CC 2015-04-28_11c Status of CalPERS Retirement System Plans NRRO yO
A. tNCORPORATEO 7Z MEMORANDUM
V T
* JULY 10, 1811
c'�l RN%P
TO: CITY COUNCIL
FROM: DEBBIE MALICOAT, DIRECTOR OF ADMINISTRATIVE SERVICES W
SUBJECT: CONSIDERATION OF THE STATUS OF THE CITY'S CALIFORNIA
PUBLIC EMPLOYEES' RETIREMENT SYSTEM ,(CALPERS) PLANS FROM
THE CITY'S INDEPENDENT ACTUARY
DATE: APRIL 28, 2015
RECOMMENDATION:
It is recommended the City Council receive and review information on the status of the City's
retirement plans with the California Public Employees' Retirement System (CaIPERS) from
the City's independent actuary, Bartel Associates, LLC
IMPACT ON FINANCIAL AND PERSONNEL RESOURCES:
There is no direct financial impact to receive and review the status of the City's retirement
plans. However, significant future impacts to the City's retirement costs are projected over
the next few years based on information provided by CalPERS.
BACKGROUND:
On February 24, 2015, the City Council directed staff to engage Bartel Associates, LLC to
provide independent actuary services in analyzing the City's CalPERS retirement plans and
project the City's CalPERS contribution costs for the next five years.
ANALYSIS OF ISSUES:
Bartel Associates has completed their actuarial analysis, a draft of which is attached to this
staff report, and will present the City Council with their findings. Based on the analysis,
recent changes to CalPERS contribution policy changes, assumption changes and risk pool
changes will result in increases to the City's contributions. The City can expect contributions
to continually increase for the Miscellaneous Plan from approximately $876,000 to
$1,485,000 until FY 2021-22, at which time the plan's side fund will be paid and contributions
will reduce to approximately $1.1 million annually. Similarly, the Police Safety Plan will
experience contribution increases from $1,072,000 to $1,411,000 until FY 2019-20, when
that side fund will be paid and contributions will reduce to approximately $1.0 million annually.
In addition to providing analysis related to the expected contributions and the plans' unfunded
liability status, Bartel Associates will discuss concepts and alternatives related to reducing the
City's unfunded liability with the City Council. This information will be useful in developing
policy and long-term strategies as the City Council and staff continue to address the City's
Item 11.c. - Page 1
CONSIDERATION OF CALIFORNIA PUBLIC EMPLOYEES' RETIREMENT SYSTEM
(CALPERS) CITY PLAN STATUS FROM THE CITY'S INDEPENDENT ACTUARY
APRIL 28, 2015
PAGE 2
fiscal sustainability, however staff is not asking the City Council to make any decisions
regarding the unfunded liability at this time.
ALTERNATIVES:
No alternatives are provided; the report is informational in nature.
ADVANTAGES:
Having a basic knowledge and understanding of CalPERS benefits, funding status and
actuarial methods will assist the Council and public in making informed decisions related to
CaIPERS issues.
DISADVANTAGES:
There are no identified disadvantages to receiving this information.
ENVIROMENTAL REVIEW:
No environmental review is required for this item.
