On August 15, 2019, Harry Markopolos, who gained fame as the person who exposed the fraud perpetrated by Bernie Madoff, released a 175-page report entitled “General Electric, A Bigger Fraud Than Enron.” GE’s stock fell 11.3% on the day; but it has since regained all that it lost after GE, security analysts and the media criticized the analysis and conclusions of the report and questioned the motivations of Mr. Markopolos, who had entered into an agreement with an unnamed hedge fund to profit from a decline in GE’s share price. Although this tempest seems to have passed, I will offer some thoughts on the content of the Markopolos report and its potential implications for investors.
Who is Harry Markopolos? Mr. Markopolos is a former security analyst and portfolio manager who is best known as the person who exposed the Ponzi scheme of Bernie Madoff. He is a Chartered Financial Analyst who served as Chairman of the CFA Society of Boston from 2002-2003. After leaving the security industry in 2004, he became a certified fraud examiner. Along with his partner John McPherson, he now leads The Fraud Investigators Team (FI) which touts its experience in fraud detection, research and exposure, having worked so far on nine major fraud investigations, including the Madoff funds and Life Partners.
The Report. The report is available as a free download at www.gefraud.com. It consists of a 6-page synopsis followed by 169 pages of supporting slides. It purports to be a “Whistleblower Report” and not investment research. (The Dodd-Frank Act amended the Securities Exchange Act of 1934 to provide protection and incentives, in the form of monetary awards, to individuals who provide information that leads to successful SEC enforcement actions that result in monetary sanctions of $1 million or more.) The report has been submitted to “select Law Enforcement entities,” including the SEC and the Dept. of Justice.
Despite its disclaimer and disclosures, it is hard to see how the report would not qualify as investment research, especially given FI’s financial arrangement with that unnamed hedge fund. Although the decline in GE’s share price was short-lived, it would not be surprising to see the SEC investigate whether FI willfully sought to drive down GE’s share price. If such an investigation were to conclude that the report is indeed investment research, the SEC might fine FI and require it to disgorge any compensation that it receives under that arrangement. Perhaps the only saving grace for FI is that the report is so full of errors, inaccuracies and exaggerations that most knowledgeable investors would tend – rightly or wrongly – to discount its conclusions.
The slide portion of the report begins with a claim in big, bold letters that “General Electric is a Bigger Fraud then Enron.” After its disclosures and disclaimers, it then asserts, also in big, bold letters, that “General Electric is Headed Toward Bankruptcy.”
In support of those assertions, it notes that investors were hit by $53.5 billion of negative surprises in 2017 and 2018, including two dividend cuts totaling $8 billion, a $15 billion charge to boost reserves at GE Capital’s insurance business, a $22 billion goodwill write-down associated with its acquisition of Alstom and an $8.5 billion restatement of contract assets (associated with its long-term service agreements). These negative surprises were major contributing factors in the loss of $130 billion of GE’s equity market value.
Still to come, the report contends, are (1) a $9.1 billion non-cash loss for the “disastrous” acquisition of Baker Hughes, (2) a $10.5 billion non-cash charge to bring its GAAP insurance reserves in line with its statutory accounting reserves and (3) an $18.5 billion cash injection to shore up its insurance reserves. I will examine each of these in some detail.
The Upcoming BHGE Losses. GE is indeed facing a large, non-cash loss, probably in excess of $9.0 billion, when it deconsolidates BHGE in the current quarter. On Sept. 11, BHGE priced a secondary offering of 115 million of its Class A shares at $21.50 and also agreed to buy 11.9 million shares of its Class B shares held by GE and its affiliates at the same price. If the underwriters’ overallotment of 17.25 million shares is exercised, GE will receive about $3 billion in total from the sale and its stake in BHGE will decline from 50.4% to 36.8%, according to my estimates. Since its equity stake will fall below the 50% threshold, GE will be required to deconsolidate BHGE from its financial statements and recognize the difference between the current market value of its 50.4% stake and its carrying value in GE’s financial statements.
FI calculates (correctly, I believe) that the potential non-cash loss on deconsolidation will be $9.1 billion. (A quick calculation: GE recorded a loss of $2.2 billion on the sale of BHGE shares in November 2018 that reduced its economic interest in BHGE by 12.1 percentage points, from 62.5% to 50.4%. $2.2 billion divided by .121 multiplied by .504 equals $9.16 billion.)
