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COMPONENT UNIT REPORTING PACKAGE AS OF , FOR THE PREPARATION OF THE FINANCIAL STATEMENTS OF THE GOVERNMENT OF THE U.S. VIRGIN ISLANDS Component Unit: Postal address: Physical address: Agency Head name: Telephone: Fax: E-mail: Finance Director: Telephone: Fax: E-mail: Financial Information Required by Component Unit A component unit is a separate legal entity in which the elected officials of the governmental primary agency (in this case the Government of the U.S. Virgin Islands) are responsible for their own financial administration. A component unit is also an entity whose relationship, nature and importance interface with the primary government agency in a way that their exclusion could result in incomplete financial statements according to the criteria of the GASB No. 14. The financial information requested throughout the Component Unit Reporting Package (the “Reporting Package”) will be used in the preparation of the financial statements of the Government of the U.S. Virgin Islands (the Government) and its related component units as of September 30, , therefore, the information submitted should be for such date or for the year ended on such date, as requested. Remember that the financial information submitted should be in conformity with your entity’s audited financial statements. NOTE: ALL APPLICABLE INFORMATION SHOULD BE INCLUDED IN THIS REPORTING PACKAGE. LINE ITEMS MUST BE COMPLETED WITH THE REQUESTED INFORMATION, WITH ADDITIONAL PAGES ADDED, WHEN NECESSARY. PROVIDING RESPONSES BY MERE REFERENCES TO THE FINANCIAL STATEMENTS WILL NOT BE ACCEPTED. FURTHERMORE, IF THE INFORMATION REQUESTED IS NOT APPLICABLE TO YOUR AGENCY, PLEASE INDICATE SO BY WRITING “N/A” (OR “NOT APPLICABLE”) AND INCLUDE A BRIEF NOTATION WHY THE REQUESTED INFORMATION IS NOT APPLICABLE. DO NOT LEAVE ANY LINE BLANK. Another important element that should be taken into consideration is that all component units of the Government have to implement the requirements to prepare financial statements in accordance with pronouncement 34 of the Governmental Accounting Standards Board, known as GASB 34 as well as any applicable subsequently issued pronouncements. The Reporting Package, along with your entity’s audited financial statements, is required by our external auditors and should be sent to the Commissioner of Finance, Department of Finance, 2314 Kronprinsdens Gade, St. Thomas, VI 00802. This information must be forwarded to the Department of Finance within one hundred and twenty (120) days of your entity’s fiscal or calendar year-end. If your entity cannot comply with this date, the Agency Head must prepare written notification addressed to the Commissioner of Finance, no more than thirty days (30) prior to the one hundred and twenty (120) day requirement, which delineates and includes: 1) management’s reason(s) for non-compliance with the aforementioned one hundred and twenty (120) day cut-off date, which must be jointly agreed-upon and formally communicated, in writing, to the independent auditing firm engaged to issue the audited financial statements, 2) a firm date of issuance for the audited financial statements and corresponding Reporting Package, which must be jointly agreed-upon and formally communicated, in writing, to the independent auditing firm engaged to issue the audited financial statements, 3) a firm date that the audited financial statements of issuance will be delivered to the Department of Finance, and 4) submission of a “draft” Reporting Package to the Department of Finance within one hundred and twenty (120) days of your entity’s fiscal or calendar year-end that is fully complete with unaudited financial information. This is important because the Government is mandated by Federal statute to submit its audited financial statements within two hundred and seventy (270) days, therefore, the expeditious dissemination of your entity’s audited financial statements in concert with the accompanying Reporting Package, within one hundred and twenty (120) days of your entity’s fiscal or calendar year-end, must be followed to full compliance by the Government. If the year-end date for the financial statements of the component unit is not September 30th, the requested information should be submitted within one hundred and twenty (120) days of your entity’s fiscal or calendar year-end. It is important to note that, once the Reporting Package is completed, it must be reviewed by your external auditors to verify that the financial information is consistent with the audited financial statements. Moreover, the external auditors should provide an attestation confirming the accuracy of the financial information contained within the Reporting Package. NOTE: REMEMBER THAT THE INDIPENDENT AUDITORS FIRM CONTRACTED BY THE COMPONENT UNIT MUST ALSO RESPOND TO THE INDEPENDENCE REPRESENTATION LETTER SENT BY OUR EXTERNAL AUDITORS. For any questions, comments or concerns related to