Saturday, November 17, 2012

Fairfax Financial Holdings (FRFHF)

Summary
Fairfax Financial Holding is primarily engaged in property casualty insurance and reinsurance. The company has an excellent track record (compounding book value at 23.5% annually since current management took over in 1985), and thus rarely trades below book value. However recently, the stock has stagnated due to short term lackluster performance (caused in large part by its defensive equity hedges) and concerns about insurance losses (principally Hurricane Sandy). Additionally, last week Fairfax was removed from the MSCI Canada index for failing a trading volume test and the stock tumbled to a 3-year low. Although it has recovered somewhat from the indiscriminate selling, it still sells below book value (price of $353.90 against a book value of roughly $360) and presents an excellent opportunity to buy into a company with a great long-term track record of creating shareholder value.

Cost of Float
Insurance companies make money by investing float, i.e., the money it receives from premiums before paying losses associated with the risks insured. So two economic factors of key importance, the cost of float and the investment returns earned on the float.

Float provides financial leverage for Fairfax without the traditional covenants or maturities of debt. Insurance underwriting adds economic value to the company if it is able to obtain the use of float at a cost (defined as the underwriting loss as a percentage of float) less than that of alternative sources of funds. In this regard, Fairfax's record since present management took over is below:
Underwriting profit (loss) Average Float Benefit (cost) of float Average Long Term Canada Treasury Bond Yield
1986 3.5 29.8 11.6% 9.6%
1987 1.0 54.8 1.8% 10.0%
1988 0.4 72.1 0.5% 10.2%
1989 -13.3 80.8 -16.5% 9.9%
1990 -12.5 137.1 -9.1% 10.8%
1991 5.3 180.7 2.9% 9.7%
1992 -16.9 183.6 -9.2% 8.8%
1993 2.1 320.4 0.6% 7.8%
1994 -16.9 683.6 -2.5% 8.7%
1995 -40.9 913.2 -4.5% 8.3%
1996 -50.6 1,423.1 -3.6% 7.6%
1997 -56.2 2,683.5 -2.1% 6.5%
1998 -311.4 5,303.3 -5.9% 5.5%
1999 -617.1 8,545.7 -7.2% 5.7%
2000 -698.8 7,905.5 -8.8% 5.9%
2001 -972.1 6,898.8 -14.1% 5.8%
2002 -31.9 4,402.0 -0.7% 5.7%
2003 95.1 4,443.2 2.1% 5.4%
2004 134.8 5,371.4 2.5% 5.2%
2005 -333.9 6,615.7 -5.0% 4.4%
2006 198.2 7,533.4 2.6% 4.3%
2007 238.9 8,617.7 2.8% 4.3%
2008 -280.9 8,917.8 -3.1% 4.1%
2009 7.3 9,429.3 0.1% 3.9%
2010 -236.6 10,430.5 -2.3% 3.8%
2011 -754.4 11,315.1 -6.7% 3.3%
Weighted Avg since inception: -2.8% 4.7%

As can be inferred from the above table, Fairfax has grown its float at a rate of 26% compounded annually, and, critically, the float has cost 1.9% less than the Canadian government's cost of capital.

As illustrated in the table below, the growth in float has slowed considerably in recent years.

Ten year period Compound Annual Growth in Float
1986 - 1996 47.2%
1987 - 1997 47.6%
1988 - 1998 53.7%
1989 - 1999 59.4%
1990 - 2000 50.0%
1991 - 2001 43.9%
1992 - 2002 37.4%
1993 - 2003 30.1%
1994 - 2004 22.9%
1995 - 2005 21.9%
1996 - 2006 18.1%
1997 - 2007 12.4%
1998 - 2008 5.3%
1999 - 2009 1.0%
2000 - 2010 2.8%
2001 - 2011 5.1%

Although concerning, the slowing growth is partly due to soft conditions in the insurance markets combined with disciplined underwriting at Fairfax (as well as the anchor that large numbers naturally create). I quote Fairfax's 2011 annual report "on average we are writing at about 0.67 times net premiums written to surplus. In the hard markets of 2002-2005 we wrote, on average, at 1.5 times. We have huge unused capacity currently and our strategy during times of soft pricing is to be patient and be ready for the hard markets to come."  This underwriting discipline (refusal to knowingly write unprofitable business) is key to achieving low-cost float. The growth will come as pricing improves, and not before.

