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HomeMy WebLinkAbout1990-11-06; City Council; 10898; GENERAL LIABILITY INSURANCE COVERAGE OPTIONSr e ~.L.I DZ CL b 2 .. g F 2 6 z 3 0 0 ur wmLamnv - AUCN BILL t/’ L’ AB#m TITLE: GENERAL LIABILITY INSURANCE DEPT. MTG. 11/6/90 - COVERAGE OPTIONS CITY I DEPT. RM CITY I RECOMMENDED ACTION: Direct staff to submit an application for membership to the California Municipal Insurance Authority (CMIA). ITEM EXPLANATION Since 1986, commercial liability insurance for public agencies, especially municipalities, has all but disappeared. Attempts to find such coverage in the traditional insurance markets have been unsuccessful. Cal-Surance, the City’s insurance broker, has made repeated inquiries into the marketplace but has found either little or no interest. The City of Carlsbad has been without auto and general liability insurance coverage and public officials liability protection since the cancellation of its policies in early 1986. As a result, one of the on-going objectives of the Risk Management Department has been to try and locate a source of liability coverage for the City. Such a source would provide the City Council with the opportunity to determine whether the City should continue to remain self-insured or whether it should absorb the cost of acquiring whatever limited coverage is available. In late 1989, a limited amount of Commercial General Liability Insurance began to become available. During that same time period, the City had completed the review process for membership in a municipal insurance pool. After reviewing the situation at length, it was determined that further study of the problem was warranted and that outside assistance should be utilized in order to provide the City with an in-depth analysis of the limited, but expanding, number of options that were becoming available for consideration. In March of 1990, Mr. Don Voller, of Tillinghast, a Division of TPF&C, the City’s benefit consultant, was asked to provide consulting services for this task. At his recommendation, applications for coverage were submitted to two national insurana brokerage firms for marketing. Frank B. Hall and Sedgwick James were utilized for that purpose. Each firm was directed to shop in markets that were available to ther but to refrain from duplicating each others efforts. As a result, one proposal for coverage was received from each of those brokers for consideration. In addition, M Voller conducted a review of existing municipal insurance pools in order to determi1 whether or not any of them would provide a viable option for consideration. 7- e m PAGE 2 OF AI3 # /<, FYf Mr. Voller analyzed the commercial insurance proposals and the various municipal insurance pool programs and submitted his recommendation to the City on September 20, 1990. It should be noted that City staff participated in the discussions regarding the various program proposals on an on-going basis. At this point in time, there are three alternatives available to the City: 1. 2. 3. Staffs recommendation is that (a) the pooled insurance alternative (#3) be selected and (b) the City of Carlsbad submit an application for membership to the California Municipal Insurance Authority (CMIA) in order to acquire general liability coverage through its pooled insurance program. FISCAL, IMPACT At this point in time, there is no fiscal impact upon the City. However, once the application process is completed, payment of the deposit premium will be required. It is anticipated that the deposit premium for membership in the California Municipa Insurance Authority (CMIA) will be in the range of $400,000 annually. Entry into thc program in mid-year will result in the premium being prorated. EXHIBITS 1. Continue to assume the liability risk and remain self-insured; Acquire liability insurance coverage through the commercial market; or Acquire liability insurance coverage through a pooled insurance program. Liability Insurance Proposals Options Analysis + m 0 CITY OF CARLSBAD LIABILITY INSURANCE PROPOSALS OPTIONS ANALYSIS Prepared By: Tillinghast, A Towers Perrin COmpa September 19, 1990 TiZZingbm a Towers Perrrn CI I ., e 0 CITY OF CARLSBAD LIABILITY INSURANCE PROPOSALS OPTIONS ANALYSIS BACKGROUND The City of Carlsbad is uninsured with respect to liability rid The City adopted this position three years ago when the commerciz insurance market became extremely restrictive, and the coverage ai limit of insurance available offered little, if any, cost benefii The City explored entry into the JPA formed by cities in San Die< County but chose not to participate. Faced