Federal Register / Vol. 75, No. 198 / Thursday, October 14, 2010 / Proposed Rules 63107 

1Public Law 111–203, 124 Stat. 1376, section 

939A (July 21, 2010). 

2 Id. 

§ 1605.2 [Amended] 

2. Amend § 1605.2, by revising 

paragraph (b)(1)(iii) and adding 

paragraph (b)(1)(iv) to read as follows: 

* * * * * 

(b) * * * 

(1) * * * 

(iii) Determine the dollar value on the 

posting date of the number of shares the 

participant would have received had the 

contributions or loan payments been 

made on time. If the contributions or 

loan payments would have been 

invested in a Lifecycle fund that is 

retired on the posting date, the 

constructed share price shall equal the 

retired Lifecycle fund share price on 

December 31 of the retirement year, 

multiplied by the current L Income 

Fund share price, divided by the L 

Income Fund share price on December 

31 of the retirement year. The dollar 

value shall be the number of shares the 

participant would have received had the 

contributions or loan payments been 

made on time multiplied by the 

constructed share price. 

(iv) The difference between the dollar 

value of the contribution or loan 

payment on the posting date and the 

dollar value of the contribution or loan 

payment on the ‘‘as of’’ date is the 

breakage. 

* * * * * 

§ 1605.12 [Amended] 

3. Amend § 1605.12, by revising 

paragraph (c)(2)(ii) to read as follows: 

* * * * * 

(c) * * * 

(2) * * * 

(ii) Multiply the price per share on the 

date the adjustment is posted by the 

number of shares calculated in 

paragraph (c)(2)(i) of this section. If the 

contribution was erroneously 

contributed to a Lifecycle fund that is 

retired on the date the adjustment is 

posted, the price per share shall equal 

the retired Lifecycle fund share price on 

December 31 of the retirement year, 

multiplied by the current L Income 

Fund share price, divided by the L 

Income Fund share price on December 

31 of the retirement year. 

* * * * * 

[FR Doc. 2010–25855 Filed 10–13–10; 8:45 am] 

BILLING CODE 6760–01–P 

DEPARTMENT OF THE TREASURY 

Office of Thrift Supervision 

12 CFR Part 560 

[Docket ID OTS–2010–0029] 

RIN 1557–AC44 

Alternatives to the Use of External 

Credit Ratings in the Regulations of 

the OTS 

AGENCY: Office of Thrift Supervision 

(OTS), Treasury. 

ACTION: Advance notice of proposed 

rulemaking. 

SUMMARY: Section 939A of the DoddFrank Wall Street Reform and Consumer 

Protection Act (the Act) directs all 

Federal agencies to review, no later than 

one year after enactment, any regulation 

that requires the use of an assessment of 

credit-worthiness of a security or money 

market instrument and any references to 

or requirements in regulations regarding 

credit ratings. The agencies are also 

required under the Act to remove 

references or requirements of reliance 

on credit ratings and to substitute an 

alternative standard of creditworthiness. 

Through this ANPR, the OTS seeks 

comment on the implementation of 

section 939A with respect to its 

regulations (other than risk-based 

capital regulations, which are the 

subject of a separate ANPR issued 

jointly with the other Federal banking 

agencies), including alternative 

measures of credit-worthiness that may 

be used in lieu of credit ratings. 

DATES: Comments on this ANPR must be 

received by November 15, 2010. 

ADDRESSES: You may submit comments, 

identified by OTS–2010–0029, by any of 

the following methods: 

• Federal eRulemaking Portal: 

‘‘Regulations.gov’’: Go to http:// 

www.regulations.gov and follow the 

instructions for submitting comments. 

• Mail: Regulation Comments, Chief 

Counsel’s Office, Office of Thrift 

Supervision, 1700 G Street, NW., 

Washington, DC 20552, Attention: OTS– 

2010–0029. 

• Facsimile: (202) 906–6518. 

• Hand Delivery/Courier: Guard’s 

Desk, East Lobby Entrance, 1700 G 

Street, NW., from 9 a.m. to 4 p.m. on 

business days, Attention: Regulation 

Comments, Chief Counsel’s Office, 

Attention: OTS–2010–0029. 

• Instructions: All submissions 

received must include the agency name 

and docket number for this rulemaking. 