The actual loss on deconsolidation will equal the GE’s carrying value for BHGE minus the net price that GE receives for the stock (probably around $21 per share, after an assumed underwriting discount of 2.25%). According to my estimates, the actual loss will be around $9.4 billion.
I estimate that roughly 27% of the loss or about $2.5 billion will be recorded as a realized loss on the recent sale of BHGE shares. The remaining $6.9 billion will represent an unrealized loss on GE’s remaining 36.8% stake in BHGE.
FI’s claim that these losses are hidden is just plain false. In the MD&A section of its 19Q2 quarterly filing with the SEC, GE disclosed that it may recognize a significant loss on deconsolidation and that “based upon BHGE’s share price of $24.84 at July 26, the loss upon deconsolidation of [GE’s] interest would be $7.4 billion.”
While FI categorizes this “hidden” loss as indicative of fraud, in fact the loss is due to the relatively weak performance of all energy stocks, especially the oilfield services sector. BHGE’s stock has actually outperformed a major competitor, Halliburton (HAL), over this time frame; while matching the performance of Schlumberger (SLB).
FI goes on to assert that under FASB accounting standards, GE should not be consolidating BHGE in its financial statements. First, it claims that GE does not control BHGE. even though it holds a 50.4% equity stake. It then argues that under the accounting rules, either GE or BHGE should consolidate the operating partnership (i.e. BHGE, LLC), but not both.
Although I am not an expert in accounting for consolidations, I do know that majority voting control almost always supports (or requires) consolidation. FI’s first point, that GE does not control BHGE even though GE owns 50.4% of BHGE’s equity just seems way off base. In its financial statements, GE states clearly that it controls BHGE.
The second point, however, that either GE or BHGE (but not both) should be consolidating BHGE, LLC is worth exploring, even though I believe that FI does not present its case correctly.
Consolidation of BHGE, LLC by both BHGE and GE is permitted, I believe, because, as FI notes on page 98 of its report (which references Note 1 of BHGE’s 2018 annual report) , BHGE says that it controls BHGE, LLC, even though it has a minority ownership stake of 49.6% because it “exercises full control” over all of BHGE, LLC’s activities. Presumably, BHGE’s control of BHGE, LLC is spelled out legally in the BHGE, LLC partnership agreement.
A picture of the relationships among GE, BHGE and BHGE, LLC is given in the chart below, which was obtained from the S4 registration statement for the merger. “New Baker Hughes” is now “Baker Hughes, a GE Company” (BHGE) and “Newco LLC” is now “Baker Hughes, a GE Company, LLC (BHGE, LLC). GE’s equity stake in both BHGE and BHGE, LLC is now 50.4% (soon to be reduced to 38.5% (or 36.8%, if the underwriters’ overallotment is exercised.)
This arrangement allows BHGE to consolidate BHGE, LLC and yet GE also (indirectly) consolidates BHGE, LLC because it consolidates BHGE. Up until the closing of the recently announced BHGE share offering, GE has controlled BHGE by virtue of its 50.4% ownership stake and its ability to appoint a majority, five of the nine, of BHGE’s board of directors.
Admittedly, this accounting treatment (i.e. BHGE’s consolidation of BHGE, LLC) does result in an anomaly: BHGE in its own financial statements classifies GE’s stake in BHGE, LLC as a noncontrolling interest, even though GE owns a majority of BHGE, LLC. On the other hand, if BHGE were deemed to be not in control of BHGE, LLC, its ownership interest in BHGE, LLC would be reported as a single line item in its financial statements, which would almost certainly be unacceptable to BHGE shareholders.
The $10.5 Billion Non-Cash Insurance Charge. GE’s exposure to losses in its run-off insurance operations, which relate mostly to its long-term care reinsurance operations, have been a significant concern to investors, ever since the surprise announcement in January 2019, that the company would take a $9.5 billion pre-tax ($6.2 billion after-tax charge) and agree to make statutory reserve contributions of $15 billion over seven years.
At the end of 2018, GE’s North American Life and Health (NALH) business had insurance reserves of $35.6 billion under generally accepted accounting principles (GAAP) and $46.1 billion on a statutory basis (i.e. according to accounting principles utilized for (state) regulatory purposes).
