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How to Get Rich Investing in Stocks by Riding the Electron Wave

How to Value a Toxic Asset

Stock-Markets / Credit Crisis Bailouts Feb 23, 2009 - 05:44 AM GMT

By: Andrew_Butter


Diamond Rated - Best Financial Markets Analysis ArticlePrice is not the same thing as Value, that's the whole point. Investment is about buying when value is more than price and selling when price is more than value; it's not complicated. Price is easy, the hard part is value.

The "vexing" problem of valuing toxic assets " was how Jeffry Sachs of Columbia University recent described the state of play of the ongoing Black Comedy (

First there was Hank Paulson, now we have Timothy Geithner, both supported by a Grand Operatic Chorus of economists, accountants, and bankers "vexing" advice eloquently from the sidelines.

"BUY those Toxic Assets...Nationalize the Banks... SAVE THE WORLD!!"

One small problem..."I got $700 billion dollars in my back pocket and there is a blank cheque for more where that came from, but, umm... I DON'T KNOW HOW TO VALUE THEM TOXIC ASSETS!!"

That's "vexing" indeed; All the Kings Horses and All the Kings Men, and they can't put Humpty Back Together Again. Oh Dear...perhaps they should have thought about that before they let Humpty fall off the wall?

One would have thought that with all the brainpower deployed on the "problem" that someone ought to be able to figure out how to value those Toxic Assets? I mean it's not hard is it? You just go down the shop, look at the price tag and Bingo!

And it's not as if there aren't some really smart people about; Nouriel Roubini for example, he figured out in 2003 that the kind of current account deficit that USA and UK were running would lead to a crisis as bad as Argentina, except much bigger, and he was right (sounds obvious in retrospect, but that's the thing about rear view mirrors). But smart as he is, EVEN he hasn't come up with just one suggestion for how you value Toxic Assets, and it's not as if he's shy about coming up with ideas.

Now it's more than four months since The US Treasury got the cash and about nine months since they started thinking about it, "vexing" indeed.

Now Jeffrey Sachs says you can "buy" them and then settle up later, when someone figures out the solution to the "problem".

That's a novel idea. One small problem, you can't easily buy something without agreeing a price; pay later sure, but you need to agree a price to put on your balance sheet, otherwise that doesn't do anything for your balance sheet. Imagine Bank of America announcing their results, "Ummm 2009 profit/loss? No idea, we will come back to you on that". Ah I do love it when economists talk dirty about how to do accountancy!


Meanwhile, shares in Citi went down 25% the other day, and everyone is standing around like a bunch of demented penguins looking at that Great White Shark in the water and wondering if they should be the first to dive in, and go fishing? Or perhaps the better part of valor is "after you Nouriel"?

So who knows how to do a valuation like that?

Sam Wylie ( pointed out correctly, it's all very well to talk about "doing a Sweden " but you can't nationalize an international bank in USA without doing a valuation of the assets. Sorry Nouriel, it's a nice idea but it's illegal.

So go on Professor, you are so smart, just one small detail and the world will follow your to hell and back...HOW DO YOU VALUE THEM?

How about calling a plumber, or a dentist?

There's a "good" idea; perhaps they know something about doing valuations? Or perhaps an accountant, surely they know, look even in IFRS they got one whole page on how to do a valuation? Or how about an economist, they are smart, they should know how to do a valuation...shouldn't they?

Or how about looking up how to do it in the “International Convergence of Capital Measurement and Capital Standards” (Basil II) issued by the Bank of International Settlements? It's got 285 pages and it mentions the word "value" 162 times. Perhaps that's worth a read?

Oh dear SORRY they don't explain how to do a valuation either! Plenty of explanation for what you do with one when you got one, but sadly no explanation for how you actually get one!

Here's an idea, perhaps the problem in the first place was that no one knew how to value those assets in the first place, and the "problem" was that a bunch of morons paid too much, and now they are broke?

But it was an Honest Mistake!

I got an idea, how about calling in an Onmistaker? That's the new word for people who are prone to make "Honest Mistakes", there are plenty of them around:

There are two types of "Honest Mistakes" you can make in these circumstances:

HONEST MISTAKE #1 : You can pay too much.

