1. Puerto
Rico
Capital
Structure
www.accelerant.biz Page
1
of
4
Accelerant
LLC
Underlying
Ratings
on
June
10,
2015
Government
Bond
Issuers Outstanding Primary
Security
Source Gov't
Backed Local Taxation Insurance S&P Moody's Fitch 6.26.15
Price Notes
General
Obligation
Unlimited $13,957
Full
faith,
credit,
and
taxing
power
of
the
Commonwealth
Yes Yes
For
PR
residents:
Exempt
from
PR
income
tax;
exempt
from
PR
gift
and
estate
tax;
For
US
residents:
subject
to
federal
taxation;
silent
on
state
and
local
taxation.
Various:
None;
National;
Assured
CCC+ Caa2 B 63.100
COFINA 16,382
Senior
Lien
A
portion
of
the
sales
tax
imposed
by
the
Commonwealth
No Yes
For
PR
residents:
Exempt
from
PR
income
and
withholdings
taxes,
including
the
AMT;
exempt
from
gift
and
estate
tax;
For
US
residents:
subject
to
federal
taxation,
exempt
from
state
and
local
tax.
Various:
None,
Ambac,
AGM,
ACA,
Assured
CCC+ Caa2 B 64.000
First
Subordinate
Lien
Sales
tax
revenue
remaining
after
the
payment
of
debt
service
on
Senior
Bonds.
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
CCC+ Caa3 B 64.000
Government
Development
Bank 8,423
General,
Unsecured,
Senior
Obligations;
neither
the
faith,
credit,
or
taxing
power
of
the
Commonwealth
nor
its
political
subdivisions
will
be
pledged
for
payment
No Yes
For
PR
residents:
Exempt
from
PR
income
and
withholdings
taxes,
including
the
AMT;
exempt
from
gift
and
estate
tax;
For
US
residents:
subject
to
federal
taxation,
exempt
from
state
and
local
tax.
Various:
None,
National
CCC Ca -‐ 43.000
Public
Finance
Corporation
(PRPFC) 2,214
Commonwealth
Appropriation
Bonds
Pledged
Revenues,
consisting
of
payments
of
principal
of
and
interest
on
the
notes
required
to
be
deposited
to
the
credit
of
the
Bond
Service
and
Redemption
Accounts
established
under
the
Trust
Agreement
and
any
other
moneys
deposited;
not
an
obligation
of
the
Commonwealth
or
any
of
its
political
subdivisions
or
public
instrumentalities
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
Various:
None,
AMBAC,
Assured,
CIFG,
AGM
CCC+ Ca -‐ 43.123
Commonwealth
Appropriation
Bonds,
Series
1998A
Pledged
Revenues,
consisting
of
payments
of
principal
of
and
interest
on
the
notes
required
to
be
deposited
to
the
credit
of
the
Bond
Service
and
Redemption
Accounts
established
under
the
Trust
Agreement
and
any
other
moneys
deposited;
not
an
obligation
of
the
Commonwealth
or
any
of
its
political
subdivisions
or
public
instrumentalities
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
Ambac AA+ Aaa -‐ 117.049
Defeased
to
maturity
Total
Government
Issuers $40,976
($
in
millions)
2. Puerto
Rico
Capital
Structure
www.accelerant.biz Page
2
of
4
Accelerant
LLC
Revenue
Bond
Issuers Outstanding Primary
Security
Source Gov't
Backed Local Taxation Insurance S&P Moody's Fitch 6.26.15
Price Notes
PR
Electric
Power
Authority
(PREPA) 9,176
Revenues
of
the
Electric
System
after
payment
of
Current
Expenses
of
the
Authority
and
any
reserve
including
Sinking
Fund
No Yes
For
PR
residents:
Exempt
from
PR
income
tax;
exempt
from
PR
gift
and
estate
tax;
For
US
residents:
subject
to
federal
taxation;
silent
on
state
and
local
taxation.
