Myth or Reality Roadshow 2014

MYTH OR REALITY: WHAT IS TPR’S
POSITION ON VIABLE RECOVERY PLANS?
BDO LLP PENSION ROADSHOW 2014

CONTENTS
1. Why are pensions seemingly so complex?
2. Myth or Reality: What is tPR’s position on Viable Recovery Plans?
1. Assessing whether a funding solution is possible
2. Undertaking an Asset Liability Modelling exercise
3. Ensuring equitable treatment of Scheme members
3. But what if the Employer isn’t viable?
4. Using ALM based de-risking tools
5. Other solutions when the Scheme is a Partner
6. The PPF position
7. Concluding remarks and Q&A

WHY ARE PENSIONS SEEMINGLY SO COMPLEX?
LIABILITY
RISK
INVESTMENT
RISK
ECONOMIC
RISK
LEGAL
RISK
COMPANY AGENDA TRUSTEE AGENDAPage 3

BUSINESS
AS USUAL
ECONOMIC
RECOVERY
PLAN
INSOLVENCY
INSOLVENT
COMPROMISE
WITH PPF
1 2 5
SOLVENT
COMPROMISE
3 4
EMPLOYER IN CONTROL… …SCHEME CAUSES
CONCERN…
…IN CRISIS… ...CATASTROPHE… …EMPLOYER LIQUIDATED
SECURITY FUNDING SEPARATION COMPROMISE EXIT
CREDITOR PARTNER tPRPPFOWNER
Page 4
WHERE IS YOUR EMPLOYER ON ITS LIFECYCLE?
The Pension Control Chevron© (charting the ‘pension demise curve’
of 6,000 schemes)

CONTENTS
2. Myth or Reality: What is tPR’s position on Viable
Recovery Plans?
6. The PPF position

MYTH OR REALITY: WHAT IS TPR’S POSITION ON
VIABLE RECOVERY PLANS?
The Regulator’s position is that they need to see enough evidence,
advice or information to support a conclusion that continuation of the
Scheme is in the best interests of the generality of members.
 They need to see the company’s business plan without which it is
not possible to meaningfully test the affordability, reasonableness
or viability of the proposed Recovery Plan
 The Trustee should be considering whether, realistically, the
Employer’s business can afford to support the Schemes in the long
term
 If it cannot, it is the duty of the Trustee to consider whether it is
in the interests of the generality of members to allow the Scheme
to continue when there is no viable funding solution
Page 6

TPR POSITION ON VIABLE RECOVERY PLANS
2. Undertaking an Asset Liability Modelling exercise on a stochastic
basis
4. Understanding how the relative position of PPF benefits and
benefits in excess of PPF is likely to vary over the term of any
Recovery Plan
5. Trustee (and Employer) will need to be able to present a coherent
case to conclude whether a Viable Recovery Plan is possible
What should the Employer & Trustees be doing?
Page 7
So let’s see what that this means in practice…..

tPR suggest that the Trustee adopts the following process:
1. Understand the strength of the Employer’s Covenant (including
legal liability for the Schemes; i.e., its Statutory Employer) and
affordability (both now and in the future)
2. Understand the Schemes’ profile in terms of maturity and duration
3. Assesses the most appropriate investment strategy to undertake in
light of the Trustee’s assessment of the strength of the Employer’s
covenant and the Schemes’ profile
Assessing whether a funding solution is possible
Page 9

4. Assess the deficit reduction contributions (“DRCs”) required to
clear the self-sufficiency deficit*
5. Adopt an investment strategy (and risk associated with this strategy)
which is commensurate with the Covenant, the Schemes’ profile
and the maturity
6. Determine whether these DRCs are affordable to the Employer
7. Assess whether alternative structures (in terms of investment
strategy and RP length) are possible, within acceptable levels of risk
being run
*tPR consider that the use of a self-sufficiency basis on which to assess viability is
more useful in determining the levels of risk supportable by the Covenant and the
reliance or otherwise on inappropriate levels of investment risk
Page 10

8. Consider in which scenarios and at what point the Schemes run out
of money
9. Consider in which scenarios the funding level deteriorates to such
a level (and considers how such a funding level should be defined)
that the Schemes are unable to pay out member benefits in full
(they define this as the “minimum viable funding level”)
10. Quantify the level of downside risk borne, in particular, by the
deferred members and the PPF
11. Consider whether other options exist to support the Schemes such
as contingent assets or guarantees.
Page 11

