions, or penalties
86
Claims File Documentation Changes

Items to be retained for FHCF on-site loss reporting
examinations

Numerous additions from 2007 – 2011, such as:


First notice of loss

Evidence to show loss was direct result of a hurricane

All adjuster estimates, including public adjusters if
provided to the company
Requirements included on the Proof of Loss Report
87
Early Reimbursements (No Change)

A company can receive reimbursements prior to the
September 1st Data Call deadline, assuming the FHCF
has the available liquid assets and the following criteria
have been met:

The company’s Data Call was submitted in advance of
the reimbursement request

Paragon has completed its review of the Data Call and
any issues have been adequately addressed by the
company

The company is fully in compliance with all other FHCF
requirements
88
Closing Remarks