HomeMy WebLinkAbout2010 12 13 Informational 102 Investment Report By PFM Asset Management LLC COMMISSION AGENDA
CONSENT
INFORMATIONAL X
ITEM 102 PUBLIC HEARING
REGULAR
December 13, 2010 MGR \ /DEPT
Meeting Authorization
REQUEST: The City Manager and Finance Department providing the Investment Report
for the fourth quarter of fiscal year 2010 (ending September 30, 2010) as prepared by PFM
Asset Management LLC.
SYNOPSIS:
Distribution of the investment report for the quarter- ending September 30, 2010
CONSIDERATIONS:
The General City Account portfolio is of high credit quality and maintains adequate liquidity.
The portfolio is invested entirely in Federal Agency, U.S. Treasury and FDIC guaranteed
corporate securities. The securities are allocated among high quality issuers rated AAA. PFM's
attached report provides additional information regarding the City's investment position at
September 30, 2010.
FISCAL IMPACT:
The weighted average yield at September 30, 2010 is 0.71%. The weighted average yield at June
30, 2010 was 0.67 %. This portfolio has an average maturity of less than one year.
COMMUNICATION EFFORTS:
The investment report will be posted to the website within a week of acceptance.
RECOMMENDATION:
It is recommended that the City Commission receive the attached investment report.
ATTACHMENTS:
Investment Report for quarter- ending September 30, 2010
City of Winter s S rin
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Investment Advisors PPM Asset Management LLC
Steven Alexander, CTP, CGFO, Managing Director 300 S. Orange Avenue, Suite 1170 One Keystone Plaza, Suite 300
Mel Hamilton, Senior Managing Consultant Orlando, FL 32801 North Front & Market Streets
David Jang, CTP, Senior Managing Consultant (407) 648 -2208 Harrisburg, PA 17101 -2044
Gregg Manjerovic, CFA, Portfolio Manager (407) 648 -1323 fax 717 - 232 -2723
Rebecca Dole, CTP, Consultant 717- 233 -6073 fax
City of Winter Springs Investment Report - Quarter Ended September 30, 2010
Table of Contents
Tab I.
Section A Market Review
Tab II.
Section B Executive Summary and General City Account Portfolio Performance
Section C Asset Allocation Chart
Tab III. September 30, 2010 PFM Month -End Statement
This material is based on information obtained from sources generally believed to be reliable and available to the public,
however PFM Asset Management LI.0 cannot guarantee its accuracy, completeness or suitability. This material is for
general information purposes only and is not intended to provide specific advice or recommendation. The information
contained in this report is not an offer to purchase or sell any securities.
Table of Contents Section i
City of Winter Springs Investment Report — Quarter Ended September 30, 2010
Fixed - income portfolios generated strong total returns in the third from (somewhat diminished) yield curve roll -down, as the Fed signals
quarter, as interest rates across the yield curve declined to new record readiness to push down rates across the yield curve.
lows. All but the shortest duration benchmarks significantly
outperformed money market instruments, which continued to offer Interest Rates and Returns
near -zero yields. Longer duration benchmarks generally performed the
best due to larger interest rate declines for longer maturities. Interest rates continued to decline steadily throughout the third quarter,
For the quarter our approach to duration was cautious, conservatively as shown in the chart below, in response to weaker- than - expected
positioning portfolio durations short of benchmark durations to guard economic data. On July 1, a 2 -year U.S. Treasury note offered a yield
against the negative effect rising interest rates would have on portfolio of 0.63 %, but by September 30 it was yielding only 0.42% — an all -
market values. time low.
Although the short bias of this strategy sacrificed some return in the 2 -Year U.S. Treasury Note Yield
quarter, value -added management techniques including strategic yield October 1, 2009 through September 30, 2010
curve placement and active sector management, worked to produce 1.20% - -- -- -- - - -- --
returns roughly even with benchmarks.