SO WHAT IS THE COMPANY’S BUSINESS PLAN?
CORPORATE STRUCTURE
Page 12
Step 1: Identify where the value is

WHY IS THE EMPLOYER COVENANT SO IMPORTANT?
1. POSITION
?
3. POWER
?
2. PROSPECTS
?
Overall
?
EMPLOYER COVENANT VECTOR
Step 2: How do you calibrate the Employer Covenant?
Page 13

0
1
2
3
4
5
6
7
8
9
10
STRONG
EMPLOYER
COVENANT
WEAK
EMPLOYER
COVENANT
SCHEME FUNDING: THE TENSION EXPLAINED
BUY
OUT
EMPLOYER
PULL
TRUSTEE
PULL
A framework for defining the impact of Employer Covenant
strength on measurement of Technical Provisions
Infinitely high Employer Covenant strength
-> Technical Provision = Best Estimate
Zero Employer Covenant strength
-> Technical Provision = Buy Out
Does a straight line join the above points? Don’t be stupid!
Employer position argues towards lower Technical Provision
Trustee position argues towards higher Technical Provision
Employer power is greatest if Employer Covenant is strong
Trustee power is greatest if Employer Covenant is weak
Where does the power switch from Employer to Trustee? The
Inflexion Point!
Scheme Funding is a negotiation with a range of outcomes
based on Balance of Powers between Employer and Trustee
…but does reality reflect the theory?










TRUSTEE
VIEW
EMPLOYER
VIEW
WHAT HAPPENS
IN BETWEEN?
IT IS A
NEGOTIATION
EmployerCovenantVector
Technical Provision Deficit
TRUSTEE
IN
CONTROL
EMPLOYER
IN
CONTROL
POWER
TRANSFERS FROM
EMPLOYER TO
TRUSTEE
WHAT IS
THE
REALITY?
BEST
ESTIMATE
SCHEME FUNDING
Page 14
Step 3: What is the shape of your Snake?

COVENANT CALIBRATION IN ACTION
Agreed start position for MoU is based on a Covenant score of 6 equating to a deficit
of £xm. Leverage of 6x is viewed as the key inflexion point.
KEY
MESSAGE
Page 15
10
9
8
7
6
5
4
3
2
0
EmployerCovenantVector
Strong
Employer
Covenant
Weak
Employer
Covenant
Neutral
+£[0]m
Surplus/Deficit based on Technical Provision
Headline
deficit
£(x)m
Leverage
3x
4x
5x
6x
7x
Point of
inflexion –
[6]x
leverage
Covenant Score
of [6] agreed as
base line for MoU
a c d
£(y)m
b
Additional
lump sum
funding from
transaction
Outside of MoU Coverage
Outside of MoU Coverage

0
1
2
3
4
5
6
7
8
9
10
0 10 20 30 40 50 60 70 80 90 100 110 120
HOW DO YOU CALCULATE THE POSITION VECTOR?
Assessment of Position is based on the
estimated outcome for the Scheme in
the event of a hypothetical insolvency
Assume a buyout deficit of £100m
Recovery of £Nil = 0/10 Position score
Recovery of £100m = 10/10 Position score
An Estimated Outcome Statement is used
to assess three scenarios:
1) High = best case (going concern sale)
2) Low = worst case (break-up sale)
3) Breakeven EV/EBITDA multiple
Employer mitigation can improve the
Scheme’s position to a certain extent…
…but mitigation provided by the wider
Group is required to maximise the
Scheme’s position
Each scenario is based on assumptions
and therefore subject to uncertainty,
resulting in a range of potential outcomes
that varies depending on the underlying
assets available to the Scheme






EMPLOYER COVENANT
POSITION SCORE
ESTIMATED OUTCOME FOR
SCHEME ON INSOLVENCY
LOW
£20M
HIGH
£40M
MAXIMUM AVAILABLE
EMPLOYER RECOVERY
MAXIMUM AVAILABLE
POSITION SCORE
(EMPLOYER ONLY)
LOW
£30M
HIGH
£50M
LOW
£70M
HIGH
£90M
MAXIMUM AVAILABLE
GROUP RECOVERY
MAXIMUM AVAILABLE
POSITION SCORE
(WITH GROUP MITIGATION)
Step 4: It’s all about Estimated Outcome Statements (EOS)
Page 16