PUBLIC NOTIFICATION AND COMMENTS:
The Agenda was posted in front of City Hall on Thursday, April 23, 2015. The Agenda and
report were posted on the City's website on Friday, April 24, 2015. No public comments
were received. -
Attachment:
City of Arroyo Grande Miscellaneous and Safety Plans CalPERS Actuarial Issues — 6/30/13
Valuation Preliminary Results by Bartel Associates
Item 11.c. - Page 2
CITY OF
"CP LIGOR N.J A/(yfr'
CITY OF ARROYO GRANDE
$ RT E L MISCELLANEOUS AND SAFETY PLANS
JISS00ATL-S, LLC
Ca1PERS Actuarial Issues — 6/30/13 Valuation
Preliminary Results
Presented by Mary Beth Redding, Assistant Vice President
Prepared by Bianca Lin, Assistant Vice President
Matthew Childs, Actuarial Analyst
Bartel Associates, LLC
April 17, 2015
Agenda
Topic Page
Definitions 1
Ca1PERS Changes 3
Investment Return 4
Miscellaneous Plan:
Demographic Information 5
Plan Funded Status 6
Contribution Rates &Projections 7
Police Safety Plan:
Demographic Information 17
Plan Funded Status 18
Contribution Rates &Projections 19
GASB 68 27
PEPRA Cost Sharing 28
Paying Down the Unfunded Liability 30
B� o\cbents\city of arroyo grande\projects\calpers\6-30-13\ba arroyograndeci 15-04-17 calpers misc safety 13 draft docx
DEFINITIONS
F—
I I
Present Value of Benefits
June30,2013
Future N.—1
Cash Current N—W
Cost
Act-10
Llabllity
• PVB-Present Value of all Projected Benefits:
• Discounted value(at valuation date-6/30/13),of all future expected benefit
payments based on various (actuarial) assumptions
• Actuarial Liability:
• Discounted value(at valuation date) of benefits earned through valuation date
[value of past service benefit]
• Portion of PVB "earned"at measurement
■ Current Normal Cost:
• Portion of PVB allocated to(or"earned"during) current year
• Value of employee and employer current service benefit
Brl April 17,2015 1 i
DEFINITIONS
I I
Present Value of Benefits
June 30,2013
` Unfunded PVB
.7
(umm.ded
Adunclnl LIA111ty)
1,1011lty
• Target-Have money in the bank to cover Actuarial Liability(past service)
• Unfunded Liability-Money short of target at valuation date
• Excess Assets/Surplus:
• Money over and above target at that point in time
• Doesn't mean you're done contributing
■ Super Funded:
• Assets cover whole pie(PVB)
• If everything goes exactly like PERS calculated,you'll never have to put another
(employer or employee) dime in
' 1" April 17,2015 2
CALPERS CHANGES
• Contribution policy changes:
• No asset smoothing
• 5-year ramp up
• Included in 6/30/13 valuation(first impact 15/16 rates; full impact 19/20)
• Assumption changes:
• Anticipate future mortality improvement
• Other, less significant, changes
• Included in 6/30/14 valuation(first impact 16/17 rates; full impact 20/21)
• Risk Pool changes
• All Risk Pools combined into one Miscellaneous & one Safety
• Collect payment on UAL as dollar amount, not as % of pay
• Payments allocated to agencies based on liability& assets rather than
payroll
• Included in 6/30/13 valuation (impacts 15/16 rates)
Bel ��
'r
April 17,2015 3 IL
INVESTMENT RETURN
3000% MVA
2250%
1500%
750%
000%
-750%
-1500%
-2250%
-3000%
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2017 2014 Eq
2015
t MVA163%153% 01%195%125%1055q-72%1-60%13 7%1166-AI2 32A11 9!g188A-5 M-240133% 17%01%132-4184V43 2
Above assumes contributions,payments,etc. received evenly throughout year.
Estimated June 30,2015 based on Ca1PERS actual return through 12/31/14 and assumed 7.5%annual
return for the remaining 6 months.
Ir