All comments received will be posted 

without change, including any personal 

information provided. Comments, 

including attachments and other 

supporting materials received are part of 

the public record and subject to public 

disclosure. Do not enclose any 

information in your comment or 

supporting materials that you consider 

confidential or inappropriate for public 

disclosure. 

• Viewing Comments Electronically: 

Go to http://www.regulations.gov and 

follow the instructions for reading 

comments. 

• Viewing Comments On-Site: You 

may inspect comments at the Public 

Reading Room, 1700 G Street, NW., by 

appointment. To make an appointment 

for access, call (202) 906–5922, send an 

e-mail to public.info@ots.treas.gov, or 

send a facsimile transmission to (202) 

906–6518. (Prior notice identifying the 

materials you will be requesting will 

assist us in serving you.) We schedule 

appointments on business days between 

10 a.m. and 4 p.m. In most cases, 

appointments will be available the next 

business day following the date we 

receive a request. 

FOR FURTHER INFORMATION CONTACT: 

William Magrini, Senior Project 

Manager, Risk Management Division, 

(202) 906–5744; or Marvin Shaw, Senior 

Attorney, Regulations and Legislation 

Division, Office of Chief Counsel, (202) 

906–6639, Office Thrift Supervision, 

1700 G Street, NW., Washington, DC 

20552. 

SUPPEMENTARY INFORMATION: 

I. Background 

Section 939A of the Act requires each 

Federal agency to review (1) any 

regulation issued by such agency that 

requires the use of an assessment of the 

credit-worthiness of a security or money 

market instrument; and (2) any 

references to or requirements in such 

regulations regarding credit ratings.1

Each Federal agency must then modify 

any such regulations identified by the 

review * * * to remove any reference to 

or requirement of reliance on credit 

ratings and to substitute in such 

regulations such standard of creditworthiness as each respective agency 

shall determine as appropriate for such 

regulations. In developing substitute 

standards of credit-worthiness, an 

agency shall seek to establish, to the 

extent feasible, uniform standards of 

credit-worthiness for use by the agency, 

taking into account the entities it 

regulates that would be subject to such 

standards.2


jlentini on DSKJ8SOYB1PROD with PROPOSALS
63108 Federal Register / Vol. 75, No. 198 / Thursday, October 14, 2010 / Proposed Rules 

3An NRSRO is an entity registered with the U.S. 

Securities and Exchange Commission (SEC) under 

section 15E of the Securities Exchange Act of 1934. 

See, 15 U.S.C. 78o–7, as implemented by 17 CFR 

240.17g–1. 

4See generally, 12 CFR part 560.40 and 560.42. 

5OTS Thrift Bulletin TB–13a ‘‘Management of 

Interest Rate Risk, Investment Securities, and 

Derivative Activities.’’ 

6OTS Thrift Bulletin TB 73a, ‘‘Complex 

Investment Securities.’’ 

This ANPR describes the areas where 

the OTS’s regulations, other than those 

that establish regulatory capital 

requirements, currently rely on credit 

ratings; sets forth the considerations 

underlying such reliance; and requests 

comment on potential alternatives to the 

use of credit ratings. On August 25, 

2010, OTS and the other Federal 

banking agencies issued a separate joint 

advance notice of proposed rulemaking 

focused on the agencies’ risk-based 

capital frameworks. (75 FR 52283) 

II. OTS Regulations Referencing Credit 

Ratings 

The non-capital regulations of OTS 

include various references to and 

requirements for use of a credit rating 

issued by a nationally recognized 

statistical rating organization (NRSRO).3

For example, OTS’s regulations 

regarding permissible investment 

securities reference or rely upon NRSRO 

credit ratings.4 A description of these 

regulations is set forth below. 

A. Investment Securities Regulations 

The OTS’s investment securities 

regulations at 12 CFR part 560 use credit 

ratings as a factor for determining the 

credit quality, liquidity/marketability, 

and appropriate concentration levels of 

investment securities purchased and 

held by savings associations. For 

example, under these rules, an 

investment security must be ‘‘Rated in 

one of the four highest categories as to 

the portion of the security in which the 

association is investing by a nationally 

recognized investment rating service at 

its most recently published rating before 

the date of purchase by the association.’’ 

Credit ratings are also used to 

determine marketability in the case of a 

security that is offered and sold 

pursuant to Securities and Exchange 

Commission Rule 144A. A 144A 

security is generally deemed by OTS to 

be marketable if it is rated investment 

grade. 