The differences between GAAP and statutory accounting reflect different approaches to viewing the performance of insurance operations. GAAP treats the insurer as a going concern, while statutory accounting assumes that it is about to be liquidated. For example, statutory accounting requires sales costs to be expensed immediately, while GAAP permits them to be amortized over the life of the policy. Statutory accounting is therefore generally more conservative than GAAP.
In NALH’s case, the difference between GAAP and statutory reserves arises primarily from two factors: The first is differences in loss estimates. Under statutory accounting, the base assumptions for estimating future claims are required to be augmented with estimates of additional losses under moderately adverse conditions. These are known as provisions for adverse deviations or PADs. Consequently, the loss estimates under statutory accounting are more conservative. The second factor is differences in discount rates. For GAAP purposes, NALH’s discount rate for loss reserve testing was 6.07% in 2018, while its statutory reserve testing discount rate averaged roughly 4.75%. A lower discount rate increases the present value of estimated future claims, which is the key determinant of required reserves.
FI claims that the wide difference between GE’s GAAP and statutory reserves – $10.5 billion – is a concern and I agree. It notes that other insurers of long-term care policies do not have as wide a gap between their GAAP and statutory reserves. It also asserts that GE will have to recognize a $10.5 billion non-cash insurance charge in 2021 to eliminate this difference in reserves when a new insurance accounting standard goes into effect.
At its Insurance “Teach-In” in March 2019, the management of NALH acknowledged that the new accounting standard will “materially affect” GE’s financial statements. It said that the new standard was quite complex, especially for reinsurers (like GE). One major difference under the new standard is a change in the discount rate. Currently, insurers are allowed to use their expected investment yield as the discount rate. Under the new standard, the discount rate will equal the yield on single-A rated bonds with a maturity that matches the duration of the insurance liabilities. The new discount rate will almost certainly be lower, which by itself will result in an increase in GAAP reserves.
It is important to remember that the new standard affects GAAP accounting, but not statutory accounting. Accordingly, it will have no impact on statutory capital requirements. Although it looks like the new accounting standards will result in GE recognizing a large non-cash GAAP loss, which will narrow the difference between GAAP reserves and statutory reserves, there will be changes in other key assumptions, such as interest rates, before adoption that could offset some of the potential charge.
Despite the FI report’s assertions, the new accounting standard does not mandate the elimination of the difference between GAAP reserves and statutory reserves, as noted by a Citigroup analyst in a recent Barron’s article.
As GE also points out, the difference between the GAAP and statutory reserves will narrow over time, but the narrowing could take the form either of additional GAAP losses or possibly reductions in required statutory reserves depending upon whether actual claims experience tracks closer to the reserve assumptions under GAAP or under statutory accounting. For example, if claims experience tracks closer to the GAAP assumptions, required statutory reserves will decline over time and GE will be able to reclaim part of its capital contributions. On the other hand, if actual claims experience tracks closer to the more conservative assumptions used to calculate statutory reserves, GE will recognize additional non-cash losses for GAAP purposes. It will not have to make additional statutory capital contributions unless its claims experience turns out to be worse than the current statutory assumptions.
The FI report suggests that GE’s delay in recognizing the losses in its insurance operations is evidence of potential fraud and an indication that more losses are on the way. Given that the insurance operations had been in run-off for over a decade, it is shocking that the company would have to recognize so large a charge so late in the wind-down process. While GE undoubtedly used the flexibility afforded under GAAP and statutory accounting rules to delay the recognition of these losses, there has been no evidence to date that company or any of its employees committed fraud in this matter. The SEC is reportedly investigating GE’s accounting practices and could conceivably make such charges, but I will be surprised if it does. In any case, GE’s current management and its Board of Directors say that these events are in the past and do not reflect how the company will be managed going forward.
The FI Report’s Estimated $18.5 Billion Required Capital Contribution to Insurance. The FI report argues that GE’s long-term care insurance metrics are woefully deficient compared with those of Prudential Insurance. In order to match Prudential, therefore, GE would have to inject $18.5 billion into its insurance operations, including:
- $9.5 billion to bring its reserves in line with Prudential’s;
- $3.6 billion to account for the shortfall in annual premiums per policy that GE receives vs. Prudential; and
- $5.4 billion for other differences vs. Prudential, like the higher average age of a policyholder, the higher percentage of policies not currently paying premiums, the higher percentage of policies paying lifetime benefits and the inability of GE to raise rates because it is a reinsurer (and not a primary insurer).