Investment Record
In addition to cost of liabilities, the other important component of insurance economics is the return on assets. Below is a table reproduced from Fairfax's 2011 Annual Report illustrating the performance of the investment company's (Hamblin Watsa Investment Council) assets managed relative to their benchmarks.

5 Years 10 Years  15 Years
Common stocks (with equity hedging)  8.70% 15.80% 14.20%
S&P 500  -0.20% 2.90% 5.50%
Taxable bonds  13.30% 12.50% 10.40%
Merrill Lynch U.S. corporate (1-10 year) bond index  6.00% 5.80% 6.30%

There's not much to say here, their record is unequivocally outstanding. Currently due to macro economic concerns, Fairfax has hedged approximately 100% of the market value of its equity portfolio. This has resulted in substantial unrealized losses the last two years.

Management
The excellent historical performance aside, management also appears to be unusually shareholder friendly. The CEO owns a large portion of the company, a stock buy back program is in place, a small dividend is paid, and management appears to have an unwavering focus on long term results. They can think independently and have swum against the tide many times in the past, including the most recent 2008 financial crisis where they profited enormously from credit default swaps.

On the con side, they initiated an unusual lawsuit against several hedge funds for an alleged short attack on the company's stock. This strikes me as expensive and possibly unhealthy for the capital markets. I don't have all the background here, and I understand the important role that confidence plays in the reinsurance markets (which could receive signals from a falling stock price), so I reserve too harsh of judgement. But I would be interested in knowing management's reasoning here (and not the boilerplate reasoning presented in public filings), because I figure a better approach would be to just buy back large amounts of stock if other people want to sell at unreasonable prices and have the last laugh that way. In any case, this appears to be mostly behind the company now. Also on the con side, there are allegations of improper tax treatment at one of its US subsidiaries. Based on what I have read, the IRS has not disputed the treatment and it is currently not under review.

Other comments
On 11/15/2012 it was announced that Fairfax will be removed from the MSCI Canada index for failing a liquidity test. This created a substantial amount of selling (for reasons unrelated to underlying business performance) by index funds and other indexers. It's worth noting that the official re-balancing of the index occurs 11/30/2012, so it is possible that the selling pressure will remain for several weeks to come.

Conclusion
Over a 27 year period, Fairfax has consistently (a) grown float at a low cost, and (b) earned superior rates of return on invested assets. These two factors have combined to allow Fairfax to compound book value 23.5% annually for the same 27 years. Without getting into specific valuation calculations in this post (e.g., given point (a), I believe it appropriate to capitalize the economic cost advantage - using conservative assumptions - as a proxy for a conservative premium to insurance capital (see PaineWebber's "Float Based Valuation" of Berkshire Hathaway) investors should be willing to pay), it seems clear to me that Fairfax should sell at a substantial premium to book value. However, due to lackluster recent performance (partly a result its defensive hedge positions), and the recent removal from the MSCI index, Fairfax currently sells for slightly less than book value. It is my opinion that the risk of loss from an investment in Fairfax at current prices is very low and the potential upside is substantial if Fairfax remains disciplined on the underwriting and investment fronts.

Disclosure: Long FRFHF

Sunday, September 9, 2012

OTC Markets Group (OTCM)

Having spent a year or so digging around the securities on the OTC markets, it finally hit me to take a look at OTC Markets Group itself. This is a company that I will pass on for now, but I think is quite interesting and potentially a very good investment for someone that understands the business better than myself (and someone without a whole lot of money to deploy given the liquidity constraints). A synopsis of the situation follows.

Background

OTCM operates an interdealer quotation system (OTC Link) that allows broker-dealers to publish their quotation prices and directly interact with one another. OTCM is not an exchange in that it does not control execution or act as an intermediary - they are a subscription based technology company. They earn revenue in three ways:
  1. Trading Services – monthly license, subscription and connectivity fees paid by broker-dealers for access to the OTC Link interdealer quotation, messaging, and trading platform. This business made up 36% and 41% of gross revenues for the years ended December 31, 2011 and 2010, respectively.
  2. Market Data Licensing – provides subscribers with access to OTC market data and security information collected through the Trading and Issuer Services products. This business made up 40% and 42% of gross revenues for the years ended December 31, 2011 and 2010, respectively.
  3. Issuer Services – various services provided to OTC issuers, such as their “premier” OTCQX marketplace, Blue Sky monitoring, news display, disclosure display. This business made up 24% and 17% of gross revenues for the years ended December 31, 2011 and 2010, respectively.
OTCQX

