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Bank of Queensland - leading indicators point to more bad debt downside risk 20121023.pdf
1. Stock Focus
Bank of Queensland (BOQ)
1
LEADING INDICATORS POINT TO MORE BAD DEBT DOWNSIDE RISK
RECOMMENDATION : NEGATIVE
WHAT’S NEW?
Underlying impaired loans are increasing. We look through the
decline in “headline” impaireds and observe that (i) <30 day overdue
stressed commercial loans increased 12% from FY11 to FY12. Table 2.
Charts 1-2; and (ii) impaireds/total loans increased in 86% of the loan
portfolio. Chart 2.
Broad-based asset quality deterioration emerging. The key driver
of impaired loan growth in 2H12 was loans <$5m, which increased 18%
to $178m and comprised 88% of new impaireds. Table 1. Chart 3.
Provision coverage is deteriorating. Collective provision/total loans
is down from 0.94% to 0.77% in 2H12, with declining CP coverage in
home loans, lines of credit and leasing segments (all of which are
vulnerable to further cyclical downside). Tables 3-4.
Dividend downside risks emerging. We expect the payout ratio to
come under increasing scrutiny, with the Board expected to review the
former management’s 50-60% payout ratio target.
WHAT’S CHANGED?
FY13F EPS down -8% to 79cps; FY14F EPS down -20% to 79cps.
FY13F DPS down -10% to 52cps; FY14F DPS down -9% to 52cps.
WHAT NOW?
Key risks include:
Cyclical risks - loan loss rates exceed our estimates as the Queensland
economy deteriorates.
Structural risks – (i) margins vulnerable to increased competition
(in deposit and lending markets); (ii) broker-driven loan growth
strategy outside Qld raises medium-term asset quality concerns; and
(iii) uncompetitive funding structure without offsetting pricing
power driven by the sector’s lowest credit rating of BBB+ (vs
comparable BEN of A- and major banks if AA-).
We remain Negative, with blended valuation $6.72 (prev. $6.51).
Trading Data
Last Price $7.46
12 month range $6.15 - $8.30
Market Cap $2,310m
Free Float $2,003m (87%)
Avg. Daily Volume 1.2m
Avg. Daily Value $9.3m
12 month return (historical) 1.1%
“Key management target” of 1.0x system
growth in Retail and Business in FY13F and
1.2x Retail system and 1.5x Business
System in FY15F.
Vulnerable to further margin downside as
BBB+ rating results in uncompetitive
wholesale funding compared to AA- rated
major banks and A- regional bank BEN.
Also, BOQ has the sector’s lowest deposit
funding mix of 57%.
Earnings Forecasts
Yr to August 09A 10A 11A 12E 13E 14E
E&P Cash EPS (¢) 110.5 92.5 74.3 (6.8) 78.7 78.8
Basic Cash EPS (¢) 110.5 92.5 74.3 (6.8) 78.7 78.8
Reported EPS (¢) 75.9 80.6 68.0 (10.1) 76.6 76.7
E&P Cash EPS Growth (%) 0.9 (16.2) (19.7) N/A N/A 0.2
DPS (¢) 52.0 52.0 54.0 52.0 51.5 51.9
Yield (%) 7.0 7.0 7.2 7.0 6.9 6.9
Grossed-Up Yield (%) 9.9 9.9 10.3 9.9 9.8 9.9
Franking (%) 100% 100% 100% 100% 100% 100%
E&P Cash Multiple (x) 6.8 8.1 10.0 - 9.5 9.5
Price/Book (x) 0.7 0.7 0.7 0.8 0.8 0.8
PEG Ratio (x) (0.2) (0.1) 1.7
Net Interest Margin (%) 1.6 1.6 1.6 1.7 1.6 1.6
Return on Average Assets (%) 0.6 0.5 0.4 0.0 0.6 0.5
ROE (%) 10.8 8.5 6.6 (0.6) 9.5 9.0
Valuation (blended) 6.72
George Gabriel, CFA
ggabriel@evansandpartners.com.au
October 23, 2012
+61 3 9631 9853
2. 2
UNDERLYING ASSET QUALITY AND PROVISION COVERAGE IS DECLINING
Historically, the time to buy banks working through a bad debt cycle is when the rate of
impaired loan growth slows (ie. “negative second derivative”). However, in the case of BOQ,
we look through the headline decline in impaired loan growth and observe evidence
of underlying asset quality deterioration:
(i) Underlying impaired loans are increasing, despite the decline in “headline” impaireds.
