Allianz Risk Transfer AG

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1 Primary Credit Analyst: Jean Paul Huby Klein, Frankfurt (49) ; Secondary Contact: Volker Kudszus, Frankfurt (49) ; Table Of Contents Major Rating Factors Rationale Outlook Corporate Profile: The Alternative Solutions Provider Within The Allianz Group Competitive Position: A Strong And Recognizable Franchise Management And Corporate Strategy: An Effective Management Structure Enterprise Risk Management: Strong Risk Controls Accounting: Reported Premium Income Does Not Reflect The Scale Of Alternative Business Operating Performance: A Sound Track Record, But Volatility And Margin Pressure Could Arise Investments: A Revised Asset Allocation Strategy After Run-Off Of Alternative-Assets Business Liquidity: Strong, And Exposure To Risk Is Reducing SEPTEMBER 3,

2 Table Of Contents (cont.) Capitalization: Strong, With A Strong Quality Of Capital Financial Flexibility: Very Strong, With AZSE's Support Related Criteria And Research SEPTEMBER 3,

3 Please note that the ratings covered by this full analysis apply only to entities of the group, which are listed below in the Ratings Detail section. These ratings do not apply to any noncore or nonrated entities of the group. Ratings assigned to noncore entities of the group are published individually. Major Rating Factors Strengths: Strategically important to ultimate parent, Allianz SE. Strong competitive position and effective management. Strong operating performance. Strong capitalization. Operating Companies Covered By This Report Financial Strength Rating AA-/Negative/-- Weaknesses: Potential for volatility in new business volumes, arising from an innovative approach to risk transfer and competitive pressure. Potential for earnings fluctuations as a result of volatility in traditional portfolios, foreign exchange effects, or challenging capital markets. Rationale The ratings on Switzerland-based Allianz Risk Transfer AG (ART AG) and its guaranteed subsidiaries, Bermuda-based Allianz Risk Transfer (Bermuda) Ltd. and Dutch entity Allianz Risk Transfer N.V. (collectively ART), reflect the companies' strategic importance to their ultimate parent Allianz SE (AZSE; AA/Negative/A-1+). As a result of this "strategically important" status, the ratings on ART currently benefit from two notches of implicit group support. Under Standard & Poor's Ratings Services' criteria, the ratings could benefit from up to three notches of support, but are capped at one notch below the ratings on AZSE's core operating subsidiaries. In our view, ART's stand-alone creditworthiness is underpinned by its strong competitive position, effective management, strong operating performance, and strong capitalization. These factors are partly offset by the potential for volatility in new business volumes, which may arise as a result of ART's innovative approach to risk transfer and its opportunistic strategy in terms of business development. We believe earnings could continue to fluctuate because of the still challenging conditions in the global economy and financial markets, foreign exchange effects, or volatility in traditional portfolios. We consider ART strategically important to AZSE, due to its strong operational integration and business relationships with other Allianz operations, especially with its intermediate parent Allianz Global Corporate & Specialty AG (AGCS; AA/Negative/--). In addition, the company plays an increasingly important role in AGCS' expansion plans and is the competence center for alternative insurance risk transfer solutions, which, we believe, provides the wider group with the means to maintain a competitive edge with corporate clients. SEPTEMBER 3,