In addition, credit ratings are used to 

determine concentration limits on 

certain investment securities. For 

example, Part 560.40 limits holdings of 

corporate debt securities of any one 

issuer that are rated in the third or 

fourth highest investment grade rating 

categories to 15 percent of the 

association’s capital and surplus. For 

securities that are rated in the highest or 

second highest investment grade 

categories, that limit is 25 percent of the 

savings association’s capital and 

surplus. 

Current Safety and Soundness 

Standards 

In addition to current regulatory 

provisions that generally limit savings 

associations to purchasing securities 

that are rated investment grade, OTS 

policy guidance also require that 

savings associations make the 

investments consistent with safe and 

sound banking practices. Specifically, 

savings associations must consider the 

interest rate, credit, liquidity, price and 

other risks presented by investments 

and the investment must be appropriate 

for the particular savings association. 

Whether a security is an appropriate 

investment for a particular association 

will depend upon a variety of factors, 

including the association’s capital level, 

the security’s impact on the aggregate 

risk of the portfolio, and management’s 

ability to measure and manage bankwide risks. In addition, an association 

must determine that there is adequate 

evidence that the obligor possesses 

resources sufficient to provide for all 

required payments on its obligations. 

Each association also must maintain 

records available for examination 

purposes adequate to demonstrate that it 

meets the above requirements. 

OTS has issued guidance on safe and 

sound investment securities practices. 

OTS expects savings associations to 

understand the price sensitivity of 

securities before purchase (pre-purchase 

analysis) and on an ongoing basis.5

Appropriate ongoing due diligence 

includes the ability to assess and 

manage the market, credit, liquidity, 

legal, operational, and other risks of 

investment securities. As a matter of 

sound practice, savings associations are 

expected to perform quantitative tests to 

ensure that they thoroughly understand 

the accompanying cash flow and 

interest rate risks of their investment 

securities. 

Sound investment practices dictate 

additional due diligence for purchases 

of certain structured or complex 

investment securities. The more 

complex a security’s structure, the more 

due diligence that savings association 

management should conduct. For 

securities with long maturities or 

complex options, management should 

understand the structure and price 

sensitivity of such securities purchased. 

For complex asset-backed securities, 

such as collateralized debt obligations, 

savings association management should 

ensure that they understand the 

security’s structure and how the 

security will perform in different default 

environments.6

Alternative Standards 

Four options for replacing the 

references to external credit ratings in 

OTS’s investment securities regulations 

include the following. 

1. Credit Quality Based Standard 

One alternative would be to replace 

the references to credit ratings with a 

standard that is focused primarily on 

credit quality. OTS could adopt 

standards similar to those applied to 

unrated securities. Specifically, savings 

associations could be required to 

document, through their own credit 

assessment and analysis, that the 

security meets specified internal credit 

rating standards. 

Under the current rules, a savings 

association may invest in a security if it 

is rated investment grade by an NRSRO. 

To demonstrate that a security is the 

credit equivalent of investment grade 

without using NRSROs ratings, a 

savings association would have to 

document, through its own credit 

assessment and analysis, that the 

security is a ‘‘pass’’ asset under its 

internal credit rating standards. 

However, because some internal rating 

systems ‘‘pass’’ some credit exposures 

that are not, or would not be, rated 

investment grade, a security will 

generally have to be rated higher than 

the bottom tier of internal credit rating 

‘‘pass’’ standards in order to be the credit 

equivalent of investment grade. 

If the OTS adopts a general creditquality based test that does not rely on 

external credit ratings, it could require 

associations to determine that their 

investment securities meet certain credit 

quality standards. Savings associations 

could be required to document an 

internal credit assessment and analysis 

demonstrating that the issuer of a 

security is an entity that has an 

adequate capacity to meet its financial 

commitments, is subject only to 

moderate credit risk, and for whom 

expectations of default risk over the 

term of the security are low. OTS would 

require savings associations to 

document their credit assessment and 

analysis using systems and criteria 

similar to the savings association’s 

internal loan credit grading system. 

These would be subject to examiner 

review and classification, similar to the 

process used for loan classifications. 


jlentini on DSKJ8SOYB1PROD with PROPOSALS
Federal Register / Vol. 75, No. 198 / Thursday, October 14, 2010 / Proposed Rules 63109 

7OTS Thrift Bulletin TB 73a, ‘‘Complex 

Investment Securities’’. 