In which case some nasty ungrateful person might suggest after the fact that you had been angling for a "consideration" (hey 5% of $700 billion is a lotta money...if you know what I mean). Could that be why a large part of the three-page manifesto produced to get Congress to approve the TARP plan was about how The Treasury Secretary was not to be considered liable, in the event that he paid too much, or well, anything in fact?

Also (small point) the taxpayer will get screwed.

HONEST MISTAKE #2 : You can pay too little.

In which case the genius of mark-to-market accounting will kick in and all the banks in USA and probably half the world will be technically, and manifestly insolvent, and there will be no way to hide that even with the most creative accounting.

Then BOOM!!

What I say is BRING BACK Arthur Andersen, what we need is some "creativity" in the accounting profession.

There is another small problem; the banks don't want to sell those assets at Fire Sale prices. I know I tried, although OK many of them are still dreaming that the Great Onmistaker will come by and pay (far) too much. We got a word for that in Dubai ; it's called the "Wait for Some Stupid ...... Valuation" (you can play with the ethnics depending on your prejudices).


Meanwhile the call for mass nationalization is getting stronger and stronger. That makes sense; if the bankers don't know how to run banks then the government should have a go; that's logical, they know how to run things don't they?

And still, with all this sense of frantic urgency, no one figured out how to do the valuations.

The GOOD NEWS is that it would appear there is slowly starting to be an understanding by the genius Onmistakers ; the people who gave us the Credit-Crunch in the first place, (although they are slowly falling to Ponzi Schemes, Elections, and Margin Calls), that:

Mark-to market is pure poison.

One thing, which is related to intelligence, (not the WMD intelligence the IQ variety) is that if the Onmistakers managed to create this mess by accident, (it was an accident wasn't it?) what's the chance they can figure out the solution?

Well the market hath spoken, and it looks like the bet is that the chance of that is about a million to one.

Oh Diddums, there you go all dressed up in your smart suit strutting your stuff, and droning on and ON; on Prime Time too, and you haven't got a clue what to do!! So close but so far, you got the cash, you got all the geniuses in the world lined up, but just you don't know how to do a "vexing"!

So if not mark-to-market then what?

Ah the Onmistakers say, "if we abandon mark-to-market, all that's left is book value, and that's even worse!!"

Well they got ONE thing right at least, which is encouraging. YES indeed Diddums, book value is (much) worse that mark-to-market.

That's why after the Asian crisis the best valuation experts in the world all huddled in a corner for about three years to produce International Valuation Standards.

There are two important things about that, the first thing is that it is about (you guessed it) VALUATIONS, the second thing is that it was explicitly designed, wait for it, to tell you how to do valuations! Imagine that, all you got to do is type "Valuation + Standards" on Google and there is the answer!!

And as a special bonus, they have a whole section on how to address the fatal poisonous flaw of mark-to-market.

Which is..."Uhh....when the market is not working well how do you mark to market?"

That was clearly a concept that was too complicated to figure out by the architects of this Great Black Comedy, which is why US GAAP and IFRS don't acknowledge that sometimes markets don't work very well, and sometimes they don't work at all.

So when the market went crazy and created the housing bubble, mark to market all the Onmistakers thought that they were (very rich) geniuses, and bid up the price of assets even more, to levels only seen previously in the 1920's and the Tulip days.

That was of course an "honest mistake".

According to US GAAP, IFRS and Basel II (nothing to do with that Basil guy in Faulty Towers), if the markets don't work properly one day, and you have to do a valuation, then you just sulk and say, "well that's not our fault."

So you shuffle your cards and "hold to maturity" or "hold to sell", or "mark to model" or (and this is hilarious, "mark to quote" - I'm not joking, some of the Maiden Lane transactions were done on that basis). And all the while you can juggle your capital adequacy formulas to "comply", or if not exactly, well at least to make it so complicated that no one can figure out if you are properly capitalized or you are not, so in any event it will take ten years to find out if you were.

Now Hear This distinguished Onmistakers !!

If you all sit down and listen carefully I will explain to you in words of one syllable why it was that on 30th July 2003 ( ) the International Valuation Standards Committee wrote to the Bank of International Settlements (that's the central bankers club - nothing to do with that other word that begins with "W"), and said that the valuations (used by bean counters and Omnistakers ), to assess capital adequacy (and other quite important stuff like are you actually making a profit not or solvent or insolvent), were...wait for it (quote):


OK just in case that's a slightly complicated concept, I will explain. From 2003 to 2007 valuations were done on housing and those valuations assumed that the market was working properly, and so the ratings of bonds collateralized by that housing and capital adequacy and profit (and bonuses), were worked out based on that assumption.