Various:
None,
AGM,
FGIC,
National
CCC-‐ Caa3 CC 50.915
PR
Highways
and
Transportation
Authority
(PRHTA)
6,464
GARVEES
Payments
of
Federal
Transportation
Funds
in
amounts
equal
to
Bond
Payments
for
Grant
Anticipation
Bonds
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
Various:
None,
FGIC,
National,
FGIC,
CIFG,
Assured
CCC+ Ca -‐ 69.250
Highway
Revenue
Bonds
1968
Resolution
Revenues
and
all
other
moneys
held
for
the
credit
of
the
1968
Sinking
Fund
(gas
and
oil
excise
taxes,
vehicle
license
fees,
tolls,
and
earnings
on
deposits)
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
Various:
None,
FGIC,
National,
FGIC,
CIFG,
Assured
CCC+ Ca -‐ 72.250
Transportation
Revenue
Bonds
Taxes
on
crude
oil,
unfinished
oil
and
derivative
products
under
the
1998
Resolution;
tolls
and
other
charges
imposed
by
the
authority
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
Various:
None,
FGIC,
Ambac,
Assured,
National
CCC+ Caa3 -‐ 64.000
Subordinate
Transportation
Revenue
Bonds
1968
Resolution
Revenues
and
1998
Resolution
Revenues
(gas
and
oil
excise
taxes,
vehicle
license
fees,
tolls,
and
earnings
on
deposits)
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
Various:
None,
FGIC CCC+ Ca -‐ 40.099
PR
Aqueduct
and
Sewer
Authority
(PRASA)
3,677
Revenue
Bonds
Gross
operating
revenue
of
the
Authority
prior
to
Current
Expenses
(net
revenue
prior
to
2012
Resolution)
No Yes
For
PR
residents:
Exempt
from
PR
income
tax;
exempt
from
PR
gift
and
estate
tax;
For
US
residents:
subject
to
federal
taxation;
silent
on
state
and
local
taxation.
Various:
None,
Assured
CCC+ Caa2 B 67.025
Guaranteed
Bonds
Net
revenue
of
the
Authority;
Good
faith
and
credit
of
the
Commonwealth
Yes
For
PR
residents:
Exempt
from
PR
income
and
withholdings
taxes,
including
the
AMT;
exempt
from
gift
and
estate
tax;
For
US
residents:
subject
to
federal
taxation,
silent
on
state
and
local
taxation.
None CCC+ Caa2 B 64.750
PR
Public
Buildings
Authority 4,255
Pledge
of
rental
revenue
of
leased
facilities;
Good
faith,
credit,
and
taxing
power
of
the
Commonwealth
Yes Yes
For
PR
residents:
Exempt
from
PR
income
tax;
exempt
from
PR
gift
and
estate
tax;
For
US
residents:
subject
to
federal
taxation;
silent
on
state
and
local
taxation.
Various:
None,
Ambac,
AGM,
FGIC,
National,
XLCA,
CIFG
CCC+ Caa2 B 57.211
Total
Revenue
Bond
Issuers $23,572
3. Puerto
Rico
Capital
Structure
www.accelerant.biz Page
3
of
4
Accelerant
LLC
Non-‐Recourse
Bond
Issuers Outstanding Primary
Security
Source Gov't
Backed Local Taxation Insurance S&P Moody's Fitch 6.26.15
Price Notes
PR
Employees
Retirement
System 2,770
Employer
Contributions
made
after
the
date
of
issuance
of
the
bonds.
No Yes
For
PR
residents:
Exempt
from
PR
income
tax;
exempt
from
PR
gift
and
estate
tax;
For
US
residents:
subject
to
federal
taxation;
silent
on
state
and
local
taxation.
None CCC+ Ca B 43.375
Infrastructure
Financing
Authority
(PRIFA)
2,135
Revenue
Bonds
(Ports
Authority
Project)
Full
faith
and
credit
of
the
Ports
Authority;
pledged
loan
repayments.
A
Letter
of
Credit
from
the
GDB.
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
Various:
None,
Assured,
FGIC,
Ambac,
FGIC,
CIFH,
B-‐ Ca -‐ 93.585
Special
Tax
Revenue
Bonds
Federal
Excise
Tax
imposed
on
Rum
and
other
articles
produced
in
Puerto
Rico
and
sold
in
the
United
States
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
Various:
None,
Ambac,
FGIC
CCC+ Ca -‐ 34.420
Children's
Trust 1,389
Tobacco
Settlement
Revenues
made
by
Original
Participating
Manufacturer's
(OPM's)
under
the
Master
Settlement
Agreement
(MSA);
OPM's
consistent
of
tobacco
companies
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
None BBB-‐ Ba1 BBB 98.756
Housing
Finance
Authority
(PRHFA) 1,005
Collateralized
by
pool
of
residential
mortgage
loans
secured
by
first
mortgages
over
qualifying
properties
No Yes
For
PR
residents:
Exempt
from
PR
income
tax;
exempt
from
PR
gift
and
estate
tax;
For
US
residents:
subject
to
federal
taxation;
silent
on
state
and
local
taxation.