If this alternative were adopted, OTS 

would continue to expect savings 

associations to understand and manage 

the associated price, liquidity and otherrelated risks associated with their 

investment securities activities. 

2. Investment Quality Based Standard 

As an alternative to a standard that 

focuses solely on credit-worthiness, 

OTS could adopt a broader ‘‘investment 

quality’’ standard that, in addition to 

credit worthiness elements (such as the 

timely repayment of principal and 

interest and the probability of default), 

would also establish criteria for 

marketability, liquidity, and price risk 

associated with market volatility. 

OTS’s current investment securities 

regulations and guidance emphasize 

ratings and marketability. An 

investment quality based standard could 

reflect some combination of these 

considerations and place quantitative 

limits on a savings association’s 

investment securities activities based on 

the levels and types of risks in its 

portfolio. As with the credit quality 

standard, OTS could require 

associations to document their credit 

assessment and analysis using systems 

and criteria similar to their internal loan 

credit grading system. Such reviews 

would be subject to examiner review 

and classification, similar to the process 

used for loan classifications. 

Under such a standard, a security 

with a low probability of default may 

nevertheless be deemed ‘‘predominantly 

speculative in nature,’’ and therefore 

impermissible, if, under the new 

standard, it is deemed to be subject to 

significant liquidity or market risk. This 

would be consistent with current OTS 

guidance, which warns that complex 

and illiquid instruments often can 

involve greater risk than actively traded, 

more liquid securities.7 This higher 

potential risk arising from illiquidity is 

not always captured by standardized 

financial modeling techniques. Such 

risk is particularly acute for instruments 

that are highly leveraged or that are 

designed to benefit from specific, 

narrowly defined market shifts. If 

market prices or rates do not move as 

expected, the demand for such 

instruments can evaporate, decreasing 

the market value of the instrument 

below the modeled value. 

3. Reliance on Internal Risk Ratings 

A third alternative could establish a 

credit-worthiness standard that is based 

on a savings association’s internal risk 

rating systems. OTS could require a 

savings association to document its 

credit assessment and analysis using 

systems and criteria similar to its 

internal loan credit rating system. Such 

reviews also would be subject to 

examiner review and classification, 

similar to the process used for loan 

classifications. 

The bank regulatory agencies use a 

common risk rating scale to identify 

problem credits. The regulatory 

definitions are used for all credit 

relationships—commercial, retail, and 

those that arise outside lending areas, 

such as from capital markets. The 

regulatory ratings ‘‘special mention,’’ 

‘‘substandard,’’ ‘‘doubtful,’’ and ‘‘loss’’ 

identify different degrees of credit 

weakness. Therefore, for example, the 

rule could define all investments 

deemed ‘‘special mention’’ or worse as 

predominately speculative. Credits that 

are not covered by these definitions 

would be ‘‘pass’’ credits, for which no 

formal regulatory definition exists 

(because regulatory ratings currently do 

not distinguish among pass credits). 

Many banks and savings associations 

have internal rating systems that 

distinguish between levels of creditworthiness in the regulatory ‘‘pass’’ 

grade. In these systems, ‘‘pass’’ grades 

that denote lower levels of creditworthiness usually do not equate to 

investment grade as defined in the 

current rule. 

Under the current rules, a security is 

not predominately speculative in nature 

if it is rated investment grade. Without 

the use of NSROs, savings associations 

would have to document, through their 

own credit assessment and analysis, that 

the security is a strong ‘‘pass’’ asset 

under its internal credit rating standards 

to demonstrate that a non-rated security 

is the credit equivalent of investment 

grade. Because most internal rating 

systems ‘‘pass’’ some credit exposures 

that are not, or would not be, rated 

investment grade, a security will 

generally have to be rated higher than 

the bottom tier of internal credit rating 

‘‘pass’’ standards in order to be the credit 

equivalent of investment grade. 

4. Reliance on External Information 

A part of their process for making 

credit-worthiness determinations, 

savings associations would be allowed 

to consider external data, including 

credit analyses provided by third 

parties, that met standards established 

by OTS. In addition, alternative ways to 

measure credit risk might be to derive 

‘‘implied ratings’’ from the market price 

of traded instruments. One type of such 

indicators is that derived from the 

equity prices. Another type is the bond 

market-implied rating base on the 

market price of debt instruments or 

credit derivatives such as credit default 

swaps. 

