Portfolio (macro) hedge accounting

Transcription

1 Portfolio (macro) hedge accounting Cancelled swaps creating amortisation challenges? ALMIS has the solution 1. Introduction An IASB 2014 Discussion Paper proposed a new approach to macro hedge accounting but it seems that initiative is being taken no further; and it will be some considerable time before any other paper emerges. In the meantime, the market continues to grapple with the application of the IAS 39 standards and guidance. Recent events in the market have highlighted certain specific considerations which can arise where swap(s) which are the hedging instrument in the hedging relationship are cancelled. This article considers an imaginary swap cancellation scenario, highlights the considerations a bankwould face in the scenario, and explains how the ALMIS hedge accounting module provides a solution. 2. Circumstances Consider the position of the Bank in the following scenario: - The Bank lends long term fixed loans when long term rates are comparatively high, say above 4.5% Some of the loans are repayment, but all are prepayable The Bank takes out a range of pay fixed receive floating interest rate swaps to hedge these loans; this hedging is based on an analysis of wide repricing time periods. The Bank adopts fair value portfolio hedge accounting in relation to its interest rate risk on this portfolio of fixed rate loan assets Interest rates fall sharply, and so the swap fair values are showing a significant liability offset by significant fair value adjustment to the hedged item asset. the swaps have a break option and are cancelled (for whatever reason), requiring de-designation of the relevant hedging relationship. The swaps are effective when they are cancelled and therefore the Bank will consider how best it now hedges the asset positions going forward, possibly by taking on new hedges for these positions at this point of de-designation, the carrying amount of the relevant loan assets includes a fair value adjustment which is material in amount; and under IAS 39 para 92 that fair value adjustment is amortised using a straight-line method 1

2 over the subsequent years the loan assets experience significantly higher than expected prepayments and the actual loan asset fair value is materially less than the carrying amount resulting from straight line amortisation, (potentially resulting in the need for an extra ordinary adjustment) One of the most fundamental issues here is that the items being hedged are amortising (repayment / prepayable) loans and the pattern of expected pre-payments can change due to interest rate changes, whereas the interest rate swap is not amortising and the swap nominal remains in full regardless of actual behaviour of the loan re-payment. This type of hedging is normal in the banking industry. Treasurers will examine the expected behaviour, take out hedges which broadly off-set the positions, and then adjust the hedging position from time to time as the position and expectations change. In this case, the hedge is however cancelled after only a few years, and the swap counter-party is paid in full based on the swap fair value at the time (which happens to be a large negative). The swap fair value and breakage cost is based on the yield curve at the time, which has fallen since the swap was taken out, but is still showing that the market is expecting short term interest rates to rise from very low levels. Following on from the cancellation, interest rates continues to fall further and pre-payments are far higher than originally expected. Analysis of a hedged portfolio of pre-payable long term fixed rate loans 2

3 3. Considerations 3.1 The amortisation requirement In our scenario (cancellation of swaps) the designated swaps are de-designated and the corresponding fair value adjustment in relation to the hedge item needs to be amortised to profit and loss. But on what basis? IAS 39 Paragraph 92 suggests the bank should amortise using the effective interest method, but if a recalculated effective interest rate is not practicable the amortisation should be on a straight-line method. 3.2 Straight line vs Effective Interest The straight-line method is well recognised and will typically result in a similar amount being amortised period to period. However, there are several important features of the effective interest method to bear in mind. The effective interest method is designed to reflect how and when interest is being earned, therefore: Clearly more interest is earned when the principal, or nominal amount of the relevant loan is higher, and less interest is earned when the nominal amount in lower. For a pre-payable repayment pool of loans, the principal balance accruing interest is far higher at the start and will reduce over the period of the fixed term. If designation is based on narrow time periods, eg monthly, then the straight-line amortisation can be performed for each time-period and the impact of this is minimal, whereas if designation is based on wider time periods, the impact of a reducing balance will be more material and the straight-line method less reliable. In the scenario envisaged the loan hedge item has a large premium, ie at the time the hedge is cancelled, the fair value of the hedged item is positive as the fixed rate on the loan (designated hedged item) is higher than the market interest rates. As the yield curve is positive at that time, the market is expecting interest rates to rise over time. Therefore, this premium rate (difference between the fixed rate and market expected rate) will be higher in the earlier years than in later years. The premium (fair value) is calculated by discounting future cash-flows. The discount rate is higher (closer to 1) in the earlier years reflecting that it is economically more beneficial to receive this premium amount sooner rather than later and therefore the EIR method shows a higher amortisation of the premium in the earlier years. All three of these components have the effect that there can be a material difference between straight line and effective interest basis. In Appendix 1 we show the difference between amortisation methods, and that this difference can be material, especially when the yield curve is not flat. 3