B/4 April 17,2015 4
r---I SUMMARY OF DEMOGRAPHIC INFORMATION—MISCELLANEOUS
2010 2011 2012 2013
Actives
• Counts 49 48 48 45
• Average PERSable Wages $73,400 $74,600 $68,000 $66,900
• Total PERSable Wages (millions) 3.6 3.6 3.6 3.3
Inactive Counts
■ Transferred 30 29 28 29
• Separated 17 17 16 15
• Receiving Payments 73 76 76 86
n
its
(B/4) April 17,2015 5 Jr,
PLAN FUNDED STATUS-MISCELLANEOUS
I �
Present Value of Benefits Present Value of Benefits
June 30,2012 June 30,2013
,- -- Unfunded PVB Unfunded PVB
Actuarial (Unfunded
ctuariy (Unfunded Actuarial babdit))
bu6d11y) Liandity
June k,2012 June 30,2013
$ 29,800,000 Actuarial Liability $ 31,300,000
23,500,000 Actuarial Asset Value N/A
(6,300,000 (Unfunded Liability) , N/A
June 30,2012 _ __ _ l June 30,2013
$ 29,800,000 1 Actuarial Liability_1 $ 31,300,000
19,700,000 Market Asset Value 1 22,000,000
(10,100,000) (Unfunded Liability) (9,300,000),
'' April 17,2015 6 Lf ��
CONTRIBUTION RATES-MISCELLANEOUS
6/30/12 Valuation
2014/2015 Contribution Rates
Total' Tier I Tier II PEPRA
2,5%@55 2%@55 2%@62
■Required Employer Contribution
• Risk Pool's Net Employer Normal 8.9% 8.9% N/A N/A
Cost
• Class 1 Benefits
❑ FAC 1 0.6% 0.6% N/A N/A
❑ PRSA 0.0% 0.0% N/A N/A
• Risk Pool's Payment on 6.2% 6.2% N/A N/A
Amortization Bases
• Amortization of Side Fund 8.8% 8.8% N/A N/A
• Total ER Contribution 24.6% 24.6% N/A N/A
• Total ER Contribution $ $876 $876 $0 $0
Weighting of total contribution projection based on estimated projected Tier 2 and PEPRA payrolls
1
April 17,2015 7
CONTRIBUTION RATES-MISCELLANEOUS
6/30/13 Valuation
2015/2016 Contribution Rates
Tota12 Tier I Tier II PEPRA
2.5 0/6@55 2%@55 2%@62
■Required Employer Contribution
• Risk Pool's Net Employer Normal 9.0% 9.1% 8.0% 6.2%
Cost
• Class 1 Benefits
❑ FAC 1 0.6% 0.6% 0.0% 0.0%
❑ PRSA 0.0% 0.0% 0.0% 0.0%
• Risk Pool's Payment on 11.2% 11.9% (0.3%) 0.0%
Amortization Bases
• Amortization of Side Fund 9.9% 10.5% 0.0% 0.0%
• Total ER Contribution 30.6% 32.0% 7.7% 6.2%
• Total ER Contribution $ $1,008 $995 $10 $3
Z Weighting of total contribution projection based on estimated projected Tier 2 and PEPRA payrolls
April 17,2015 8 '""
CONTRIBUTION RATES—MISCELLANEOUS
• Valuation 6/30/12 6/30/13
• Contribution Year 2014/2015 2015/2016
• Required Employer Contribution
• Risk Pool's Net Employer Normal Cost 8.9% 9.0%
• Final Average Compensation(1-Year) 0.6% 0.6%
• Total Normal Cost 9.5% 9.6%
• Risk Pool's Payment on Amortization Bases 6.2% 11.2%
• Amortization of Side Fund 8.8% 9.9%
• Total Employer Contribution 24.6% 30.6%
• Total Employer Contribution $ $876 $1,008
• What Happened from 6/30/12 to 6/30/13:
• 2014/15 Rate 24.6%
• Asset Method 1.3%
• Risk Pool Changes 3.3%
• Golden Handshake 0.3%
• (Gains)/Losses 1.1%
uu • 2015/16 Rate 30.6%
April 17,2015 9
CONTRIBUTION PROJECTIONS—MISCELLANEOUS
■ Market Value Investment Return:
• June 30, 2014: 18.4%3
Poor Expected Good
• June 30, 20154 (0.4%) 3.2% 6.7%
• June 30, 2016 - 2020 0.2% -4.1% 7.5% 11.3% - 15.1%
• No Other: Gains/Losses, Method/Assumption Changes, Benefit Improvements
• Excludes Employer Paid Member Contributions (EPMC)
• Includes Ca1PERS Board adopted assumption changes, first impact 2016/17
• Tier 2 2 @55 FAE3, effective 12/21/2012
• New hire assumptions:
• Assumes 50% of 2013 new hires will be Classic Tier 2 Members (2%@55)
and 50% will be New Members with PEPRA benefits.
• Assumes Classic Members will decrease from 50% to 0% of new hires
over 20 years
' Based on Ca1PERS CAFR.