with a growing concei about remaining O1bare1' on liability risk and having received i offer from the California Municipal Insurance Authority (CMIA) , tk City is interested in an in-depth analysis of the CMIA proposal a1 a further analysis of available options. Tilli%@m m a Towers Pevrin co ?, rn m DISCUSSIONS OF OPTIONS Tillinghast reviewed the present liability risk program of the Cii of Carlsbad. Exhibit A. is a discussion of the present program ai the options that are available to the City. Our discussion rep0 recommended that the City change from its program of total sel insurance and consider a variety of options available to cap t City's liability risk. The recommendations specifically called f the consideration of either commercial excess liability insuran or participation in a risk management and insurance Joint Powe Authority. As a result of the recommendation City staff underto to acquire commercial insurance quotations and to evalua additional JPAs in comparison to the existing proposal to join t California Municipal Insurance Association (CMIA). ANALYSIS OF INSURANCE AND RISK MANAGEMENT JPAS We evaluated a number of JPAs based upon information developed the League of California Cities and independent informati obtained through Tillinghast client sources. The comparison five individual JPAs are displayed in Exhibit B. In additic since one of the key factors in comparison involves insurar policy coverage, we have displayed the coverage differences Exhibit C. The differential between the JPAs is not great wk objective issues are charted. There are other issues, howevc that are important: , Tilliqhm I R Towers Perrin cl , w 0 Two of the JPAs (BICEP and ICRMA) are capitalized by th utilization of Certificates of Participation (COP). Ne members have to participate in the COP on a pro-rata basis We do not recommend consideration of a JPA funded in thi manner as it becomes an unnecessary financing technique Experience appears to demonstrate that JPAs can b successfully funded by annual premium contributions withou the necessity of using COP. 0 Tillinghast believes that long term stability c administration and management of the JPA is best accomplishe by the use of full time staff. Management under thes conditions is more stable and the interests of the members ar better reflected by the staff. SANDPIPA and OCCRMA ar supported by independent outside consultants in key areas c risk management and underwriting. Both of these JPAs ha\ opposed building staff. ICRMA is managed by one consultant c a I1turnkeyl1 basis, which is and improvement over tk individual consultant approach. BICEP is in the process c hiring an independent risk manager, continuing to rely untj then on the services of the insurance broker for the JP2 CMIA has taken the approach of using fulltime staff and j managed by an individual with an outstanding reputation in tk public sector. TiZZingbm a Towers Pervin co I rn 0 Financial condition of the JPA is a critical element i developing long term stability and cost control. We ha access to detailed financial information for CMIA, SANDPI1 and BICEP. All three of these JPAs are very solid from financial standpoint. The attitude of the JPA from financial standpoint is important because it impacts tk stability of annual premium funding. The more conservatiT the approach, the greater premium cost stability is expectc to be achieved. SANDPIPA appears to be the most conservatil in its approach, but all three JPAs are consewative. It : not anticipated that great fluctuations will occur on i annual basis, absent unusually bad loss experience. Finances can be affected by the amount of loss that is poolec None of the JPAs pooled what we believe to be an excessi. amount of loss. Based upon the number and size 1 participants, only BICEP appears to be pooling extraordinary amount. But, even in BICEP, this amount pooled loss is mitigated by the existence of COP financi that is the JPA's backup source of funding. o Geographic concentration of participants can be a significa issue, particularly when the participants are commonly pooli or consulting on other areas of operation. Initially, JP were concentrated geographically but as they have expande there are been a tendency to acquire members throughout t Tillingbm a Towers Perrin c( I z 0 0 state or at least in contiguous counties. In our. opinior geographic distribution of membership is not a drawback to successful JPA. The issue of geographic concentration is be: evaluated by the City as it reviews its links with other Sz Diego or Orange County cities. 