The fastest growing revenue source has been the Issuer Services business, specifically the OTCQX marketplace. OTCM organizes the equity securities quoted on its platform into three tiers depending mainly on information availability. OTCQX is OTCM’s highest tier, and is available to those meeting certain financial standards, disclosure requirements, and professional advisor sponsorship via OTCM’s “DAD/PAL” program. The DAD/PALs perform a review of the company’s disclosure to monitor compliance with OTCQX requirements. It is divided into OTCQX U.S. (requires a DAD – Designated Advisor for Disclosure – sponsor) and OTCQX International (requires a PAL – Principal American Liaison – sponsor). For inclusion in the OTCQX marketplace, issuers pay a one-time $5,000 application fee and a $15,000 annual subscription fee. In return they receive the means for creating a marketplace for their securities along with other services such as Blue Sky monitoring. This value proposition is more compelling for international companies wishing to reach U.S. investors, but who are already subject to home country/exchange reporting and accounting requirements.

Currently there are 389 companies on the OTCQX marketplace with a new company added every couple of days. The number of companies on the OTCQX marketplace is one of the key metrics to watch in order to track the progress of the business.

Key Financial Stats

Price: 7.09
Diluted Shares: 10.56mm
Mkt Cap: 76.33mm
Cash: 11.73mm
Debt: 0
Long Term Liabilities: 1.42mm
Equity: 13.78mm
EPS (TTM): 0.49
EPS (5y FY avg): 0.29
P/Diluted EPS (TTM): 14.47

Further to the above, over the last several years:
  • Returns on equity have been very high (averaging north of 40%)
  • Growth has been substantial, with revenues and diluted EPS growing respectively at 13% and 19% compounded annually over the last 5 years.
Competitors

OTCM is currently in a unique position in that it within its niche OTC security space, their competitive position is protected from the major exchanges by regulations that disallow them to quote prices in unlisted securities.  So currently OTCM’s direct competition is limited to FINRA’s OTC Bulletin Board (“OTCBB”).  OTCM has handily trounced OTCBB as illustrated by, among other metrics, the quote counts in OTCM’s financial reports. However in late 2009 FINRA filed a proposed rule change with the SEC (the Quotation Consolidation Facility or QCF) under which FINRA would provide a national best bid or offer for OTC securities traded on interdealer quotation systems for inclusion in the NASDAQ UTP Level One feed (at $4 per quote). This would essentially annex much of OTCM’s Market Data Licensing business.

Also, additional potential competitors are on the horizon.
  1. Per OTCM’s financial reports, the SEC approved the creation of the “BX Venture Market,” a proposed listing market for OTC equity securities to be operated by NASDAQ OMX Group. Issuers listed on the BX Venture Market must be SEC registered and current in their reporting, and meet corporate governance standards similar to the listing requirements on The NASDAQ Stock Market.  OTCM Expects that the BX Venture Market will compete with its OTCQX U.S. marketplace (represents around 5% of the companies on OTCM’s platform, and at least – probably quite a bit more – 2% of revenue)
  2. In early 2011, FINRA completed the sale of its OTC Bulletin Board assets to Rodman and Renshaw Capital Group, an investment bank. It is currently not clear what Rodman plans to do with these assets.
Comments

 Pros:
  • On the basis of historical earnings, and historical earnings growth, OTCM looks quite exciting at its current P/E
  •  On a forward looking basis, OTCM also appears to be benefitting from significant tailwinds.
    • The universe of securities that OTCQX could appeal to (e.g., international companies that do not wish to be burdened by SEC registration requirements like SOX) is very large
    • The JOBS act, signed into law in April 2012, promotes alternative means for raising capital for smaller companies by easing securities regulations. This is likely to broaden the universe of OTC traded securities.
    • OTCQX annual renewal rates have been over 90%
  • Clean balance sheet
  • The founder runs the business and owns around 40% of the company
  • For various reasons, risk of fraud strikes me as close to nil
  • Pays modest dividend yielding 2.3%
Risks:
  • Regulation: I have a hard time believing that the FINRA QCF proposal will be approved by the SEC. On the other hand, I am not familiar with the forces at work behind the scenes. More generally, this business is quite sensitive to the whims of regulators.
  • Competition: The main thing preventing me from committing to OTCM is an insufficient understanding of the business and competitive environment. Why, for example, couldn’t someone else start a new quotation platform for lower fees and ruin OTCM’s business or at least erode its economics? I don’t quite grasp this yet, as it doesn’t seem particularly difficult to me.
  • Technology change: OTCM is largely a technology company and its OTC Link platform is sensitive to changes in technology and/or obsolescence. I don't have any particular insight to evaluate this risk.
  • Credit risk: OTCM will be accepting greater credit risk going forward through its factoring program, whereby it purchases access fee receivables from the broker-dealers participating on its platform. Currently I think this is a minor risk, but it something that should be monitored going forward using various receivables metrics.
  • In the event regulation, competition, or other factors erode OTCM’s business, there are few hard assets to fall back on to support the stock price
These are things I continue to investigate and learn about as I follow this company and talk to those closer to the industry. Given that growth is a critical part of the long thesis, a better understanding of these forces is required on the investor’s part.