WHAT ARE THE EMPLOYER’S PROSPECTS?
• Actuals – how accurate were the past forecasts?
• Forecasts – which one do you focus on?
o Their targets?
o The one they show the shareholders?
o The one they show the banks?
o The one they should show a prudent Trustee…..
-£4m
£4m
£8m
£12m
FY06 FY07 FY08 FY09 FY10 FY11 FY12 FY13 FY14 FY15
Actual F1 F2 F3 F4
EBITDA
Significant increase in
EBITDA from FY12
Negative and
decliningEBITDA
Initial improvement in
EBITDA followed bydecline,
negative from FY15
Significant increase in
EBITDA from FY12
(butless than F3)
Step 5: Choosing the right forecast
WHAT IS AFFORDABLE?Page 17

BUT WHAT ABOUT POWER?
Employer
right
Subject to
advice
Must
consult
Subject to
advice
Trustee
rightUnspecified
1. Wind up power
2a. Contributions (TD&R)
3. Amend rules
4. Appoint Trustees
5. Interpret TD&R
2b. Contributions (PA)
BUT IT IS NOT JUST ABOUT THE TD&R!
Step 6 : What is the Balance of Powers
Page 18
6. Investment

HOW CAN TPR POWERS BE USED?
FSDsTYPEAEVENTS
MULTI-EMPLOYER
PPF
SCHEME
FUNDINGFind
Value
Demand
Value
Preserve
Value
Insure
Value
Apportion
Value
THE
FAMOUS
FIVE©
FSDsTYPEAEVENTS
MULTI-EMPLOYER
PPF
SCHEME
FUNDINGFind
Value
Demand
Value
Preserve
Value
Insure
Value
Apportion
Value
THE
FAMOUS
FIVE©
THE FAMOUS FIVE
Do you have any
other original
Employers?
Page 19
Step 7: But how effective are they?

Notification
& Reporting
Escrow A/C
or Bank
Guarantee
Security
ABC/SLP
Group
Guarantee
Negative
Pledge
Subordinate
IC Loans
Undertaking
(Sale
Proceeds)
1 2 3 6 754
HOW CAN YOU IMPROVE YOUR COVENANT?
1 2 3 6 754
Most Trustee impact
Potential loss of control for the Group
Least Trustee impact
Minimal loss of control for the Group
Step 8: The Mitigation Map
What are each of these Mitigation Steps worth on the Covenant Score?
Page 20

tPR would expect the ALM work (or similar) would illustrate the:
1. Progression of the funding level of the Scheme relative to a self
sufficiency target
2. Possibility of how likely it is that the Scheme may run out of money
and at what point
3. How likely it is that the Scheme will breach the minimum viable
funding level (‘MFL’)
4. Possibility of either running of out money or breaching MFL and the
level of the downside risk associated with alternate strategies
5. ALM should demonstrate the sensitivities associated with differing
levels of DRCs (on a variety of differing investment strategies) to
illustrate how this affects the funding outcomes.
WHAT IS ASSET LIABILITY MODELLING (ALM)
Page 22

The Trustees should be able to summarise by consideration of the ALM
and Covenant analysis:
6. What level of investment risk and Recovery Plan length are
supportable by the Covenant
7. Based on the level of investment risk that the Covenant can
support, what is the broad investment strategy that would be
appropriate
8. Based on this investment strategy and Recovery Plan length, what
deficit contributions are required
9. And finally, assess whether the company can actually afford these
contributions
Page 23
WHAT IS ASSET LIABILITY MODELLING (ALM)

THE SEVEN DWARFS ASSET PROFILE
Deferred
Pensioner
Active
MEMBERSHIP
PROFILE
Page 24
WHAT (MINIMUM VIABLE) FUNDING LEVEL?
Step 9: Asset Liability Modelling (ALM) using the ‘Self-
Sufficiency’ Dwarf
Identifying where the source of the Scheme risk is…..
Special
Deferred
Best
Estimate
Self-
Sufficiency
What is the Scheme Duration?
40%
22%
17%
14%
7%
0%0%
Equities
Gilts
Bonds
DGF
Other
20%
50%
10%
20%

IT’S ALL ABOUT CASH FLOW – OVER A LONG TIME!
Page 25
Step 10: Identify Scheme’s underlying cash requirement
IS THE DURATION AND MIX UNDERSTOOD?

