napf brochure asset pooling made simple 20100301

Asset Poolingmade simple

March 2010

Asset Pooling made simple

Acknowledgements

We would like to thank the following organisations for their help in producing and sponsoring this guide alongside KPMG

UK and KPMG Netherlands.

This guide is for information only. It is not investment advice.

Published by the National Association of Pension Funds Limited 2010 ©

First published: March 2010

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Contents

1 Introduction 2

2 What is asset pooling? 3

2a Definition 3

3 Why pool? 4

3a Diversification 4

3b Cost 4

3c Governance 4

3d Flexibility & Control 4

4 Key considerations 5

4a Legal and regulatory aspects 5

4b Tax aspects 6

4c Operational aspects 9

5 Common entity pooling vehicles 12

5a UK insurance companies 12

5b UK authorised investment funds 13

5c UK unauthorised unit trust 13

5d Dutch FGR structure 13

5e Luxembourg FCP structure 14

5f Irish CCF structure 15

5g Which to choose? 16

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1. Introduction

Today, the investment universe in which pensions operate is vast and complex. An increasing number of asset classes,

investment strategies, and managers provide pension schemes with a variety of diversification options. This

diversification of schemes’ portfolios can pose problems in terms of implementation and governance. The more

diversification, the smaller the average mandate becomes. Properly implementing a relatively small allocation to a

certain asset class or strategy through segregated mandates (where single managers manage different parts of the

investor’s assets as a separate portfolio) may not be feasible. And even where it is feasible, the average cost of a

segregated mandate, tends to increase as the mandate becomes smaller.

Figure 1: Economies of scale in asset management

Rather than giving up on the goal of diversification, pooling represents a potential solution to this problem. Pooling

allows schemes to jointly invest their assets across different asset classes, strategies, and managers with other

investors and thereby enables pension schemes to optimally diversify their portfolio in a cost efficient manner.

This apparent win-win scenario has led many schemes to actively consider and pursue pooling.

There are two different ways to pool assets. One method, called pension pooling, is to merge two or more pension

schemes together, thereby creating a larger single pension scheme with higher levels of diversification at a lower cost

than the separate schemes. Another method, called asset pooling, is to jointly invest in specific asset classes,

strategies or managers with other investors. Since pension and asset pooling are quite different solutions with distinct

complications, this made simple guide focuses on asset pooling.

This document aims to make clear what asset pooling is, what the benefits are, the key issues that need to be

considered, and describe the key pooling structures that may be appropriate for UK pension schemes.

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2. What is asset pooling?

2a Definition

Asset pooling refers to the joint investment by multiple investors in a single portfolio of assets (the pool). This pool is

managed by a manager. This manager may manage the assets directly or it may be a multi-manager who appoints other

managers to each part of the pool. The parties involved can be other pension funds or they can be other types of

investors, such as charities or individuals (as illustrated in figure 2).

Figure 2: Asset pooling

Essentially asset pooling is the opposite of a segregated mandate, in which a manager manages part of the investor’s

assets as a separate portfolio.

In practice, there are two ways in which asset pooling can be structured: virtual pooling and entity pooling. With

virtual pooling, the investor still appoints a manager to manage a segregated account under an Investment Management

Agreement (IMA). However, the manager uses an administrative solution that enables the manager to manage multiple

segregated accounts as if they were a single, pooled account.

Entity pooling involves transferring the legal ownership of the assets to an entity in exchange for a ‘claim’ on the net

assets, such as a unit, share or participation. The value of this ‘claim’ is determined by the value of the assets and

liabilities held by the entity. While the pension scheme no longer legally owns the underlying assets, the ‘claim’ on the

assets is economically the same as owning them directly. This guide is focused on the more popular entity pooling.

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3. Why pool?

The benefits of entity pooling occur in four key areas: diversification, reduced costs, enhanced governance,

and increased flexibility and control.

3a Diversification

Pooled funds enable pension schemes to diversify their investments across more asset classes, strategies and managers

than they might be able to achieve individually. In some asset classes, the minimum investment required for a

diversified segregated portfolio is considerable. Examples are asset classes that are “chunky”, such as private equity

and direct investment in property. The same problem can occur if the pension scheme wishes to diversify its

investments across multiple managers, whether these are alternative investment managers or more traditional

managers. In both cases, entity pooling represents a way to achieve diversification.