4 3.3 Impact of higher/earlier than expected pre-payments The differences above are exacerbated even further when we observe higher than expected loan prepayments as interest rates fall further and borrowers forfeit penalty interest to refinance these loans at far lower rates. There is some confusion with the language used in IAS 39, for example IAS 39 AG 128. Items that were originally scheduled into a repricing time period may be derecognised because of earlier than expected prepayments or write -offs caused by impairment or sale It is the word may that concerns us. It must mean should otherwise the standard is saying we can include assets on the balance sheet that have been sold and don t exist. But then perhaps it is saying may to allow for impracticalities? Behavioural prepayment experience rarely follows expectations closely. Regardless of which amortisation method is used, the accounting profession seem unanimous that a bank should on an ongoing basis be reviewing the behavioural prepayment experience and adjusting the amount amortised accordingly. Also, the Bank should take account fully of any actual pre-payments, so that there are no circumstances where the amortised amount includes loans that have already been sold, pre-paid or have become impaired. In the scenario envisaged the loan assets do experience significantly higher than expected pre-payments mainly because of a significant fall in interest rates. With a review of prepayment actual experience and a review of future expectations continually ongoing, a regular adjustment of the amounts amortised needs to take place. This is however a significant system challenge when the amounts being amortised cannot be specifically identified and tracked. The system impracticalities that allow straight line amortisation in the first place mean that is may also be impractical to account for any higher than expected pre-payments that will arise. 4. Some conclusions If the prepayment experience does prove higher than expected and occurs over successive reporting periods but is not regularly reflected by adjustments to the amortised amounts in the relevant reporting periods this could result in the need for a material extraordinary adjustment. 4.1 Different amortisation methods, different results 4

5 In the scenario envisaged the fair value adjustment to be amortised is a significant one, as the swaps are long term and interest rates have moved, and furthermore the pre-payments post adjustment are higher than originally expected. Straight line amortisation is always an approximation however in this case the straight-line method materially misrepresents the financial position. A fair value amount is a complex calculation as the market yield curve used to measure the fair value is based on market expectations of future interest rates, and these future interest rates are not constant over time. For example, in 2012 the yield curve was significantly positive, ie the market expected interest rates to rise gradually over a long period. The lower the rate, the higher the value of a fixed loan. In year 1 the expected market rate was lower than year 2 and so on. As the fair value is calculated based on expected rates as well as expected amounts, the fixed loan fair value will be higher in the earlier periods than it would in later periods. For a positive yield curve, the EIR amortisation of the fair value would give a higher amortisation amount in earlier years than later years when rates were expected to rise. (See Appendix 1) The true position is even more complex in practice, as the actual and expected pre-payments will inevitably change over time, and to be true to the principles of hedge accounting detailed in IAS 39, the amortisation should therefore change as actual and expected pre-payments and even loan impairments change. 4.2 The need for granular loan data This article has already recognised that in the sort of scenario envisaged the bank needs to conduct an ongoing review of both the behavioural prepayment experience and any impairments, and to adjust the amount being amortised accordingly. This cannot be done without granular data showing the actual experience of the portfolio loans over the percentage of loans that were originally designated. 4.3 Confusion of concepts Regardless of any impracticalities, there is confusion over key concepts. IAS 39 brought in the concept of fair value accounting that were hitherto historic cost or amortised cost. Amortised cost is one thing and fair value is another. An issue here is that in attempting to conduct a fair value approach, we need to use an amortised approach for any fair value adjustments, and this is inherently confusing. There are circumstances, due to changing interest rates, where the amortised adjustment on a balance sheet has a positive value whereas the item it relates to has no economic value or becomes negative in true value. A fair value item can go up or down as interest rates change however the fair value adjustment will only reduce, regardless of future changes in interest rates. The value presented on the balance sheet can therefore be difficult to understand. This is perhaps one of the difficulties the IASB are having in replacing macro hedge accounting is IFRS 9. 5