(ii) Broad-based deterioration in the loan book is emerging.
(iii) Leading indicators of asset quality raise “red flags”.
(iv) Provision coverage is deteriorating.
(v) The Queensland macroeconomic backdrop is deteriorating.
We explain these points in more detail below.
(i) Underlying impaired loans are increasing
BOQ highlighted that its total impaired asset balance declined from $578.7m in 1H12 to
$525.3m in 2H12. Chart 1. However, the underlying trends are:
Total impaireds increased to $781.5m (up 35.0%) prior to property realisations and
the sale of ~$156m of impaired property to Goldman Sachs on 17 July 2012 (reported to
be at a 62% discount to face value). Chart 1.
Impaireds/total loans increased in 86% of the loan portfolio: housing (60% total
loans), lines of credit (15% total loans) and leasing (11% total loans). Lines of credit
arrears increase was significant, up from 0.88% to 1.79% of total loans. Chart 2.
CHART 1: IMPAIRED LOAN BALANCES
Source: BOQ Presentation
3. 3
CHART 2: IMPAIRED LOAN TRENDS
Source: EAP Research
(ii) Broad-based loan book deterioration
BOQ’s impaired loan cycle has progressed from large exposures to a more broadly-
based portfolio deterioration, indicating that the macroeconomic cycle could drive
further bad debts across these loan portfolios.
88% of new impaired loans are <$5m in value in 2H12 (compared to 30% in 1H11),
which increased by 18% in 2H12. Table 1. Chart 3.
Management has guided that two-thirds of the next period’s bad debts will be from their
retail loan book (housing and lines of credit).
TABLE 1: IMPAIRED LOAN TRENDS
Source: EAP Research
4. 4
CHART 3: NEW IMPAIRED LOANS
Source: BOQ Presentation
(iii) Leading indicators of asset quality
The key “red flag” is that commercial loans less than 30 days past due are
increasing, up 12% in FY12 (vs FY11). This is a key area to watch. Table 2.
TABLE 2: ASSET QUALITY LEADING INDICATORS
BOQ stressed loans trend analysis (A$m) FY10 FY11 FY12
% growth
FY11-
FY10
% growth
FY12-
FY11
Retail 826 677 652 -18% -4%
Commercial 246 207 231 -16% 12%
Less than 30 days past due (DPD) 1,072 884 883 -18% 0%
Retail 139 254 163 82% -36%
Commercial 131 108 93 -17% -14%
31 to 90 days past due (DPD) 270 362 256 34% -29%
Retail 186 318 232 71% -27%
Commercial 142 165 115 16% -30%
More than 90 days past due (90 DPD) 327 483 347 47% -28%
Total loans past due but not impaired 1,669 1,729 1,486 4% -14%
Impaired loans 148 444 525 201% 18%
Loans past due and impaired 1,817 2,173 2,011 20% -7%
Gross loans and advances 32,439 34,065 35,005 5% 3%
(90 DPD + impaired)/gross loans 1.46% 2.72% 2.49%
(Past due + impaired)/gross loans 5.6% 6.4% 5.7%
Source: Company Reports; EAP Research
5. 5
(iv) Provision coverage is deteriorating
We believe that there is potential for increased provisioning because (i) underlying impaireds
are increasing, and (ii) provision coverage is declining.
Collective provision/total loans down from 0.94% in 1H12 to 0.77% in 2H12, with
reduced coverage in home loans, lines of credit and leasing segments. Tables 3-4.
Specific provision coverage down from 43.0% to 41.9%. BOQ reportedly sold some
distressed property loans to Goldman Sachs at a 62% discount to face value. If this
discount is applied to BOQ’s existing impaired commercial loans, this implies ~$48m in
additional losses.
