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The Importance of Price Curve Management
In A More Regulated Commodity Trading Environment
INTRODUCTION
In an era of significantly tighter regulation and oversight of commodity markets, forward price curves have taken
on a whole new level of importance. Internal and external auditors, as well as regulators, want to be certain that the
valuations used to build up financial statements are irrefutable and truly represent fair value based on reliable data.
Indeed, several of the regulations now in force also call for increased and better documented risk management
processes, including mark-to-market and profit and loss calculations.
Increasingly, funding banks and shareholders also desire in-
creased transparency into risk management for assurances
and forward price curves are central to that function. No matter
how good the risk management systems are, it is the data that
they utilize that is key to good risk management, and market
pricing is a key ingredient in that data. Furthermore, the for-
ward curve requirements don’t just impact commodity trading
and hedging operations, but also the treasury function.
In a previous paper1
, Commodity Technology Advisory
defined forward curves and looked at their uses and the
source of the forward curve data in some detail. In es-
sence, forward curves have three major uses:
	1/ Financial statements – companies use forward
curves as inputs to derivative valuation models in
order to calculate the fair value of commodity in-
ventories or financial instruments that are carried
on the balance sheet (IFRS 13 and ASC 820).
	2/ Asset Valuation – curves can be used to provide an
asset holder with an estimate of an asset’s current
and future value.
	3/ Risk Management and Reporting – a variety of
forward curve types will be used as a part of the
process of calculating risk metrics.
Indeed, given the above, it is fairly easy to begin to understand
that the forward curve is both a central and critical piece of data
used at the heart of all commodity-trading firms and across a
number of different areas of the business. A basic question
then, often asked by auditors and others, both internal and ex-
ternal, is how are the forward curves derived and maintained?
© Commodity Technology Advisory LLC, 2015, All Rights Reserved.
1) Managing Forward Curves in A Complex Market, ComTech Advisory White Paper, 2015
© Commodity Technology Advisory LLC, 2015, All Rights Reserved.
DEMANDS FOR CURVES
Only rarely will sources provide complete and accurate forward curves that suit the precise purposes of a market
participant. Although external data aggregators can and do provide a variety of pricing data, these prices will
typically come from many sources of variable quality and reliability, thus internally derived curves must be used
quite frequently. This may be as a result of incomplete published curves, the absence of a liquid market, the lack
of reliable sources for prices, or the desire to use a proprietary model on a particular pricing algorithm. In these
cases, the onus is on the user of such derived price curves to be able to demonstrate how the price curve has
been constructed for audit and other purposes.
Curves can be derived in any number of ways, for exam-
ple, based upon a nearby liquid market price as a spread,
or they may be based on a pricing formula referencing mul-
tiple differing liquid prices. In many scenarios, the source
data might be provided in different units of measure, or cur-
rencies, to that which is required. There is room for error
in manipulating price data for unit of measure or currency
conversions; therefore, automation of such transformations
via rules-based instructions is preferred. Whichever way the
price curve is derived, the auditor will need to be able to re-
view the construction methodology, as well as see the actual
underlying values and calculation of how each price on the
curve was derived.
For full audit capability, it isn’t just the source prices that
need to be maintained along with historical versioning and
correction tracking, but also the resulting price curves. Se-
rious issues can arise when updated prices are available for
a price curve. In effect, after the source price is updated,
the derived curve must then be updated, while a historical
version of the curve needs to also be maintained in order to
allow reproducibility of calculations such as profit and loss
or mark-to-market calculations in the past. In order to assure
that there is no operator or human error in the process, the
price curve should be updated automatically, at the time the
updated price becomes available.
Finally, there are many versions of curves used for a variety
of different purposes such as asset valuation, transfer pric-
ing, mark-to-market, value-at-risk and so on. Each of these
needs to be maintained with a complete and full history, and
the result can be an explosion of forward curve data that
needs to be managed with an enterprise strength approach.
Furthermore, it is appropriate to restrict the access of differ-
ent user types through some form of security system.
The Importance of Price Curve Management In A More Regulated Commodity Trading Environment A ComTechAdvisory Whitepaper
© Commodity Technology Advisory LLC, 2015, All Rights Reserved.
WHAT IS REQUIRED?
