50-Cent Debt Test
Transcription
50-Cent Debt Test
Overview Of Proposed Legislation To Modify The “50-Cent Debt Test” History of the “50-Cent Debt Test” Voters typically approve an “Unlimited Tax” to repay Texas school district bonds authorized in a bond election. However, the “50-Cent Debt Test” (the “Test”) was enacted in year 1991 (20-years ago) which is currently incorporated within Chapter 45 of the Texas Education Code. As implemented, the Test essentially limits a school district’s maximum Interest & Sinking Fund (“I&S”) tax rate to 50.0 cents, equating to a “debt limit” of 7% of a district’s taxable assessed valuation. Prior to the “50-Cent Debt Test,” the “debt limit” for school districts was 10% of taxable assessed valuation. Prior to a new bond sale, the Test requires a school district to demonstrate to the Attorney General its new and existing bonds may be repaid from a maximum I&S tax rate of 50.0 cents or less. The Subchapter B portion of a district’s Tier I State funds, Existing Debt Allotment (“EDA”) and Instructional Facilities Allotment (“IFA”) State funds can be pledged to the repayment of bonds to comply with the Test. Once pledged, Tier I State funds must be used for bond payments prior to a district levying an I&S tax rate above 50.0 cents. During the 81st Legislative Session, Rep. Aycock (Killeen) filed H.B. 3697 to amend the “50-Cent Debt Test.” H.B. 3697 garnered support from the Equity Center, Fast Growth School Coalition, Texas School Coalition, TASA, TASB, the Municipal Advisory Council of Texas, industry participants and numerous school districts. H.B. 3697 was folded into Rep. Hochberg’s H.B. 3646 (i.e. the House of Representative’s School Finance Bill). Prior to the final reading, the proposed legislation was removed by Rep. Hancock. 1 The Results of Increasing Student Enrollment, Declining State Funding Assistance, Slowing Property Value Growth and Rising Construction Costs for School Facilities Due to limited current debt capacity and the need to comply with the “50-Cent Debt Test”, school districts are being forced to extend the repayment term on bonds for up to 40-years. The extended repayment terms is estimated to increase the interest cost borne by taxpayers by over $20.0 billion over the next 5-years. As bond repayments are deferred to comply with the Test, school districts become more leveraged as bonds are being added faster than they are being repaid: reducing future bond capacity, adding pressure to bond ratings, and increasing the total cost to taxpayers and the State of Texas. The recent economic and credit crisis is a direct result of “too much leverage” within the financial markets – There is a reason there are not 40-year home mortgages. Many school districts have been required to annually pledge $ millions of Tier I State funds for bond payments to comply with the Test, further diminishing the dollars available to school districts for instruction. Inherent conflict in school district bond market, investors purchased bonds based upon “Unlimited Tax” pledge – not “Unlimited Tax Pledge” once Tier I State funds to maintain school district operations have been depleted. School districts have been forced to delay the construction of school facilities approved by voters. We estimate school districts have over $2.5 billion of bonds previously approved by voters that cannot be issued due to the “50-Cent Debt Test.” Negatively impacts the economy of the State of Texas by directly reducing the dollar amount of school construction projects being completed, resulting in less: Employment, Consumer Spending, Demand for Materials, Home Construction, Sales Tax, etc. and lower property value growth. 