Conclusion

At current price levels around 76mm, OTCM seems like a potentially exciting opportunity given its current earnings, historical growth, growth outlook, and clean balance sheet. At the moment however, I am not comfortable enough with the long-term competitive environment to purchase the stock. This is definitely a company that I will continue to monitor on a regular basis may at some point invest in.

Disclosure: No position

Sunday, August 12, 2012

Q.E.P. Co., Inc. (QEPC)

Background

For some time now, I have been researching companies trading on the Pink Sheets - hoping to find cheap stocks buried among the shell companies, development stage companies, and a host of other unattractive securities. QEPC is one such interesting opportunity for the small investor. 

QEPC is a provider of flooring and industrial solutions. QEPC sells a comprehensive line of hardwood flooring, flooring installation tools, adhesives and flooring related products targeted for the professional installer and the "do-it-yourselfer."  QEPC voluntarily delisted from the NASDAQ in 2009, and the shares have since traded in the OTC markets.

Over the last several years, QEPC has been growing both organically and through acquisitions. Their acquisition history has been interesting - purchasing broken businesses on the cheap, and plugging the products into QEPC's distribution system (below I include some links where management discusses a recent acquisitions which gives a little insight into this strategy).

Except per share amounts, all numbers in tables and text below are in thousands.

Financial Performance

QEPC's six-year record is below. These are for fiscal years ending in February.

Income 2012 2011 2010 2009 2008 2007
Revenue 261,408 237,886 205,853 203,603 217,505 216,006
COGS 182,520 164,334 140,486 147,571 154,684 156,658
Operating Income 16,172 15,169 13,712 -4,425 9,685 -3,642
Interest Exp 929 1,363 1,156 1,740 2,538 2,977
Pre tax earnings 15,243 13,806 12,556 -6,165 7,147 -6,619
Provision for taxes 5,022 4,372 3,579 1,090 3,512 624
Earnings 10,221 9,434 8,977 -7,255 2,196 -5,806
CFO 12,173 9,545 15,312 -520 7,212 4,859
Balance Sheet
Cash 976 447 856 695 949 822
Receivables 35,386 31,350 32,792 26,746 32,543 34,491
Inventory 31,441 34,447 30,485 24,446 26,496 27,042
Assets 87,209 88,175 86,047 68,965 85,626 87,156
Equity 45,435 35,243 26,025 15,540 26,355 22,050
Notes Payable, Debt, LOC 12,660 21,663 26,831 29,566 31,236 36,439
Other Information
Diluted Shares 3,392 3,409 3,496 3,415 3,588 3,411
Depreciation 2,613 2,565 1,518 2,005 2,089 2,568
CapEx 1,068 2,814 601 842 2,981 730
Goodwill Impairment 0 0 0 7,927 0 7,520


Some of my notes/comments on the financial performance:
  • Adjusting for the goodwill impairments, which appear to have been taken simply because of a decline in the stock price (which has since risen), QEPC has earned 33,214 in total or 5,536 on average
  • Cash flow from operations totaled 48,581 (or 8,097 on average)
  •  Debt is being aggressively paid down
Valuation

After adjusting the earnings record for the goodwill impairments mentioned above, FIFO to LIFO COGS adjustment, Capex/depreciation differences, changes in capital structure and +/- a few other small items, I estimate that QEPC's no growth earning power is between 5,500 and 7,500. Slapping an 8-10x multiple on this, gets a value of 44,000 to 75,000.

The above calculations do not directly account for growth potential (which historically has been positive). In a related context, they also do not directly consider the non-zero probability that an improvement in the housing market in the coming years will increase QEPC's earning power materially.  For these reasons, I am inclined to believe that QEPC's value is towards the high end of that range (which actually is a closer approximation of cash flow from operations), and may prove too conservative in the several years to come.