TABLE 3: BOQ LOAN PROVISIONING PER SEGMENT AS AT 2H12
Segment Description
Value
(A$bn)
% total
loans
%
impaired
Collective
Provision
(A$m)
Specific
Provision
(A$m)
Impaired
loans
(A$m)
Specific/
impaired
(%)
CP/net
loans (%)
Total
Provision/Loans
ratio
Home Loans 60% Qld, 16% Vic, 13% NSW, 8% WA 20.3 59.5% 0.61% 26 41.3 123.9 33.3% 0.13% 0.33%
Lines of credit Secured by resi mortgages 5 14.7% 1.79% 14.1 32.7 89.5 36.5% 0.29% 0.94%
Commercial SME segment 5.1 15.0% 5.58% 121.1 127.9 284.4 45.0% 2.51% 4.88%
Leasing BOQ Equipment Finance 3.7 10.9% 0.71% 26.9 17.6 26.3 66.9% 0.73% 1.20%
Provision overlays (GRCL) 70.2
Total 34.1 100.0% 258.3 219.5 524.1 41.9% 0.77% 1.40%
Source: EAP Research
TABLE 4: BOQ LOAN PROVISIONING PER SEGMENT AS AT 1H12
Segment Description
Value
(A$bn)
% total
loans
%
impaired
Collective
Provision
(A$m)
Specific
Provision
(A$m)
Impaired
loans
(A$m)
Specific/
impaired
(%)
CP/net
loans (%)
Total
Provision/Loans
(%)
Home Loans 60% Qld, 16% Vic, 13% NSW, 8% WA 19.4 57.7% 0.46% 37.9 27.6 88.6 31.2% 0.20% 0.34%
Lines of credit Secured by resi mortgages 5.2 15.5% 0.88% 22.8 19.1 45.5 42.0% 0.44% 0.81%
Commercial SME segment 5.3 15.8% 8.00% 156.6 187.9 424.2 44.3% 3.21% 6.50%
Leasing BOQ Equipment Finance 3.7 11.0% 0.53% 20.3 13.9 19.7 70.6% 0.55% 0.92%
Provision overlays (GRCL) 74.4
Total 33.6 100.0% 312 248.5 578 43.0% 0.94% 1.67%
Source: EAP Research
Furthermore, we believe the disclosed “key management targets” of 28-34bps in bad debts to
gross loans in FY13F normalising to 20bp in FY15 is optimistic, given it will likely take more
time for changes to risk appetite at the front end of the book to work through the whole book
and reduce the average portfolio loss rates. Chart 4.
6. 6
CHART 4: KEY MANAGEMENT TARGETS
Source: BOQ Presentation
(v) Queensland downside risks prevail
The CEO has previously referred to stresses in the SE Queensland property market, with price
declines of 50-60%. Refer EAP Note, “SE Queensland Property – Slowing One Day...Declining
the Next”, dated 9 October 2012.
At the FY12 results analyst briefing, he commented that whilst property clearance rates were
improved, it is still too early to call a market bottom.
7. 7
BLENDED VALUATION
Our $6.72 blended valuation reflects the risks of BOQ’s narrow business and geographical mix,
near-term credit quality and operational concerns and long-term structural funding
disadvantages. Table 5.
Our 30% discount to the price/book value and 9.0x FY13F PE multiple are consistent with
depressed trading historical multiple ranges and have been selected to incorporate suitable
margin of safety discounts which we believe are warranted before investors should consider
investing in BOQ. Chart 5-6.
TABLE 5: BLENDED VALUATION
Method Key Inputs Value ($)
Discounted cash flow 11% Discount Rate $6.92
Price/book value 0.70x FY13F and FY14F $6.57
Dividend yield/bond yield 1.6x 5.5% bond yield $6.26
PE valuation FY13F PE of 9.0x $7.12
Average $6.72
Source: EAP Research
CHART 5: HISTORICAL PRICE/EARNINGS CHART 6: HISTORICAL PRICE/BOOK MULTIPLE
Source: Factset
8. 8
FY12 RESULT SUMMARY
Key result highlights are:
Net interest income increased +1.4% as average interest earning assets
increased +1.35% and net interest margin remained steady at 1.66% over FY12.
Table 6. NIM will benefit in 1H13 from the full period impact of BOQ’s +25bp out-of-cycle
rate rises on the RBA rate cuts in May (-50bp), June (-25bp) and October (-25bp).
Reasonable +2.8% growth in operating income, driven by other banking income
(+10.8%, fees and commissions; BOQ Finance); and net insurance income (+4.5%).
Disappointing cost performance, with +14.5% expense growth and a 55.3% cost-to-
income ratio, driven by increased employee costs (+11.3%, FTE -10 to 1,448), IT costs
and occupancy costs. Negative “jaws” for two consecutive halves is a concern (-
6.4% and -11.7% in 1H12 and 2H12).