Well sadly, like the man said in Under Siege II (the one with the train), I quote... "Assumptions are the Mother of all F**K ups!" What just happened honorable Onmistaker s, in case you didn't notice, was a F**K up to dwarf all F**K ups.

Here is the thing, the markets were NOT working properly, which is why many of the fantastic "profits" that were declared "mark-to-market" over that period, were not profits, if assessed over a time-span of more than five minutes, they were losses, and half of the loans that were written, are under-water.

I.e. the valuation used to assess capital adequacy and used to calculate profits and BONUSES were "fundamentally flawed and bound to be misleading".

Oh well, you say... "that was an honest mistake - at least under US GAAP and IFRS", and HEY we got audits to prove it!"

Sure that's why you are in Government, you can afford to say things like that; you can put you hand in the pocket of the taxpayer whenever it suits you.

So what's so special about International Valuation Standards?

From time to time in every business there is a requirement to do a valuation of your assets, which is how you work out everyone's bonuses (and other inconvenient stuff like whether your capital adequacy conforms to the regulations, how much money you pay to the taxman, and Oh...I nearly forgot, how much money you hand over to your shareholders).

So putting Voodoo Valuation Standards to one side for a moment, this is how you do a valuation according to International Valuation Standards (IVS).

1: First you ask yourself "What is the purpose of this valuation".

The reason you do that is because a valuation is different depending on the purpose. If for example you want to know what PRICE you can sell an asset for today, then you need to know just that, and a very good marker for that is mark-to-market.

But dear Onmistaker, IF the purpose of the valuation is to figure out what PRICE the asset might be worth in three years time when for example a homeowner sends you a nice gift-wrapped package of Jingle Mail, or when you have to pay back a loan and cover that by selling the asset, THEN the PRICE could be very different.

Oh the Onmistakers say, "but it's very difficult to work out what the price might be in three years time. So lets not bother".

This leads to the second point:

2: IVS clearly mandates that the person doing the valuation must not be a complete idiot.

A good test is that they must be capable of doing more that just looking up the market price today. My wife can do that, that's all I get...."did you know (breathless), that bread in shop "X" is 15% cheaper than in shop "Y"; fascinating, "yes Dear really it is", but if she is as smart as she says she is, why did she marry me?

Yes it's difficult. If it were easy we would let shop attendants and, Onmistakers do it.

Oh you say so "how do you do it?" Well this is how, you spend ten years learning how to do it and you get a collection of your peers who know how to do it to agree that you do know how to do it. Just like brain surgery.

That way if two independent valuation specialists were to do two completely independent valuations, (a) for the same purpose, (b) of the same thing, (c) strictly complying with International Valuation Standards...they could be relied on to come up (independently) with more or less the same answer.

And sweet Onmistaker, if you want to know how that's done, buy a copy of International Valuation Standards, read it (462 pages), and you will start to at least have some sort of clue before you stand up in public and embarrass yourself again.

3: Market Value or Other Than Market Value

The next thing you do is ask yourself the question "Is the market working properly today or not".

If it's not are not supposed to rely on it for a valuation. That's a bit like saying "if you know that the breaks on your car are not working...don't drive it".

Oh say the Onmistakers, "but in that case we can't do a mark-to-market valuation." Yes sweethearts, that's EXACTLY right, you CAN'T.

What you do is as follows:

A: You write in BIG RED LETTERS on the top of your valuation that the market today cannot be relied on because it might be in what IVS calls "disequilibrium", (and the question is "are you sure it's working, not are you sure it's not working"),

B: Then you work out the "Other than Market Value" which is your considered estimate of what, in your opinion the asset would have been worth IF THE MARKET HAD BEEN WORKING PROPERLY.

How you do that is the same sort of principle that you use when you have a toothache (you go to a dentist), or of you have a leak in your house (you call a plumber). You call someone who knows what he is doing to give you his professional opinion.

And if you don't believe him, GET A SECOND OPINION.

DON'T try and do it on your own! I know you can buy self-extraction tools in USA these days to save on dental bills, but I really wouldn't recommend it.