6 5. A solution, using a matching methodology We have specialised in macro hedge accounting since its outset in 2005 and focus on specific hedging practices used by lending institutions. Whilst we support conventional re-pricing time period approaches to hedge accounting used by many firms and documented by accounting firms, we have always offered an alternative approach using a specific matching methodology Re-pricing time-period approach Re-pricing time-period M1 M2 M3 Mxx Loans x x x x Swaps y y y y Effectiveness is then measured for each time-period. With this approach the re-pricing amounts for each time-period is calculated from parts of different loans and swaps. If we use narrow time periods then often effectiveness cannot be demonstrated as the bullet swap is re-pricing in only one period against a loan that will re-price in many. Firms can get around this by performing the analysis in wider time-period, however this can lead to inaccuracies when performing fair value calculations. As discussed above accurate EIR and fair value calculations are often not practical using this approach. It can become impractical to track the movement of the individual loans as they are sold or become impaired from one period to the next. To allow an accurate and practical calculation and EIR amortisation adjustment and to track and therefore account for actual impairments or sales or earlier than expected pre-payments we developed a matching methodology to demonstrate effectiveness where the system will automatically match entire loans to swaps based on their entire fair value off-set due to changes in interest rates. ALMIS matching methodology 100% Loan 1 Maturity 31/12/xx 100% Loan 2 Maturity 31/12/xx Analysis of expected cash-flows; 6

7 Loan cash-flow Swap Cash-flow M1 x y M2 x y M3 x y.. Mxx x y Total PV x y The analysis is performed by measuring a total PV from each entire loan and comparing this with the PV of designated swaps, where hedge effectiveness can be demonstrated by calculating the change in PV of the loan will off-set a change in PV of the Swap. The fair value of the hedged item is based on the loan PV which can be measured using the rate of the matched swap, giving a closer off-set. The methodology allows consistent and documented ways to match entire loans to swaps that are effective; and in addition the methodology applies the hedged (fixed swap) rate to the matched loan. By keeping a record of the individual loan unique reference (eg account number) and the hedged rate, it is practical for our system to track the behaviour (eg pre-payment, sale, impairment) of the designated hedged amount from period to period. As demonstrated in Appendix 2, the amortisation of the hedge item amount is based on an accurate EIR method, but also takes full account of earlier than expected loan prepayments, sales and impairments, which can be removed in the periods they occur. As demonstrated in the example, the amortisation amount is calculated, using the EIR method, to be 2,241,743 (It is 1,621,458 using a straight-line method), yet when we take account of actual sales, earlier than expected pre-payments and impairments in the year, the annual amortisation amount is correctly stated as 4,051,897 and the lower hedged item amount can be correctly stated on the balance sheet. This differs from the repricing time-period methods where the PV s and effectiveness are measured based on the analysis of a total nominal amount or cash-flow for each re-pricing time-period This matching methodology attempts to more closely approximate the micro approach to hedge accounting, and at the same time provide the advantages of the portfolio approach, eg take account of dynamic hedging, a single effectiveness test and journal. For our cancelled swaps, we will know which entire loans are designated and therefore are to be dedesignated from the portfolio and amortised to P/L. As we have the terms of each entire loan, we can perform this amortisation so that it does not overstate the fair value hedged item on the balance sheet, and 7

8 releases this item to P/L as the fixed loans are repaid. The fair value hedged item is realised based on the expected forward rates used to calculate the swap breakage, and to take account any actual pre-payments or impairments as they arise. 6. Conclusion The circumstances of our scenario demonstrate that designation by re-pricing time buckets and the straightline amortisation method can lead to an extra ordinary adjustment in the reported accounts due to an over statement of the true economic position in previous years. The complexities of portfolio hedge accounting can make it impractical to calculate the true economic value of the hedge item being de-designated from period to period. Straight line amortisation adjustments are therefore to be discouraged, especially when the hedge item amount being straight-line amortised is material. However, by adopting a matching methodology this straight-line method can be completely avoided and therefore there will be no chance of further extra ordinary adjustments. The P/L will reflect the true economic write-off of the designated hedge item amount, as the entire hedge item can be tracked and measured accurately from period to period. Whist this method is not prescribed specifically in IAS 39, it does meet all the criteria set out in AG , and therefore should be used when it is possible, and therefore avoid material misstatements and adjustments associated with accounting based on re-pricing time buckets and straight line amortisations. 8