the Reporting Package, please contact the Commissioner of Finance, Department of Finance, 2314 Kronprinsdens Gade, St. Thomas, VI 00802. Guides and Useful Publications In order to inconsistencies in the implementation of the requirements of GASB 34, and other complex pronouncements, we request that all entities obtain the following guides and publications for the preparation of their basic financial statements and related disclosures: Governmental Accounting, Auditing, and Financial Reporting – Using the GASB 34 Model – Published by the Government Finance Officers Association – available at www.gfoa.org. Publications of the Governmental Accounting Standards Board (GASB) – available at www.gasb.org. Codification of Governmental Accounting and Financial Reporting Standards – (Statement 34 Edition): Section 2300.901 of this publication has a useful checklist to determine if the basic disclosures, applicable to each component unit, has been included Implementation Guides – Questions and Answers: Guide to Implementation of GASB Statement 9 on Reporting Cash Flows of Proprietary and Nonexpendable Trust Funds and Governmental Entities that Use Proprietary Fund Accounting – (Note - GASB 34 amended this pronouncement and now it only allows for the preparation of the statements of cash flows using the direct method) Guide to Implementation of GASB Statement 10 on Accounting and Financial Reporting for Risk Financing and Related Insurance Issues Guide to Implementation of GASB Statement 14 on the Financial Reporting Entity Guide to Implementation of GASB Statements 43 and 45 on Financial Reporting for Postemployment Benefit Plans Other than Pension Plans and Accounting and Financial Reporting by Employers for Postemployment Benefits other than Pension. Guide to Implementation of GASB Statement 31 on Accounting and Financial Reporting for Certain Investments and for External Investment Pools. Guide to Implementation of GASB Statement 34 on Basic Financial Statements – and Management’s Discussion and Analysis – For State and Local Governments Implementation Guide – Guide to Implementation of GASB Statement 34 and Related Pronouncements General Information Enter the name of the component unit, the law that created it, a brief description of its functions, its organization and any other general information. Legal name: legislation: Description of its main functions: Please indicate the name of the members of the Entity’s Board of Directors and their positions. Also, indicate the position of the members of the Entity’s Board of Directors within the Cabinet or if it is a private company. The Board of Directors of the consists of members. Please indicate the process for the selection of each one of the members of the Board of Directors (e.g., appointed by the Governor, appointed by the Governor with the Senate consent, by referendum, by industry professionals, public interest, etc.): Information Related to the Audited Financial Statements of the Component Unit In addition to the information requested throughout this Reporting Package, please include a copy of the audited financial statements for the year ended September 30, , including the independent auditor’s report relating to the audited financial statements. The audited financial statements should include at least the balance sheets, statements of operations and cash flows with its corresponding notes. Entity Fiscal Year End: September 30, Audit Opinion Issued: If opinion has been modified (other than unqualified opinion) please complete the following: Type of Modification: Reason for Modification: Amount (if determinable): Correction Action Plan to be taken by Component Unit to resolve the issue: Type of Modification: Reason for Modification: Amount of Modification (if determinable): Correction Action Plan to be taken by Component Unit to resolve the issue: Type of Modification: Reason for Modification: Amount of Modification (if determinable): Correction Action Plan to be taken by Component Unit to resolve the issue: Type of Modification: Reason for Modification: Amount of Modification (if determinable): Correction Action Plan to be taken by Component Unit to resolve the issue: Type of Modification: Reason for Modification: Amount of Modification (if determinable): Correction Action Plan to be taken by Component Unit to resolve the issue: Type of Modification: Reason for Modification: Amount of Modification (if determinable): Correction Action Plan to be taken by Component Unit to resolve the issue: Type of Modification: Reason for Modification: Amount of Modification (if determinable): Correction Action Plan to be taken by Component Unit to resolve the issue: Type of Modification: Reason for Modification: Amount of Modification (if determinable): Correction Action Plan to be taken by Component Unit to resolve the issue: Type of Modification: Reason for Modification: Amount of Modification (if determinable): Correction Action Plan to be taken by Component