Capital position largely stable - at 8.5% core tier 1 capital (versus 1H12 pro-
forma 8.6%), at the top end of peer range.
TABLE 6: GROUP PERFORMANCE
Group Performance
1H09 2H09 1H10 2H10 1H11 2H11 1H12 2H12
1H10-
2H10
2H10-
1H11
1H11-
2H11
2H11-
1H12
1H12-
2H12
Interest Income 1098 933 1004 1233 1315 1362 1327 1270 22.8% 6.6% 3.6% -2.6% -4.3%
Interest Expense -872 -678 -729 -947 -1005 -1049 -1003 -942 29.9% 6.1% 4.4% -4.3% -6.1%
Net Interest Income 227 255 275 286 310 313 324 328 3.9% 8.5% 1.0% 3.3% 1.4%
Other Banking Income 77 71 68 75 61 71 53 59 9.9% -18.0% 15.8% -25.4% 10.8%
Net Banking Operating Income 304 325 343 360 371 384 376 387 5.1% 3.1% 3.5% -2.0% 2.7%
Net Insurance Op. Income 0 0 0 7 19 22 20 21 10.8% -6.0% 4.5%
Total Operating Income 304 325 343 368 391 406 397 408 7.2% 6.3% 3.8% -2.2% 2.8%
Other Expenses -212 -158 -161 -187 -185 -189 -197 -226 -16.5% 1.3% -2.2% -4.2% -14.5%
Pre-prov Operating Profit 92 167 182 180 206 217 200 182 -0.9% 14.1% 5.3% -7.8% -8.8%
Bad Debts Expense -28 -38 -51 -53 -134 -66 -328 -73 -2.7% -154.5% 50.8% -395.8% 77.6%
Profit Before Tax 64 129 131 128 71 151 -128 109 -2.4% -44.1% 111.1% -185.1% -184.9%
Income Tax -18 -34 -40 -37 -21 -42 38 -35
Statutory NPAT 46 95 91 91 50 108 -91 73 0.1% -44.6% 114.9% -183.7% -181.1%
Adjustments 34 12 2 13 5 13 18 30
Normalised NPAT 81 107 93 104 54.9 121.7 -72.4 103 11.1% -47.1% 121.7% -159.5% -242.3%
Source: BOQ reports
Growth ratesNormalised Earnings
9. 9
FINANCIAL SUMMARY
Bank of Queensland BOQ
As at: 23/10/2012 Recommendation: Negative Share Price $7.46
Year end August 2011A 2012E 2013E 2014E
INCOME STATEMENT
Interest Income $m 2,677 2,596 2,483 2,715
Interest Expense $m (2,053) (1,945) (1,821) (2,029)
Net Interest Income $m 623 652 662 686
Non Interest Income
Fees & Commissions $m 135 120 156 149
Trading Income $m 0 0 0 0
Other Banking Income $m (3) (9) (9) (10)
Banking Non Interest Income $m 132 112 147 139
Wealth Management Income $m 0 0 0 0
Income/(Loss) from Associates $m 0 0 0 0
Total operating income $m 796 804 861 887
Operating Expenses
Personnel Expenses $m (155) (166) (154) (154)
Occupancy & Equipment $m (94) (117) (111) (114)
Total Operating Expenses $m (374) (423) (398) (404)
Pre Prov. Oper. Profit Before Tax $m 422 382 463 483
Bad debt charge $m (201) (401) (114) (131)
Pre Tax Profit $m 222 (19) 349 352
Tax Expense $m (63) 2 (105) (106)
Minorities $m 0 0 0 0
Reported Profit Statutory $m 159 (17) 245 246
Cash earnings adjustment $m 14 9 6 7
Reported Cash Profit $m 165 (18) 243 243
Preference Share Dividends $m (8) (10) (8) (10)
E&P Normalised NPAT $m 165 (18) 243 243
E&P Cash EPS ¢ 74.3 (6.8) 78.7 78.8
Basic Cash EPS ¢ 74.3 (6.8) 78.7 78.8
Reported EPS ¢ 68.0 (10.1) 76.6 76.7
Dividend per Share ¢ 54.0 52.0 51.5 51.9
BALANCE SHEET
Gross Loans & Other Receivables $m 34,065 35,004 36,181 37,886
Total Assets $m 39,901 41,758 43,902 46,182
Impaired Assets $m 444 525 400 327
Deposits & Other Pub. Borrowing $m 36,278 37,860 39,985 42,093
Bonds, notes & subordinat’d debt $m 0 0 0 0
Total Shareholder Equity $m 2,574 2,899 2,862 2,979