The Federal Reserve has acknowledged a slowing recovery in recent 1.00% -
statements, pledging to "provide additional accommodation if needed
to support economic recovery and to return inflation, over time, to 0.80% -
levels consistent with its mandate." This "additional accommodation"
A144\1441141
would almost certainly come in the form of further quantitative easing
— a process by which the central bank purchases large amounts of 0.60%
government securities in the open market over a period of months in
an effort to push interest rates down and support economic expansion. 0.40%
With a slower pace of economic growth and the Fed's renewed focus Oct 09 Jan 10 Apr 10 Jul 10
on easing, it is likely that rates will remain at recent levels for months, Source data: Bloomberg Markets
opening a window for us to extend durations closer to those of
benchmarks. While short-term rates declined considerably in the quarter, the decline
in rates was most dramatic in longer -term securities, where
Thus our strategy for the fourth quarter is built around somewhat diminishing inflation expectations and the prospect of Fed intervention
longer durations to take advantage of the steep yield curve. Despite had a stronger effect. 5- and 10 -year Treasury yields fell 40 to 50 basis
the sharp decline in long term rates during the third quarter, by historic points between June and September.
standards, the spread between 2 -year and 10 -year Treasuries remains
wide. With the prospect of low growth and low inflation over the next The table on the next page shows quarter -end yields for various U.S.
several quarters, extensions to the range of 90% to 95% of benchmark Treasury securities, changes in the quarter, and changes for the past 12
durations are designed to earn somewhat higher income and benefit months.
PFM Asset Management LLC Section A -1
City of Winter Springs Investment Report - Quarter Ended September 30, 2010
The yield curve flattened sharply, reducing the benefit of roll -down.
Summary of U.S. Treasury Security Yields Short-term rates remain near zero, intermediate rates have fallen to
Dal z 1 t, 1 , �, z 5 1 ii record lows, and longer rates have fallen 100 to 150 basis points from
their April highs. During the quarter, the difference between 2- and 10-
September 30, 2010 0.15% 0.19% 0.25% 0.42% 0.63% 1.26% 2.51% year U.S. Treasury yields was as high as 2.45 %, but by quarter end,
June 30, 2010 0.17% 0.22% 0.31% 0.60% 0.97% 1.77% 2.93% the difference had fallen to 2.09 %.
Change over Quarter -0.02% -0.03% - 0.06% -0.18% -0.34% -0.51% -0.42% The spread between U.S. Treasury and Federal Agency rates
September 30, 2009 0.11% 0.17% 0.38% 0.95% 1.42% 2.31% 3.31% fluctuated within a narrow range during the quarter, though it
Change over Year 0.04% 0.02% -0.13% -0.53% - 0.79% -1.05% -0.80% remained tight by historic standards, reflecting a perception of reduced
Source data: Bloomberg risk and increased liquidity for agency debt. For example, the spread
on 2 -year maturities ranged between 16 and 23 basis points, and the
With the decline in interest rates, the market values of fixed- income spread on 5 -year maturities ranged between 20 and 28 basis points, all
portfolios increased considerably, both quarter - over - quarter and year- well below historical averages.
over -year. As the chart below illustrates, portfolios with longer durations
outperformed those with shorter durations. Duration Adjusted Returns of Merrill Lynch 1 -3 Year Indices
Quarterly and 12 -Month Total Return as of September 30, 2010
The 1- to 3 -year U.S. Treasury benchmark returned 0.62% (2.50%
annualized), while the 3- to 5 -year U.S. Treasury benchmark returned 5.11%
2.46% (10.21% annualized). The duration of the 3- to 5 -year U.S. 5%
Treasury benchmark was 3.85 years, versus 1.89 years for the 1- to 3- 4%
year U.S. Treasury benchmark.
3% 2.53% 2.58%
Total Returns of Merrill Lynch U.S. Treasury Indices
Quarterly and 12 -Month Total Return as of September 30, 2010 2% 1.72%
8% 1% 0.62% 0.60% . 1
7.06 "° I
7% 1-- 0% 1 _
6 % U.S. Treasury Federal Agency AA/AAA Corporate
5% 4.23% Current Quarter • Past 12 Months
4% Source data: Bank of America Merril Lynch; Bloomberg Markets
3% 2.53 " /° 2.46% Duration- adjusted return incorporates an adjustment to the market value return
2% 1 32% j (but not the income return) of each benchmark to account for their varied
durations, making it easier for investors to assess the relative risk and return of
0 .13% 0.62% benchmarks of different lengths.
1%
0.04% - , 1 i � 1
0 % Spreads between Treasuries and corporate securities narrowed in
3mo 1 -3yr 1 -5yr 3 -5yr response to improving corporate balance sheets and greater investor
Quarter • 1 Year appetite for risk, contributing to the strong performance of the
Source data: Bank of America Merrill Lynch; Bloomberg Markets corporate sector. As the chart above illustrates, on a duration - adjusted
t.