In many companies, much of the basic work around price curves is performed in spreadsheets. Many E/CTRM
solutions actually lack basic curve functionality and pre-suppose that price data, including curves, will be
brought in and stored for later use. They lack any ability to derive curves, track changes, monitor reasons for
changes and audit such changes. As a result of increased regulatory oversight, commodity-trading firms now
need a significantly more robust and auditable solution for forward curve management. This solution should
provide:
	1/ The ability to define an automated methodology to
create forward curves from specified source data,
using a simple or complex formulation.
	2/ The automated recording of all calculations used
within the process of curve creation with a com-
plete audit trail.
	3/ The long term storage of all source data along with
the resulting curves, including versioning of those
curves, with the ability to easily access that data on
demand.
	4/ Testing of curve methodology. Prior to promoting a
curve methodology definition to production status,
the ability to thoroughly test all the scenarios that
a rule-based framework requires to operate effec-
tively. This would provide the confidence required
for downstream system capture, data integrity and
documented proof to any internal or external over-
sight.
	5/ A rules-based approach which would allow adjust-
ments for units of measurement and currency con-
versions along with other manipulations.
	6/ A rules-based approach which would also provide
fallback scenarios in cases where a price is miss-
ing or unavailable for a period of time. Should the
previous price be used or should some other tem-
porary derived price fixing mechanism be used.
Again, as more reliable prices came in, the old
price curve would be maintained.
	7/ Storage for all curves able to be manipulated and
the results of those manipulations. The manipula-
tions might be used for stress testing or another
reason, but it is important to have a complete audit
trail of prices, price curves and reasons for chang-
es.
	8/ Flexibility. It should be relatively easy to set up de-
rived curves that are formula-based with a good
deal of flexibility. These may be used for pricing or
as valuation tools and each needs to be subject to
all the rigors outlined above.
	9/ Security of access. The auditor will want assuranc-
es that access to curves for editing is limited to
those responsible.
10/ The ability to visualize the curve and manipulate
it within the context of a visualization tool is also a
nice to have feature.
With an increased demand from inside and outside auditors,
regulators and stakeholders for this kind of rigor around
prices and forward curves, the time has definitely arrived for
comprehensive, robust and flexible solution that meets all of
the above criteria. The risk to the business of not being able
to demonstrate this level of completeness around prices and
forward curves are simply now too great and could threaten
lines of credit, equity value and stakeholder sentiment, the
profitability of the business and more importantly, its reputa-
tion and brand.
The Importance of Price Curve Management In A More Regulated Commodity Trading Environment A ComTechAdvisory Whitepaper
The Importance of Price Curve Management In A More Regulated Commodity Trading Environment A ComTechAdvisory Whitepaper
© Commodity Technology Advisory LLC, 2015, All Rights Reserved.
DATAGENIC
A COMPREHENSIVE SOLUTION
There is no substitute for a purpose-built application that addresses the specific requirements relating to for-
ward curves, their construction, storage and integration with target systems. Having the correct agile data man-
agement platform in place allows the full complement of services to be harnessed during the curve build and
management processes (for instance, validation, business process management, data and process dashboard,
etc.). Additionally, the curve building application needs to be highly configurable to account for the many input
parameters and rich metadata information that are used in the build process and curve management. Examples
include the curve methodology, the source data sets and the fair value hierarchy.
DataGenic is a leading provider of software and services in the
commodity data management arena including that of forward
curve management. It has spent a considerable amount of time
and expertise in developing these tools in order to offer a com-
prehensive, flexible, transparent and auditable solution that
can also integrate with the E/CTRM solution of your choice.
DataGenic provides an agile data management structure,
the associated processes and controls, the curve building
application and framework to provide for the structured
management of all curves and curve building methodol-
ogies while allowing flexibility to change and adapt the
curve construction. Its solutions meet the criteria outlined
above while offering many significant advantages and
benefits over other solutions including:
	/ Standardized Logic – Rule formation is standardized
providing the ability to ensure that standards are de-
vised, used and defendable as opposed to writing ap-
plications with no standards or with no transparency
into the standards used.
	/ Ease of Use – The rules can be written in a ‘natural’
language such as English making it both easy to use
and to understand and defend.
	/ Centralized Knowledge Base – All the rules and li-
braries are server based so they are accessible and
usable by anyone (they are also automatically kept
up to date with the latest versions) in and outside of
the enterprise.