None A+ -‐ A 106.155
Industrial,
Tourist,
Educational,
Medical,
and
Environmental
Control
Facilities
Financing
Authority
(AFICA)
976
Revenues
from
specific
project
via
Debt
Service
Reserve
Fund
No Yes
For
PR
residents:
Exempt
from
PR
income
tax;
exempt
from
PR
gift
and
estate
tax;
For
US
residents:
subject
to
federal
taxation;
silent
on
state
and
local
taxation.
Various:
None,
National,
ACA
CCC+ -‐ -‐ 60.930
Municipal
Finance
Agency
(MFA) 485
Payments
of
principal
of
and
interest
on
general
obligation
municipal
bonds
and
notes
and
investment
income
from
the
Reserve
Account
and
the
Acquisition
Fund
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
Various:
None,
AGM,
Assured,
CIFG,
CCC+ Caa3 -‐ 91.983
University
of
Puerto
Rico 452
Tuition
and
student
fees,
rentals
and
other
charges
for
the
right
of
use
or
occupancy
of
the
facilities
of
the
University
of
a
capital
nature
financed
by
bonds,
net
bookstore
receipts,
interest
on
investments,
overhead
allowances
on
federal
research
projects,
other
income,
debt
service
grant
programs
of
U.S.
Government
or
any
agency
No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
Various:
None,
National
CCC+ Caa3 -‐ 74.000
Convention
Center
District
Authority
(PRCCDA)
409 Hotel
occupancy
tax
revenues No
Federal,
state,
and
local
tax
exempt;
Not
an
AMT
tax
preference
item
Various:
CIFG,
Ambac,
FGIC
CCC+ Ca -‐ 77.889
Industrial
Development
Company
(PRIDCO)
184
Gross
revenues
received
by
PRIDCO
from
revenue-‐producing
real
properties,
machinery,
equipment,
first
mortgages
on
real
property,
or
first
mortgage
bonds,
which
are
specified
by
PRIDCO
No Yes
For
PR
residents:
Exempt
from
PR
income
tax;
exempt
from
PR
gift
and
estate
tax;
For
US
residents:
subject
to
federal
taxation;
silent
on
state
and
local
taxation.
Various:
None,
National
CCC+ Caa2 -‐ 65.000
Total
Non-‐Recourse
Bond
Issuers $9,805
4. Puerto
Rico
Capital
Structure
www.accelerant.biz Page
4
of
4
Accelerant
LLC
Notes Primary
Security
Source,
Government
Backing,
and
Taxation
information
obtained
from
review
of
Official
Statements.
Outstanding
amounts
obtained
from
Bloomberg.
Ratings
obtained
from
Bloomberg
Primary
Security
Source,
Government
Backing,
Taxation,
and
Insurance
represent
the
general
case.
There
are
over
2,000
Puerto
Rico
Bond
Issues
outstanding
and
exceptions
abound.
"Local"
here
means
that
some
local
bonds
have
been
issued
by
that
issuer.
Local
bonds
are
generally
tax
exempt
for
bona
fide
Puerto
Rico
residents
under
Section
937
of
the
Code,
but
for
U.S.
residents
are
subject
to
U.S.
Federal
Income
tax
under
Section
103(a)
of
the
Code.
Within
some
issues,
local
bonds
will
comprise
only
certain
Series.
June
26,
2015
Price
is
the
most
recent
price
and
may
not
have
traded
on
June
26,
2015.
Prices
will
vary
by
issue
specifics,
including
insurance
and
other
factors.
Data
obtained
from
Bloomberg
and
EMMA.
About
Accelerant
Accelerant
is
a
securities
litigation
consulting
firm
sepcializing
in
large
and
complex
cases.
We
bring
broad
and
deep
securities
and
regulatory
knowlede
as
well
as
analytic
rigor
to
our
work.
Our
experts
have
industry,
academic,
and
regulatory
experience
which
they
bring
to
bear
on
all
client
matters.
Accelerant's
clients
value
our
ability
to
communicate
complex
ideas
simply,
our
reputation
for
unbiased,
independent
and
high
quality
analysis,
and
our
commitment
to
a
highly
responsive
work
ethic.
Accelerant
is
headquartered
in
New
York
City.
Contact
For
further
information,
please
contact:
Jack
Duval
|
Managing
Partner
Accelerant
845.605.1007
jack@accelerant.biz