PFM Asset Management LLC Section A - 2
City of Winter Springs Investment Report – Quarter Ended September 30, 2010
basis, Treasury and Agency benchmarks performed roughly in line and commodity prices have risen based on the prospect for stronger
with one another, while corporate benchmarks significantly global demand. These developments should ultimately aid U.S. export
outperformed. sectors and large, global businesses based in the U.S., but do little to
As corporate spreads continued to narrow in the quarter, we generally aid small, domestic firms.
increased corporate holdings, selectively purchasing the securities of The Federal Reserve has become increasingly focused on inflation —
highly -rated issuers on our approved list. In many portfolios we or, more properly, the lack thereof. As the following chart shows,
incorporated commercial paper, which offered some additional value though underlying price data show modest inflation, the majority of
over short-dated Treasury bills, Agency discount notes, and money Fed governors have signaled support for a new round of quantitative
market instruments. easing that would involve the central bank purchasing $1 trillion of
government securities in an effort to push long -term interest rates even
Economic Outlook lower, ultimately encouraging modest price increases that would help
debtors and, perhaps, stimulate spending.
Economic data was generally weak in the third quarter, pointing
toward a slowing recovery and uncertain prospects for future growth. Core and Non -Core Consumer Price Index
The final measurement of second quarter GDP was an anemic 1.7% August 2005 through August 2010
and economist estimates call for third quarter growth of under 2.0 %. 6% 1 AL
5% ` f ± 11
Economic conditions remain subject to considerable uncertainty, with 4% _ t- .,___.._ ..__....___.___r.,t_,„a____ t !I i the most likely scenario being modest growth and little -to -no inflation 3% -/ 1 I
for the foreseeable future. The current pace of expansion is insufficient 2% _. t 4%.• ' ^ '� ; __.. ' ! ~ � -.�.__
to make a real dent in unemployment, with nearly 8 million jobs lost 1% : ` ; ; %
r
since 2008. Unemployment remains persistently high, near 10 %, with 0% ._._. _ __ --.- .__.__- t L � I -- -
most businesses still hesitant to add new employees. - F ;. �`
8 � 8 _
17 - - - Consumer Price Index le
The housing sector remains weak with housin starts � 8 buildin Core CPI J
_.---- ... -__
permits, and sales relatively unchanged in recent months, and housing -3% — _,__
prices showing no signs of recovery. The pace of manufacturing Aug 05 Aug 06 Aug 07 Aug 08 Aug 09 Aug 10
activity has accelerated, but is hardly booming, as evidenced by only Source data: U.S. Department of Labor, Bureau of Labor Statistics
small upticks in factory orders, stable manufacturing employment, and
continued low rates of capacity utilization. Retail sales, though Investment Strateev
positive year- over -year, are not strong enough to provide significant
fuel to recovery. Given the increased likelihood that low interest rates will persist over
the next several quarters, we plan to manage portfolios slightly closer
Global economies, particularly in Asia and emerging markets, are out- to those of their respective benchmarks. This cautious duration
pacing the U.S. The dollar weakened significantly in the quarter (from extension should offer an opportunity to add value, while providing
$1.19 to $1.35 versus the Euro at quarter -end), as fears of a European enough flexibility to respond to changing interest rate scenarios. We
meltdown diminished and growth picked up in Western Europe. Oil remain concerned that when interest rates rise from their record lows,
PFM Asset Management LLC Section A - 3
4
J
('ilv of Winter Springs cslnent Report Quarter Ended Seinember 30, 2010
as they surely will, longer duration investments will experience market
value declines that will lead to strongly negative returns for an
extended period. We believe the best defense is to keep portfolios
somewhat shorter; even though such a strategy may give up some
return in the short run, it will mitigate the effects of a rise in rates.
With rates at record lows, even a slight increase has the potential to
more than offset interest income, resulting in a negative total return.
We also plan to maintain or increase holdings of assets other than
Treasuries because, although credit spreads are generally narrow,
strong government and central hank action to promote economic
growth and keep interest rates low should aid these types of
investments.