2 What Has Caused the Need to Amend the “50-Cent Debt Test”? Increasing Construction Costs for School Facilities; Increasing Student Enrollments; Additional Facility Mandates; Taxable Valuation Growth Has Lagged the Cost of Construction; and Declining State Funding for Bond Payments. 3 Construction Costs Have Dramatically Increased Since year 2004 prices of construction materials have risen by 115% more than consumer costs as shown below. Change in Producer Prices for Inputs to Construction Industries ("PPI") Versus Consumer Price Index ("CPI") September 2002 Through December 2010 155 CPI 150 PPI for Inputs to Construction Industries 145 140 Construction PPI Change 44.3% Time Period Sep. 2002 – Dec. 2010 135 CPI Change 21.1% 130 125 120 115 110 105 Dec-10 Sep-10 Jun-10 Mar-10 Dec-09 Sep-09 Jun-09 Mar-09 Dec-08 Sep-08 Jun-08 Mar-08 Dec-07 Sep-07 Jun-07 Mar-07 Dec-06 Sep-06 Jun-06 Mar-06 Dec-05 __________ Source: Bureau of Labor Statistics (CPI, PPI). Base date is September 2002. Sep-05 Jun-05 Mar-05 Dec-04 Sep-04 Jun-04 Mar-04 Dec-03 Sep-03 Jun-03 Mar-03 Dec-02 Sep-02 100 4 Student Enrollment Continues to Increase Since year 2001, student enrollment within Texas public schools has increased by 611,178 students or an average increase of 76,397 students per year. This equates to approximately 750 new elementary schools, 475 new middle schools or 240 new high schools. Annual Student Enrollment Texas School Districts Annual Student Enrollment Increase 125,000 74,616 76,397 Average 65,660 2008/09 2009/10 67,173 2007/08 63,835 118,826 67,494 2004/05 50,000 65,358 88,216 Enrollment 4,721,284 4,646,668 4,581,008 4,450,000 2006/07 0 2005/06 2009/10 2008/09 2007/08 2006/07 2005/06 2004/05 2003/04 2002/03 2001/02 75,000 25,000 3,250,000 3,000,000 100,000 Hurricane Katrina 2003/04 3,500,000 4,331,174 3,750,000 4,263,680 4,000,000 4,198,322 4,250,000 4,110,106 Enrollment 4,500,000 4,513,835 4,750,000 2002/03 Despite the economy, student enrollment continues to grow. Source: Texas Education Agency - PEIMS. 5 Amount of Voter-Approved Bonds Outstanding Has Increased The dollar amount of bonds outstanding within Texas school districts has increased from $26.3 billion to $59.7 billion, representing an increase of 127.3%. This increase is due to increasing construction costs, rapid student enrollment increases, unfunded State mandates and the longer repayment period of bonds required to comply with the Test. Dollar Amount of Voter-Approved Bonds Outstanding Texas School Districts $90 Principal (In Billions) $80 $70 $60 Dollar amount of bonds outstanding has increased by 127.3%. In comparison, the State’s debt (excluding local debt) has increased by 187% since FY 2000. $50 $40 $47.6 $30 $20 $10 $26.3 $29.6 $32.6 $37.1 2003/04 2004/05 $53.5 $58.0 $59.7 2008/09 2009/10 $39.9 $0 2001/02 2002/03 __________ Source: Texas Bond Review Board and Municipal Advisory Council of Texas. 2005/06 2006/07 2007/08 6 Taxable Assessed Valuation Growth Has Slowed/Stopped Since year 2001, the taxable assessed valuations of Texas school districts increased from $960.4 billion to $1.66 trillion, representing an increase of 72.9%. However, taxable values have actually declined by $8.9 billion or 0.53% over the last 2-years. Taxable values decreased by Annual Taxable Assessed Valuation Growth 0.53% during the last 2-years. Texas School Districts $1,660.05 2003/04 $1,505.45 2002/03 $1,355.22 2001/02 $1,686.05 $600 $1,057.86 $800 $1,015.19 $1,000 $1,123.63 $1,200 $1,204.54 $1,400 $960.39 Tax Value (In Billions) $1,600 $1,668.93 $1,800 2008/09 2009/10 2010/11* $400 $200 $0 __________ *2010/11 Tax Data is Preliminary Source: Texas Comptroller of Public Accounts - Property Tax Division. 