PROJECTED BENEFIT OUTFLOW OF THE SCHEME
-
5
10
15
Volatility due to inflation,
early retirement and
longevity
Increase in Pension
Payments due to
pensioners retiring
£xm
Scheme wind up due to
member death
Median Path
The benefit outflow has significant volatility
Page 26

0
100
200
300
2013 2016 2019 2022
VAR ANALYSIS: ASSETS ONLY
Investments: 70% Equities, 30% Gilts
A funnel of doubt of future asset returns (assuming no
deficit contributions)
1/20 chance
Var5 – 1/20 chance of any outcome
being above this line (2 Standard
Deviations from Best Estimate)
50% of outcomes
1/6 chance of any particular
outcome being below the line
(1 Standard Deviation below BE)
Var95 – 1/20 chance of any outcome
being below this line (2 Standard
Deviations from Best Estimate)
Median Path (assumes
Best Estimate returns)
£m
The Prudent Path needs to be improving over time
Page 27

PROJECTED SURPLUS / DEFICIT
Combining the benefit outflow and asset projections
-100
-50
0
50
100
150
2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023
With deficit contributions of £1.4m a year for 10 years, the median result is fully funded in 10 years
MEDIAN PATH
Page 28

A TYPICAL SCHEME EXAMPLE
How much cash does the Scheme actually need?
Best Estimate results
Assets = £140m, Liability = £150m
Deficit = £10m
Gilts + 2% discount rate
70% Equity, 30% Gilts
Self Sufficiency results
Assets = £140m, Liability = £200m
Deficit = £60m
Gilts + 0% discount rate
100% Gilts
Page 29

WHAT HAPPENED?
How much cash does the Scheme actually need?
[ ]Best Estimate. 70% Equity 30% Gilts
Full funding in 10 years. Median case
• £10m lump sum or
• £1.4m p.a. for 10 years
Full funding in 10 years. Prudent case
• £6.5m p.a. for 10 years
Self Sufficiency. 100% Gilts
Full funding in 10 years. Median case
• £7m p.a. for 10 years
Full funding in 10 years. Prudent case
• £9m p.a. for 10 years
1. WHAT IS YOUR PREFERRED BASIS?
2. WHAT IS YOUR RISK APPETITE?
3. HOW MUCH CAN YOU AFFORD TO GIVE ANYWAY?
Page 30

In carrying out the above, the Trustee needs to ensure that all the
Schemes’ members are treated equitably and that no cohort/class of
membership is receiving inequitable treatment relative to other
cohorts/classes, although tPR accepts that there may be reasonable
grounds for treating different cohorts/classes differently as long as this
different treatment does not lead to inequitable consequences:
1. Trustees need to understand the impact of additional benefits
falling into the highest priority class(es) under the statutory priority
order ("Scheme Drift") over time compared to the level of deficit
contributions being made.
2. This should address the extent to which additional high priority
exposure is expected to accrue on account of benefit increases
above the levels which would be granted if the Scheme were to
wind up at the present time.
EQUITABLE TREATMENT OF THE SCHEME'S
MEMBERS
Page 32

3. This information should enable Trustees to understand how not
winding up their Scheme may transfer value from younger Scheme
members to older Scheme members. This should enable a broader
view as to who is bearing the risk of the Scheme continuing as a
going concern and the level of these risks specifically being borne
by members
4. As part of understanding the impact on different cohorts of the
continuation of the Scheme, the Trustees should understand the
impact of continuing the Scheme on the Scheme's potential
discontinuance/(solvency) position
5. This should ignore the existence of the PPF as a source of funding
MEMBERS
Page 33

In particular, Trustees should understand the:
6. Impact on the members of the Scheme (especially deferred
members) of continuing to pay benefits in full
7. Costs (Employer and Trustees) incurred by the continuation of their
Scheme
8. Impact on the above of different investment strategies, in particular
in the event of downside scenarios.
MEMBERS
Page 34