	/ Transparency – The use of a rules-based system
allows users to break problems down into distinct
conditions making the logic used more precise, re-
liable and understandable to other people such as
auditors, regulators and stakeholders.
	/ Mitigation of Key Person Dependency – The central-
ized, automated and server based curve construc-
tion mitigates the risk of the over reliance on peo-
ple-based operations, which include concentrated
knowledge, sickness, holidays, and attrition.
	/ Collaborative – Curve building logic does not need
to be dealt with in isolation – many people across the
enterprise can contribute to the library.
DataGenic’s Genic CurveBuilder is a purpose-built application
that fully utilizes artificial intelligence and helps to remove the
complexity of building curves and allow unlimited flexibility
while delivering full transparency. While many still utilize un-
documented and uncontrolled spreadsheets or ‘black box’ pro-
grams that don’t allow visibility, Genic CurveBuilder provides
the kind of a comprehensive solution needed to meet the de-
mands of the current regulatory environment.
The application supports an unlimited number of curves,
curve histories, curve interdependencies and curve complex-
ities (combined with curve versioning, curve testing and roll-
back). Curve generation is completely automated and fully
logged, driven by an event (e.g. data update) or time sched-
uled. It also supports any asset class meaning it can handle the
needs of the treasury department and any curve construction
© Commodity Technology Advisory LLC, 2015, All Rights Reserved.
SUMMARY
Commodities trading businesses are extremely complex and are increasingly subject to regulation, transparency and report-
ing. Funding banks and outside investors are increasingly aware of both the compliance issues and of the risk posed by trad-
ing, buying or selling physical commodities and commodities futures. Increasingly, they demand and expect that risk is well
managed and that the data utilized by the risk systems is verifiable, defendable and trustworthy.
Price data and forward curves are a key and central component in this new era of compliance and transparency and all trading
firms now need to ensure that they have a comprehensive, explainable and defendable approach to gathering, calculating and
maintaining this critical information, underpinning their transactions and valuations.
Under such circumstances, a robust and fully transparent data and curve management application architecture is no longer a
luxury option, but rather a base requirement. Under such circumstances, a robust and fully transparent data and curve man-
agement capability, such as that provided by DataGenic’s CurveBuilder product, has become a necessity for those trading
organizations that find themselves increasingly under the microscopes of regulators, stakeholders and financiers.
methodology. In combination with other products and ser-
vices delivered by DataGenic, it meets all of the above require-
ments and includes comprehensive workflow, data versioning
and corrections reporting. DataGenic is also a data aggrega-
tor offering over 400 data feeds to its clients. In fact, Data-
Genic has built and delivers a suite of applications that handle
everything related to data management from cleansing and
validation of data to powerful charting and visualization tools
to examine and drill down into that data.
The Importance of Price Curve Management In A More Regulated Commodity Trading Environment A ComTechAdvisory Whitepaper
ABOUT DATAGENIC LTD
DataGenic is the leading global provider of on-premise and in-cloud Smart Commodity Data Man-
agement software, delivering intelligent analytics, real-time data content and proven business value.
The innovative solutions include a data-agnostic multi-commodity data management platform, visual mapping
and management of business processes, extensive and extensible data quality management, unlimited for-
ward curves construction and an intelligent decision framework. DataGenic customers include participants in
the energy, metals, minerals, chemicals, agriculture, shipping and food and beverage industries.
DataGenic operates in Europe, Asia and the Americas.
For more information, please contact DataGenic at:
AMERICAS: +1 281 810 8290
EMEA: +44 203 814 8500
APAC: + 91 802 662 2607
info@datagenicgroup.com
ABOUT
Commodity
Technology
Advisory
LLC
Commodity Technology Advisory is the leading analyst organization covering the ETRM and
CTRM markets. We provide the invaluable insights into the issues and trends affecting the
users and providers of the technologies that are crucial for success in the constantly evolving
global commodities markets.
Patrick Reames and Gary Vasey head our team, whose combined 60-plus years in the energy
and commodities markets, provides depth of understanding of the market and its issues that is
unmatched and unrivaled by any analyst group.
For more information, please visit:
www.comtechadvisory.com
ComTech Advisory also hosts the CTRMCenter, your online portal with news and views about
commodity markets and technology as well as a comprehensive online directory of software
and services providers.