3b Cost

Even where a pension scheme is able to achieve its desired diversification through segregated mandates, entity pooling

can result in a lower overall cost of implementing the portfolio.

One reason is that management fees tend to be proportionately lower for larger mandates. If the manager of the pool

negotiates with the external managers for the pool as a whole, the pool manager should be able to achieve lower

management fees than would be the case for each pension fund separately.

The same logic applies to other management expenses related to custody, administration and voting, as well as to

potential sources of income such as commission recapture (whereby commission charges are controlled through

negotiations with brokers) and securities lending (the market practice whereby securities are temporarily transferred

by one party to another for a fee).

Transaction expenses may also be lower with entity pooling than with a segregated mandate, because an inflow into

the pool by one investor can be netted against an outflow from another investor, thereby avoiding the need for

transactions in the underlying portfolio. In addition, where there is a need for transactions in the underlying portfolio,

those transaction expenses may also be lower. The larger the pool, the larger the average transaction size will be. In

most cases the transaction costs will fall as the size of trade increases.

3c Governance

Although trustees will always remain responsible for the governance oversight, by employing a multi-manager to

manage the pooled fund, pension schemes are able to delegate the governance concerning manager selection to a

single multi-manager. As a result, trustees need to monitor fewer underlying managers and can spend more of their

time on setting, monitoring, and evaluating their overall investment strategy.

3d Flexibility and Control

By investing in pooled funds to gain diversified exposure across asset classes, pension funds are able to monitor and

manage their asset allocation in an efficient manner by making straightforward and timely asset allocation switches to

alter their investment strategy. This is an advantage when compared with investing in multiple smaller segregated

mandates, which can be complex, costly, and time intensive.

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4. Key considerations

Whether investing using a segregated mandate or a pooled fund, trustees should always take care to ensure that the

proposed investment is consistent with the scheme’s legal requirements and investment principles, and that the fees

and expenses are clear and acceptable. When considering entity pooling, there are three key areas that require special

attention before deciding whether to invest through a pooled fund. These are the legal and regulatory, tax, and

operational aspects of the pooled fund.

4a Legal and regulatory aspects

UK pension trustees are generally entitled to make use of pooling funds, whether the vehicles are established in the

UK or overseas. However, as pooling involves the transfer of the legal title of the underlying investments to a separate

entity, there are a number of legal issues trustees should consider in advance.

First, trustees should check that the structure of the pooled vehicle is consistent with the Occupational Pension

Schemes (Investment) Regulations 2005, particularly if the investment is a large proportion of the scheme’s assets.

Those regulations generally require schemes to invest predominantly in listed assets, but contain exemptions where

schemes invest in some (unlisted) pooling vehicles.

Secondly, trustees will need to be satisfied that they have fulfilled their fiduciary duties in using a particular pooled

fund. In the main, this involves ensuring that they have fully considered the effect of their decision, and have obtained

all necessary information to make a decision. So, for example, trustees will need to consider the following questions:

• What documents govern the pooled fund? Can the governing documents be changed without trustee

consent?

• Who owns the assets in the pooled fund? What is the risk of insolvency of the owner of the assets and

what will happen in that case? Are the assets kept safe by a custodian? If so, who is the custodian and

what will happen in case of insolvency of the custodian?

• Are there any restrictions on withdrawing from the pool? If so, are there any scenarios in which these

restrictions may not be in the interest of the pension scheme?

Finally, various procedural requirements are likely to apply. There may be a need to obtain written professional advice

before investing or to ensure that the decision, delegated by the trustee, is taken by an FSA authorised investment

manager. Trustees should look at the investment powers under their Trust Deed, and their Statement of Investment

Principles, and see whether they need revising (both of which may need some employer involvement or consent).

A UK pension scheme is legally allowed to participate in both regulated and unregulated pooled funds. However, the

scheme’s Trust Deed and Rules or Statement of Investment Principles may impose restrictions.

If a pooled fund is regulated, it will be regulated by the regulatory authority in the country where the fund is located.

And within a given country, there may be several possible regulatory regimes that can apply to the fund. Trustees should

therefore ensure that they determine the country where the fund is located, the identity of the regulator, and the

regulatory regime that applies to the pooled fund.