0 All JPAs are expanding their rlproductrl line. Most JPAs we] formed to pool liability risk, but most that have SOI maturity offer other insurance products generally on a joii purchase basis rather than an approach through the pooling ( loss. The only differences between JPAs with respect to th. question is in the length of time that the JPA has been . operation. Virtually all JPAs are attempting to broaden tl insurance products and services offered to their membershi] COMMERCIAL INSUWCE PROPOSALS The City has received two commercial excess liability insuran proposals. The terms of coverage and the limits and cost a reflected in Exhibits C. and D. One of the important subjecti. issues with respect to commercial insurance is the durability the insurance market and the stability of annual premium cost. T insurer sponsored by Frank B. Hall has been in the public sect marketplace for many years. Its coverage and cost have vari somewhat over this period but it has never failed to provide market of some value even in the most difficult of times. T TiLling-haJ a Towers Perrin c6 .) - e m market sponsored by Sedgwick James is new to the public entit market, but the overall program manager has been in the publi sector for many years. With the use of another insurer thj program manager was the last provider of excess liability insuranc to the City of Carlsbad. CONCLUSIONS AND RECOMMENDATIONS 0 The commercial excess liability insurance proposals ai reflective of the most competitive market conditions in tl past decade. Des-pite the competitiveness of the market, tl cost remains high and will probably increase at the ne: market turndown. Coverage is reasonable in relation to th; offered by JPAs. Coverage, however, has been more restrictiy in the past and similar to premium cost will probably chanc to a more restrictive form at any market turndown. 0 Early indications of maturing experience seem to indicate th, JPAs are doing a good job of fulfilling their objective * stabilize premium cost over a period of time. We anticipa. that this will continue in those areas of cost that a pooled. The JPAs are still subject to the insurance market 1 excess layers of liability insurance where the JPA acts as agent for the participants. The bulk of the cost liability, however, is still contained in the pooled layers that the cost fluctuation, while not eliminated, is heavily mitigab TilliTZ&Z I aTowers Perrin ci a w e 0 In our preliminary evaluation, we reduced the JPA options 1 CMIA and SANDPIPA. We recommend that CMIA be the JPA c choice for the City. In our opinion, they have demonstratc competitive cost and a flexibility of approach. They a15 have a fulltime staff that is professional and attentive 1 the needs of their members. This JPA also continues to grc and attract new participants. As this growth continues, thc should achieve greater stability and offer better purchasii power in the non-pooled risk areas. 0 We recommend that the City move from its present position 1 non-insurance on liability risk and apply to CMIA fl acceptance and an updated cost proposal for the current yea Tillingba I a Towers Perrin ci rn m .. CITY OF CARLSBAD LIABILITY OPTIONS ANALYSIS SUMMARY Tillinghast has reviewed the options available to the City of Carlsbad with respect to the funding of liability risk and have the following recommendations: 0 Request a proposal from S. J. Petrakis Insurance Services, Inc. for liability insurance with a $10 million limit of liability, excess of optional Self Insured Retentions of $250,000, $500,000 and $1 million per occurrence o Request a proposal from the AIG Companies for liability insurance with a $10 million limit of liability, excess of a Self Insured Retention of $1 million. o Request the broker selected by the City to secure the AIG proposal to verify the availablity of any special programs Tillingbm I a Towers Pewin ti J rn that might be available to the City that would provide insurance and not be solely a cost plus mechanism. 