4 ART's competitive position is strong, in our view, and management is a positive factor for the rating. The team's success to date is a reflection of its small, manageable size and adherence to strong underwriting discipline, coupled with access to the resources of one of the world's largest insurance providers. The termination of ART's alternative-assets business in 2009 underlines ART's strategic refocus on risks related to insurance and reinsurance, which supports other initiatives of the Allianz group. We expect ART to continue to increase its share of traditional business and pursue its opportunistic approach in the alternative risk transfer segment, backed by AZSE's increasingly cohesive approach to managing relationships with key corporate and reinsurance clients. We view ART's operating performance as strong. ART has made a positive contribution in each of its 15 years in operation, providing a consistent stream of earnings to the Allianz group. ART has regularly been a top-quartile performer among Allianz's subsidiaries according to economic value-added analysis (EVA), which is one of AZSE's main metrics for appraising the performance of its subsidiaries. We expect ART's focus on maintaining the diversity within its risk portfolio to continue to underpin a sophisticated approach to risk management. This, in our view, should enable ART to report sustainable net income of more than 40 million on its nontraditional business in 2012 and continue to exceed its parent's EVA targets. However, rising competitive pressures could dampen margins on new transactions. We regard ART's capitalization as strong and we expect it to remain at least strong because of its very strong capital adequacy as measured by our risk-based capital model. We believe that the company needs to operate with capital that is at least strong to maintain a buffer against potential earnings volatility and finance further business expansion. In addition, we believe that AZSE is committed to maintaining ART's capitalization at a level commensurate with our rating parameters. Despite what we view as ART's robust risk management framework and consistent earnings track record, the alternative nature of the deals it underwrites within the nontraditional segment means that the risk of earnings volatility remains. This can stem from asset or liability exposures, until ART has fully shifted its remaining alternative assets to lower-risk classes and reduced the relative weight of alternative-asset exposures in the investment portfolio. ART's nontraditional portfolio is also exposed to structured credit and long-tail casualty lines (for the latter there is a long time frame between claims-causing incidents and claim settlements). As a result, the continuation of a challenging economic environment could hamper the earnings of these lines. Nevertheless, we believe that ART's stringent approach to setting risk limits, the diversity within its nontraditional portfolio, and its sound record partly mitigate the downside risk to earnings. Earnings volatility can also arise from insurance risk in the traditional portfolios or from foreign exchange effects in ART AG's profit and loss account. This is because most of ART AG's transactions are either structured in U.S. dollars or euros, while it reports publicly in Swiss franc. Outlook The negative outlook on ART reflects that on its ultimate parent AZSE. We expect that ART, in view of its strategic importance to AZSE, will continue to benefit from financial and liquidity support from AZSE and its intermediate SEPTEMBER 3,

5 parent--agcs AG--if necessary. A negative rating action on AZSE would trigger a similar action on ART. We could also lower the ratings if ART's strategic role within the Allianz group or financial support from the group were to weaken, which we consider unlikely however. We regard rating upside as unlikely at this stage. Corporate Profile: The Alternative Solutions Provider Within The Allianz Group ART was formed in 1997 as the center of excellence for nontraditional risk management techniques to enable the Allianz group to offer holistic risk management solutions to its clients. Since the termination of the alternative-assets business in 2009, which was placed into run-off, ART has focused on three strategic business segments related to insurance and reinsurance risk: Corporate Solutions, Insurance-Linked Markets (ILM), and Reinsurance Solutions, collectively referred to as "nontraditional" business. Furthermore, ART is expanding its business share in the traditional insurance business, operating more in line with AGCS. ART is highly integrated into AGCS' operations, sharing management responsibilities in different central departments like finance or risk management. Furthermore, the company is integrated into the Allianz group's plans for an increasingly systematic approach to serving corporate and reinsurance customers. ART lends its expertise to the group's product offering in the area of alternative risk transfer and underwrites or otherwise facilitates transactions on behalf of the Allianz group. The termination of its alternative-assets business is a reflection of ART's strategic shift toward insurance-related risks. We understand that ART will continue to write traditional industrial insurance business, directly or through its subsidiaries, at various locations, such as in Switzerland, the Gulf region, and South America. ART AG is the parent company of the ART group and it maintains subsidiaries in the Bermudas and the Netherlands, which it guarantees, and is in the process of setting up a subsidiary in South America. We do not expect any changes to ART's current legal structure. Competitive Position: A Strong And Recognizable Franchise Table 1 Allianz Risk Transfer/Competitive Position --Year ended Dec (Mil. CHF) Gross premiums written (GPW) 787 1,259 1,154 1,331 1,675 Annual change in GPW (%) (37.4) 9.1 (13.3) (20.5) 87.5 Net premiums written (NPW) ,128 1,441 Annual change in NPW (%) (73.2) 28.8 (40.0) (21.7) 85.1 Net premiums earned ,214 1,270 Total revenue ,308 1,336 CHF--Swiss franc. SEPTEMBER 3,