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Investing in a regulated pooled fund is not necessarily better than investing in an unregulated fund. Depending on the

nature of the regulation, regulated pooled funds may provide additional comfort concerning the security of the assets

in the pooled fund. On the other hand, regulated pooled funds may also impose investment restrictions. For example,

regulated pooled funds under the European Union’s Undertakings for Collective Investments in Transferable Securities

(UCITS) regulation, which is primarily aimed at retail investors, currently restricts investment in certain asset classes,

for example commodities, private equity and direct investment in property, and in the use of derivatives. While

investing in an unregulated pooled fund will require greater due diligence, the restrictions imposed by regulated funds

are not necessarily in the interest of the pension scheme.

4b Tax aspects

One main objective of pooling is to ensure that, even though the underlying assets are no longer directly legally owned

by the pension scheme but by a pooling entity, the return on investment by participating in the pool is the same as

owning the underlying assets directly. Since pension funds typically benefit from tax exemptions, this means ensuring

that investing through a pooled fund does not lead to a higher tax burden.

In general, there are three types of taxes that can apply to pension schemes:

• Direct taxes

Direct taxes may arise at the pension scheme level, or at the pooled fund level in the form of withholding tax. As

above, direct tax should not arise at the investor level because of domestic tax exemptions available to pension

funds. Withholding tax may be deducted from distributions of income on investments, though the use of

transparent pools (as described below) can allow pension investors to retain the tax treaty benefits and thereby

secure the same rates of withholding tax as when investing in the underlying assets directly.

• Indirect taxes

VAT may arise on fees charged to the pooled fund.

• Transfer taxes

Stamp duty may arise on transactions in certain assets in the pooled fund.

When changing from investing using a segregated account to using a pooled fund, the tax situation may change

because the pooling entity may be subject to different taxation than the pension scheme itself, as illustrated in

Figure 3:

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Figure 3: Pooling tax considerations

From a tax perspective, there are two types of pooled funds: opaque and transparent (as described in figure 4).

Figure 4: Types of pooled funds

• Opaque pooled funds

An opaque pooled fund, on the other hand, is considered a separate legal entity that may be subject to taxation.

It is not necessarily true that an opaque pooling vehicle leads to higher taxation than direct investment by the

pension scheme. This depends on various factors, including the tax status of the pooled fund, the type of income

and gains generated by the investments and the countries being invested in. After paying taxes on income and

capital gains (if any) within the opaque pooled fund, the participant will generally only be taxed (if at all) on the

distributions made by the pooled fund and any gain on disposal of their participation.

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In some cases, the difference between a direct investment and an investment through an opaque pooling vehicle

can lead to significant differences in return on investment (ROI).

In order to provide an illustration of the impact of tax on the return on investment (the tax drag or extra taxation),

figure 5 assumes a UK pension fund made an initial investment of £1 billion in European equities (as represented

by the MSCI Europe benchmark) in 2000. Using the estimated dividend yield on this investment for 2000 to 2009,

the estimated net-of-tax yields for an investment in a transparent and an opaque pooled fund are calculated. The

tax drag is assumed to be constant over time for the purpose of this modelling. In reality tax drag would vary each

year as country weightings, dividend yields and withholding tax rates vary over time. Over the period, the opaque

pooled fund results in a tax drag of £57 million over the period, equating to 57 basis points, compared to a

transparent pooled fund. This is a significant figure that could easily be doubled if investments were made outside

Europe, such as in the US.

• Transparent pooled funds

A transparent pooled fund so legal personality so is not considered a taxable entity by the tax authorities. In this

case, the pension scheme that participates in the pooling vehicle remains the beneficial owner of the underlying

investments and, as a result, is subject to the same taxation as if the securities were owned directly.

In order for this transparency to work, the transparency must be recognised by the country in which the income or

gains are generated, the country in which the pooled fund is located, and the country in which the pension scheme

is located. Countries use different criteria to determine whether or not an entity is transparent. These criteria

typically relate to legal concepts of ownership, which differ from country to country. For example, common law

countries use the concept of ‘beneficial ownership’, which is less familiar in civil law countries. Consequently, the

challenge for entity pooling is to identify an entity that is considered transparent by all target countries of

investment. Certainty can be achieved by seeking some form of ruling from the tax authorities. For example in

the UK, HMRC have been approached for rulings as to the transparent nature of many investment vehicles which

are listed in HMRC’s International Tax Manual 180030.