And whatever you do don't ask a bean counter to do it. They know as much about markets as dentists, and to do an Other than Market Valuation you have to know a lot more about markets than going down to the supermarket and checking what the special deal on tins of sardines is today. Bean counters know this, that's why they insist on mark-to-market, otherwise they might be found out as a bunch of Onmistakers.

And Please God, don't ask an economist to do it!

I know economists say their "profession" is a quantitative "science", and sure they use numbers, lots of them, the problem is that if you give two economists the same set of numbers to add up they will come up with different answers. And that's the whole thing about valuations, you get two or a hundred valuations done independently, and the answer should be more or less the same, that's the whole point.

It's interesting to see the resurgence of Keynes; Nouriel Roubini calls him the "world's greatest economist" (he was a mathematician actually). But Keynes had this idea that economics should one day be like plumbing, or dentistry, you got a problem with your economy and you call an economist. And they tell you how to fix it.

Yet search far and wide, you will not find one economist who has a clue how to do a valuation, that's the one job that is needed to "solve" the "vexing" problem, you got All the Kings Horses and All the Kings Men, and they can't figure it out!

What would happen if International Valuation Standards were adopted now?

The other day on a Google jaunt I saw:

This referenced ; a certain Mr. Thomas Patrick of New Vernon Capital examined 3,700 mortgage securitizations from Alt-A mortgages with a face vale of $1.4 trillion. He found $948 billion were current on interest and principal, that's 67%.

But banks were carrying the PERFORMING mortgages at 50% of par due to mark-to-market rules.

If those mortgages were valued by an INDEPENDENT third party valuer (or two if you wanted a second opinion), for the purpose of determining what they would be worth now IF the market were working, then most likely they would be held at what...85% of par, perhaps more?

Perhaps that's why the banks are "insolvent"?

A separate analysis Martin Hutchinson came up with the result that only two big banks in USA are probably zombies, the rest either OK or walking wounded that can recover with some Tender loving Care.

But of course there is a complication, could it be that simple?

Ever stopped to think why banks fell in love with asset backed securities?

Well if all those securities, which are basically mortgages were considered "loans" then the ratios of "hard stuff" that banks would have to employ as a back-up so they could write loans (and conform to banking regulations), would be much higher than if (or after) the loans got magically "transformed" into asset backed securities.

That's because, well everyone knows that (a) loans need to have provisions against default and (b) you can't (easily) trade them. So if the word gets out that your bank is run by a bunch of morons, and all the depositors roll into town to get their money back (like they did at Northern Rock in UK), then quite soon you will run out of cash and you won't be able to pay them because you won't be able to sell the loans easily.

So you will have to go crawling to the Central Bank and say "hey buddy we are too big to fail"...or get strung up by the depositors (and the counter parties too, don't forget them).

But Asset Backed Securities, which are called "ABS" by people in the "know" (no not the brakes but they are just as good on ice), can be traded easily because there is a "market". So Central Banks mandate that banks can hold a lot less cash and other good stuff in reserve if they package loans up into ABS's. Which means they can lend more money to people without any known source of regular income at 100% LTV with teaser rates (which has to be a good thing, doesn't it?).

So bingo - "package up those mortgages", sell some on and make your profit, or hell even keep them on your books. Then go out and LEND LEND LEND.

The theory is of course that if all those depositors turned up looking fierce, you could make a couple of calls, sell the ABS's, and pay money to your depositors.

Great system! Only one problem, if the market for them ABS is stalled. Then you can't sell any, and the depositors start to be rather rude.

Right now the banks have got their knickers in a bit of a twist:

In the run up to the popping of the bubble if they wrote a 100% LTV loan for 100 on Monday, by Friday the asset that was used as a collateral on the loan was worth 150. That's pretty safe isn't it, what's the chance of someone with an asset worth 150 defaulting and then you can't get 100 foreclosing on him? The lower the risk of default the higher the rating of the bond that's structured on it so the less "good stuff" you need to have to carry it on your books.

So mark-to-market everything was looking dandy, and the morons in the banks awarded themselves huge bonuses for engineering this sterling demonstration of how to create a perpetual motion machine, that defied gravity as well, (and the morons on the Boards approved the bonuses).

And the regulator comes by to pick up his tickets for the game, and says "Hey Bob, how are your assets today". And you say "Well hey Hank, mark-to- market they are looking just dandy".