6 ART has developed a strong and recognizable franchise in the nontraditional alternative risk transfer segment, thanks to its structuring expertise and reputation as a consistent source of financially strong risk capacity. We consider that ART's adaptability, which stems from its size and structure, enables it to take advantage of short-term dislocations between traditional markets and corporate customers' demand for individualized insurance solutions. ART's competitive position benefits from access to the resources of the Allianz group. ART works closely with other members of the group, mainly global industrial and specialty lines writer AGCS and a virtual reinsurance unit within AZSE, called Allianz Re. In its Corporate Solutions segment, we expect ART to further participate in, and benefit from, a "select account" initiative. In this combined initiative with AGCS, ART aims to better exploit the group's broad-based expertise to enhance its service offering to key corporate clients, with benefits for both AGCS and ART. ART focuses on multiyear captive solutions and tailored client solutions. Since the initiative started in 2007, the relative weight of deal income from this business segment has increased, reaching about 39% in 2011 after an average 23% in In the ILM segment, which contributes about 42% of ART's deal income in 2011, ART acts in multiple functions along the value chain of ILM transactions. This provides it with what we consider to be thorough market expertise in a field where insurance and capital markets converge. Furthermore, ART coordinates business activities with Allianz Re and contributes its expertise on investor demand (namely, the placement of Allianz's risks into capital markets, which is ultimately executed by Allianz Re). A key focus is on products related to natural catastrophes. Reinsurance Solutions contributes about 3% of ART's deal income in 2011, which is far below our expectation of about 18%. The decrease resulted from the high amount of natural catastrophes in ART underwrites, via brokers, special coverage--similar to those in the Corporate Solutions segment--for other clients that traditional markets do not cater for. Over the years, ART has built direct relationships with both intermediaries and clients. This has enabled it to establish a franchise in its own right, further reinforcing its competitive position. Moreover, ART benefits from its strong position in a variety of distribution channels. Prospective We expect ART to continue to expand its market shares in traditional business, offering products that are in line with AGCS. We also expect further integration of ART within AGCS as the company takes over responsibility for business in some growth markets. ART is in our view likely to expand its nontraditional alternative risk transfer book as appropriate transaction opportunities arise, but we believe growth will remain constrained, particularly in challenging economic conditions. This is because alternative risk transfer solutions are often rather complex, perceived as expensive, and require both clients and risk carriers to have considerable know-how. Increasing competitive pressures in the corporate solutions and insurance and reinsurance segments will likely dampen new business growth and create some margin pressure on new transactions. However, we think that the growth of the sector, at least in terms of premium volume if not deal flow, will be spurred by episodes of short-term dislocations in traditional markets and clients' increasing appetite for, and acceptance of, structured solutions. Over the longer term, ART's continued successful collaboration with AGCS and other group companies in a maturing alternative risk solutions market could further support our view of ART's strategic relevance within the Allianz group. SEPTEMBER 3,

7 We consider ART's unique entrepreneurial culture, fast response rate, and ability to innovate to be critical to its ongoing success. Consequently, an erosion of any of these characteristics is likely to have a negative impact on our view of ART's stand-alone financial strength. Management And Corporate Strategy: An Effective Management Structure We regard ART's management as a positive factor for the ratings because it is a small, strong, and closely knit team with extensive multidisciplinary experience. We consider management's adherence to ART's focused strategy and the robustness of ART's approach to risk management to be important factors for its success. Strategy One of ART's main functions is to help AZSE broaden and deepen its franchise in international industrial lines insurance. However, in our view, ART is selective in risk-taking and may occasionally act in an advisory capacity to its affiliates, without taking the underlying risk. Unlike a traditional insurance company that tends to buy and hold risk, ART uses its structuring expertise to actively manage its exposures. We view this approach as positive because it enables ART to manage its aggregate exposures within its risk tolerance, as well as to generate excess returns in certain situations. ART is selective in underwriting and structuring profitable business. ART's business acquisition strategy is opportunistic, in our view, because it tends to participate in deals that enable it to develop unique structuring expertise. The company exploits this expertise, either as the principal risk carrier or in an advisory capacity. ART's underwriting approach facilitates sound profitability, as demonstrated by its positive track record. We expect the level of integration between ART and other members of the Allianz group to increase further. We believe that ART's client focus, risk-modeling know-how, and structuring expertise will ensure its continued role as an intrinsic part of the AGCS division and the broader Allianz group. ART's know-how also supports the group's placement of insurance risk into capital markets. Operational management ART's operational management is strong, in our view, supported by a flexible corporate structure with fast response times. We understand that ART plans further improvements to systematically exploit the potential of Allianz group's customer base. We believe that, combined with a continuous enhancement of competencies and skills, this will be key to sustainable long-term growth in the alternative risk transfer segment. Key-person risk is an important factor, due to ART's small size. The company has actively worked on reducing this risk by broadening the involvement of different staff in each transaction, for example, by separating the underwriting and deal management functions. ART is well integrated into AGCS' operating model and is important as the competence center for alternative risk transfer solutions within the Allianz group, highlighting its strategic importance. Furthermore, the company is widely integrated into the Allianz group in terms of finance, accounting, investment, and risk management. SEPTEMBER 3,