9 Amortisation amount Appendix 1 EIR v Straight line amortisation Simple Example, with a rising yield curve Fixed 4% - repaid over 6 months ALMIS Method value entire loan / amortise using EIR Designated Zero Market Market Premium Discounted Opening Fixed Coupon Discount Implied Fixed Implied Premium Month Balance Rate Spot Rate Forward (MIF) Cash-flow Cash-flow (1 / (1+ r * n/days) (DRs/DRl) - 1 * Days/t Balance * Fixed Rate Balance * MIF Fixed CF - MIF CF Premium * DR 1 100, % 1.00% % , % 1.25% % , % 1.50% % , % 1.75% % , % 2.00% % , % 2.25% % monthly amortisation under EIR method Fair Value Adjustment (premium over loan balance) Month Re-pricing time bucket - sum of digits straight line amortisation Opening Re-pricing Fair Value M1 M2 M3 M4 M5 M6 Balance Gap per time bucket (see calc below) 1 100, , , , , , , , , , , , Designated Zero Market Market Premium Discounted Opening Fixed Coupon Discount Implied Fixed Implied Premium Month Balance Rate Spot Rate Forward (MIF) Cash-flow Cash-flow 1 16, % 1.00% % , % 1.00% % , % 1.25% % , % 1.00% % , % 1.25% % , % 1.50% % , % 1.00% % , % 1.25% % , % 1.50% % , % 1.75% % , % 1.00% % , % 1.25% % , % 1.50% % , % 1.75% % , % 2.00% % , % 1.00% % , % 1.25% % , % 1.50% % , % 1.75% % , % 2.00% % , % 2.25% % EIR v Straight line amortisation M1 M2 M3 M4 M5 M6 EIR Straight line