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Figure 5. Comparison of opaque and transparent pooling structures

Source: Northern Trust

4c Operational aspects

Pooled funds are considerably more demanding in terms of custody and administration than segregated mandates. The

participating pension scheme does not have to manage these aspects itself. This is the responsibility of the manager

of the pooled fund, who will generally appoint a custodian to perform some or all of these tasks. It is nevertheless

important for trustees to verify that the manager has taken appropriate measures to implement these operational

aspects of the pooled fund.

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• Safekeeping

Whether assets are held in a segregated account or in a pooled fund, pension schemes should consider whether

their assets are properly ring-fenced so they are not affected by the insolvency of the manager. The key difference

is that, in the case of a pooled fund, the manager of the pool will generally take on some responsibility for

arranging the safekeeping.

• Trade settlement and corporate actions

In order to keep track of the assets that are held in the pooled fund, transactions need to be settled and corporate

actions need to be processed in a timely and orderly fashion. Once again, this also needs to occur in a segregated

mandate. The only difference is that, in the case of a pooled fund, the manager of the pool is responsible for

arranging these activities.

• Tax reclaims

The income generated by the investments of a UK pension scheme may be subject to withholding tax in the country

where the income and capital gains are generated. However, UK pension schemes can often benefit from lower

tax rates as a result of the Double Tax Agreements (DTAs) between the UK and other countries. Ensuring that the

tax burden for the pension scheme is minimised is already complex when a pension scheme invests using segregated

managers: in some cases, pension schemes can achieve tax relief at source, whereas pension schemes need to file

tax reclaims in other cases.

Organising the tax reclaim process in a pooled fund is potentially even more complicated, especially when the

pooled fund is tax transparent and has participants that are subject to different tax rates. This may occur when

the participants are from the same country but have a different tax status (e.g. a pension scheme and a retail

investor) or if they are from different countries (e.g. a UK pension scheme and a Dutch pension scheme). In that

case, it is not just the process of reclaiming taxes that becomes considerably more complicated. The distribution

of income and capital gains is also more complicated because different participants in the pooled fund will have a

right to different after-tax income and capital gains. This requires special fund accounting procedures, as

described below.

• Securities lending

When investing via a segregated manager, the pension scheme is in direct control over whether the securities held

by it are lent to third parties and, if so, the terms on which this lending takes place. When investing through a

pooled fund, these tasks are delegated to the manager of the pool subject to any terms concerning securities

lending in the pooled fund’s documentation. However, in some pooled fund vehicles, it is possible to organise

securities lending on a participant-by-participant basis. While this gives the participating pension scheme more

control over its securities lending within the pool, participant-level lending is administratively more complex as

participant-by-participant administration of the securities lent and collateral and fees received must be

maintained.

• Proxy voting

Institutional investors are under increasing political, social, and regulatory pressure to take an interest in how

voting rights are exercised. When investing in pooled funds, voting rights are exercised by the manager, subject

to any restrictions in the pooled funds’ documentation. A pension scheme should ensure that the manager reports

on their policies regarding voting rights.

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• Fund accounting

Fund accounting is the maintenance of books and records of a pooled fund to accurately record and value the

assets, liabilities, income and expenses in accordance with the laws and regulations of the jurisdiction where the

pooled fund is located. This process culminates in the calculation of the Net Asset Value (NAV) of the pooled fund,

the number of shares, rights, or participations issued by the pooled fund to each participant, and the Net Asset

Value per share, right, or participation.

Fund accounting for pooled funds becomes complicated when there are differences between the participants.

These differences may be due to differences in tax status, in country of origin, or in participation in securities

lending. In that case, the fund accounting must take place not only at the level of the fund, but also at the level

of each share class, which represents a group of participants that are identical in terms of accounting treatment.

This process is illustrated in Figure 6 below.

Figure 6. Fund accounting in a (transparent) pooled fund

In short, entity pooling can lead to additional complications in the operational aspects associated with the

administration of the pool and the rights of the individual participants. While the manager of the pooled fund is

responsible for organising these aspects – and will generally do so by appointing a custodian for some or all of the

operational aspects – trustees should determine prior to participating in a pooled fund how these aspects are organised

and what, if any, residual risks these imply for the pension scheme.