2004/05 2005/06 2006/07 2007/08 7 State Funding for Bonds Has Declined State funding assistance received by Texas school districts for the payment of bonds has decreased by $213.2 million or 26.9%. Annual State Funding Assistance ("IFA/"EDA") for Bonds Texas School Districts $750.0 $729.8 $735.5 $763.9 15.0% $580.1 $500.0 $671.8 $550.0 $712.8 $600.0 $759.1 $650.0 $747.4 $700.0 30.0% $793.3 Funding (In Millions) $800.0 45.0% Percentage of State Funding/Total Bond Payments With bond payments increasing and State funding decreasing, the percentage of annual bond payments covered by State funding has declined from 35.4% to 12.1%. $850.0 0.0% 2001/02 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/10 __________ Source: Texas Education Agency - PEIMS and Texas Bond Review Board. 8 Texas School Districts – Summary Texas School Districts - Years 2001/02 Through 2009/10 Percentage Change In Student Enrollment, Principal Amount Of Bonds, Taxable Assessed Valuation, State Funding Assistance For Bonds And Median Interest & Sinking Fund Tax Rate 160% 140% Percentage Change 120% 127.3% 100% Tax base growth of school districts and State funding assistance is not paying for the increase in the bonds needed and approved by voters for school facilities, resulting in ongoing pressure on I&S tax rates and limited future bond capacity. 80% 60% 40% 20% 0% 14.9% (26.9%) -20% -40% 87.5% 75.6% Year 2001/02 Through 2009/10 Student Enrollment Taxable Assessed Valuation Median Interest & Sinking Fund Tax Rate Principal Amount Of Debt State Funding Assistance For Debt __________ Source: Texas Education Agency - PEIMS, Municipal Advisory Council of Texas, Texas Comptroller of Public Accounts - Property Tax Division and Texas Bond Review Board. 9 Fast Growth School Districts - Summary Fast Growth School Districts - Years 2001/02 Through 2008/09 Percentage Change In Student Enrollment, Principal Amount Of Bonds, Taxable Assessed Valuation, State Funding Assistance For Bonds And Median Interest & Sinking Fund Tax Rate 175% Tax base growth of school districts and State funding assistance is not paying for the increase in the bonds needed and approved by voters for school facilities, resulting in ongoing pressure on I&S tax rates and limited future bond capacity. Percentage Change 150% 150.3% 125% 100% 75% 99.5% 50% 25% (7.7%) 35.8% 57.6% 0% -25% Year 2001/02 Through 2008/09 Student Enrollment Taxable Assessed Valuation Median Interest & Sinking Fund Tax Rate Principal Amount Of Debt State Funding Assistance For Debt __________ Source: Texas Education Agency - PEIMS and Texas Bond Review Board. 10 Result – Increasing I&S Tax Rates and Diminishing Bond Capacity Historical Trend of Interest & Sinking Fund Tax Rates Years 2001/02 - 2010/11 250 30.0 Cents or Higher 212 40.0 Cents or Higher 200 No. of ISDs 50.0 Cent Maximum Rate 150 Over the last 5-years, the number of school districts with a I&S tax rate of 40.0 cents or higher has increased by 938%. 100 50 83 37 22 5 0 2 2001/02 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/10 2010/11 __________ Source: Texas Comptroller of Public Accounts - Property Tax Division. 11 No. of I&S Tax Rates Above 40.0 Cents By Region – Year 2010/11 Region 1 – High Plains Region 2 – Dallas-Fort Worth Metroplex Region 3 – East Texas Region 4 – Houston Metroplex 3 Region 5 – Central Texas 41 Region 6 – South Texas Region 7 – West Texas 7 1 13 10 8 12 Subcommittee on Public Education Funding – Representative Listing of Texas School Districts With An I&S Tax Rate of 40.0 Cents or More Senator Florence Shapiro Allen Independent School District Irving Independent School District Lovejoy Independent School District McKinney Independent School District Melissa Independent School District Princeton Independent School District Prosper Independent School District Wylie Independent School District Senator Robert Duncan Frenship Independent School District Lubbock-Cooper Independent School District