Unit to resolve the issue: Type of Modification: Reason for Modification: Amount of Modification (if determinable): Correction Action Plan to be taken by Component Unit to resolve the issue: Financial Statements – Format GASB 34 Basic Disclosures List During the preparation of basic financial statements please follow these guidelines to you have all required disclosures: Governmental Accounting, Auditing, and Financial Reporting – Using the GASB 34 Model – Published by the Government Finance Officers Association – Available on www.gfoa.org (Pages 177 to 211) Codification of Governmental Accounting and Financial Reporting Standards – (Statement 34 Edition) – Published by the Governmental Accounting Standards Board – Section 2300.901 of this publication has an easy to follow list to determine if the basic disclosures applicable to each component unit has been included Deposits and Investments – GASB 40 (Amendment to GASB 3) Cash and Investment Risk Categories Information concerning cash and investment risk categories is required by GASB 40 Deposit and Investment Risk Disclosure. Please complete the following tables related to the cash and investment risk, using the Excel spreadsheet entitled “Component Unit_Reporting Package_FY10_FINAL_October 31 2010.” Credit Risk Please provide agency policy relating to credit risk. Concentration of Credit Risk Is there a Concentration of Credit Risk? If the answer is in the affirmative, please explain. Interest Rate Risk Please provide agency policy relating to risk of interest rate. Please complete the following table using the Excel spreadsheet entitled “Component Unit_Reporting Package_FY10_FINAL_October 31 2010.” Foreign Currency Risk Please provide agency policy relating to foreign currency risk, if applicable. Please complete the following table related to foreign currency investments using the Excel spreadsheet entitled “Component Unit_Reporting Package_FY10_FINAL_October 31 2010.” Accounts Receivable from Other Governmental Entities Due from other governmental entities Remember to confirm the balance with the governmental entity with which the transaction occurred to avoid differences between agencies. Please indicate any differences found and the reason for the same. Differences found (details) Capital Assets For capital assets the following information is required: Policy to capitalize assets including infrastructure Policy for estimating the useful life of capital assets used to calculate depreciation Also, GASB 34 requires presenting detailed information in the notes of the financial statements relating to the capital assets. Historical cost and accumulated depreciation should be segregated in the following categories: The main classifications for capital assets are (land and land improvements, infrastructure, buildings and improvements, vehicles, equipment, construction in progress, etc.) Governmental activities Business-type activities Capital assets that are or have been depreciated Capital assets that have not been depreciated (including infrastructure reported under the modified approach of depreciation) The following information should be presented for each of the major classifications of capital assets and accumulated depreciation in the notes to financial statements Beginning balance Increases (for example, acquisitions of capital assets, capitalized improvements, current depreciation expense relating to the accumulated depreciation) Reductions (for example, sale of capital assets and other dispositions) Ending balance Notes to the financial statements need to present the amount of depreciation for the fiscal year charged to each of the functions of government (for example, general government, public safety, health, education, public housing and welfare, culture and recreation, transportation and communication) Blended Component Units Please complete Attachment B Discretely Presented Component Units Please complete Attachment C Works of art and historical treasures Works of art and historical treasures are similar assets and as capital assets they must be capitalized subject to certain restrictions. Capitalized collections should be presented in the notes to the financial statements as segregated into two categories: non-depreciable and depreciable. If there are collections that were not previously capitalized, the notes to the financial statements should include a description of the collections and the reasons why there were not capitalized. Other Construction-in Progress commitments: Please describe active construction projects through (date), the costs incurred to date and the remaining estimated cost to complete the project. Restricted assets Agency’s restricted assets consist of cash, investments and other assets to be used for the following purposes: Due To Governmental Entities* Amounts Due to Governmental Entities (Not Accounts Payable): Accounts Payable and Other Amounts Due To Governmental Entities* Accounts Payable and Other Amounts