Investors typically require a lower 

return for an investment with a lower 

risk of default. For example, the yield 

spread (difference between the yield on 

a corporate bond relative to a similar 

government bond) is often used as a 

measure of relative credit-worthiness, 

with reduction in the credit spread 

reflecting improvement in the issuer’s 

perceived credit quality. Implied yield 

spreads could thus provide a useful 

market-based indication of creditworthiness, provided that investors 

have sufficient information. 

OTS would establish conditions 

under which savings associations could 

rely on external market data and 

information as part of their due 

diligence requirements. 

III. Request for Comment 

OTS is seeking public input as it 

begins reviewing its regulations 

pursuant to section 939A of the DoddFrank Act. In particular, OTS is seeking 

comment on alternative measures of 

credit-worthiness that may be used 

instead of credit ratings in the 

regulations described in this ANPR. 

Commenters are encouraged to address 

the specific questions set forth below; 

OTS also invites comment on any and 

all aspects of this ANPR. 

General Questions 

1. In some cases the regulations 

described in this ANPR use credit 

ratings for purposes other than 

measuring credit-worthiness (for 

example, the definition of 

‘‘marketability’’ at 12 CFR part 560). 

Should the Dodd-Frank Act’s 

requirement for the removal of 

references to credit ratings be construed 

to prohibit the use of credit ratings as a 

proxy for measuring other 

characteristics of a security, for 

example, liquidity or marketability? 

2a. If continued reliance on credit 

ratings is permissible for purposes other 

than credit-worthiness, should OTS 

permit savings associations to continue 

to use credit ratings in their risk 

assessment process for the purpose of 

measuring the liquidity and 

marketability of investment securities, 

even though alternative measures to 

determine credit-worthiness would be 

prescribed? 

2b. What alternative measures could 

the OTS and savings associations use to 

measure the marketability, and liquidity 

of a security? 

3. What are the appropriate objectives 

for any alternative standards of creditVerDate Mar<15>2010 16:04 Oct 13, 2010 Jkt 223001 PO 00000 Frm 00004 Fmt 4702 Sfmt 4702 E:\FR\FM\14OCP1.SGM 14OCP1

jlentini on DSKJ8SOYB1PROD with PROPOSALS
63110 Federal Register / Vol. 75, No. 198 / Thursday, October 14, 2010 / Proposed Rules 

8 75 FR 52283, August 25, 2010. 

worthiness that may be used in 

regulations in place of credit ratings? 

4. In evaluating potential standards of 

credit-worthiness, the following criteria 

appear to be most relevant; that is, any 

alternative to credit ratings should: 

a. Provide for a reasonable and 

objective assessment of the likelihood of 

full repayment of principal and interest 

over the life of the security; 

b. Foster prudent risk management; 

c. Be transparent, replicable, and well 

defined; 

d. Allow different banking 

organizations to assign the same 

assessment of credit quality to the same 

or similar credit exposures; 

e. Allow for supervisory review; 

f. Differentiate among investments in 

the same asset class with different credit 

risk; and 

g. Provide for the timely and accurate 

measurement of negative and positive 

changes in investment quality, to the 

extent practicable. 

Are these criteria appropriate? Are 

there other relevant criteria? Are there 

standards of credit-worthiness that can 

satisfy these criteria? 

5. OTS recognizes that any measure of 

credit-worthiness likely will involve 

tradeoffs between more refined 

differentiation of credit-worthiness and 

greater implementation burden. What 

factors are most important in 

determining the appropriate balance 

between precise measurement of credit 

risk and implementation burden in 

considering alternative measures of 

credit-worthiness? 

6. Would the development of 

alternatives to the use of credit ratings, 

in most circumstances, involve cost 

considerations greater than those under 

the current regulations? Are there 

specific cost considerations that OTS 

should take into account? What 

additional burden, especially at 

community and regional savings 

associations, might arise from the 

implementation of alternative methods 

of measuring credit-worthiness? 