Avg housing loans $m 23,192 24,755 25,477 26,891
Avg non-housing loans $m 9,485 9,306 9,578 10,110
Avg total gross loans $m 32,678 34,061 35,055 37,001
Avg Interest Earning Assets $m 38,174 39,410 40,876 43,093
Avg Total Assets $m 38,975 40,687 42,200 44,489
Avg Interest Bearing Liabilities $m 35,740 36,774 38,910 41,041
Avg Total Liabilities $m 36,483 37,515 39,651 41,783
Avg Shareholders’ Equity $m 2,492 3,172 2,549 2,707
GROWTH RATES
Per Share
E&P Cash EPS % (19.7)% N/A% N/A% 0.2%
Basic Cash EPS % (19.7)% N/A% N/A% 0.2%
Dividend Per Share % 3.8% (3.7)% (1.0)% 0.8%
Profit & Loss
Net Interest Income % 11.0% 4.5% 1.6% 3.7%
Banking Non Interest Income % (0.1)% (15.6)% 31.9% (5.5)%
Wealth Management Income % N/A% N/A% N/A% N/A%
Total Non Interest Income % (0.1)% (15.6)% 31.9% (5.5)%
Total Operating Income % 12.0% 1.0% 7.1% 3.0%
Operating Expenses % 7.5% 13.0% (5.8)% 1.6%
Pre-Provision Profit % 16.3% (9.6)% 21.4% 4.2%
Impairment Charges % 92.4% 100.0% (71.6)% 14.8%
Cash Profit % (16.3)% N/A% N/A% 0.2%
Balance Sheet
Gross Loans & Other Receivables % 5.0% 2.8% 3.4% 4.7%
Total Shareholders’ Equity % 7.1% 12.7% (1.3)% 4.1%
Average Balance Sheet
Housing Loans % 10.3% 6.7% 2.9% 5.6%
Non-Housing Loans % 4.7% (1.9)% 2.9% 5.6%
Avg Interest Earning Assets % 8.7% 3.2% 3.7% 5.4%
Avg Interest Bearing Liabilities % 8.2% 2.9% 5.8% 5.5%
Year end August 2011A 2012E 2013E 2014E
VALUATION METRICS
E&P Cash P/E Multiple x 10.0 - 9.5 9.5
Basic P/E Multiple x 10.0 - 9.5 9.5
Price/Pre-prov. operating profit x 4.0 6.0 5.0 4.8
NTA per share $ 8.8 7.6 7.5 7.7
Book Value per Share $ 11.4 9.4 9.3 9.5
Price/NTA x 0.8 1.0 1.0 1.0
Price/Book x 0.7 0.8 0.8 0.8
Dividend per Share ¢ 54.0 52.0 51.5 51.9
Dividend Payout Ratio x 0.7 (7.6) 0.7 0.7
Dividend Yield % 7.2% 7.0% 6.9% 6.9%
Grossed Up Yield % 10.3% 9.9% 9.8% 9.9%
Issued Shares m 225.4 308.8 308.8 313.5
Weighted Average Shares m 221.9 263.8 308.8 308.8
PERFORMANCE ANALYSIS
Profitability
Income / Avg Assets % 2.0% 2.0% 2.0% 2.0%
Expense / Avg Assets % 0.2% 0.0% 0.2% 0.2%
Return on Average Assets % 0.4% 0.0% 0.6% 0.5%
Return on Ordinary Equity % 6.6% (0.6)% 9.5% 9.0%
Return on Risk Weighted Assets % 0.8% (0.1)% 1.1% 1.1%
Net Interest Margin Analysis
Net Interest Spread % 1.3% 1.3% 1.4% 1.4%
Net Interest Margin % 1.6% 1.7% 1.6% 1.6%
Non Int. Income to Total Income % 21.7% 19.0% 23.1% 22.6%
Efficiency
Cost/Income % 47.0% 52.5% 46.2% 45.6%
Tax Rate
Effective tax rate % 28.4% 11.4% 30.0% 30.0%
CAPITAL ADEQUACY
Risk Weighted Assets $m 20,525 21,098 21,247 22,236
Tier 1 Capital $m 1,718 1,998 2,033 2,150
Total Capital $m 2,343 2,657 2,707 2,865
Tier 1 Ratio % 8.4% 9.5% 9.6% 9.7%
Tier 2 Ratio % 3.1% 3.1% 3.2% 3.2%
Total Capital Ratio % 11.4% 12.6% 12.7% 12.9%
ACE Ratio % 6.7% 8.9% 8.6% 8.4%
Tangible Leverage Ratio % 5.0% 5.6% 5.3% 5.2%
ASSET QUALITY
90-day Past Due Loans $m 483 347 264 216
Non Performing Loans $m 444 525 400 327
NPL / Gross Loans and Other Rec % 1.3% 1.5% 1.1% 0.9%
Total Provisions $m 254 413 138 (115)
Total Prov. / Gr. Loans & Oth Rec % 0.7% 1.2% 0.4% (0.3)%
Individual Provision $m 174 220 (28) (266)
Individual Provision Cover % 39.1% 41.9% (7.0)% (81.6)%