Then Oh DEAR, the price of housing halved (most people with even half a brain are saying 40% peak to trough these days), then the rating agencies started reading their terms of engagement frantically to see if they were liable.

What it says, if it has AAA on the box, is that the probability of default is about 0.26%...if that turns out to be 26% well you risk getting some noses put out of joint.

"Ah...but that was just "An OPINION", an honest mistake!!"

I even heard one of those clowns say that "well we didn't account for market risk". That's funny, they had all these models and models of models working out the statistical probability of default, all based on studies of how actual real-life markets worked in the past, and based on that they proscribed what LTV and DSCR you should use for each tranche as you sliced and diced. It was like a MAGIC edict from on HIGH; us simple peons just ran the numbers like they told us to.

And they didn't think that "markets" might have some bearing on the answer!! So what did they use...Divine Messages from George W?

Now the bankers are a bit stuck, because if they declare that those assets are NOT liquid then they would have to be considered loans, and the amount of "value" that would be created (in terms of capital adequacy) by going back to Book or by employing Voodoo Valuation Standards wouldn't be enough to do the trick to make up for the fact that the asset could no longer be considered liquid.

So two choices (a) mark-to-market (and you are screwed), and (b) don't mark-to-market (and you are screwed too)!!

So how can you un-twist a banker's knickers? it looks like All the Kings Horses and All the King's Men are slowly starting to realize that you can't actually do anything without actually DOING A VALUATION.

Except talk a lot (and "vex"), and there has been a lot of that going around these days!

The only other alternative is to muddle through, pretend that the capital adequacy of the banks is OK and they are not insolvent (a sort of "King has no clothes scenario"), throw a lot of money around at random (some of that HAS to hit the target), and eventually the market will heal itself. It's an expensive strategy, but USA is very much the type of nation that just throws money at a problem until it goes away (that's if they want it to go away).

What's NOT going to happen is nationalization or even putting banks into administration unless they voluntarily come forward and admit that they are insolvent. There isn't the legal structure, there aren't the resources, and there aren't the balls; you need all three!

Mmmm...oh sorry need all four !

The basic problem that banks have now is that if they look at their solvency, well that's Voodoo Valuation Standards, and if they look at their capital adequacy that's still got to be mark to market. A sort of endemic schizophrenia ensues as they hop around on hot bricks.

But the reality is that the government will cover the capital adequacy issue (it's a cushion for a rainy day, well, it's raining)...and the insolvency issue, if you can keep the cash flow going, well that can look after itself. Forget about banning mark-to-market, just say that the government will look after the capital adequacy, the reality is that's what they are doing anyway, the government nationalized the cushion a year ago.

So what happens if they decide to go the VALUATION route?

It's actually not hard, but first you got to get all the people who don't know what they are doing out of the kitchen.

Then you hire or contract some people who understand the product, get them to read International Valuation Standards (at least once), and get them to sit a test if you like (it's not a hard concept and if you can handle the complexity of working with MBS, CDO's and CDS's etc....literally, a week for someone with half a brain to get up to speed).

But they must know something about MARKETS, it's all about markets, knowing how to count backwards from the square root of Pi in your head or wax (or vex) eloquently about the "dangers of current account deficits", just doesn't hack it. An if they don't have a degree in economics, so much the better.

And the important thing to remember about valuation is to identify and clearly flag what you DON'T Know. Then you give an OPINION.

So you set everyone loose with oversight from some people who have been doing valuations all their lives (in accordance with International Valuation Standards), with the following instructions.

1: The valuation should be STRICTLY in accordance with IVS (you can audit that).

2: The Purpose of the valuation is to provide AN ESTIMATE of the "Other than Market Value" of the toxic asset in question (i.e. an OPINION on how much the asset could sell for on the date of the valuation, if the markets were working properly).

3: If you do any insider trading or funny deals with anyone we will transport you off to Guantanamo and water-board you.

That's it.

Could it be that simple?

This is the thing, none of this has any effect on the fiction and fairy stories that the banks might or might not be playing with Voodoo Valuation Standards.

This is something completely different and has ABSOLUTELY NO BEARING (under current laws and regulations) on capital adequacy or solvency.

And if you start to try and mess with the "The King has no clothes" story you will get everyone really nervous, and the last thing you want when Diddums starts to get panic attacks (like now) is people making people nervous.