10 Appendix 2 Amortisation based on EIR and taking account higher than expected pre-payments on the de-designated hedged item amounts Effective Interest Method Effective Interest Method Year 1 Year 2 - Taking account higher than expected prepayments Expected Fixed Interest Spot Disc Fixed Forward Market Market Amortisation Expected Fixed Interest Spot Disc Fixed Forward Market Market Month Nominal Rate Cashflow Rate Rate DCF Rate Cashflow DCF Premium Amount Month Nominal Rate Cashflow Rate Rate DCF Rate Cashflow DCF Premium M0 44,881,558 M1 44,581, , , ,304 19, ,095 M2 44,285, , , ,611 19, ,262 M3 44,014, , , ,071 20, ,416 M4 43,718, , , ,041 20, ,920 M5 43,430, , , ,282 20, ,214 M6 43,133, , , ,176 20, ,796 M7 42,845, , , ,030 20, ,461 M8 42,548, , , ,661 20, ,305 M9 42,251, , , ,231 20, ,210 M10 41,962, , , ,023 20, ,940 M11 41,664, , , ,020 20, ,422 M12 41,375, , , ,260 21, ,702 2,241,743 M13 41,147, , , ,998 19, ,773 M13 40,328, , , ,462 17, ,388 M14 40,919, , , ,184 20, ,404 M14 39,290, , , ,399 17, ,349 M15 40,709, , , ,314 20, ,195 M15 39,093, , , ,826 17, ,901 M16 40,480, , , ,585 20, ,743 M16 38,873, , , ,820 17, ,762 M17 40,258, , , ,005 20, ,154 M17 38,659, , , ,054 18, ,430 M18 40,029, , , ,419 21, ,560 M18 38,439, , , ,980 17, ,359 M19 39,806, , , ,222 20, ,592 M19 38,225, , , ,762 18, ,464 M20 39,577, , , ,577 20, ,057 M20 38,005, , , ,455 18, ,627 M21 39,347, , , ,835 20, ,619 M21 37,785, , , ,093 18, ,845 M22 39,124, , , ,036 20, ,250 M22 37,570, , , ,823 18, ,003 M23 38,894, , , ,980 20, ,122 M23 37,349, , , ,843 18, ,840 M24 38,670, , , ,785 20, ,161 M24 37,134, , , ,081 18, ,489 M25 38,482, , , ,937 18, ,007 M25 36,954, , , ,960 17, ,659 M26 38,294, , , ,809 18, ,152 M26 36,774, , , ,139 18, ,533 M27 38,119, , , ,723 18, ,321 M27 36,606, , , ,267 18, ,540 M28 37,931, , , ,735 18, ,328 M28 36,425, , , ,522 18, ,337 M29 37,747, , , ,830 18, ,275 M29 36,248, , , ,913 18, ,008 M30 37,558, , , ,042 18, ,084 M30 36,067, , , ,299 19, ,677 M31 37,373, , , ,291 18, ,879 M31 35,889, , , ,232 18, ,808 M32 37,184, , , ,615 19, ,579 M32 35,707, , , ,565 18, ,529 M33 36,994, , , ,310 19, ,913 M33 35,525, , , ,811 18, ,337 M34 36,809, , , ,791 20, ,465 M34 35,347, , , ,005 18, ,203 M35 36,619, , , ,834 21, ,443 M35 35,165, , , ,969 18, ,290 M36 36,433, , , ,464 22, ,850 M36 34,987, , , ,806 18, ,525 M175 19,556, , , ,323 41,310 25,639 M175 13,689, , , ,630 32,103 16,581 M176 19,422, , , ,227 48,161 18,106 M176 13,595, , , ,629 32,002 16,199 M177 19,288, , , ,380 48,099 17,479 M177 13,502, , , ,634 31,906 15,813 M178 19,154, , , ,541 48,047 16,851 M178 13,408, , , ,600 27,414 19,836 M179 19,019, , , ,484 40,869 23,371 M179 13,313, , , ,588 31,680 15,090 M180 18,884, , , ,718 47,848 15,707 M180 13,219, , , ,606 31,588 14,696 M181 18,748, , , ,260 48,052 14,819 M181 13,124, , , ,629 31,505 14,301 M182 18,612, , , ,291 33,417 28,836 M182 13,028, , , ,493 26,995 18,346 M183 18,476, , , ,634 40,452 21,157 M183 12,933, , , ,608 31,293 13,565 M184 18,339, , , ,551 40,266 20,692 M184 12,837, , , ,643 31,218 13,165 M185 18,201, , , ,828 32,805 27,537 M185 12,741, , , ,683 31,138 12,759 M186 18,063, , , ,235 39,821 19,881 M186 12,644, , , ,729 31,065 12,352 M187 17,926, , , ,119 39,614 19,443 M187 12,548, , , ,424 26,507 16,452 M188 17,793, , , ,329 32,175 26,290 M188 12,455, , , ,753 30,885 11,611 M189 17,668, , , ,813 39,174 18,693 M189 12,368, , , ,846 30,842 11,208 M190 17,551, , , ,733 38,993 18,303 M190 12,286, , , ,964 30,819 10,809 M191 17,444, , , ,945 31,622 25,173 M191 12,211, , , ,548 26,239 15,005 M192 17,344, , , ,546 38,637 17,650 M192 12,141, , , ,181 30,763 10,098 M193 17,251, , , ,517 38,490 17,308 M193 12,075, , , ,609 30,950 9,545 M194 17,160, , , ,696 31,165 24,192 M194 12,012, , , ,167 21,568 18,611 M195 17,089, , , ,437 38,207 16,737 M195 11,962, , , ,963 26,191 13,698 M196 17,028, , , ,492 38,117 16,450 M196 11,919, , , ,056 26,171 13,449 M197 16,978, , , ,687 30,869 23,391 M197 11,884, , , ,230 21,420 17,980 M198 16,932, , , ,595 37,955 15,977 M198 11,852, , , ,211 26,129 13,045 M199 16,889, , , ,689 