4 Based on CalPERS return of(0.5%)through 12/31/14 and assumed annual return for 6 months
nApril 17,2015 10 ` "" "
CONTRIBUTION PROJECTIONS-MISCELLANEOUS
---
■ Contribution projections include
• New Contribution Policy Changes
• Risk pool changes
❑ Agency's payroll share: 0.158%
❑ Agency's liability share: 0.265%
❑ Higher contribution because of higher liability share compared to
payroll share
• Contribution policy &risk pool changes took place in June 30, 2013
valuation first affecting 2015/16 contribution rate
r
April 17,2015 11
CONTRIBUTION PROJECTIONS-MISCELLANEOUS
This page intentionally left blank.
x'
B
'' 1" April 17,2015 12
CONTRIBUTION PROJECTIONS—MISCELLANEOUS
50%
46 1%
45% X3191°
I
406%
° n { 1 38 7%
40% 37.2% j _ j
34 3% 37:5.%--_37.8/
35/ 35.6%r- �
f i
' \%
__--32:39/6--3 3 5% 33 9% 33 5% o o
30% 0:6°!0''' 31'1/0 8 2/o ,
27•.8%
25% 6
20%
1 /o
15% t4 7°fo
10% 9.2%. _ 9:0.%� 8.9-%
5%
0%
14115 15/16 16/17 17/18 18/19 19/20 20/21 21/22 22/23
—Total —Normal Cost DUAL Payment
Br� April 17,2015 13 l I
CONTRIBUTION PROJECTIONS—MISCELLANEOUS
i
$2,000
$1,800 1,8'12
1,6,45 I
$1,600 i {
1,504
$1,400 L----1_.429-- i,
78-..-- 'I
1,197
_1f -1;278
3__ 2$1,200 J8 " 1, 7 1,1J 86
095''— 1-1J
;23; 1,169
$1,000 —4-008-
4-00 —
y✓
876° j
$800 —
$600 95-
$400
338 314 335 '-337 341 345 =350=�35$�`�358
$200
$0
14/15 15/16 16/17 17/18 18/19 19/20 20/21 21/22 22/23
—Total ®Normal Cost —UAL Payment
April 17,2015 14
CONTRIBUTION PROJECTIONS—MISCELLANEOUS
Comparison of Ca1PERS Required Funding and 15-Year Accelerated Amortization
40%
36.40/ 37.3°/ 37.9% 37 % 8%
'
,-37-2%,A71,8%
35%
30% FY
2021/22
25%
20%
15% 11
t
10%
`8.5%
7.5% 7.2% 7.0%
5%
0%
14/15 19/20 24/25 29/30 34/35 39/40 43/44
"Current ®15-Year Fresh Start
April 17,2015 15 '-_
CONTRIBUTION PROJECTIONS—MISCELLANEOUS
This page intentionally left blank.
4'
1" April 17,2015 16
FSUMMARY OF DEMOGRAPHIC INFORMATION—POLICE SAFETY
2010 2011 2012 -2013
Actives
• Counts 25 25 24 25
• Average PERSable Wages $97,300 $96,900 $81,300 $83,700
• Total PERSable Wages (millions) 2.4 2.4 2.1 2.3
Inactive Counts
• Transferred 5 5 4 3
• Separated 2 2 5 5
• Receiving Payments 27 27 30 32
April 17,2015 17
PLAN FUNDED STATUS—POLICE SAFETY
1 I
Present Value of Benefits Present Value of Benefits
June 30,2012 June 30,2013
Unfunded PVB �.r Unfunded PVB
Actuerlal \ -
Llabiliry Aetunrlel (Unfunded
(UaI-ded Llabllity Ll.bility)
June 30.2012 _ ( June 30.2013
1
_$__23,700,000 Actuarial Liability m$ 25,000,000
18,400,000_Actuarial Asset Value N/A
—_(5,300,000)1 (Unfunded Liability) N/A
June 30.2012 _�June 30,2013
$ 23,700,000 1 Actuarial Liability $ 25,000,000
' 15,500,000 j Market Asset Value 17,400,000
_ (8,200,000)L(Unfunded Liability) L (7,6001000)
In �
April 17,2015 18
CONTRIBUTION RATES-POLICE SAFETY
r i
6/30/12 Valuation
2014/2015 Contribution Rates
Totals Tier I Tier II PEPRA
3%@50 3%@55 2.7%@57
■Required Employer Contribution
• Risk Pool's Net Employer Normal 17.3% 17.5% 15.4% N/A
Cost