0 Select a Joint Powers Authority (JPA) from either the California Municipal Insurance Association (CMIA) or the S Diego Pooled Insurance Program Authority (SANDPIPA) and request a proposal to affect membership. As the first ste in implementing this recommendation, request SANDPIPA to make a presentation to the City as to the current status o its program including financial information, participant profile and governance issues. TiZZingba a Towers Pewin L I 2 W m BACKGROUND The City is currently uninsured for liability risk. It has expressed an interest in evaluating options that may be availabl to the City to fund liability risk. We considered several options including the City remaining uninsured: CURRENT CITY LIABILITY PROGRAM Currently the City is without insurance for liability risks. This is an unusual situation within the California public sector o Going completely without insurance is against a clear trenc When public entities were unable to acquire affordable insurance in the mid '80s, most of them participated in JPI that permitted them to pool risk. Subsequently, all JPAs have been able to purchase excess insurance above the poolt limits putting a reasonable cap on potential liability for its participating members. Many of those that have remainc out of the participation in a JPA have purchased some form of commercial excess insurance as the insurance market has marginally improved. 0 Going completely.without liability insurance is rare for a City the size of Carlsbad. Many of the public entities th have remained llbarelt are considerably larger and have more financial resources. TilliTZ& a Towers Pervin ti I 0 0 0 The impact of going bare on liability risk must be evaluate in conjunction with the potential for a catastrophic loss involving several exposure areas. An illustration of the linkage of exposure areas will serve to clarify this threat. Earthquake and fire are two perils that could trigger a combined loss involving several areas of exposure. These two perils may occur singly or in combination. Negligence in the case of earthquake may be hard to establish but man! entities believe that the courts may take a strict liabilii stance on loss arising out of earthquake and involving Cit] property. Under either the earthquake or fire scenario, several categories of loss could be involved: 0 Direct damase to City DroDertv. This risk is general insured. 0 Internmtion of Citv Services. This category of loss could involve a delay in income and substantial expediting expense to get the services back into operation. 0 Third Partv Liabilitv. This risk can involve injury persons occupying City property at the time of damage Tilliqhm a Towevs Pervin ci I 0 0 or destruction and consequential damage to third part! property arising out of fire from City premises. 0 Workers' Compensation. A number of employees could injured in the same occurrence where third party injuries are sustained. The key issue is that an occurrence could take place in which liability is only one aspect of the loss and the Cit could be materially impacted on such combined events. Evaluation Running against such a strong trend within the public sector, is in the interest of the City to investigate the options to their present program. City may not evidence a major catastrophic potential, it may no be the best allocation of City resources to completely self fun liability risk. id While the present risk profile of the COMMERCIA& INBURANCE Historical Pers~ective The commercial insurance market has changed over the last decad in several important areas. Cost has materially increased and Tillingba I a Towers Pcrrin c m W .. the availability of insurance has materially decreased. -This ha occurred at a time when the overall insurance market expanded substantially in capacity and the cost of insurance has continue to decline. perception of their profit potential in writing public sector business. This anomaly appears to stem from insurers' 0 Premiums : Premiums applicable to the public sector have remained higher than the balance of the insurance market at both hi( and low times of the insurance market cycle. This appears to be primarily a function of limited competition for pub1 sector business. While JPAs have had some affect in keepi. commercial insurance premiums from rising even more than they have, until there is greater capacity and more competition, it does not appear that premium rates will co down. In fact, it would appear that what limited insuranc is now available is rising in cost. 0 Self Insured Retentions (SIRS): One very effective way for an insurer to increase its cost is to raise SIRs while keeping premiums relatively stable. In today's insurance market, SIRs are routinely from $250,000 to $l,O,OO,OOO per occurrence before excess Tilliwba I a Towcrs Pcvnn c 0 0 insurance is available. This technique effectively furthe removes the insurer from loss but keeps the premium level about at the same point. 