37,890 15,726 M199 11,822, , , ,330 26,126 12,823 M200 16,848, , , ,790 30,647 22,692 M200 11,793, , , ,371 21,326 17,425 M201 16,807, , , ,804 37,734 15,297 M201 11,765, , , ,496 26,085 12,447 M202 16,766, , , ,879 37,656 15,067 M202 11,736, , , ,605 26,074 12,239 M203 16,725, , , ,881 30,416 22,033 M203 11,707, , , ,507 21,223 16,895 M204 16,685, , , ,960 37,477 14,668 M204 11,679, , , ,750 26,017 11,885 M205 16,644, , , ,910 30,247 21,626 M205 11,651, , , ,846 25,996 11,690 M206 16,603, , , ,019 37,283 14,287 M206 11,622, , , ,626 21,107 16,385 M207 16,563, , , ,057 37,180 14,088 M207 11,594, , , ,969 25,922 11,355 M208 16,523, , , ,952 29,983 21,016 M208 11,566, , , ,050 25,890 11,173 M209 16,482, , , ,079 36,962 13,738 M209 11,537, , , ,726 20,977 15,895 M210 16,442, , , ,093 36,837 13,556 M210 11,509, , , ,150 25,800 10,860 M211 16,401, , , ,958 29,697 20,437 M211 11,481, , , ,216 25,757 10,691 M212 16,361, , , ,076 36,600 13,238 M212 11,453, , , ,807 20,833 15,426 M213 16,322, , , ,068 36,467 13,078 M213 11,425, , , ,296 25,652 10,399 M214 16,283, , , ,939 29,393 19,891 M214 11,398, , , ,349 25,600 10,243 M215 16,244, , , ,020 36,204 12,789 M215 11,371, , , ,872 20,679 14,980 M216 16,205, , , ,985 36,055 12,648 M216 11,343, , , ,405 25,479 9,972 M217 16,166, , , ,886 29,069 19,375 M217 11,316, , , ,893 20,565 14,703 M218 16,126, , , ,895 35,767 12,387 M218 11,288, , , ,446 25,348 9,713 M219 16,087, , , ,833 35,602 12,265 M219 11,261, , , ,472 25,278 9,578 M220 16,048, , , ,792 28,726 18,892 M220 11,233, , , ,921 20,385 14,288 M221 16,008, , , ,699 35,295 12,036 M221 11,206, , , ,486 25,129 9,340 M222 15,969, , , ,610 35,113 11,930 M222 11,178, , , ,495 25,044 9,216 M223 15,929, , , ,659 28,359 18,437 M223 11,150, , , ,925 20,189 13,894 M224 15,890, , , ,432 34,781 11,730 M224 11,123, , , ,481 24,881 8,999 M225 15,850, , , ,314 34,589 11,646 M225 11,095, , , ,472 24,788 8,890 M226 15,811, , , ,488 27,972 18,011 M226 11,068, , , ,905 19,979 13,520 M227 15,772, , , ,097 34,236 11,474 M227 11,040, , , ,434 24,607 8,692 M228 15,733, , , ,953 34,024 11,405 M228 11,013, , , ,407 24,503 8,595 M229 15,693, , , ,279 27,568 17,618 M229 10,985, , , ,862 19,754 13,167 M230 15,654, , , ,690 33,651 11,264 M230 10,958, , , ,341 24,305 8,417 M231 15,615, , , ,517 33,430 11,214 M231 10,931, , , ,296 24,191 8,333 M232 15,578, , , ,035 27,151 17,259 M232 10,905, , , ,797 19,520 12,838 M233 15,546, , , ,242 33,053 11,107 M233 10,882, , , ,223 23,993 8,182 M234 15,515, , , ,071 32,835 11,080 M234 10,860, , , ,182 23,881 8,114 M235 15,485, , , ,815 26,752 16,952 M235 10,839, , , ,751 19,298 12,546 M236 15,456, , , ,786 32,456 11,008 M236 10,819, , , ,105 23,682 7,987 M237 15,428, , , ,594 32,228 11,000 M237 10,799, , , ,051 23,567 7,935 M238 15,400, , , ,576 26,348 16,683 M238 10,780, , , ,696 19,071 12,280 M239 15,372, , , ,277 31,840 10,959 M239 10,761, , , ,956 23,358 7,828 M240 15,345, , , ,591 31,909 10,665 M240 10,741, , , ,885 23,230 7,787 M241 15,318, , , ,839 26,234 16,139 M241 10,722, , , ,620 18,836 12,038 M242 15,291, , , ,781 31,806 10,337 M242 10,704, , , ,762 23,009 7,701 M243 14,596, , , ,124 30,185 9,901 M243 10,217, , , ,980 21,874 7,338 M244 14,227, , , ,540 24,099 14,857 M244 9,959, , , ,429 17,357 11,033 M245 13,381, , , ,562 27,413 9,097 M245 9,367, , , ,887 19,915 6,692 M246 11,975, , , ,349 24,384 8,174 M246 8,382, , , ,294 17,740 5,987 M247 11,032, , , ,946 18,476 11,427 M247 7,722, , , ,848 13,341 8,454 M248 9,272, , , ,455 18,695 6,348 M248 6,490, , , ,426 13,629 4,622 M249 6,720, , , ,183 13,467 4,623 M249 4,704, , , ,953 9,828 3,354 M250 3,921, , , ,691 6,491 4,032 M250 2,745, , , ,124 4,696 2,974 M251 2,890, , , ,361 5,733 1,996 M251 2,023, , , ,274 4,190 1,442 M252 1,561, , , ,582 3,077 1,084 M252 1,093, , , ,960 2, M253 1,158, , , ,447 1,895 1,184 M , , , ,427 1, M , , , ,228 1, M , , , ,315 1, M , , , ,033 1, M , , , , M , , , ,420 1, M , , , , M , , , , M , , , M , , , , M , , , M , , , , M , , M , , , , M , , , M , , , , M , , , M , , , , M , , M , , , , M , , , M , , , , M , , ,385,948 12,334,051 4,051,897