PFM Asset Management LLC Section A - 4
City of Winter Springs Investment Report - Quarter Ended September 30, 2010
Executive Summary
PORTFOLIO STRATEGY
The City's General City Account Portfolio is of high credit quality and maintains adequate liquidity. The portfolio is invested
entirely in Federal Agency, U.S. Treasury, and FDIC guaranteed corporate securities. The securities in the portfolio are allocated
among high quality issuers rated AAA.
By the end of the third quarter, the markets' fears over the European sovereign debt crisis were still not fully alleviated. Market
participants, as well as members of the Federal Open Market Committee, have painted a dreary picture of slow economic growth
for the foreseeable future. Second quarter growth in the U.S. was 1.7 %, down from an initial reading of 2.4 %. This figure was
disappointing, both in terms of its overall low level and compared to growth of 3.7% and 5.0% in the previous two quarters.
Minutes from recent Federal Open Market Committee meetings show that the fed may maintain the fed funds target rate at 0% to
0.25% for the foreseeable future. The majority of fed governors have signaled new quantitative easing strategies, with the potential
for purchasing $1 trillion of longer -term government debt. The fed would need to create cash in order to purchase these securities.
The securities would most likely be purchased from banks, thus increasing banks' excess reserves. In doing so, the hope is that
these increases in bank reserves will allow the banks to increase their lending, and ultimately stimulate economic growth.
Y We have already seen the effects of the feds proposed quantitative easing, as Short-Term rates have recently fallen to new lows. If
the fed moves forward with and is successful in implementing quantitative easing, Short-Term interest rates may fall even more.
The high level of uncertainty regarding future economic growth may cause continued volatility in market rates.
Y The General City Account Portfolio continues to provide the City with favorable yield relative to the benchmark. At quarter end
the portfolio had a Yield to Maturity at Cost of 1.05 %, exceeding the Yield to Maturity of its benchmark the Merrill Lynch 6 Month
U.S. Treasury Bill Index by 90 basis points (0.90 %).
Y PFM will continue to follow the prudent investment strategies that have safely provided the City with favorable yield and
maintained adequate liquidity during this period of significant market and economic turmoil.
PFM Asset Management LLC Section B - 1
City of Winter Springs Investment Report - Quarter Ended September 30, 2010
The City's Investment Statistics
Amortized Cost'" Amortized Cost'.' Mi ntet Value" Market Value'" Duration (Years)
AltalatliSEI Bentemter 30.2010 June 90. 201Q September 30. 2010 Jung 30. 2010 September 30.201Q
General City Account Portfolio $15,263,870.84 $19,322,874.54 $16,319,817.26 $19,403,183.56 0.54
Fidelity Institutional Money Market Fund Government Portfolio (Fund 0257) 2,809,471.47 5,992,302.08 2,808,471.47 5,992,302.08 0.003
Money Market Fund - State Board of Administration Pool A 4.06 40,724.18 4.00 40,724.18 82 Days
Money Market Fund - State Board of Administration Pool B 782,783.08 823,035.87 782,713.08 823,035.67 WA
Bank of America Cash for Operation - depository 3,837,861.75 1,518,858.58 3,637,881.76 1,518,856.56 0.003
Water & Sewer 2000 - Fidelity Institutional Money Market Fund Government Portfolio (Account 0364) 716,686.48 716,548.41 116,888.48 716,548.41 0.003
Water & Sewer 2000 - Money Market Fund - State Board of Administration Pool A 0.11 1,181.93 0.11 1,181.93 52 Day*
Water & Sewer 2000 - Money Market Fund - State Board of Administration Pool B 22,717.66 23,686.67 22,717.66 23,888.87 WA
Water & Sewer Series 1992 Refunding Revenue Reserve - BONY 1,305,089.63 1,305,069.93 1,308,089.83 1.305,069.93 0.003
Total $26;426,146.58 $29,744,479.97 528,466,892,00 $29,824,768.98
Yield to Maturity Yield to Maturity Yield to Maturity Yield to Maturity
on Cat' on Cost' at Marlat at Market Duration (Years)
Sestambar 30. 201Q June 30.2010 ll t tuber 39. 201Q June 30. 201Q June 30. 201Q
General City Account Portfolio 1.05% 1.00% 0.30% 0.39% 0.88
Fidelity Institutional Money Market Fund Government Portfolio (Fund 0257) 0.01% 0.01% 0.01% 0.01% 0.003
Money Market Fund - State Board of Administration Pool A 0.33% 0.34% 0.32% 0.34% 45.9 Days
Money Market Fund - State Board of Administration Pool B 0.00% 0.00% 0.00% 0.00% N/A
Bank of America Cash for Operation - depository 0.30% 0.30% 0.30% 0.30% 0.003
Water & Sewer 2000 - Fidelity Institutional Money Market Fund Government Portfolio (Account 0384) 0.01% 0.01% 0.01% 0.01% 0.003
Water & Sewer 2000 - Money Market Fund - State Board of Administration Pool A 0.32% 0.34% 0.32% 0.34% 45.9 Days
Water & Sewer 2000 - Money Market Fund - State Board of Administration Pool B 0.00% 0.00% 0.00% 0.00% N/A
Water & Sewer Series 1992 Refunding Revenue Reserve - BONY 0.90% 0.00% 0.00M 0.00% 0.003
Weighted Average Yield 0.11% 0.87% 0.04% 0.27%
Banelimi[ka Jactarebar 30.2010 June 30. 201Q
Merrill Lynch 8 Month U.S. Treasury Bill Index' 0.15% 0.20%
Notes:
I. on . Imdod.e. bee, Ind,dke *cause Internet.
2. In ad., to drnplY.dm Wee amud ImmemIlne reprenp requirements: forward strap aims '.Indeed In me monthly balances.
3. Excludes any money market Iundles.I Oelnp. hold In cu.lodlm mount.
4. Put prlom,.noo a not Indlanee of Mum nuke.
P. Some eloombee.
PFM Asset Management LLC Section B - 2
City of Winter Springs Investment Report - Quarter Ended September 30, 2010
General City Account Portfolio Composition and Credit Quality Characteristics
Security Type' September 30. 2010 % of Portfolio June 30. 2010 % of Portfolio
U.S. Treasuries $2,618,651.28 16.05% $2,617,875.82 13.49%
Federal Agencies 9,166,601.33 56.17% 10,431,862.76 53.76%
Commercial Paper 0.00 0.00% 1,799,920.80 9.28%
Certificates of Deposit 0.00 0.00% 0.00 0.00%
Bankers Acceptances 0.00 0.00% 0.00 0.00%
Repurchase Agreements 0.00 0.00% 0.00 0.00%
Municipal Obligations 0.00 0400% 0.00 0.00%
Corporate Notes /Bonds 0.00 0.00% 0.00 0.00%
Corporate Notes/Bonds - FDIC Insured 034,464.67 27.79% 4,553,504.17 23.47%
Mortgage Backed 0.00 0.00% 0.00 0.00%
Money Market Fund /Cash 0.00 0.00% 0.00 0.00%
Totals $0,010,017.78 100.00% $19,403,163.55 100.00%
Portfolio Composition Credit Quality Distribution"
as of 09/30/10 as 0109/30/10
U.S. Federal
Treasuries Agency
16% Obligations AAA
56% 84 %
':;4f,4 , , ^,1 +0 141,
t
Corporate TSY
Notes/Bonds - 16%
FDIC Insured
28%
Nobs:
1. End of quarter trade -lab market values of portfolio holdings, Including accrued Interest.
2. Cradf rating of securities held In portfolio, exclusive of money market fund.
3. A rating of "T8Y" Indicates the security Is an obligation of, or explicitly guaranteed by the U. 8. Government.
il
PFM Asset Management LLC Section B - 3
ii
1
8
City of Winter Springs Investment Report - Quarter Ended September 30, 2010
General City Account Portfolio Maturity Distribution
Maturity Distribution' September 30. 2010 June 30. 2010
Overnight (Money Market Fund) $0.00 $0.00
Under 8 Months 10,575,963.08 6,218,961.18
8 - 12 Months 3,116,285.94 10,566,843.46
1 - 2 Years 2,627,368.26 2,617,358.91
2 - 3 Years 0.00 0.00
3 - 4 Years 0.00 0.00
4 - 5 Years 0.00 0.00 r'
5 Years and Over 0.00 0.00
Totals $16,419,017,28 $19,403,163.55
a
Portfolio Maturity Distribution'
70% - 65%
D September 30, 2010
60% - 54% DJune 30, 2010
2 50% ,
40% " r
°
32 %�' `
30% w ,
i�!