8 Financial management ART's financial management is fairly conservative, in our view. The company defines its risk tolerance according to its ability to meet its planned underwriting result. AZSE's goal is sustainable profitability, so we don't believe ART is under pressure from its parent company to achieve any rapid growth targets. ART is structured for moderate growth and a low fixed-cost base, with staffing and deal costs having significant variable components. The company delegates its asset management to Allianz group affiliates, but it defines and monitors its own investment strategy. We expect the company to continuously hold a certain minimum capital volume above the requirements for its current alternative risk transfer portfolio. Therefore, we believe the transfer of some of AGCS' risks onto ART's balance sheet will consume some of that excess capital. Enterprise Risk Management: Strong Risk Controls We consider ART's enterprise risk management to be strong. As such, we regard it as unlikely that ART will experience major losses outside its risk tolerance. The high level of risk inherent in ART's business model is largely offset by the combination of strong risk controls in key areas and what we see as ART's strong risk management culture. An independent head of risk management with escalation rights into AGCS AG and AZSE, as well as underwriting and risk management committees, further strengthen ART's risk management framework. ART has adopted a sophisticated approach to risk management and strives to continuously enhance its risk management framework. In 2011, ART implemented a deal management function that allows the separation of the underwriting and surveillance functions. Before underwriting any new deals, ART assesses the impact of each additional transaction on the aggregate exposure of its portfolio, using stochastic models. We view the most significant risks relating to ART's portfolio as modeling risks, including appropriate risk-aggregation assumptions and deal-structuring issues. ART has substantially enhanced its model documentation and has embedded this as part of its underwriting process for new deals. ART's stochastic models underpin its decisions relating to risk acceptance, pricing, risk mitigation, and portfolio management. Consequently, any deficiencies in the models' parameters, particularly regarding the prediction of how individual deals will behave under exceptional circumstances, could cause ART's exposure to exceed its stated tolerance. ART continuously improves the models and is using certain proprietary models for the Swiss Solvency Test, a mechanism imposed by the Swiss insurance regulator to measure the capital required to support the risks carried by insurance companies. Legal and compliance risks are inherent in ART's business, given the types of deals it underwrites. However, we consider these risks to be partly offset by the thorough review of each deal by a legal expert before acceptance. Accounting: Reported Premium Income Does Not Reflect The Scale Of Alternative Business ART's fully audited financial statements are prepared under Swiss generally accepted accounting principles, which is the basis for the financial tables in this report. In addition, in line with the Allianz group, ART prepares an abridged set SEPTEMBER 3,

9 of financial statements under International Financial Reporting Standards (IFRS) for group-reporting purposes. Fluctuations in foreign exchange rates can create volatility in ART AG's Swiss-franc-denominated financial statements. However, we recognize that ART mainly focuses on profitability in euro terms because ART is consolidated into AGCS and AZSE in euros. The premiums reported by the alternative business won't always reflect this segment's overall contribution because many transactions create fee or investment income only. Our capital analysis focuses on an aggregate view of ART's global presence, using internal IFRS financials. We have assigned individual risk factors to each nontraditional deal (see the "Capitalization" section for further details). Operating Performance: A Sound Track Record, But Volatility And Margin Pressure Could Arise Table 2 Allianz Risk Transfer/Operating Statistics --Year ended Dec Gross combined ratio (%) Gross loss ratio (%) Net combined ratio (%) Net loss ratio (%) Net expense ratio (%) Acquisition expense ratio (%) Administrative expense ratio (%) Three-year average combined ratio (%) Return on revenue (%) Direct yield on invested assets (%) Yield (including realized) (%) (0.1) 4.4 EBIT on adjusted equity (%) ART's operating performance is strong, reflecting, in our view, prudent underwriting and a well-diversified risk portfolio. However, the alternative nature of the deals ART underwrites within the nontraditional segment means that the risk of earnings volatility remains. The still challenging economic and financial markets and insurance risk in the traditional portfolios can also pose a risk to earnings. Since 2001, ART's annual EVA contribution on nontraditional business has been more than Swiss franc (CHF) 25 million. More importantly, ART has made a positive contribution in each of its 15 years in operation, providing a consistent stream of earnings for the Allianz group. We note however that the challenging economic and financial markets of recent years have suppressed the company's earnings in the past, but earnings have improved over the past two years in a more benign climate. ART's total net income increased strongly in 2011 to 218 million from 48 million in This was mainly owing to SEPTEMBER 3,