Trustees should also understand how the relative position of PPF
benefits and benefits in excess of PPF is likely to vary over the term of
any Recovery Plan proposed and in particular how this coverage varies
for different cohorts of the Scheme membership.
The main sources of increase are generally:
1. Pension increases in excess of PPF increases
2. Effect of members reaching NPA and having 100% cover rather than
90% subject to a cap
3. Cash commutation
4. Revaluation of deferred benefits
5. Effect of early retirement
6. Other Scheme-specific items not included above
PPF DRIFT
Page 35

 Assessing whether a funding solution is possible
 Undertaking an Asset Liability Modelling exercise on a stochastic
basis
 Ensuring equitable treatment of Scheme members
 Understanding how the relative position of PPF benefits and
benefits in excess of PPF is likely to vary over the term of any
Recovery Plan
5. Trustee (and Employer) will need to be able to present a coherent
case to conclude whether a Viable Recovery Plan is possible
“tPR do not wish the Trustee to have to commission disproportionate
amounts of advice at excessive cost; however the Trustee (and
Employer) will need to be able to present a coherent case to conclude
whether a Viable Recovery Plan is possible.”
What should the Employer & Trustees be doing?
Page 36

BUT WHAT IF THE EMPLOYER ISN’T VIABLE?
…what is the consequence for the Scheme?
LOST THE
BUSINESS
IN TROUBLE,
IN DENIAL
LOST
CONTROL
IN TROUBLE,
BUT IN CONTROL
The Control
Watershed©
Concern
Comfort
Crisis
Catastrophe?
Employer suffers a loss of CONTROL and a degradation of
VALUE for all stakeholders:
Page 38

INSOLVENCY
1 2 53 4
EMPLOYER IN CONTROL… …SCHEME CAUSES
CONCERN…
…IN CRISIS… ...CATASTROPHE… …EMPLOYER LIQUIDATED
CREDITOR PARTNER OWNER PPF EXIT
tPR
Page 39
THE PENSION CONTROL CHEVRON©
Charting the ‘pension demise curve’ of 6,000 schemes
20% 40% 20% 20%
54 schemes with liabilities in excess
of £1.2 billion each who have a
Employer in Chevron 3 or 4
90% of Chevron 4 are Schemes with less
than £120m liabilities, 40% less than
£12m
1
2 3
4 5
6 7
8 9
10
New PPF Levy consultation splits Employers over 10 bands
tPR define 4 types: Strong, Tending to Strong, Tending to Weak & Weak

6. The PPF position
CONTENTS

USING ALM DE-RISKING TOOLS
WARNING! ONLY VALID IN THESE TWO AREAS….

STRATEGIC DE-RISKING / FLIGHT PLAN
0
Fundinglevel
Time
Lower funding range
Inflation hedging
Upper funding
range
Enhanced
Transfers
Actual funding
level
Longevity swap
Buy-in
Target funding
level
• Set your long term objectives - target of removing the Scheme from the
company balance sheet
• Manage Scheme risk through a combination of strategic and tactical asset
allocation - trigger based actions
• Risks removed after cost benefit analysis
Lower funding range
Upper funding
range
Target
funding level
Page 42

WHAT'S THE POTENTIAL IMPACT OF THESE
DE-RISKING OPTIONS…AND THE COST?
Possible reduction in:
(ignoring second order effects)
De-risking
option
Investment
risk
Interest
risk
Inflation
risk
Longevity
risk
Technical
Provisions
Buy-in/out
costs
Scheme
design
Investment
strategy
Liability
management
?
Longevity
Swap
Transfer to
insurer
Captives
All de-risking options will reduce volatility in future deficit levels
Page 43

COST EFFECTIVE SOLUTIONS?
• Buy-in vs Buy-out
• Is a buy-in better than holding bonds?
• Use ALM to decide!
Premium
Pension payments
Pension scheme Insurer
Segregated account
Collateral
assets
Assets, if
required
ALL risks can be transferred
for a premium
Positive
experience
Page 44
Buy-in/Buy-out

1. Managing liability risks – interest rate, inflation and longevity
2. Generating appropriate investment returns – i.e. growth
Provider
Liability hedge
MAKING LEVERAGE A GOOD NAME?
Cash/gilts
Growth
strategies
Managing liability
risks:
Investing assets to
track liability
movements
Generating asset
growth:
Investing assets to
deliver the right
level of return
Page 45
Leveraged Liability Driven Investment (LDI) Strategy
Use ALM to understand the duration risks and liability hedge appropriately!