Using diluted shares at the current share price of 14.95, QEPC currently sells for 50,541.

Other comments and notes

Below are some notes, both in the positive and negative columns. 

Pros:



Cons: 
  • They had some accounting issues in 2005 and 2006 (a material control deficiency that resulted in a restatement); this appears to have been honest mistakes, not fraud
  • Sales are heavily concentrated in Home Depot and Lowes; a counterpoint is that the product mix they sell to them is pretty diverse, but this counterpoint still depends on HD and Lowes staying in business
  • Other obvious cons with pink sheets stocks (outside of SEC purview, a lot less volume)


One additional comment is that - although I would prefer to know the answer to this question - I do not know exactly why QEPC appears this cheap. There are some usual explanations that obviously contribute (e.g., pink sheets, limited volume, lack of analyst coverage etc), but I cannot confidently say this is the whole reason. Despite this, and the noted cons above, the price appears low enough so as to offer a reasonable degree of safety. That is, absent fraud which I believe highly unlikely.

I emphasize that investors must do their own research and reach their own conclusions with regard to any investment decision.

Disclosure: Long QEPC

Sunday, July 1, 2012

Investment Research Notes - The L.S. Starrett Company (SCX)

I learned of SCX while going through the pink sheets which is where the B shares of this company trade (the A shares are listed on the NYSE). Although I do not plan to invest in SCX, I use this short post to document my notes and reasoning because SCX was a little more interesting than the majority of companies I come across on the pink sheets.  (Note that except for basically voting rights, the B and A shares are identical).

SCX’s products include precision tools, electronic gages, gage blocks, optical and vision measuring equipment, custom engineered granite solutions, tape measures, levels, chalk products, squares, band saw blades, hole saws, hacksaw blades, jig saw blades, reciprocating saw blades, M1® lubricant and precision ground flat stock.  At the current price of $11.57, SCX trades at slightly over 50% of book value, or , after adding back the large LIFO reserve, at 95% of net current assets (Current Assets + LIFO Reserve -  All Liabilities).  SCX also pays a modest dividend - currently yielding 3.3% (TTM). In total over the last 11 years, SCX has paid $5.52 in dividends.

All net-nets have issues and risks investors must come to terms with, and SCX is no exception. The main issue with SCX is that it is not profitable. Over the past 11 years the company has earned - after substituting PP&E additions for depreciation in the earnings calculation - $0.19 per share on average and  $2.10 in total. However, it's not bleeding significant amounts of money either. From a business perspective - the products the company produces strike me as commodity products. To compete in such a landscape the company must transform itself into a low cost producer. SCX has expanded its operations in China however I'm not convinced it has the scale and distribution network to operate profitably in the long term.

The dividend's decline is another item that detracts from the long thesis. Since 2001, it has declined from $0.80 to $0.32. Also, the split share class is cause for some concern. The disproportionate voting rights accorded the B shares prevents potential value extraction by an activist investor.

Overall, the price is not currently attractive enough for me to invest. I will however keep this company on my radar and potentially get interested if it dips to the $8 range.

Disclosure: No position, and no intention of initiating one

Saturday, June 2, 2012

National Western Life Insurance (NWLI) – Personal Investment Mistake


NWLI sells a broad portfolio of individual whole life, universal life and term insurance plans, and annuities. In May 2011, I began buying NWLI around $160 per share which was around 47% of the then current book value. The stock was fairly stagnant and I continued buying as it fell to $150, building a modest position. For reasons I discuss below I decided to sell in early 2012 at $136 for a 15% loss. Meanwhile, over this short period, the business continued its slow and steady performance. This post is to reflect on my reasoning, and hopefully learn from the situation. Which decision (to buy or sell) was a mistake? My opinion obviously is the purchase, but only time will tell.

The Abridged Bull Thesis
Preliminary notes:
·         The stock is a split class, with the Class B (200,000 outstanding) electing two thirds of the board with the Class A (3,434,766 outstanding) electing the remainder. On a per share basis, Class B effectively has half the interest in earnings as Class A. Robert Moody Sr, the Chairman and CEO, owns 99% of the Class B and 34% of the Class A shares. In the rest of the post, I refer only to Class A shares.
·         An interesting bit of history about the Moody Family can be found in this book. Be sure to visit their pyramids if you’re in Galveston.