Due to Governmental Entities: Do not include notes payable or bonds to other governmental entities. Include name of the sections where the account payable is included in the financial statements. Please detail any difference found when confirming the balances with the governmental entity with which the transaction was performed Compensated Absences – GASB 16 Indicate the cumulative amount for vacation pay and sick leave, and indicate in which section of the financial statements it is included. ** Please provide name of the section in the financial statements in which such accrual is reflected. Long Term Obligations Payable (Bonds, Notes) Provide the requested information related to long-term payable obligations and the movement of such obligations during the year using the Excel spreadsheet entitled “Component Unit_Reporting Package_FY10_FINAL_October 31 2010.” Please submit bond and note information separately. (Please do not make references to financial statements without writing anything.) Bonds Payable Bonds- Rollforward and Amortization Schedule Year ended : Future debt obligations by year due of above mentioned bonds. Year ending : Note: Total balance of principal must coincide between both analyses. Financial information submitted should coincide with the audited financial statements. Obligations Payable to Non-Governmental Units (Excluding Bonds) Future debt obligations of the above mentioned payable(s) Year ending : Note: Total balance of principal must coincide between both analyses. Financial information submitted should coincide with the audited financial statements. Presentation of Obligations for Financial Statements Presentation of Revenue and Expenses for Financial Statements GASB 34 requires as part of the financial statements to present a statement of activities. In the table below present the income and expenses of the component unit segregated under the provisions of statement, using the Excel spreadsheet entitled “Component Unit_Reporting Package_FY10_FINAL_October 31 2010.” Total must be the same as the total of reported in the financial statements. Blended Component Units Discretely Presented Component Units Changes in the Reporting Legal Entity, in Policies and Other Changes in Net Assets Please describe any changes done to the reporting entity during Fiscal Year 2010 (e.g., transfer of operations, consolidations and termination of certain operations, creation of new subsidiaries or , change in the nature of the operations, etc.) RISK MANAGEMENT Please describe risk programs managed by your organization, if applicable, (e.g., self insured) CONTINGENCIES Please describe contingencies of the entity as of , including amounts registered in books to cover potential negative consequences. Subsequent Events Disclose subsequent events at the closing date of the financial statements until the date of preparing report. Subsequent events are transactions that affect the value of an asset or create a debt and will have a material affect on the Balance Sheet or Income Statement. Only accomplished or planned transactions with a value of $500,000 should be considered. Some examples of subsequent event transactions are: resolution of legal cases, costs questioned by the Federal Government, new lawsuits, new bond issues and sales of significant assets. Contributions Provide the following information related to the contributions received by the Government (including PFA payments made on behalf of the Component Unit) as of , and during the fiscal year ended. Please confirm with the Government to avoid differences between the Government’s financial statements and its component units. 1. Operational Contributions 2. Capital Contributions 3. Receivable balance as of : Note: Provided information should correspond with audited financial statements. Certification I certify that the information submitted on these forms is correct to the best of my knowledge and understanding. Title: Firm Name: Date: Reminder REMEMBER THAT THE INDEPENDENT AUDITING FIRM CONTRACTED BY THE COMPONENT UNIT MUST RESPOND TO THE INDEPENDENCE REPRESENTATION LETTER SENT BY THE INDEPENDENT AUDITING FIRM OF THE GOVERNMENT. THE FOLLOWING REPORTING PACKAGE HAS BEEN REPRODUCED WITH THE WRITTEN CONSENT OF THE GOVERNMENT. THIS WRITTEN CONSENT IS EXPRESSLY AND EXCLUSIVELY FOR THE USE OF GOVERNMENT AS A TOOL IN THE PREPARATION OF ITS BASIC FINANCIAL STATEMENTS. THIS AUTHORIZATION IS NOT AUTOMATICALLY EXTENDED TO ANY OTHER ENTITY, THEREFORE, THE USE OF THIS REPOTING PACKAGE IS LIMITED TO THE INFORMATION CONTAINED HEREIN. Attachment A: Component Unit General Information Component Unit: Postal address: Physical address: Agency Head name: Telephone: Fax: E-mail: finance director: Telephone: Fax: E-mail: point of contact: Telephone: Fax: E-mail: EXTERNAL AUDTOR: NAME: Telephone: Fax: E-mail: EXTERNAL AUDTOR: MANAGER NAME: Telephone: Fax: E-mail: Attachment B: Capital Assets – Blended Component Units Governmental Activities Rollforward