Panhandle Independent School District Robert Lee Independent School District Senator Dan Patrick Katy Independent School District Spring Independent School District Waller Independent School District Senator Eddie Lucio, Jr. None Senator Kel Seliger None Senator Craig Estes Anna Independent School District Aubrey Independent School District Bland Independent School District Blue Ridge Independent School District Celina Independent School District Community Independent School District Denton Independent School District Gunter Independent School District Jacksboro Independent School District Krum Independent School District McKinney Independent School District Melissa Independent School District Millsap Independent School District Princeton Independent School District Prosper Independent School District Sherman Independent School District Van Alstyne Independent School District Senator Royce West Cedar Hill Independent School District DeSoto Independent School District Grand Prairie Independent School District Irving Independent School District 13 I&S Tax Rates of 40.0 Cents or Higher – Year 2010/11 48.2% are “Non-Fast Growth” School Districts and 51.8% are “Fast Growth” Royal ISD (59.00 Cents) Bishop Consolidated ISD (52.38 Cents) Joaquin ISD (51.80 Cents) Allen ISD (50.00 Cents) Anna ISD (50.00 Cents) Aubrey ISD (50.00 Cents) Blue Ridge ISD (50.00 Cents) Burleson ISD (50.00 Cents) Caddo Mills ISD (50.00 Cents) Celina ISD (50.00 Cents) Dickinson ISD (50.00 Cents) Eagle Mountain-Saginaw ISD (50.00 Cents) Elgin ISD (50.00 Cents) Ennis ISD (50.00 Cents) Lake Dallas ISD (50.00 Cents) Lake Worth ISD (50.00 Cents) Little Elm ISD (50.00 Cents) Melissa ISD (50.00 Cents) New Caney ISD (50.00 Cents) Prosper ISD (50.00 Cents) Spring Hill ISD (50.00 Cents) White Settlement ISD (50.00 Cents) Crowley ISD (49.50 Cents) Hutto ISD (49.50 Cents) Millsap ISD (49.50 Cents) Keller ISD (49.06 Cents) Bland ISD (49.00 Cents) Del Valle ISD (49.00 Cents) Denton ISD (49.00 Cents) McKinney ISD (48.80 Cents) Needville ISD (48.00 Cents) Floresville ISD (47.58 Cents) Bloomington ISD (47.50 Cents) Lovejoy ISD (47.50 Cents) Manor ISD (47.50 Cents) Longview ISD (47.30 Cents) Wylie ISD (47.00 Cents) Forney ISD (46.00 Cents) Frenship ISD (46.00 Cents) Hitchcock ISD (46.00 Cents) Jacksboro ISD (46.00 Cents) Hubbard ISD (45.99 Cents) Lubbock-Cooper ISD (45.90 Cents) Mansfield ISD (45.60 Cents) Community ISD (45.50 Cents) Crandall ISD (45.36 Cents) DeSoto ISD (45.00 Cents) Dripping Springs ISD (45.00 Cents) Princeton ISD (45.00 Cents) Bastrop ISD (44.10 Cents) Krum ISD (44.00 Cents) Overton ISD (44.00 Cents) Panhandle ISD (44.00 Cents) Robert Lee ISD (44.00 Cents) Harlandale ISD (43.48 Cents) Banquete ISD (43.34 Cents) Canton ISD (43.10 Cents) Huffman ISD (43.00 Cents) Rockwall ISD (43.00 Cents) Taylor ISD (43.00 Cents) Commerce ISD (42.51 Cents) Grand Prairie ISD (42.50 Cents) Irving ISD (42.50 Cents) Judson ISD (42.30 Cents) Hays Consolidated ISD (42.13 Cents) Pflugerville ISD (42.00 Cents) Spring ISD (42.00 Cents) Franklin ISD (41.80 Cents) Angleton ISD (41.52 Cents) Lindale ISD (41.50 Cents) South San Antonio ISD (41.49 Cents) Leander ISD (41.48 Cents) Central Heights ISD (41.00 Cents) Giddings ISD (41.00 Cents) Gunter ISD (41.00 Cents) San Diego ISD (40.49 Cents) Iola ISD (40.34 Cents) Argyle ISD (40.00 Cents) Cedar Hill ISD (40.00 Cents) Katy ISD (40.00 Cents) Sherman ISD (40.00 Cents) Van Alstyne ISD (40.00 Cents) Waller ISD (40.00 Cents) Note: District’s highlighted in “blue” represent “Non-Fast Growth School Districts.” Source: Texas Comptroller of Public Accounts - Property Tax Division 14 Example No. 1 – Central Texas School District (ADA of 5,412) – Tier I State Funds Pledged for Bond Payments District may need to use $87,918,913 of “Tier