Although the concept of comparing GE’s insurance metrics to another insurer’s seems reasonable, in this case it is not clear that it is a valid comparison because NALH is a reinsurer and operates under a different business model than Prudential, a primary insurer. (By way of analogy, a reinsurer is to a primary insurer as a stock option is to common stock. In essence, reinsurers sell puts to primary insurers.)
Thus, reinsurers typically receive lower premiums per policy than primary insurers because they are insuring only a portion of the risk. They also have lower operating costs, because primary insurers must maintain the sales and administrative infrastructure to interface with their individual policyholders.
While comparing the statutory financial statements of NALH and Prudential’s long-term care business is a relatively straightforward exercise, I suspect that neither entity provides sufficient detail about the terms of their (primary or reinsurance) contracts to make it possible to prepare reasonably accurate financial projections. For example, it is possible (although apparently not likely) that NALH has loss limits on some of its reinsurance contracts. Likewise, both NALH and Prudential recognize reinsurance recoverables, but the amount of recoverables can change over time based upon claims experience, changes in contract terms and the purchase (or sale) of additional reinsurance. FI in its report calls upon GE to disclose NALH’s actuarial assumptions. which would allow it and other interested parties to improve their financial forecasts and get a better handle on sensitivities.
The FI report does not offer any analysis to support its implicit claim that that the $30.4 billion of statutory long-term care reserves is inadequate. It ignores the discussion and analysis that GE provides in its 2018 annual report that highlights the more conservative assumptions contained in the determination of statutory reserves. It also ignores the fact that the Kansas Insurance Dept. (KID), NALH’s regulator, approved that statutory reserve assessment.
For its part, KID took the unusual step of issuing a press release about the FI report to refute its conclusions. In the press release, KID noted that FI stands to profit from a decline in GE’s share price and issued the following assessment:
“After initial review, components of this particular report appear fairly simplistic in nature and don’t appear to incorporate certain technical reserve considerations that were considered during the Department’s most recent financial examination as of December 31, 2017 and the annual analysis review of the confidential Actuarial Opinion Memorandum at December 31, 2018.”
Although the $18.5 billion future capital contribution assessment seems clearly to be both simplistic and biased, it is not unreasonable to conclude, based upon the company’s own disclosures, that GE’s reserve requirement assumptions are not conservative and therefore that it may indeed have to make additional capital injections most likely in excess of $1 billion in the future.
In its 2018 reserve adequacy testing, NALH recognized $2.0 billion of GAAP reserve deficiencies as it revised its assumptions to reflect adverse experience in incurred and paid claims during the year; but this was entirely offset mostly by an increase in the discount rate due to expectations of higher returns on its investment portfolio and also a modest increase expected future premium increases. On a statutory basis, a $1 billion reserve deficiency was likewise offset by gains from higher future premium expectations and an increase in the discount rate.
While the 2019 reserve adequacy testing is currently underway, it appears that GE will have to recognize a GAAP loss this year that will probably be in excess of $1 billion. By my estimates, U.S. Treasury rates are down about 75 basis points over the past year. GE has disclosed that a 25 basis point decline in its discount rates (for both GAAP and statutory purposes) would require a $1 billion increase in estimated future policy benefit reserves. Still, it is not clear that the NALH’s discount rates will rise in lockstep with Treasurys.
There may be some offsets to the increase in reserves required by a lower discount rate. Year-to-date (through June 30), incurred insurance claims were down 2.3% to $981 million, while paid claims declined 8.9% to $824 million. If those percentages hold up for the full year, GE may be able to offset at least part of the negative impact of the rising discount rate with gains from the slight improvements in claims experience.
Even so, some industry watchers see continued headwinds for the long-term care sector. For example, Fitch recently released a report that argues that assumptions about future claims are still not sufficiently conservative. The ratings agency focuses especially on morbidity improvement (i.e. the assumption that the health of the insured population will improve over time which would delay long-term care claims). It says that GE’s assumption of a 1.25% annual improvement in morbidity, while not as aggressive as some insurers, is still higher than the 0% improvement assumption of others, which appears more realistic. In its 2018 annual report, GE discloses that a reduction of its morbidity improvement assumption to zero would require a $3.7 billion increase to future policy benefit reserves.