Please visit the CTRMCenter at:
www.ctrmcenter.com
19901 Southwest Freeway
Sugar Land TX 77479
+1 281 207 5412
Prague, Czech Republic
+420 775 718 112
ComTechAdvisory.com
Email: info@comtechadvisory.com

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Importance of Price Curve Management In A More Regulated Commodity Trading Environment

  • 1. WHITE PAPER Sponsored by The Importance of Price Curve Management In A More Regulated Commodity Trading Environment
  • 2. INTRODUCTION In an era of significantly tighter regulation and oversight of commodity markets, forward price curves have taken on a whole new level of importance. Internal and external auditors, as well as regulators, want to be certain that the valuations used to build up financial statements are irrefutable and truly represent fair value based on reliable data. Indeed, several of the regulations now in force also call for increased and better documented risk management processes, including mark-to-market and profit and loss calculations. Increasingly, funding banks and shareholders also desire in- creased transparency into risk management for assurances and forward price curves are central to that function. No matter how good the risk management systems are, it is the data that they utilize that is key to good risk management, and market pricing is a key ingredient in that data. Furthermore, the for- ward curve requirements don’t just impact commodity trading and hedging operations, but also the treasury function. In a previous paper1 , Commodity Technology Advisory defined forward curves and looked at their uses and the source of the forward curve data in some detail. In es- sence, forward curves have three major uses: 1/ Financial statements – companies use forward curves as inputs to derivative valuation models in order to calculate the fair value of commodity in- ventories or financial instruments that are carried on the balance sheet (IFRS 13 and ASC 820). 2/ Asset Valuation – curves can be used to provide an asset holder with an estimate of an asset’s current and future value. 3/ Risk Management and Reporting – a variety of forward curve types will be used as a part of the process of calculating risk metrics. Indeed, given the above, it is fairly easy to begin to understand that the forward curve is both a central and critical piece of data used at the heart of all commodity-trading firms and across a number of different areas of the business. A basic question then, often asked by auditors and others, both internal and ex- ternal, is how are the forward curves derived and maintained? © Commodity Technology Advisory LLC, 2015, All Rights Reserved. 1) Managing Forward Curves in A Complex Market, ComTech Advisory White Paper, 2015
  • 3. © Commodity Technology Advisory LLC, 2015, All Rights Reserved. DEMANDS FOR CURVES Only rarely will sources provide complete and accurate forward curves that suit the precise purposes of a market participant. Although external data aggregators can and do provide a variety of pricing data, these prices will typically come from many sources of variable quality and reliability, thus internally derived curves must be used quite frequently. This may be as a result of incomplete published curves, the absence of a liquid market, the lack of reliable sources for prices, or the desire to use a proprietary model on a particular pricing algorithm. In these cases, the onus is on the user of such derived price curves to be able to demonstrate how the price curve has been constructed for audit and other purposes. Curves can be derived in any number of ways, for exam- ple, based upon a nearby liquid market price as a spread, or they may be based on a pricing formula referencing mul- tiple differing liquid prices. In many scenarios, the source data might be provided in different units of measure, or cur- rencies, to that which is required. There is room for error in manipulating price data for unit of measure or currency conversions; therefore, automation of such transformations via rules-based instructions is preferred. Whichever way the price curve is derived, the auditor will need to be able to re- view the construction methodology, as well as see the actual underlying values and calculation of how each price on the curve was derived. For full audit capability, it isn’t just the source prices that need to be maintained along with historical versioning and correction tracking, but also the resulting price curves. Se- rious issues can arise when updated prices are available for a price curve. In effect, after the source price is updated, the derived curve must then be updated, while a historical version of the curve needs to also be maintained in order to allow reproducibility of calculations such as profit and loss or mark-to-market calculations in the past. In order to assure that there is no operator or human error in the process, the price curve should be updated automatically, at the time the updated price becomes available. Finally, there are many versions of curves used for a variety of different purposes such as asset valuation, transfer pric- ing, mark-to-market, value-at-risk and so on. Each of these needs to be maintained with a complete and full history, and the result can be an explosion of forward curve data that needs to be managed with an enterprise strength approach. Furthermore, it is appropriate to restrict the access of differ- ent user types through some form of security system. The Importance of Price Curve Management In A More Regulated Commodity Trading Environment A ComTechAdvisory Whitepaper