I” State funds for bond payments during this time period to maintain an I&S tax rate of 50.0 cents of less. $0.70 $0.65 $0.60 $0.55 $0.45 $0.40 $0.35 District’s current I&S tax rate is 50.0 cents. $0.30 $0.25 Additional Bond Capacity Pursuant to 50-Cent Debt Test $0.20 $0.15 $0.10 Projected I&S Fund Tax Rates - Existing Bonds $0.05 $0.00 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035/36 2036/37 2037/38 2038/39 2039/40 2040/41 2041/42 2042/43 2043/44 2044/45 2045/46 2046/47 2047/48 2048/49 2049/50 2050/51 I&S Fund Tax Rate $0.50 $0.50 15 Example No. 2 – North Texas School District (ADA of 2,121) – Deferring Bond Repayment Terms $6,500,000 $6,000,000 $5,500,000 School district was forced to defer bond payments over a 40-year period and not make a principal payment for 35-years to comply with the Test, increasing the cost to taxpayers by over 180%. $5,000,000 Annual Debt Service $4,500,000 $4,000,000 $3,500,000 $3,000,000 $2,500,000 $2,000,000 $1,500,000 $1,000,000 $500,000 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035/36 2036/37 2037/38 2038/39 2039/40 2040/41 2041/42 2042/43 2043/44 2044/45 2045/46 2046/47 2047/48 2048/49 2049/50 $0 Series 2010A - Interest Equals $38,343,372.71 or 2.26X the Principal Amount of the Series 2010A Bonds Series 2010A - Principal Equals $16,896,582.85 Existing Debt - Principal Equals $68,067,990.80 Note: Debt service payments reflect payments from September 1 through August 31. 16 Example No. 3 – North Texas School District (ADA of 21,251) – Amendments Would Reduce the Total School “Tax Bill” of Taxpayers and Provides Future Bond Capacity. $116.745 Million Bond Sale - 40-Year Amortization Maximum I&S Tax Rate of 50.0 Cents. $0.60 $116.745 Million Bond Sale Principal = $116,745,000 Interest = $440,705,000 Debt Service = $557,450,000 I&S Tax Rate $0.50 $0.40 $0.30 $116.745 Million Bond Sale Existing Debt Service $0.20 $0.10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 2035/36 2036/37 2037/38 2038/39 2039/40 2040/41 2041/42 2042/43 2043/44 2044/45 2045/46 2046/47 2047/48 2048/49 2049/50 2050/51 $0.00 $116.745 Million Bond Sale - 30-Year Amortization Maximum I&S Tax Rate of 56.0 Cents. $0.60 $116.745 Million Bond Sale Principal = $116,745,000 Interest = $148,585,000 Debt Service = $265,330,000 $0.40 Maximum I&S Tax Rate = 31.0 Cents Interest Cost Projected Savings Projected Interest $116.745 Million Bond SaleCost = $14,350,512 Existing Debt Service 2050/51 2049/50 2048/49 2047/48 2046/47 2041/42 2040/41 2039/40 2038/39 2037/38 2036/37 2035/36 2034/35 2033/34 2032/33 2031/32 2030/31 2029/30 2028/29 2027/28 2026/27 2025/26 2024/25 2023/24 2022/23 2021/22 2020/21 2019/20 2018/19 2017/18 2016/17 2015/16 2014/15 2013/14 2012/13 2011/12 $0.00 2045/46 $0.10 2044/45 Represents Interest Cost Savings to Taxpayers of $292,120,000 2043/44 $0.20 2042/43 $0.30 2010/11 I&S Tax Rate $0.50 17 Summary of Proposed Amendments to the “50-Cent Debt Test” Repeals Existing “50-Cent Debt Test” and Prior Pledges of Tier I State Funds for Bond Payments; Implements a “Debt Limit” Equal to 10% of Taxable Assessed Valuation with Adjustments for: Smaller districts with less than 4,000 students; Districts with student enrollment of at least 15% during the preceding 3-years; and District’s receiving IFA/EDA State assistance to maintain “equity among districts.” Incorporates Debt Management Safeguards and Increases Accountability to Taxpayers Require School Districts to Adopt a Debt Management Policy to: Maintain financial stability; Provide debt management flexibility to meet future facility needs; Preserve public trust; Minimize cost of taxpayers; Preserve access to capital markets; Improve bond ratings; and Increase taxpayer oversight of bond programs. Require Development of 5-Year Capital Improvement Plan and Require Annual Public Hearing to Review. Limits the Amount of Bonds Allowed for “Athletic Facilities” to 10% of a District’s Bond Capacity. 