• Class 1 Benefits
❑ FAC1 0.9% 1.0% 0.0% N/A
❑ PRSA 0.0% 0.0% 0.0% N/A
• Risk Pool's Payment on 9.1% 9.4% 5.9% N/A
Amortization Bases
• Amortization of Side Fund 23.1% 25.5% 0.0% N/A
• Total ER Contribution 50.3% 53.3% 21.4% N/A
• Total ER Contribution $ $1,072 $1,029 $43 $0
S Weighting of total contribution projection based on estimated projected Tier 2 and PEPRA payrolls
9-1 April 17,2015 19
CONTRIBUTION RATES-POLICE SAFETY
6/30/13 Valuation
2015/2016 Contribution Rates
Totae Tier I Tier II PEPRA
3 /6 50 3%@55 2.7%@57
■Required Employer Contribution
• Risk Pool's Net Employer Normal 17.1% 17.6% 15.6% 11.2%
Cost
• Class 1 Benefits
❑ FAC1 0.8% 1.0% 0.0% 0.0%
❑ PRSA 0.0% 0.0% 0.0% 0.0%
• Risk Pool's Payment on 10.1% 12.5% (0.4%) 0.0%
Amortization Bases
• Amortization of Side Fund 22.2% 27.3% 0.0% 0.0%
• Total ER Contribution 50.1% 58.4% 15.3% 11.1%
• Total ER Contribution$ $1,144 $1,081 $56 $7
6 Weighting of total contribution projection based on estimated projected Tier 2 and PEPRA payrolls
RM Iii
April 17,2015 20
CONTRIBUTION RATES—POLICE SAFETY
• Valuation 6/30/12 6/30/13
• Contribution Year 2014/2015 2015/2016
• Required Employer Contribution
• Risk Pool's Net Employer Normal Cost 17.3% 17.1%
• Final Average Compensation(1-Year) 0.9% 0.8%
• Total Normal Cost 18.2% 18.9%
• Risk Pool's Payment on Amortization Bases 9.1% 10.1%
• Amortization of Side Fund 23.1% 22.2%
• Total Employer Contribution 50.3% 50.1%
• Total Employer Contribution $ $1,072 $1,144
■ What Happened from 6/30/12 to 6/30/13:
• 2014/15 Rate 50.3%
• Asset Method 1.6%
• Risk Pool Changes (0.1%)
• (Gains)/Losses 1.7%
• 2015/16 Rate 50.1%
April 17,2015 21
CONTRIBUTION PROJECTIONS—POLICE SAFETY
■ Market Value Investment Return:
• June 30, 2014: 18.4%7
Poor Expected Good
• June 30, 20158 (0.4%) 3.2% 6.7%
• June 30, 2016 - 2020 0.2% -4.1% 7.5% 11.3% - 15.1%
• No Other: Gains/Losses, Method/Assumption Changes, Benefit Improvements
• Excludes Employer Paid Member Contributions (EPMC)
• Includes CalPERS Board adopted assumption changes, first impact 2016/17
• Tier 2 3 @55 FAE3, effective 12/9/2011
• New hire assumptions:
• Assumes 50% of 2013 new hires will be Classic Tier 2 Members (3%@55)
and 50% will be New Members with PEPRA benefits.
• Assumes Classic Members will decrease from 50%to 0% of new hires
over 10 years
7 Based on CalPERS CAFR.
e Based on CalPERS return of(0.5%)through 12/31/14 and assumed annual return for 6 months.
B' '" April 17,2015 22 i� �
CONTRIBUTION PROJECTIONS—POLICE SAFETY
■ Contribution projections include
• New Contribution Policy Changes
• Risk pool changes
❑ Agency's payroll share: 0.166%
❑ Agency's liability share: 0.155%
❑ Modestly lower contribution because of lower liability share compared
to payroll share
• Contribution policy &risk pool changes took place in June 30, 2013
valuation first affecting 2015/16 contribution rate
Brl
April 17,2015 23
CONTRIBUTION PROJECTIONS—POLICE SAFETY
This page intentionally left blank.