  • 4. © Commodity Technology Advisory LLC, 2015, All Rights Reserved. WHAT IS REQUIRED? In many companies, much of the basic work around price curves is performed in spreadsheets. Many E/CTRM solutions actually lack basic curve functionality and pre-suppose that price data, including curves, will be brought in and stored for later use. They lack any ability to derive curves, track changes, monitor reasons for changes and audit such changes. As a result of increased regulatory oversight, commodity-trading firms now need a significantly more robust and auditable solution for forward curve management. This solution should provide: 1/ The ability to define an automated methodology to create forward curves from specified source data, using a simple or complex formulation. 2/ The automated recording of all calculations used within the process of curve creation with a com- plete audit trail. 3/ The long term storage of all source data along with the resulting curves, including versioning of those curves, with the ability to easily access that data on demand. 4/ Testing of curve methodology. Prior to promoting a curve methodology definition to production status, the ability to thoroughly test all the scenarios that a rule-based framework requires to operate effec- tively. This would provide the confidence required for downstream system capture, data integrity and documented proof to any internal or external over- sight. 5/ A rules-based approach which would allow adjust- ments for units of measurement and currency con- versions along with other manipulations. 6/ A rules-based approach which would also provide fallback scenarios in cases where a price is miss- ing or unavailable for a period of time. Should the previous price be used or should some other tem- porary derived price fixing mechanism be used. Again, as more reliable prices came in, the old price curve would be maintained. 7/ Storage for all curves able to be manipulated and the results of those manipulations. The manipula- tions might be used for stress testing or another reason, but it is important to have a complete audit trail of prices, price curves and reasons for chang- es. 8/ Flexibility. It should be relatively easy to set up de- rived curves that are formula-based with a good deal of flexibility. These may be used for pricing or as valuation tools and each needs to be subject to all the rigors outlined above. 9/ Security of access. The auditor will want assuranc- es that access to curves for editing is limited to those responsible. 10/ The ability to visualize the curve and manipulate it within the context of a visualization tool is also a nice to have feature. With an increased demand from inside and outside auditors, regulators and stakeholders for this kind of rigor around prices and forward curves, the time has definitely arrived for comprehensive, robust and flexible solution that meets all of the above criteria. The risk to the business of not being able to demonstrate this level of completeness around prices and forward curves are simply now too great and could threaten lines of credit, equity value and stakeholder sentiment, the profitability of the business and more importantly, its reputa- tion and brand. The Importance of Price Curve Management In A More Regulated Commodity Trading Environment A ComTechAdvisory Whitepaper
  • 5. The Importance of Price Curve Management In A More Regulated Commodity Trading Environment A ComTechAdvisory Whitepaper © Commodity Technology Advisory LLC, 2015, All Rights Reserved. DATAGENIC A COMPREHENSIVE SOLUTION There is no substitute for a purpose-built application that addresses the specific requirements relating to for- ward curves, their construction, storage and integration with target systems. Having the correct agile data man- agement platform in place allows the full complement of services to be harnessed during the curve build and management processes (for instance, validation, business process management, data and process dashboard, etc.). Additionally, the curve building application needs to be highly configurable to account for the many input parameters and rich metadata information that are used in the build process and curve management. Examples include the curve methodology, the source data sets and the fair value hierarchy. DataGenic is a leading provider of software and services in the commodity data management arena including that of forward curve management. It has spent a considerable amount of time and expertise in developing these tools in order to offer a com- prehensive, flexible, transparent and auditable solution that can also integrate with the E/CTRM solution of your choice. DataGenic provides an agile data management structure, the associated processes and controls, the curve building application and framework to provide for the structured management of all curves and curve building methodol- ogies while allowing flexibility to change and adapt the curve construction. Its solutions meet the criteria outlined above while offering many significant advantages and benefits over other solutions including: / Standardized Logic – Rule formation is standardized providing the ability to ensure that standards are de- vised, used and defendable as opposed to writing ap- plications with no standards or with no transparency into the standards used. / Ease of Use – The rules can be written in a ‘natural’ language such as English making it both easy to use and to understand and defend. / Centralized Knowledge Base – All the rules and li- braries are server