The bull thesis for NWLI is quite compelling. The business is boring, has been in business since 1956, and is not covered by the sell-side (plusses in my book). NWLI’s performance over the last decade has been steady:
·         typically earning around 6-8% on equity
·         book value and statutory capital have grown 9% and 8.5% compounded annually
At the time I began purchasing NWLI (May 2011) it was selling for around 47% of book value and 66% of statutory capital and surplus (statutory accounting principles are meant to present financials conservatively – almost on a liquidation basis – whereas US GAAP book value presents things on a going concern basis). This is as opposed to the 12 year historic average 68% and 95% respectively.

The company’s assets are apparently managed conservatively with most of the insurance float invested in high quality bonds to match liabilities (see latest SEC filings for details of their asset mix/quality). Because the company seeks to match assets and liabilities, interest rate risk is reduced, however the company remains exposed to rapid (‘80s-esque) increases in interest rates – a scenario that could result in policy surrenders (as policyholders seek higher returns elsewhere, before crediting rates are increased) requiring the sale of fixed-income positions that have fallen in value (so called “disintermediation” risk). The company manages this risk with life and annuity policy features discouraging surrender (e.g., market value adjustments and surrender charges). Their fixed-index annuity products (by far their biggest annuity product) are hedged with OTC options (exposing them to counterparty non-performance risk managed partly by diversification and collateral arrangements).

So far so good, the company:
·         is consistently profitable and significantly cash flow positive
·         conservatively manages its assets
·         has no long-term debt
·         is selling at a huge discount to book value

My Actions
My actions with respect to this stock were amateurish at best. I purchased NWLI in May – Aug 2011, at prices between $150-160 – which I was very excited about. I held my shares for a short period, selling in Feb 2012 at $136.

My change in opinion centered on corporate governance and concerns about management. Below is the list of items that I grew too uncomfortable with in aggregate to continue holding shares. To varying degrees, I was aware of these items prior to investing, however at the time I was not overly concerned. I think the reason for this was the large discount to book and statutory figures combined with consistent reported profitability.
1.       Poor capital allocation
o   NWLI trades at an incredibly low price in relation to every conceivable valuation metric. So it’s hard to imagine a better use of capital for this company than to repurchase a reasonable amount of its own shares – even if it had to forego writing marginally profitable business in the short term to free up capital.
o   Management has paid lip service to this idea, however has not acted and seems content not to regardless of how large the discount (i.e., attractiveness) becomes.
o   Management’s arguments against this course of action (balance sheet strength) are insufficient in my opinion. To me it seems like management is focused on empire building and other self-serving activities. But size does not equate to adequate shareholder returns.
2.       Incestuous board with questionable qualifications
o   4 immediate Moody Family members and 1 in-law on the board
o   Compensated between 70k-115k
o   Multiple have backgrounds that do not appear particularly relevant to the insurance business (e.g., trustee/staff of the Moody Foundation, or manager of the retirement homes owned by the company)
3.       Conflicts of interest and related-party transactions
o   Mr. Moody is also the Chairman and CEO of ANAT. ANAT and NWLI sell similar life and annuity products and therefore compete. Which company gets the best ideas and attention?
o   The list of related party transactions is not short, and includes payments of $3.6m, $2.9, $2.7m, $2.3m, and $1.4m and receipts of $1.5m, $1.3m, $1.3m, $1.2m, and $0 for the last 5 years; it is not clear to me that these recurring transactions are being executed at arms-length terms
4.       Highly questionable auditor independence
o   KPMG (either Dallas or Austin office) has audited NWLI 16 of the last 19 years (couldn’t find data prior to this); 2011 audit fees of $692k; a 3 year interlude with Deloitte
o   ANAT is also audited by KPMG; 2011 audit fees of $3.2m and tax fees of $936k
o   The Moody Foundation controlled by Mr. Moody is also audited by KPMG; fees not disclosed

In short, I am not on the same page with management on a variety of levels, most importantly with respect to attitudes towards shareholders and economic objectives. To me it seems management places its interest ahead of shareholders, and favors size over returns on capital. Further, neither the board nor the auditors seem capable of questioning management on behalf of shareholders. And although the company has no long-term debt, it is still a highly leveraged financial institution with an opaque balance sheet. To remain a shareholder of such a company, I would need to strongly believe in the skills and integrity of management, and be in tune with their economic philosophy. I could not confidently make these assertions.   So I sold at $136 for a 15% loss, believing that the market has appropriately discounted their assets.