Business-Type Activities Rollforward: Depreciation Expense by Function of Government: Attachment C: Capital Assets – Discretely Presented Component Units Total Depreciation Expense: $ Name of Officer Position Selection Process Term / Expiration Date Michael Jetson, Jr. Chairman Appointed by Governor Two (2) Years / February 2012 Larry Dutch Secretary Appointed by Governor Two (2) Years / February 2012 AMOUNT AMOUNT AMOUNT AMOUNT Cash and cash equivalents: Balance in Books Balance in Bank RESTRICTED NOT RESTRICTED Deposits in commercial banks Deposits in governmental banks Total 0 0 0 0 Investments Ratings Ratings Ratings AMOUNT AMOUNT Market Value MOODY's Standard & Poor RESTRICTED NOT RESTRICTED Mortgage Backed securities US Government and agency securities Negotiable certificates of deposit US Corporate Stocks Non US Corporate Stocks US Corporate Bonds Commercial Paper Foreign and municipal bonds Money Market Fund Security Lending Transactions Investment in equity securities Other (_____________) Total Investments 0 0 0 0 0 Maturity Maturity Maturity Maturity Maturity Maturity Asset Type Maturity From/To Market Value Less Than 1 Year 1-5 Years 6-10 Years More Than 10 Years No Established Maturity Grand Total Mortgage Backed securities US Government and agency securities Negotiable certificates of deposit US Corporate Stocks Non US Corporate Stocks US Corporate Bonds Commercial Paper Foreign and municipal bonds Money Market Fund Security Lending Transactions Investment in equity securities Other (_____________) Total 0 0 0 0 0 0 0 Type of Investment Local Currency Market Value Governmental Agency Line in Financial Statement Amount Receivable Purpose Name of the Project Cost through (date) Commitment Remaining Restricted Asset Type Purpose / Description Amount Governmental Entity Date of Transaction Purpose Amount Due As of Maturity Governmental Entity Date of Transaction Purpose Amount Due As of Maturity Line item of the Financial Statements ** Balance as of Vacation Accrued Sick Leave Accrued Other (Specify) Series Interest Rate Maturity Through Beginning Balance Additions Reductions Ending Balance Amount due within one year Subtotal Bonds Subtotal Bonds Subtotal Bonds Less: unamortized debt reacquisition costs Less: unamortized debt reacquisition costs Less: unamortized debt reacquisition costs unamortized Premium/(Discount) unamortized Premium/(Discount) Total bonds - - - - - Year ending September 30, Principal Interest Total 2011 2012 2013 2014 2015 2016-2020 2021-2025 2026-2030 2031-2035 Thereafter Debt Reacquisition Cost Premium/(Discount) Total Type of Obligation (Notes Payable, Line of Credit, etc.) Interest Rate Maturity Through Beginning Balance Additions Reductions Ending Balance Amount due within one year Total - - - - - Year ending September 30, Principal Interest Total 2011 2012 2013 2014 2015 2016-2020 2021-2025 2026-2030 2031-2035 Thereafter Total Obligations due within a year Amount Subtotal Obligations due in more than a year Subtotal Debt Total Presentation of Revenue and Expenses for Financial Statements - Blended Component Units Presentation of Revenue and Expenses for Financial Statements - Blended Component Units Presentation of Revenue and Expenses for Financial Statements - Blended Component Units Presentation of Revenue and Expenses for Financial Statements - Blended Component Units Presentation of Revenue and Expenses for Financial Statements - Blended Component Units Presentation of Revenue and Expenses for Financial Statements - Blended Component Units Presentation of Revenue and Expenses for Financial Statements - Blended Component Units Presentation of Revenue and Expenses for Financial Statements - Blended Component Units Net (Expense) Revenue and Changes in Net Assets Net (Expense) Revenue and Changes in Net Assets Net (Expense) Revenue and Changes in Net Assets Net (Expense) Revenue and Changes in Net Assets Program Revenues Program Revenues Program Revenues Program Revenues Program Revenues Program Revenues Primary Government Primary Government Primary Government Primary Government Functions Expenses - Total Charges for Services Charges for Services Operating Grants and Contributions Operating Grants and Contributions Capital Grants and Contributions Capital Grants and Contributions Governmental Activities Business-Type Activities Business-Type Activities Total Primary Government Governmental activities General Government $ $ $ $ $ $ $ $ $ Public Safety Health Education Public Housing and Welfare Culture and Recreation Transportation and Communication Total governmental activities $ $ $ $ $ $ $ $ $ Business-Type Activities Lotteries $ $ $ $ $ $ $ $ $ $ Unemployment fund Other (Specify) Total business-type activities $ $ $ $ $ $ $ $ $ $ Total primary government $ $ $ $ General Revenues General Revenues General Revenues $ $ $ $ Taxes Taxes Taxes Interest and other Interest and other Interest and other Other (please list) Other (please list) Other (please list) Contributions