1" April 17,2015 24 �n '
Item 11 c Page 15
CONTRIBUTION PROJECTIONS—POLICE SAFETY
70%
60% 58.4%
550% -5,6 5P/o
_ --•—°-'54:5-%
'-y
50% 0�3%� 50.1% 52:6% 54.0% 54.5%; 499%
V 43 5% �
\40 4%
40% '
% �°___. !%=--3 1
36.3-%--, 3-6.6 6.;..% -36.4%
0
32 a
30% )31 8°/u 28 9% 25j1% 20 4%20%
'. . . 0 7.20 16:8%
10%
0%
14115 15116 16/17 17/18 18/19 19/20 20/21 21/22 22/23
-=Total —Normal Cost —WJAL Payment
April 17,2015 25
777-1 1 CONTRIBUTION PROJECTIONS—POLICE SAFETY
$1,800
$1,600
1,4159
$1,400 403-
_/-1,321— 1,3611 1,284 1
$1,200 _ '1;240"°J1,310 \\ I
01;144-1 yt\ 1,)52�
1,072" \1;040
$1,000 I_ 1;024-
934° 9—
$800 765
$600 684 573
1
$400 g�, '=408 440`442 d47 --456--- 460` =463
$200
$0
14/15 15/16 16/17 17/18 18/19 19/20 20/21 21/22 22/23
Total —Normal Cost —UAL Payment
B� April 17,2015 26
GASB 68
■ Pension Accounting:
• GASB 68, Accounting for Employers, approved June 25, 2012
• Replaces GASB 27
• Effective 2014/15
• Major Issues:
• Unfunded liability on balance sheet
• Expense calculation disconnected from contribution calculation
• Discount rate is
❑ Expected return on plan assets when assets sufficient to pay benefits
❑ Municipal bond rate when assets not sufficient to pay benefits
Likely caused Ca1PERS to modify asset smoothing and/or amortization
policy to avoid using discount rate lower than expected return (7.5%).
• Estimated June 30 2014 Unfunded Actuarial Liability in Millions
Total Pension -Fiduciary Net Net Pension
Liabilit (AAL) Position (MVA) Liability AL
Miscellaneous $ 32.5 $25.2 $ 7.3
Police Safety 26.2 20.2 6.0
Total 13.3
' April 17,2015 27 L
PEPRA COST SHARING
• Target of 50% of total normal cost for everyone
• New members must pay greater of 50% of total normal cost or bargained
amount if higher
• Employer cannot pay any part of new member required employee contributions
• Employer may impose current employees pay 50% of total normal cost (limited
to certain amounts) if not agreed through collective bargaining by 1/1/18
• Miscellaneous
Current Members New Members
Tier 1 Tier 2 Tier 3
2.5%(R)55 2%(&55 2%(&62
• Employer Normal Cost 9.7% 8.0% 6.24%
• Member Normal Cost 7.9% 6.9% 6.25%
• Total Normal Cost 17.6% 14.9% 12.49%
• 50% Target 8.8% 7.45% 6.25%
r a�.-
B/[
April 17,2015 28 `"y
PEPRA COST SHARING
■ Police Safety
Current Members New Members
Tier 1 Tier 2 Tier 3
3%n50 3%(a-)55 2.7%6D57
• Employer Normal Cost 18.5% 15.6% 11.2%
• Member Normal Cost 9.0% 9.0% 11.5%
• Total Normal Cost 27.5% 24.6% 22.7%
• 50% Target 13.75% 12.3% 11.35%
nB
April 17,2015 29
F-71 F PAYING DOWN THE UNFUNDED LIABILITY
• Pension Obligation Bond (POB)
• Interest arbitrage between expected CalPERS earnings and rate paid on
POB
• Not guaranteed
• Borrow from General Fund
• Pay GF back like a loan
• Payments come from all funds
• Request shorter amortization period of CalPERS
• Higher short term payments
• Less interest and lower long term payments
• One time payments
• Council resolution to use portion of one time money
i
��,_
April 17,2015 30
l
PAYING DOWN THE UNFUNDED LIABILITY
■ Internal Service Fund vs. Irrevocable Supplemental (§115) Pension Trust
• Internal Service Fund
❑ Restricted investments
O Likely low(0.5% - 1.0%) investment returns
O Short term/high quality
O Designed for preservation of principal
❑ Assets could be used by Council for other purposes
• Irrevocable Supplemental (§115) Pension Trust
❑ One Trust established so far
❑ PARS &PFM
❑ Investments significantly less restricted
O Designed for long term returns
O Likely much higher(5% - 7%) investment return
❑ Assets could not be used by Council for other purposes
❑ Can only be used to pay
O Reimburse City for Ca1PERS contributions
O Make payments directly to Ca1PERS
April 17,2015 31
Item 11.c. - Page 19
THIS PAGE INTENTIONALLY LEFT BLANK
Item 1 1.c. - Page 20