0 Policy Coveracre: Another major cost impact comes from restricting the coverage that is offered, again without any corresponding decrease in the premium level. Some programs were switche to claims made from occurrence and restrictions were place upon the coverage made available for errors and omissions risks, street and road design risks, police activity and a number of other areas that varied in importance depending upon the entity and the exposure that existed. For exampl dam and reservoir exclusions became common and, while this did not impact all entities, for those that it did, the impact was substantial since it involved catastrophic and not routine risk. Current Insurance Market Condition The current insurance market for public entities is relatively small but those insurers that have remained in the market have been stable. The commercial insurance market may fluctuate bul as of now, it would appear to be primarily composed of: Tillin& a Towers Pewill i I e w 0 S. J. Petrakis Insurance Services, Inc. IPetrakis) This is a general agency that has specialized in public sector business for a number of years. Its primary insurer until recently has been the Planet Insurance Company which is a member of the Reliance Insurance Companies group. It is an admitted insurer in the state of California and is rated by Best's as A:X. When it first entered the market, this insurer offered excellent coverage and cost. Over a period of time, however, the coverage was substantially restricted and cost rose both as a result of premium and SI increases. In 1990 Petrakis was forced to seek another insurer because of the cost and restrictive coverage features of the Planet program. They have replaced the Planet with the Insurance Company of the West (ICW). ICW is headquartered in San Diego. The company is admitted in the state of California and carries a Best's rating of A:VII, generally on the low end of acceptability from a size standpoint. Recent available results of the insurer, as indicated in Best's, appears to be favorable. ICW has greatly improved the coverage offered-by the Planet program and indications are that ICW can offer up to $10 million in limits of coverage If the entire limit were put out on ICW paper, details of Tilling-haJ a Towcrs Pervin CI m 0 m their reinsurance would be needed since this company is toc small for that size limit without quality reinsurance. Early indications are that ICW would require a $250,000 minimum SIR under their program. available. The program in ICW has not been in force long enough to get a sense as to premium cost but Petrakis has indicated that it will do as well or better than the Plane! with improved better coverage. Higher SIRs would be Generally, Petrakis requires an agent or broker to represe: their program exclusively. require two agents or brokers if other parts of the market were to be considered. This means that the City may 0 AIG ComDanies This insurance group has remained active in the public sector for a number of years. it has been active in programs that require high SIRs, generally in the $1 million-and-over range. been active in high excess layers of insurance and in writing excess insurance for California JPAs. solution to the absence of insurance for Carlsbad by allowing the City to take a high SIR and securing catastrophe insurance above that level. For the most part, however, It has also It could be An actual proposa Tillin& m a Towers Pewin c m e from the AIG is required before any cost benefit analysis can be considered. High SIR programs tend to vary from one entity to another too much to make a reasonable prediction about cost. 0 Other There are no other consistent programs currently available in the commercial insurance market. There are from time tc time individual proposals that are developed but most of these are on some form of cost plus basis and they do not adequately provide insurance protection. assist the City in the spreading of loss over a period of time in the event that an individual loss or series of losses fall within a short time frame that might put a strain on a City's cash position. They primarily Evaluation Both the Petrakis program and the AIG program are viable option for the City. premium cost to be determined. Securing a proposal from both groups, plus any miscellaneous individual insurance proposals that might be available, would be in the interest of the City. Coverage offered is reasonable with only the Tillin& a Towers Pervin c 1 e m JOINT POWER8 AUTHORITIES (POOLING) A Joint Powers Authority (JPA) has three primary functions: 0 Provide a vehicle for the pooling of liability and other risks among participants. 