18 Benefits of Amending the 50-Cent Debt Test Amending the “50-Cent Debt Test” benefits ALL Texas school districts. Requires NO additional State funding assistance. On a local option basis, provides school districts with the flexibility to reduce the interest cost associated with school facility construction by over $20 billion in the next 5-years by reducing the repayment term of bonds. Allows voter-approved construction projects to be fully completed, creating more jobs, consumer spending, home construction, sales tax, taxable values, etc. to help stimulate and stabilize the Texas economy. Based upon an independent economic study, over the last 8-years school facility construction has had an $84 billion economic impact statewide, supported 50,000 jobs annually and generated $2.4 billion of additional State/local tax revenue. Over the next 10-years, school facility construction is expected to have a $94 billion economic impact, support 55,000 jobs per year and produce over $2.6 billion of additional State/local tax revenue. Creates future bond capacity for school districts to meet future facility needs at a lower I&S tax rate, as interest costs and repayment terms are reduced. Provides school districts the flexibility to meet published “bond repayment” guidelines of bond rating agencies; potentially enhancing the bond ratings of Texas school districts and lowering interest costs. Generates ongoing capacity within the Permanent School Fund Guarantee Program. Mitigates the need to fund bond payments with “Tier I” State funds allowing such dollars to be maintained in the classroom. 19 BOSC, Inc. – Specialized Texas School District Finance Professionals For additional information or questions, please contact the following: William J. Gumbert Joshua M. McLaughlin 333 West Campbell Road, Suite 350 │ Richardson, Texas 75080 E-Mail: [email protected] Direct: 214.576.0880 │ Mobile: 214.212.3153 │ Fax: 214.576.0890 333 West Campbell Road, Suite 350 │ Richardson, Texas 75080 E-Mail: [email protected] Direct: 214.576.0878 │ Mobile: 972.897.0503 │ Fax: 214.576.0890 Managing Director, Director of Texas Public Finance Securities offered by BOSC, Inc., Registered Investment Advisor, a registered Broker/Dealer, Member FINRA/SIPC Investment Banker, Texas Public Finance Securities offered by BOSC, Inc., Registered Investment Advisor, a registered Broker/Dealer, Member FINRA/SIPC Mike Jolly Dr. Cathy Bryce 333 West Campbell Road, Suite 350 │ Richardson, Texas 75080 E-Mail: [email protected] Direct: 512.868.1980 │ Mobile: 512.751.0479 │ Fax: 214.576.0890 333 West Campbell Road, Suite 350 │ Richardson, Texas 75080 E-Mail: [email protected] Mobile: 214.477.5972 │ Fax: 214.576.0890 Investment Banker, Texas Public Finance Securities offered by BOSC, Inc., Registered Investment Advisor, a registered Broker/Dealer, Member FINRA/SIPC Omar Garcia State Funding Consultant, Texas Public Finance 333 West Campbell Road, Suite 350 │ Richardson, Texas 75080 E-Mail: [email protected] Direct: 512.243.5917 │ Mobile: 512.565.7005 │ Fax: 214.576.0890 Securities offered by BOSC, Inc., Registered Investment Advisor, a registered Broker/Dealer, Member FINRA/SIPC Investment Banker, Texas Public finance Securities offered by BOSC, Inc., Registered Investment Advisor, a registered Broker/Dealer, Member FINRA/SIPC Alison Mabry Associate, Texas Public Finance 333 West Campbell Road, Suite 350 │ Richardson, Texas 75080 E-Mail: [email protected] Direct: 214.576.0881 │ Mobile: 254.744.4555 │ Fax: 214.576.0890 Securities offered by BOSC, Inc., Registered Investment Advisor, a registered Broker/Dealer, Member FINRA/SIPC 20