This annual reserve testing process is more consequential for GE because it does not have sufficient available capital to adopt more conservative assumptions. If it were able to contribute more capital more quickly to NALH, the associated increase in reserves would give it a greater cushion to absorb adverse claims experience without having to record losses on its income statement. As a result, annual reserve adjustments are likely to continue to add volatility to GE’s earnings going forward.
In addition, the FI report does not recognize the steps that NALH is taking to limit its exposure. These include pursuing rate increases or benefit reductions where possible (and working with its primary insurer customers to make sure that they pursue every opportunity to raise rates); The report should have addressed these important potential mitigating factors explicitly to support its $18.5 billion capital shortfall assessment.
Other Problems. The FI report levels additional charges about problems in GE’s financial position and in its financial reporting that it asserts are evidence of fraud. Based upon my analysis, these charges are at best unsubstantiated or at worst patently false.
Working Capital Deficiency: The report claims that, excluding BHGE, GE had a working capital deficiency of $20.2 billion and a current ratio of 0.67 at the end of 2018, and asserts this this is a red flag for potential liquidity problems and insolvency. It also accuses GE of hiding this problem by incorrectly including the results of BHGE in its consolidated financial statement.
What the report does not state, however, is that the working capital deficit arises because of a $20.9 billion liability for progress collections and deferred income. The company discloses in Note 10 of its financial statements that it receives cash in advance of delivery under ordinary commercial payment terms for milestone payments on orders of customized equipment and also to reserve production slots on big ticket items, such as wind blades. In this way, GE is in the enviable position of having its industrial customers finance (at a zero percent interest rate) a significant portion of its working capital requirements.
Of course, that does not prove that GE does not have a working capital problem. But to make that assessment, an analyst would have to have a good understanding of the cash conversion cycle in each of GE’s businesses. This would allow him or her to quantify GE’s consolidated working capital requirements and compare those requirements to its current working capital position. However, like most companies, I believe that GE does not provide sufficient disclosure to allow an analyst to make that determination with an acceptable degree of precision.
Yet, we can get a sense of possible deterioration in GE’s working capital position by seeing how it changes over time. I calculate that GE’s working capital deficit (excluding BHGE) has improved from negative $34.9 billion in each of 2016 and 2017 to negative $20.7 billion in 2018. The improvement is due to a reduction in short-term liabilities, including lower short-term debt, lower progress collections and deferred income and a reduction in other liabilities. Much of this has been driven by asset sales.
The FI report’s failure to disclose these mitigating factors is clear indication of bias in its presentation and assertions. I assume that Mr. Markopolos did look at the trend in working capital over the past few years, especially since he claims to have read all of GE’s annual reports from 2002 to 2018. Had he offered an analysis of why the working capital deficit should still be considered a problem, even after adjusting for the uniqueness of GE’s cash conversion cycle and the recent historical trend, I believe that his assertions would be more credible.
Business Segment Financial Reporting. The FI report argues that GE has been running a decades long accounting fraud by only providing top line revenues and bottom line profits for its business segments. This presentation format leaves out cost of sales, SG&A expenses, R&D expense and corporate overhead allocations. The report also notes that GE changes its financial statement reporting formats for its business segments (i.e. the number of segments and/or how they are defined) every few years, making it difficult to compare performance across years.
Of course, Mr. Markopolos is correct in noting that GE only provides revenues and profits for its business units. But he also knows very well that nearly all public companies report their business segment results this way. These disclosures are all that is required under GAAP. I cannot think of a single company that gives expense line item breakdowns for its business units. (There may be some, but they are clearly in the minority.)
GE also does make frequent changes to how it defines its business segments. Many of the changes are driven by acquisitions and divestitures. Some are driven by bona fide organizational changes. (For example, Renewable Energy was separated from the Power & Water segment in 2015). But it is also likely that GE does, as Mr. Markopolos asserts, make changes to its business segments from time to time for other purposes, including to make multi-year performance comparisons more difficult.
GE’s segment revenues and profits have also changed significantly in recent years as a result of changes in accounting standards, especially because of the adoption of ASC 606, which governs the recognition of revenues from contracts with customers. For many years, GE has used contracts extensively in its relationships with customers; so it is not a surprise to see the recently adopted standard have a significant impact across all of GE’s business segments.