0 Act as a joint purchasing group to provide excess insuranc 0 Provide risk management services to augment the efforts of the participating members. These functions are all predicated upon participants making lon term commitments to the JPA. In virtually all JPAs, participants do not pool all layers of loss. Each participant assumes a first layer of loss directly and above that point, the JPA then pools losses up to the next layer where the JPA is able to purchase excess insurance. In theory, the amount of loss pooled will vary from time to time with the insurance market willingness and capacity to provide affordable excess insurance. While some additional JPA histor; is necessary to verify whether or not this function has operatt successfully, it appears at this time that it has, in fact, dol Tillingh a Towers Perrin t I rn m 1 so. that serve the small and medium sized public entities that are not able to take on massive self insured retentions of their owl Probably the function has worked the best for those JPA's JPA's have also been extremely active in providing risk management services to members. been two-fold. First, risk management and risk control is essential to the success of any self-insured venture, joint pooling concept is indeed a joint self-insurance venture. Risk management and risk control activities help to protect the viability of the pool-by reducing and mitigating loss to its members. Secondly, risk management and risk control measures were established as an enticement to the commercial insurance marketplace to provide the catastrophic excess insurance layers Risk management and risk control to protect the viability of pools has been a hit and miss function thus far since pools havc varied so widely in their application of requirements. There h( been some reluctance to discipline participants and the functio has probably offered more value in screening out new applicants who are not risk control oriented. commercial excess insurance has remained largely theoretical an it appears that the availability of excess insurance is still motivated primarily by the economics of the insurance market. The purpose of this activity h; and the The function of attracting JPAs have practically no variation in the concept on which they are established. There are, however, a number of areas where Tillingbm I a Towers Perrrn ci m e 3 JPAs have both objective and subjective differences and these need to be understood in looking at the selection of a JPA: Capitalization JPAs are, in fact, insurance companies in organization and operation. GASB 10 recognizes this similarity in proposed accounting rules that will be applicable to pooling entities anc in turn, to their participants. There are two basic approaches to capitalization: 0 JPAs will capitalize on the basis of annual premium contribution. it could be quickly depleted of capital and result in an early lvcapital callvv on the participants. As JPAs age, th concern tends to dissipate and has not been a problem in California JPAs, thus far. In this approach the JPA runs the risk that 0 Some JPAs have capitalized by the issuance of tax exempt Certificates of Deposit (COP). This approach was an answe to the concern over early depletion of capital. It was a1 felt that this approach would further attract excess insurers and reinsurers since they would be dealing with a JPA that had, through the use of debt obligations, "pre- funded" any potential major losses situations. are operating successfully with the use of COP Several JE Tilli&6Z I a Towevs Pervin c m q capitalization, but, in retrospect, the use of COPS may no have been as necessary as it was believed originally. New participants into such pools have to assume their percenta obligation of the COP debt by crediting the obligation of the original participants. Membership Profile JPAs do not have the large number of participants (insureds) common to a commercial insurer. As a result, it is very important that the pooling participants have certain characteristics that have a significant influence on the overal success of the JPA: 0 GeoaraDhic Continuity There are both pluses and minuses to JPAs comprised of a geographic continuity of participants. - A JPA comprised of participants on a statewide basis could tend to produce more favorable loss results overall. Northern California experience generally rc better than Southern California in both liability anc workers' compensation risks and will tend to balance out the Southern California experience. - Entities that have geographic continuity, however, h? opportunities to share in other forms of Joint Power: Tilliqhz a Towers Perriii ci m 0 U 1 Authorities or participate in county or regional problem solving and, as a result, are better acquainte with management approach in the regional entities. 