UNFUNDED LIABILITY SIDE RISK MANAGEMENT
Longevity swaps - Scheme specific
1. Basis, idiosyncratic and systematic (trend) risks covered
2. Exchange fixed cash flows for variable actual cash flows
3. Collateral posted and topped up/reduced as the swap unwinds
4. “Carve out” if with a bank, “whole of life” if with an insurer
Fixed leg
Floating leg
Pension scheme ProviderPensioners
Monthly payments until last pensioner dies
Monthly fixed payments to provider for a fixed term
Page 46

1.Hedges systematic trend risk, up to 85% basis risk
2.Population hedge, rather than scheme specific
3.15-20 year derivative, what is its value for money?
4.Use ALM!
Pension scheme Provider
Notional x 100 x fixed mortality rate
Notional x 100 x realised mortality rate
Fixed Amount
Floating Amount
UNFUNDED LIABILITY SIDE RISK MANAGEMENT
Page 47
Longevity Swaps – Index-based

CONTENTS
4. Relative position of PPF plus and minus benefits
6. The PPF position

OTHER SOLUTIONS WHEN THE SCHEME IS A
PARTNER
Page 49
WARNING! IF THESE DON’T WORK YOU
ARE MOVING TO THE RIGHT

SO WHAT IF THE SCHEME IS A PARTNER/OWNER?
Page 50
Employer
Scheme
Shares /
Share
options
A flexible, parallel vehicle to provide a source of security and funding to
the Scheme
EMPLOYER COVENANT
OBLIGATION TO PAY
EQUITY
CASH ASSETS
PenCapT©
Intangible
Assets
…but how does this link into the wider Pension Strategy?
Escrow
Account
DEBT
Bank
Guarantee/
Letter
of Credit
Tangible
Assets
Insured
assets
Marconi (2005)
TUI (Brand) (2011)
M&S (Property) (2006 )
GKN (IP) (2010)
Diageo (Whisky stocks) (2010)
Dairy Crest (Cheese) (2013)
PPF compliant
contingent assets (2006)
Uniq Plc (2011)
UK Coal (2012)
Kodak (2013)

PPF PLUS COMPROMISES
Page 51
WARNING! YOU ARE NOW CONSIDERING ABANDONMENT

Background
1. Metal trading company solely dependent on its 65 year old CEO and his
relationships in the company’s target market
2. Trading severely impacted by global credit crunch
3. CEO took reduced significant Transfer Value in 2009 to remove Technical
Provisions deficit
4. Technical Provisions deficit reappeared at next valuation!
5. Due to age of CEO and inability to sell the company or recruit a new CEO due
to the Scheme, any Technical Provisions deficit now based on buyout and
would require funding over a very short period
6. Buyout funding unaffordable
Outcome
7. PPF+ compromise:
i. Insolvency outcome + 20%
ii. 33% quasi equity stake
iii. Debenture behind banks for duration of quasi equity stake
EXAMPLE TRANSACTION
Project Jess
BUSINESS
AS USUAL
SIGNIFICANT
RECOVERY
PLAN
LIQUIDATION
INSOLVENT
COMPROMISE
WITH PPF
1 2 5
SOLVENT
COMPROMISE
3 4
SECURITY Co FUNDING Co RECOVERY Co COMPROMISE Co LITIGATION?
Uniq plc (current)
Project Beaverbrook (current)
Project Oracle
Project Oasis
Project Brad
WHERE ARE YOU?
Project Radio (current)

PPF COMPROMISES
Page 54
WARNING! THERE IS A NEW STAKEHOLDR
WHO HAS JUST TAKEN CONTROL

WHY ARE PENSIONS SEEMINGLY SO COMPLEX?
LIABILITY
RISK
INVESTMENT
RISK
ECONOMIC
RISK
LEGAL
RISK
COMPANY AGENDA TRUSTEE AGENDAPage 56

MYTH OR REALITY?
1. A collision of different universes
2. Unproven tools in different terrains
3. Management and Trustees need to change their mind set?
4. Conflicts around terminable consequences
5. Are we making it up as we go along?
6. But what is the alternative?
7. What would the Man on the Clapham Omnibus say?
8. Heightened accountability with hindsight?
9. Substance over Form?
10. Principles or Rules?
11. MFR Mark II or a new Paradigm?
Page 57

Myth or Reality Roadshow 2014

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