7. The credit rating alternatives 

discussed in this ANPR differ, in certain 

respects, to those being proposed by 

OTS and other federal banking agencies 

for regulatory capital purposes.8 OTS 

believes such distinctions are consistent 

with current differences in the 

application and evaluation of credit 

quality for evaluating loans and 

investment securities and those used for 

risk-based capital standards. Are such 

distinctions warranted? What are the 

benefits and costs of using different 

standards for different regulations? 

Alternatives for Replacing References to 

Credit Ratings in Part 560 

8. What are the advantages and 

disadvantages of the alternative 

standards described in the 

SUPPLEMENTARY INFORMATION? 

9. Should the credit-worthiness 

standard include only high quality and 

highly liquid securities? Should the 

standard include specific standards on 

probability of default? Should the 

standard vary by asset class? Are there 

other alternative credit-worthiness 

standards that should be considered? 

Should a combination of creditworthiness standards be used, and if so, 

in what instances would this be 

preferred? Would different creditworthiness standards be appropriate for 

different asset classes, probabilities of 

default, varying levels of liquidity, 

different types securities or money 

market instruments, etc? 

10. If OTS relied upon internal rating 

systems, should the credit-worthiness 

standard include any pass grade or 

should it only be mapped to higher 

grades of pass? 

11. Alternatively, should the banking 

regulators revise the current regulatory 

risk rating system to include more 

granularity in the pass grade and 

develop a credit-worthiness standard 

based upon the regulatory risk rating 

system? 

12. Should OTS adopt standards for 

marketability and liquidity separate 

from the credit-worthiness standard? If 

so, how should this differ from the 

credit-worthiness standard? 

13. Should an alternative approach 

take into account the ability of a 

security issuer to repay under stressed 

economic or market environments? If so, 

how should stress scenarios be applied? 

14. Should an assessment of creditworthiness link directly to a savings 

association’s loan rating system (for 

example, consistent with the higher 

quality credit ratings)? 

15. Should a savings association be 

permitted to consider credit assessments 

and other analytical data gathered from 

third parties that are independent of the 

seller or counterparty? What, if any, 

criteria or standards should the OTS 

impose on the use of such assessments 

and data? 

16. Should a savings association be 

permitted to rely on an investment 

quality or credit quality determination 

made by another financial institution or 

another third party that is independent 

of the seller or counterparty? What, if 

any, criteria or standards should OTS 

impose on the use of such opinions? 

17. Which alternative(s) would be 

most appropriate for smaller, 

community-oriented savings 

associations and why? 

18. Are there other alternatives that 

ought to be considered? 

19. What level of due diligence of a 

savings association should be required 

when considering the purchase of an 

investment security? How should OTS 

set minimum standards for monitoring 

the performance of an investment 

security over time so that savings 

associations effectively ensure that their 

investment securities remain 

‘‘investment quality’’ as long as they are 

held? 

Dated: October 6, 2010. 

By the Office of Thrift Supervision. 

John E. Bowman, 

Acting Director. 

[FR Doc. 2010–25845 Filed 10–13–10; 8:45 am] 

BILLING CODE P 

SMALL BUSINESS ADMINISTRATION 

13 CFR Part 107 

RIN 3245–AF56 

Small Business Investment 

Companies—Conflicts of Interest and 

Investment of Idle Funds 

AGENCY: U.S. Small Business 

Administration. 

ACTION: Proposed rule. 

SUMMARY: The U.S. Small Business 

Administration proposes to revise a rule 

which prohibits a small business 

investment company (SBIC) from 

providing financing to an Associate, as 

defined in the rules, unless it first 

obtains a conflict of interest exemption 

from SBA. The revision would eliminate 

the requirement for an exemption in the 

case of a follow-on investment in a 

small business concern by an SBIC and 

an Associate investment fund, where 

both parties invested previously on the 

same terms and conditions and where 

the follow-on investment would also be 

on the same terms and conditions as 

well as in the same proportions. In 

addition, this rule would implement 

two provisions of the Small Business 

Investment Act. First, it would bring the 

public notice requirement for conflict of 

interest transactions into conformity 

with statutory requirements. Second, it 

would expand the types of investments 

an SBIC is permitted to make with its 

‘‘idle funds’’ (cash that is not 

immediately needed for fund operations 

or investments in small business 

concerns). Finally, the rule would 

remove an outdated cross-reference and 

eliminate a section that exactly 


jlentini on DSKJ8SOYB1PROD with PROPOSALS