Collective Provision $m 80 193 166 151
Collective Prov. / Perform. Loans % 0.2% 0.6% 0.5% 0.4%
Impairment Charges / Avg RWA % 1.0% 1.9% 0.5% 0.6%
Imp Assets / Gr. Loans & Oth Rec % 1.3% 1.5% 1.1% 0.9%
Impaired asset coverage % 39.1% 41.9% (7.0)% (81.6)%
Collective Provision / RWA % 0.4% 0.9% 0.8% 0.7%
BDD / Gr. loans and Oth Rec % 0.6% 1.1% 0.3% 0.3%
WEALTH MANAGEMENT
Funds Under Administration $m 0 0 0 0
Inforce Premiums $m 0 0 0 0
Funds Mgt Revenue Margin % 0.0% 0.0% 0.0% 0.0%
Life Insurance Revenue margin % 0.0% 0.0% 0.0% 0.0%
Shareholder Invest. Returns % 0.0% 0.0% 0.0% 0.0%
10. 10
RESEARCH RECOMMENDATION DEFINITIONS
Positive Stock is expected to outperform the S&P/ASX 200 over the coming 24 months
Neutral Stock expected to perform in line with the S&P/ASX 200 over the coming 24 months
Negative Stock is expected to underperform the S&P/ASX 200 over the coming 24 months
Speculative Stock has limited history from which to derive a fundamental investment view or its prospects
are highly dependent on event risk, eg. Successful exploration, scientific breakthrough, high
commodity prices, regulatory change, etc.
Suspended Stock is temporarily suspended due to compliance with applicable regulatory and/or Evans &
Partners policies in circumstances where Evans & Partners is acting in an advisory capacity.
Not Rated Stock is not included in our investment research universe.
Research Criteria Definitions
Recommendations are primarily determined with reference to how a stock ranks relative to the S&P/ASX 200 on
the following criteria:
Valuation Rolling 12 month prospective multiples (composite of Price-to-Earnings Ratio, Dividend
Yield and EV/EBITDA), or long-term NPV for resource stocks.
Earnings Outlook Forecast 2 year EPS growth.
Earnings Momentum Percentage change in the current consensus EPS estimate for the stock (rolling 1 year
forward basis) over the consensus EPS estimate for the stock 3 months ago.
Shareholder Returns Composite of forecast ROE (rolling 1 year forward basis) and the percentage change in
ROE over 2 years.
Debt Servicing Capacity Rolling 12 month EBIT Interest Cover ratio.
Cyclical Risk Qualitative assessment of the 2 year outlook for a stock/industry’s profit cycle.
Industry Quality Qualitative assessment of an industry’s growth/returns potential and company specific
management capability.
Financial Transparency If we don’t understand it, we won’t recommend it.
For stocks where Evans & Partners does not generate its own forecasts, Bloomberg consensus data is used.
Analysts can introduce other factors when determining their recommendation, with any material factors stated in
the written research where appropriate.
11. 11
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I, George Gabriel, CFA, hereby certify that all the views expressed in this report accurately reflect my personal views about the subject
investment theme &/or company securities. I also certify that no part of my compensation was, is, or will be, directly or indirectly, related
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