F- 20% VA+ 19% ' ,,� k ' r
I r,, 13%
10% t " ""+�''
0% 0% 0% . 0% 0% 0% 0% 0% 0% 0% 0%
Overnight Under 8 Months 6 -12 Months 1 - 2 Years 2 - 3 Years 3 - 4 Years 4 - 5 Years 5 Years and Over
Notes:
1. Callable securities In portfolio are Included In the maturity distribution analysis to their stated maturity date, although they may be called prior to maturity.
i
PFM Asset Management LLC Section B - 4
n M w
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;i
City of Winter Springs, Florida' Asset Allocation as of September 30, 2010*
$esarety Type. September 30, 9010 September 30, 1010 Now Permitted by Policy Asset Allocation
United Slates Treasury Securities 2,002,015.71 11.13% 100% as of September 70, 2010
United Stew Government Agency BocurllW 0.00% 75%
Federal inatrumentalltise 0,130,1119.75 79.00% 50% Federal lretrumentalktet -
Certificates al Deposit - 0.00% 25% 39.09%
Repurchase Agreements - 0.00% 50% - Corporate Mobs • FDIC
!routed
Commercial Peper - 0.00% 30% 19.29%
Corporate Now • FDIC Insured 4,611572.90 10.20% 10%
Mortgage-Backed Securities 0.00% 0% - -
Unked States Treasury
Bankers' Acceptances - 0.00% 30% Securities
State and/or Local Government Debt (GO and Revenue) - 0.00% 20% 11.13% - Money Market Mutual Funds
Money Mantra MuUUl Funds 9.002,295.59 11.25% 2 100% I 15.36%
Bank of America Cash for
Intergovernmental menl.l Investment Pool • 0.00% 21% Operation
Bank of America Cash for Operation 7,577,01.75 15.17% 2 100% 15.13%
IndIvldual leaser Brea September 30, 3010 September 20, 9510 Now Permitted by Policy hmdlvlduse weer Bredaswt September 30, 9010 BspleMber 10, 010 Now Permuted by Policy
Government National Mort age Association (ONMA) - 0.00% 50% CD - Bank A 0.00% 10%
US Erpor -Import Bank (Erin) - 0.00% 10% CD - lank B - 0.00% 15%
Fenner. Hone AdmNNtreson (FMHA) • 0.00% 50% Fury collateralized Repo -A - 0.00% 25% ..
Federal Financing Bank - 0.00% 10% Fully m0sten0rsd Repo • 5 0.00% 25%
Federal Housing AdmkdstrMbn (FHA) - 0.00% 50% CPA • 0.00% 10%
General Son em Administration - 0.00% 50% CP I - 0.00% 10%
New Commurdlw Act 0.6110re. - 0.00% 50% General Electric Caporals Now . FDIC Insured 1001.02752 0.411% 25%
US Public Housing Now I Bonds - 0.00% S0% JP Morgan Chase Corporate Now • FDIC Insured 1.102.010.00 051% 25%
US Dept of Housing end Urban Development - 0.00% 50% Bank of Aesd. Capone. Now • FDIC Insured 1,507,00.0 055% 25%
Federal Farm Credit Bark (FFCB) - 0.00% 30% Corporate Now • FDIC Insured D • 0.00% 25%
Federal Home Loan Bras (FHLB) 2,171300.17 10.14% 25% Corporals Now • FDIC insured E - 0.00% 25%
Federal National Morale's Aesoclalbn (FNMA) 5,172,210.42 22.12% 25% BA Bank A - 0.00% 10%
Federal Hem. Leen Mtrlg.ga Corpora5err (FHLMC) 150,010.10 0.52% 25% BA Sank B - 0.00% 10%
S tudent Loan MarbeWmp A.sootetlon (SLMl1) 0.00% 25% BA Bank C - 0.00% 10%
Munlelpal NofsUBond. • 0.00% 20%
Fidelity I stitutIonal Money Market Fund Government Portfolio (Fund 0257) 2,105,471.47 10•01% 2 25%
Money MAN Fund - Slate Board of Addnistrasar 713 ,707.12 i3O% 2 21%
MY:
1. Darr nor a aluMborrpmrar.
2. Yaps M scar.
s ate sneer timer mesas ms re prase soap. rakAp.umM M.N.
PPM Meet Management LLC Section C -1
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