All that "Other than Market Value" does is provide a rational and transparent basis for knowing how much an interested buyer might reasonably be expected to buy an asset for, and an interested seller might reasonably be expected to sell it for, today, if the market was working.

That's absolutely nothing to do with mark-to-market , fair-value, " hold to maturity", "hold my hand", "mark-to-model", or "mark-to-quote" ...nothing to do with any of that.

The next thing that will happen is that EVERYONE WILL *****!!


Here is a tip, if ever you get into the valuation business (third party i.e. truly independent rather than dressing up one side of the table). Rule of Thumb if everyone doesn't *****, then, you made a mistake.

The banks will say that the value is too low, and the crowd of "vexing" onlookers will say that it's too high. And the government will say well "take it or leave it if you want any more support" , and the banks will say "OK then we will do a "Lehman", so there!!"

Ouch...nasty nasty!! GIRLS!!!

The solution?

Two things you need to know about valuations, first they are OPINIONS; second they are quite regularly proved (in retrospect) to have been WRONG!!

This is explained very nicely in IVS, so long as the valuation was done properly, with all the information that could reasonably be obtained at the time, analyzed properly, and properly documented, even if the answer was completely wrong it is deemed to have been right. And if you don't like that, do another one!!

It's like the referee in UK Football (that's Soccer in USA ). His word is final! There was an incident recently when a referee declared that there was a goal (for those of you who don't know, the point is to get the ball inside the goal), except that the ball actually missed the goal by about two feet. Everyone (except the referee) saw it, the TV played back endless replays, everyone (on the losing side) bitched, (which is because they are sore losers and very un-sportsman-like; but I think they were from Wigan , so you have to make allowances); even the referee admitted that he had made a mistake.

BUT. The goal stood!!

Just because there is uncertainty in every valuation, doesn't mean that they are not useful, they are certainly a lot more useful than those archaic "ratings" which are also OPINIONS but can be wildly more wrong that any valuation done in accordance with IVS (a rating is like a valuation, it says something about the future, the ratings of AAA were opinions, and they were extraordinarily wrong).

The big difference is that IVS is transparent, ratings are (we are told) magic, try and get a rating agency to tell you how he got his result, they won't tell you.

Ratings were invented before anyone had computers (how did they do it then...must have been "divine thought channeling") and they are about as relevant now (and as discredited) and the first version of MS-DOS. Perhaps it's time to upgrade to Vista (or be a devil buy a Mac), the name of that program is International Valuation Standards.

So, you do the valuations; everyone is bitching and if you live in South America you might get shot.

Lot of money at stake, people can get emotional!

But the thing is (a) the government doesn't really want to buy those toxic assets, and it doesn't really care if it makes a profit or not (it's certainly not interested in making windfall profits), (b) the banks would rather not have anything (at all) to do with the government, and particular selling their toxic assets at a price that might just be proven to have been way too low, once the market re-starts.

So this is what you do:

The government offers to buy at say 10% less than the Other than Market Value as assessed above, AND also you have the option of selling to the private sector at the assessed price.

AND the banks have the option to buy that asset back in the future from the government (put a cap on the time), at the price they sold it for, plus a small "consideration", but not from the private sector. So "mark-to-market" the private sector made 10% just playing the game.

Worst case the government paid too much ...well S**T Happens, it won't be the first time. The most important thing is you won't be able to mark-that-transaction-to market (under the stupid rules that exist and should be changed, but not in a hurry or it will be worse), because you will have to price the option.

And who knows what's that might be worth?

I dunno...get a valuation!

Or wait until a market for the options start, if/when that happens you are half way to getting the wholesale market to re-boot, which is what has to happen before the curtain comes down on this dark comedy.

By Andrew Butter

Andrew Butter is managing partner of ABMC, an investment advisory firm, based in Dubai ( ), that he setup in 1999, and is has been involved advising on large scale real estate investments, mainly in Dubai.

© 2009 Copyright Andrew Butter- All Rights Reserved
Disclaimer: The above is a matter of opinion provided for general information purposes only and is not intended as investment advice. Information and analysis above are derived from sources and utilising methods believed to be reliable, but we cannot accept responsibility for any losses you may incur as a result of this analysis. Individuals should consult with their personal financial advisors.

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