10 unusually high reserve releases after the termination of a traditional reinsurance contract. However, even without the one-time effect, the overall results nearly doubled compared with Positive earnings throughout the financial crisis demonstrate the still sound underlying margins of ART's business and the increasing diversity of deals executed within its three areas of expertise. In our view, this allows for positive earnings even under very demanding market conditions. The traditional portfolios currently consist of relatively small industrial lines business underwritten in Switzerland and the Gulf region, which together earned net premiums of about 100 million in These portfolios contribute to potential earnings volatility and have been posting losses in the past, but made a positive contribution in Foreign exchange effects can influence ART AG's profit and loss account because most of its transactions are in U.S. dollars or euros, whereas it reports publicly in Swiss franc. We base our analysis on euro values because ART is consolidated into AGCS and AZSE in this currency. Prospective In our view, the individual performance of various transactions demands management's close attention, given the currently challenging markets. However, the increasing number of transactions and broader risk diversity in ART's portfolio, as well as the termination of the alternative-assets business, should enhance earnings stability. For 2012 and beyond, we expect ART to achieve net income of at least 40 million on its nontraditional business. We expect the run-off process of its alternative-assets business to generate additional positive returns on average. Nevertheless, we acknowledge that individual years could be affected by adverse performance. For our ratings on ART, we assume that there will be no further material impairments on the company's alternative-asset transactions. For the traditional business, we assume a positive net income contribution. Investments: A Revised Asset Allocation Strategy After Run-Off Of Alternative-Assets Business Table 3 Allianz Risk Transfer/Investment Statistics --Year ended Dec Total investments (mil. CHF) 2,088 2,037 1,779 2,058 2,497 Investment in affiliates (%) Loans to affiliates (%) Bonds and other fixed-interest securities (%) Equities and other variable-interest securities (%) Cash and bank deposits (%) Other investments (%) CHF--Swiss franc. In our view, ART manages the assets backing its traditional insurance book prudently, both in terms of credit quality SEPTEMBER 3,

11 and asset-liability matching. We expect the exposure on its alternative-assets portfolio to reduce gradually and ART to most likely reinvest these assets in bonds. We believe these risk-mitigation measures could stabilize investment income in the future and shift ART's risk-capital requirements from investment to insurance risks. Alternative-asset investments placed in transactions as part of ART's nontraditional business have historically exposed ART to high market risk and, in the past, to substantial impairments. Given the expected underlying future profitability of the currently 15 remaining alternative-asset investments, ART is not rushing to offload them. This means that the average life of the remaining exposures is still four years, with some longer than 10 years. As this portfolio continues to reduce, however, we expect ART's alternative assets to increasingly comprise highly rated investments. As of Dec. 31, 2011, bonds formed 74% of ART's total invested assets, cash 21%, equities 1%, reinsurance deposits 3%, and the remainder, other investments. Bonds are generally of a high quality, with 62% of the portfolio rated 'AAA', 22% 'AA', 7% 'A', 5% rated 'BBB', and the remainder in the non-investment grade category as of year-end ART tightly controls asset-liability mismatches by investing its technical liabilities in cash and bonds, and its investment guidelines limit mismatches within plus or minus 10% (currency mismatch) and plus or minus six months (duration mismatch). Liquidity: Strong, And Exposure To Risk Is Reducing Liquidity can be a major issue for providers of alternative risk transfer solutions. ART sets specific liquidity cover on transactions to match the most severe potential liquidity requirements. Nevertheless, certain financial transactions can also give rise to additional liquidity demands. We expect the termination of ART's alternative-assets business to reduce its liquidity needs over time. In addition, we don't expect ART to suffer any liquidity constraints because it actively manages its liquidity profile with a highly liquid investment portfolio and it has access to backup liquidity from its parent if needed. As of year-end 2011, ART's overall liquidity had remained strong. Capitalization: Strong, With A Strong Quality Of Capital ART's capitalization is strong, in our view. The company benefits from very strong capital adequacy as measured by our risk-based capital model, sound reserves, and comprehensive, tailored reinsurance protection. We believe that the company needs to operate with capital that is at least strong, to maintain a buffer against potential earnings volatility and finance further business expansion. We regard quality of capital as strong, with the majority comprising hard capital components such as shareholders' funds. Capital adequacy Capital adequacy benefits from a high proportion of shareholders' funds and risk mitigants within ART's transactions. We have assessed nontraditional transactions individually and applied conservative capital charges, based on our determination of the risk ART carries on its balance sheet. We generally reduce the exposure according to the credit quality of reinsurance or the credit quality of any security pledged or issued. Capital requirements for the nontraditional book are then input into our risk-based capital adequacy model, where we combine them with the requirements for the traditional book. The charges on ART's nontraditional portfolio amount to about 30% of the company's overall capital requirements at year-end 2011, in our capital adequacy assessment. SEPTEMBER 3,