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5. Common entity pooling vehicles

Common types of pooling vehicle used by pension schemes are:

• UK Insurance companies

• UK authorised investment funds

• UK unauthorised unit trusts

• Dutch Fonds voor Gemene Rekening (FGR)

• Luxembourg Fonds commun de Placement (FCP)

• Irish Common Contractual Fund (CCF)

Historically, UK pension funds have used insurance companies and authorised funds to pool with other UK pension

schemes and/or other types of UK investors.

UK pension schemes can, however, also use the Dutch FGR, Luxembourg FCP, and Irish CCF as vehicles for entity pooling.

One benefit of these vehicles is that they facilitate cross-border pooling: pooling by investors from different

jurisdictions. These European vehicles were first used by UK pension schemes to pool with the overseas pension

schemes of the same corporate sponsor. But these vehicles can also be used to pool the assets of unrelated pension

schemes from one or more countries. In fact several asset managers are now offering pooled funds that use these

European vehicles to offer pooling to pension schemes in a variety of countries. As financial markets are likely to

continue down the path of internationalisation, the Dutch FGR, Luxembourg FCP, and Irish CCF are likely to become

increasingly common pooling vehicles for use by UK and wider European pension schemes.

In the following paragraphs we will discuss the key legal, regulatory and tax aspects of the aforementioned pooling

vehicles.

5a UK insurance companies

It is common for asset managers to establish insurance companies in order to offer the pooling option to UK pension

schemes.

Legal and regulatory aspects

By participating in a UK insurance company fund, the legal title to the assets is transferred to the insurance company

in exchange for an insurance policy.

Unlike other entity pooling vehicles, the insurance company is subject to the FSA’s capital requirements for life

insurance companies. These capital requirements are however typically minimised by matching assets closely with

liabilities.

The insurance company is regulated by the FSA.

Tax aspects

UK insurance companies are opaque for withholding tax purposes but they can access the UK’s extensive range of tax

treaties. This means that investment through a UK insurance company is tax efficient for a UK pension scheme. For

example, a Competent Authority Agreement was agreed in 2005 that enables pension fund business of insurance

companies to qualify for the zero per cent rate of US withholding tax.

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5b UK authorised investment funds

Asset managers also commonly offer pooling via a UK authorised investment fund, i.e. an open-ended investment

company (OEIC) or an authorised unit trust. In practice, managers tend to combine the benefits of authorised funds

and insurance companies by using a hybrid structure which allows pension funds to invest in a range of widely held

authorised funds, via an insurance policy.


By participating in a UK authorised investment fund, the legal title to the assets is transferred to the fund in exchange

for a share or unit.

An advantage of UK authorised investment funds over UK insurance companies is that they can be used to pool the

assets of UK pension schemes together with the assets of other types of UK investors for example individuals and

charities.

UK authorised investment funds are subject to regulation by the FSA. As such, they are subject to the FSA’s investment

and borrowing rules.

Tax aspects

UK authorised investment funds are not transparent for withholding tax purposes and are subject to different tax rates

than UK pension schemes. As a result, these vehicles can be less tax efficient when investing in certain asset classes

(e.g. US equities). However, UK authorised funds are able to access the UK’s tax treaties so are generally efficient.

5c UK unauthorised unit trust

Another common UK entity pooling vehicle is the unauthorised unit trust (UUT).


By participating in a UUT, the legal title to the assets is transferred to the trust in exchange for units.

UUTs are not authorised by the FSA. They are therefore not subject to the FSA’s investment and borrowing rules. As

a result, UUTs are often used for pooling investments in asset classes such as private equity and direct investment in

property.

Tax aspects

UUTs are not transparent for withholding tax purposes and are subject to different tax rates than UK pension schemes.

As a result of their UK tax status, UUTs are generally only used by UK pension funds and UK charities. Like insurance

companies, UUTs can be efficient for investing in US equities as they are covered by the above Competent Authority

Agreement.

5d Dutch FGR structure

The Fonds voor Gemene Rekening (FGR) has been used in the Netherlands since the late 1960’s as the Dutch equivalent

of the UK unit trust for the pooling of Dutch pension scheme assets. The FGR is a well-established entity pooling vehicle

which has the support of a broad network of DTA Treaties negotiated by the Dutch government, the FGR has more

recently started to be used for pooling pension assets of non-Dutch pension schemes, including schemes in the UK.