0 Size/similaritv of Services JPAs with entities of reasonably similar size and services creates a homogeneity that can be important in the construction of policy coverage and the development of excess insurance for the JPA in total. 0 Financial Condition/Manasement Management and financial condition are important factors ir successful pooling. Participants are comfortable with and are able to work out problems when they are pooling with a peer group with respect to management philosophy and direction and where financial condition is healthy. Financial condition impacts the degree to which an entity : able to fund their own SIRS and their pool share and also the degree to which they will be supportive of risk management practices within their entity. 0 Losses Losses are generally the outcome of management practices, financial condition, size and services. To the extent tha these conditions are similar, the pool participants should develop reasonably similar long term loss experience. The Tillingbcz a Towers Pevvin ci I m w are, however, aberrations, and knowledge of loss experienct significantly different from the City could be a reason to avoid such an entity as a pooling partner. Governance Most JPAs are established with similar terms and conditions of membership. The most important conditions deal with: 0 Underwritina Reauirements for Membershir, Most JPAs have an underwriting committee that will review new members with concentration on an analysis 1 risk management practices of the entity. 0 Conditions for Withdrawal A two to three year withdrawal condition is not unusual. In the case of some JPAs where coverage is a claims made basis, withdrawal can be effected with six month notice, but withdrawal from such JPAs are a problem with respect to how to provide for the needed "tail insurance" for claims made subsequent to the withdrawal date. cost It is important to obtain a financial statement of the JPA and some history as to premium levels and the magnitude of assessments that have been required to keep the JPA funded. It Tillingbm 1 a Towevs Pervin ci m w 1 is also important to look at the level of risk sharing as well a the overhead expenses being generated by the JPA. Future Goals A JPA should provide an explanation of its future and the visior it has of the JPA profile for the future. primarily with the direction of the JPA as it involves expansioi of its base of participants and any anticipated change in profi: of the members in terms of geographic location, size, type of entity, and type of services provided. This should deal Evaluation We have reviewed a number of JPA potentials for the City. We recommend against participation in a JPA capitalized by COPS. 1 the remaining JPAs, we recommend that the City investigate two. The first is the California Municipal Insurance Authority (CMIA The City has already invested considerable time in investigatin this JPA and little, if any, additional work would be required. It would appear that it is a good candidate for the City. The second JPA is the San Diego Pooled Insurance Program Authority (SANDPIPA). points that are discu,ssed above. This JPA appears to fit most of the positive profi Ti1liq.a I a Towers Perrin ci n N8mbemhlpProRk OS&a Q-k 0 Lhmklpdsorvku n - Pooung Progrun a uMdatoryRkk.Pookd cl ftotonuonPrkrto poollno cw 0 AmountPookd 0 Raxlsot Pooung cl commorcklExcon In- n Lou Rnwvn Rqulmd n Cialm AdminMratlon 2swmbam smtewldo WldVWktkll $4 mlllkn XI $1 mwon 3 tlmor SIR Admlnistratw hlred by Pool I JPA COMPARISONS I 10 Nembom San Dkgoco. wlda vuktkn uablllty $100,000 mln. sm(@o max. $2 mllllonl G @lxmlPb Achurlal l atablkh: rater lor-oath S6 mllllon XI $2 mllllon 3 tlmea SIR Admlnlstmtor wlected by member Actuarkl rrklbllxh- mantolproqmc- Urn mDIa tar each mombar $0 mUlion x0 $2 mllllon 3tlflMxSIR Admlnlrtretor wlected by member 5mombom so. callfomia Full kwtco $1 mullon $1 mllllon x0 $1 mllllon $15 mlllion XI $10 mllllon Actumrkl l atclb- llwnont 01 mte8 tar oath P-P=U~ member $8 mllllon xa $2 mlluon No rqulred amount Admlnletrator nleccced by member 23momb.m so. caluomk Full Sorvka uablllty sim,mo t0 $1 mlllkn Up to $2 mllllon x.otSlR $5 mllllon to $10 mlluon ProBpactlvm djuatmont band on varkur a&o 01 l xpoxuro hctom a kn l xporkncm $3 mllllon xa $2 mlllion No rqulnd amount s&cted by mrmber m w gn z 0 m iz z 0 0 z ilf 7 - rn 0 ., W 63 iz o> aOz WOO OLI? +n a zoa 7 3ng ZSO 68 2; z m W w W Yp=O 4s Jw = 0 > .E &OE wo 0 WAS =EO 3=cn -as zoz hi ggiz 65s 898 s e m .- * W +- Jw = 0 > .E aOE uo 0 KZO 3a WQE zz -a8 os: $8: (.j 6gz fz8 z 0 m v W >a- Aw =I 0 > .E &OE wo 0 OLE Kg0 am CnPE ZZ -ag YSP so= 4 6g= Bg8 I f 0 rn )r- ‘r * tn z 0 v) z a ne az 38 98s up 7 8s >tn I-2 i3; k z a i J