The FI report takes GE to task for restating 2017 revenues and profits by business segment (pgs. 126 and 127) and for restating its 2017 consolidated balance sheet (pgs. 128 and 129). The report does not mention, however, that the company filed an 8-K on April 13, 2018 that described these changes in detail, most of which were associated with the adoption of ASC 606 and other standards and also U.S. tax reform. Of course, it is possible that there was some “hanky-panky” associated with the changes outlined in that 8-K filing; but identifying and proving that would be very difficult, if not impossible.
I believe that the consolidated financial statements matter most to companies and their accountants for attestation purposes. Companies may not want to provide an accurate picture of segment performance for competitive and other reasons. The changes in the number of segments and segment definitions over the years by GE are a red flag, but they are not proof of fraud. Although GE’s business segments have changed frequently over the years, its consolidated financial statements have been remarkably consistent from year to year, more so than most companies.
Summary: Of the three charges that the FI report argues are yet to come, #1 is correct because GE will record a loss of about $9.4 billion upon deconsolidating BHGE.
GE may also very well face a charge of up to $10.5 billion to narrow the difference between NALH’s GAAP and statutory reserves over time, much of which will likely be recognized upon the adoption of the new insurance accounting standard in 2021. Conceivably, GE could avoid much of the $10.5 billion charge if its claims experience tracks closer to the GAAP estimates or it finds other ways to reduce its potential liability, but industry buzz suggests that long-term care loss assumptions industrywide are understated.
As for the third charge – the estimated $18.5 billion capital contribution to shore up future policy benefit reserves, FI’s estimates are unsupported at best. Based upon GE’s sensitivity analysis, recent industry trends and commentary from the credit rating agencies, I think that the company may eventually face an additional capital contribution in excess of $1 billion and perhaps as high as $10 billion, but the actual amount will depend upon a lot of variables, including the course of interest rates.
Taken together, the first two charges – the $9.4 billion BHGE deconsolidation charge and the $10.5 billion difference between GAAP and statutory insurance reserves – are non-cash. That would of course affect GE’s leverage calculation on a book value basis, but the FI report does not consider potential offsets, including a likely gain well in excess of $1 billion upon the completion of the pending sale of GE’s Life Sciences business to Danaher.
Although the debt-to-book capitalization ratio is an important indicator of leverage, what is critical is GE’s ability to service the debt – i.e. make interest and principal payments on a long-term basis. For now, GE has been focused on reducing its debt and planned asset sales should allow it to make additional progress on that score, but the asset sales are also reducing the company’s earnings base. It seems that some improvement in profitability will be necessary over time in order for GE to maintain its investment grade debt rating.
Finally, the FI report makes sensational claims about GE’s perpetration of accounting fraud. Those claims are just not supported by the evidence offered in the report.
In fact, the report is full of errors, inaccuracies and exaggerations. On the surface, it would be reasonable to question the competency of Mr. Markopolos. But he is an experienced investment professional, a former chairman of the CFA Society of Boston and a certified fraud examiner who tells us that he teaches advanced forensic accounting to certified fraud examiners.
The only way, it seems to me, to reconcile the report with the man who prepared it is to conclude that many of the errors and inaccuracies were deliberate. In the report, Mr. Markopolos said that he avoided revealing every technique that he used to reach his conclusions; but it seems to me that he is using this report as advertising to encourage investors to contact him to find out what he has really learned in his six month analysis of GE. He may also be angling for investors to retain him and his firm to monitor GE’s future performance and financial reporting practices.
Although, as I have noted, the FI report is deeply flawed, I believe that it should not be ignored, especially coming so soon after the announcement that GE is seeking a replacement for CFO Jamie S. Miller. New management, led by CEO H. Lawrence Culp, asserts that things have changed and the company is being managed differently now. Certainly, the abatement of the steady series of big negative surprises that decimated GE’s share price from 2017 to mid-2019 has helped investors and analysts (including me) become more optimistic about the company’s recovery, even in a “reset” year. Still, Mr. Markopolos’s report reminds us that we must remain vigilant because the pressure on the management of publicly-traded companies to generate superior stock price performance at almost any cost is unrelenting.
September 15, 2019
Stephen P. Percoco
839 Dewitt Street
Linden, New Jersey 07036
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