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The FGR is a contract-based pooled fund where the participants enter into a contract, with the manager and depositary

of the pool. On participating in an FGR, the assets are transferred to a stichting (similar to a UK trust) that acts as the

manager and depository of the pool. In exchange, the participants receive a ‘claim’ on the assets, known as a share

or participation in the fund.

The FGR can be regulated or unregulated. In practice, most FGRs that are used by pension schemes are unregulated

to achieve maximum efficiency. However, the participants and the manager may agree to comply with a light

regulatory regime or UCITS regulation by the Dutch Authority for Financial Markets (AFM). The FGR contract is very

flexible in terms of governance, investments and fee structure.

Tax aspects

The FGR can be structured as an opaque or a transparent vehicle for withholding tax purposes, whichever is optimal

given the nature of the underlying investments. The FGR is not subject to Dutch corporate tax and management fees

are exempted from Dutch VAT. As a result, a wide variety of investors, including UK pension schemes, can participate

in the FGR.

One advantage of the Dutch FGR is that the contract can be structured so as to support participant-level securities

lending. This provides participants with the option to implement a bespoke securities lending policy that is different

from the policies of the other participants.

5e Luxembourg FCP structure

Luxembourg offers the investment fund industry a modern legal and tax environment. The continuing development of

Luxembourg as a centre of financial and investment fund services has led to a concentration of specialist service

providers there. Moreover, Luxembourg has an established reputation as a fund centre.


Like the FGR, the Luxembourg Fonds commun de Placement (FCP) is a contract-based pooled fund with no separate

legal personality. A FCP must therefore be managed by a Luxembourg management company on behalf of joint owners

who retain ownership of the underlying assets. Investor’s liability is limited to contribution and capital commitment.

The Commission de Surveillance du Secteur Financier (CSSF) provides regulatory oversight.

The FCP may segregate its assets into separate pools or sub-funds. Each sub-fund’s liability is ring fenced (explained in

section 4.3). As well as being UCITS structured, the FCP can be established as a non-UCITS fund with reduced assets

restrictions and relaxes regulation.

Tax aspects

The FCP is tax transparent for Luxembourg purposes, but, as with all funds, transparency also depends on the approach

of the tax authorities in the countries of investment.

Services rendered directly to an FCP are currently exempted from VAT if they qualify as “management services of

investments funds”. Services covered by this definition are administrative services and investment advice services.

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5f Irish CCF structure

The Common Contractual Fund (CCF) was established in 2003 as a tax efficient way for pension funds and institutional

funds to pool their investments together. The Irish industry’s capacity and scale to service and meet all CCF reporting

requirements, has positioned the Irish CCF as an optimal investment pooling structure.


The CCF is a contract-based fund with no separate legal personality and is transparent for Irish legal and tax purposes.

The Irish CCF is governed by Irish law and is regulated by the Irish Financial Services Regulatory Authority.

If a CCF is established as a UCITS fund it is subject to the investment objectives and policies relevant to UCITS funds.

If however the fund is a non-UCITS fund it can make use of the broader investment objectives and policies that are

available to non-UCITS. This allows for a large degree of flexibility in investment style. CCF can also be structured as

umbrella funds with multiple sub-funds within the one fund structure.

Tax aspects

As the CCF is a tax transparent vehicle, this means investors should still have access to tax treaty relief in the investor’s

home country. As with the FGR and FCP, this ultimately depends on the view of the tax authorities in the countries of

investment.

5g Which to choose?

In practice, the choice of which vehicle to choose depends on non-tax factors. For a fund to be on the short list,

an appropriate tax and regulatory structure are given. Instead, the choice depends on the capability of the

management company and its administrators to service a product and the location of the operators’ existing products.

All the funds listed above would be credible options for most UK schemes.

It is likely that competition between jurisdictions will increase in coming years as pooling techniques develop and have

wider application, following the implementation of UCITS IV in July 2011.

Ultimately, in deciding between these jurisdictions and structures, pension fund investors should aim to be no worse

off as a result of pooling their investments than if they had invested directly in the relevant investments held by the

vehicle on their behalf.

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The National Association of Pension Funds Limited 2010 ©

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The publisher (The National Association of Pension Funds Ltd) or sponsoring company cannot accept responsibility for

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result of any information given in this publication.

ISBN 978-1-907612-01-5

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March 2010

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