to permanent funds Contributions to permanent funds Contributions to permanent funds Contributions to permanent funds Special items Special items Special items Transfers Transfers Transfers Total general revenues, contributions, special items and transfers Total general revenues, contributions, special items and transfers Total general revenues, contributions, special items and transfers Total general revenues, contributions, special items and transfers $ $ $ $ Change in net assets Change in net assets Change in net assets Change in net assets Net assets - beginning Net assets - beginning Net assets - beginning Net assets - ending Net assets - ending Net assets - ending $ $ $ $ Presentation of Revenue and Expenses for Financial Statements – Discretely Presented Component Units Presentation of Revenue and Expenses for Financial Statements – Discretely Presented Component Units Presentation of Revenue and Expenses for Financial Statements – Discretely Presented Component Units Presentation of Revenue and Expenses for Financial Statements – Discretely Presented Component Units Presentation of Revenue and Expenses for Financial Statements – Discretely Presented Component Units Presentation of Revenue and Expenses for Financial Statements – Discretely Presented Component Units Presentation of Revenue and Expenses for Financial Statements – Discretely Presented Component Units Presentation of Revenue and Expenses for Financial Statements – Discretely Presented Component Units Program Revenues Program Revenues Program Revenues Program Revenues Program Revenues Net (Expense) Revenue and Changes in Net Assets Functions Expenses - Total Charges for Services Operating Grants and Contributions Capital Grants and Contributions Capital Grants and Contributions Capital Grants and Contributions [Insert Component Unit Name] Component Unit [Insert Name of Component Unit] $ $ $ $ $ $ $ General Revenues $ Interest and other Other (please list) Contributions to permanent funds Contributions to permanent funds Contributions to permanent funds Contributions to permanent funds Special items Transfers Total general revenues, contributions, Total general revenues, contributions, Total general revenues, contributions, Total general revenues, contributions, special items and transfers special items and transfers special items and transfers $ Change in net assets Change in net assets Change in net assets Change in net assets Net assets - beginning Net assets - beginning Net assets - ending Net assets - ending $ Date Description of Subsequent Event(s) Amount Receipt Date Description Amount received Total Receipt Date Description Amount received Total Operational Contributions Capital Contributions Total Agency Head Signature Finance Director Signature Print Name Print Name Date: Date: INDEPENDENT AUDITING FIRM OF COMPONENT UNIT: Signature Print Name Initial Balance Final Balance Additions Withdrawals Transfers Governmental Activities Non Depreciated Capital Assets: Land and land improvements Infrastructure Construction in progress Total Non Depreciated Capital Assets Other Capital Assets: Buildings and building improvements Equipment and furniture Infrastructure Others (specify) Total of Other Capital Assets at Historical Cost Less Accrued Depreciation: Building and property improvements Equipment and furniture Infrastructure Others (specify) Total Accumulated Depreciation Total Net Capital Assets of Governmental Activities Initial Balance Final Balance Additions Withdrawals Transfers Business-Type Activities Non Depreciated Capital Assets: Land and land improvements Infrastructure Construction in progress Total Non Depreciated Capital Assets Other Capital Assets: Buildings and building improvements Equipment and furniture Infrastructure Others (specify) Total of Other Capital Assets at Historical Cost Less Accrued Depreciation: Building and property improvements Equipment and furniture Infrastructure Others (specify) Total Accumulated Depreciation Total Net Capital Assets of Business-Type Activities Governmental Activities: General Government Public Safety Health Education Public Housing and Welfare Culture and Recreation Transportation and Communication Total Depreciation Expense for Governmental Activities Business-Type Activities: Lotteries Unemployment fund Other (Specify) Total Depreciation Expense for Business-Type Activities Initial Balance Final Balance Additions Withdrawals Transfers Non-depreciated Capital Assets: Land and land improvements $ - Infrastructure - Construction in progress - Total of non-depreciated capital assets $ - Other capital assets: Building and property improvements - Equipment and furniture - Infrastructure - Others (specify) - Total of other capital assets at historical cost $ - Less: Accumulated Depreciation Building and property improvements - Equipment and furniture - Infrastructure - Others (specify) - Total Accumulated Depreciation $ - Total of Capital Assets $ - $ - $ - $ - $ -