based so they are accessible and usable by anyone (they are also automatically kept up to date with the latest versions) in and outside of the enterprise. / Transparency – The use of a rules-based system allows users to break problems down into distinct conditions making the logic used more precise, re- liable and understandable to other people such as auditors, regulators and stakeholders. / Mitigation of Key Person Dependency – The central- ized, automated and server based curve construc- tion mitigates the risk of the over reliance on peo- ple-based operations, which include concentrated knowledge, sickness, holidays, and attrition. / Collaborative – Curve building logic does not need to be dealt with in isolation – many people across the enterprise can contribute to the library. DataGenic’s Genic CurveBuilder is a purpose-built application that fully utilizes artificial intelligence and helps to remove the complexity of building curves and allow unlimited flexibility while delivering full transparency. While many still utilize un- documented and uncontrolled spreadsheets or ‘black box’ pro- grams that don’t allow visibility, Genic CurveBuilder provides the kind of a comprehensive solution needed to meet the de- mands of the current regulatory environment. The application supports an unlimited number of curves, curve histories, curve interdependencies and curve complex- ities (combined with curve versioning, curve testing and roll- back). Curve generation is completely automated and fully logged, driven by an event (e.g. data update) or time sched- uled. It also supports any asset class meaning it can handle the needs of the treasury department and any curve construction
  • 6. © Commodity Technology Advisory LLC, 2015, All Rights Reserved. SUMMARY Commodities trading businesses are extremely complex and are increasingly subject to regulation, transparency and report- ing. Funding banks and outside investors are increasingly aware of both the compliance issues and of the risk posed by trad- ing, buying or selling physical commodities and commodities futures. Increasingly, they demand and expect that risk is well managed and that the data utilized by the risk systems is verifiable, defendable and trustworthy. Price data and forward curves are a key and central component in this new era of compliance and transparency and all trading firms now need to ensure that they have a comprehensive, explainable and defendable approach to gathering, calculating and maintaining this critical information, underpinning their transactions and valuations. Under such circumstances, a robust and fully transparent data and curve management application architecture is no longer a luxury option, but rather a base requirement. Under such circumstances, a robust and fully transparent data and curve man- agement capability, such as that provided by DataGenic’s CurveBuilder product, has become a necessity for those trading organizations that find themselves increasingly under the microscopes of regulators, stakeholders and financiers. methodology. In combination with other products and ser- vices delivered by DataGenic, it meets all of the above require- ments and includes comprehensive workflow, data versioning and corrections reporting. DataGenic is also a data aggrega- tor offering over 400 data feeds to its clients. In fact, Data- Genic has built and delivers a suite of applications that handle everything related to data management from cleansing and validation of data to powerful charting and visualization tools to examine and drill down into that data. The Importance of Price Curve Management In A More Regulated Commodity Trading Environment A ComTechAdvisory Whitepaper
  • 7. ABOUT DATAGENIC LTD DataGenic is the leading global provider of on-premise and in-cloud Smart Commodity Data Man- agement software, delivering intelligent analytics, real-time data content and proven business value. The innovative solutions include a data-agnostic multi-commodity data management platform, visual mapping and management of business processes, extensive and extensible data quality management, unlimited for- ward curves construction and an intelligent decision framework. DataGenic customers include participants in the energy, metals, minerals, chemicals, agriculture, shipping and food and beverage industries. DataGenic operates in Europe, Asia and the Americas. For more information, please contact DataGenic at: AMERICAS: +1 281 810 8290 EMEA: +44 203 814 8500 APAC: + 91 802 662 2607 info@datagenicgroup.com
  • 8. ABOUT Commodity Technology Advisory LLC Commodity Technology Advisory is the leading analyst organization covering the ETRM and CTRM markets. We provide the invaluable insights into the issues and trends affecting the users and providers of the technologies that are crucial for success in the constantly evolving global commodities markets. Patrick Reames and Gary Vasey head our team, whose combined 60-plus years in the energy and commodities markets, provides depth of understanding of the market and its issues that is unmatched and unrivaled by any analyst group. For more information, please visit: www.comtechadvisory.com ComTech Advisory also hosts the CTRMCenter, your online portal with news and views about commodity markets and technology as well as a comprehensive online directory of software and services providers. Please visit the CTRMCenter at: www.ctrmcenter.com 19901 Southwest Freeway Sugar Land TX 77479 +1 281 207 5412 Prague, Czech Republic +420 775 718 112 ComTechAdvisory.com Email: info@comtechadvisory.com