12 Reserves We consider ART's loss reserves to be conservative, although they have not been independently certified in recent years. The company determines reserves individually for each transaction, either when it suspects losses or receives notification. This process is supported by ART's probabilistic modeling methodology. Reserves are not discounted in the financial statements, and we view ART as cautious in its recognition of revenue and earnings. Reinsurance ART purchases reinsurance on a contract-by-contract basis, and we consider reinsurer credit risk to be minimal. ART generally uses highly rated reinsurers (with a minimum rating of 'A-') or secured letters of credit to protect its transactions. We view ART's reinsurance panel as providing strong protection against the potential volatility of its nontraditional portfolio on a deal-by-deal basis. Financial Flexibility: Very Strong, With AZSE's Support Table 4 Allianz Risk Transfer/Financial Statistics --Year ended Dec (Mil. CHF) Capitalization Reported shareholders' equity* Change in adjusted equity (%) 40.9 (1.0) 17.2 (14.8) 8.5 Reinsurance Reinsurance utilization ratio (%) Reserving Loss reserves/net premiums written (%) *Excluding outstanding share capital. CHF--Swiss franc. As a strategically important member of the Allianz group, ART's financial flexibility is tied to that of its parent and we therefore consider it to be very strong. Related Criteria And Research Principles Of Credit Ratings, Feb. 16, 2011 Management And Corporate Strategy Of Insurers: Methodology And Assumptions, Jan. 20, 2011 Refined Methodology And Assumptions For Analyzing Insurer Capital Adequacy Using The Risk-Based Insurance Capital Model, June 7, 2010 Interactive Ratings Methodology, April 22, 2009 Group Methodology, April 22, 2009 Ratings Detail (As Of September 3, 2012) Operating Companies Covered By This Report SEPTEMBER 3,

13 Ratings Detail (As Of September 3, 2012) (cont.) Allianz Risk Transfer AG Financial Strength Rating Counterparty Credit Rating Financial Enhancement Rating Allianz Risk Transfer (Bermuda) Ltd. Financial Strength Rating Financial Enhancement Rating Allianz Risk Transfer N.V. Financial Strength Rating Financial Enhancement Rating Related Entities Allianz Global Corporate & Specialty AG Financial Strength Rating Issuer Credit Rating Allianz SE Financial Strength Rating Issuer Credit Rating Commercial Paper Junior Subordinated Junior Subordinated A+ Senior Unsecured Subordinated Domicile AA-/Negative/-- AA-/Negative/A-1+ AA-/--/-- AA-/Negative/-- AA-/--/-- AA-/Negative/-- AA-/--/-- AA/Negative/-- AA/Negative/-- AA/Negative/-- AA/Negative/A-1+ A-1+ A AA AA- Switzerland *Unless otherwise noted, all ratings in this report are global scale ratings. Standard & Poor's credit ratings on the global scale are comparable across countries. Standard & Poor's credit ratings on a national scale are relative to obligors or obligations within that specific country. Additional Contact: Financial Institutions Ratings Europe; FIG_Europe@standardandpoors.com SEPTEMBER 3,

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