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Item 7A. Quantitative and Qualitative Disclosures About Market Risk

2023-03-07 compared with 2022-03-10 · 83 added, 130 removed, 32 unchanged (87% of the section changed)

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Risk Management

To the extent consistent with maintaining our REIT qualification and our exemption from registration under the Investment Company Act, we seek to manage risk exposure by closely monitoring our

portfolio and actively managing financing, interest rate, credit, prepayment and convexity (a measure of the sensitivity of the duration of a loan to changes in interest rates) risks associated with holding our portfolio.

Generally, with the guidance

and experience of our Manager:

To the extent consistent with maintaining our REIT qualification and our exemption from registration under the Investment Company Act, we seek to manage risk exposure by closely monitoring our portfolio and actively managing financing, interest rate, credit, prepayment and convexity (a measure of the sensitivity of the duration of a loan to changes in interest rates) risks associated with holding our portfolio.

Generally, with the guidance and experience of our Manager:

• we manage our portfolio through an interactive process with our Manager and service our self-originated loans through our Manager’s servicer;

• we invest in a mix of floating- and fixed-rate loans to mitigate the interest rate risk associated with the financing of our portfolio;

we actively employ portfolio-wide and asset-specific risk measurement and management processes in our daily operations, including utilizing our Manager’s risk management tools such as software and services

licensed or purchased from third-parties and proprietary analytical methods developed by our Manager;

• we actively employ portfolio-wide and asset-specific risk measurement and management processes in our daily operations, including utilizing our Manager’s risk management tools such as software and services licensed or purchased from third-parties and proprietary analytical methods developed by our Manager;

• we seek to manage credit risk through our due diligence process prior to origination or acquisition and through the use of non-recourse financing, when and where available and appropriate.

In addition, with

respect to any particular target investment, prior to origination or acquisition our Manager’s investment team evaluates, among other things, relative valuation, comparable company analysis, supply and demand trends, shape-of-yield curves,

delinquency and default rates, recovery of various sectors and vintage of collateral.

In addition, with respect to any particular target investment, prior to origination or acquisition our Manager’s investment team evaluates, among other things, relative valuation, comparable company analysis, supply and demand trends, shape-of-yield curves, delinquency and default rates, recovery of various sectors and vintage of collateral.

Changes in Fair Value of Our Assets

We generally hold our target investments as long-term loans;

however, we may occasionally classify some of our loans as held for sale.

We may carry our loans at fair value or carrying value in our consolidated balance sheet.

As of December 31, 2022, three of our loans held for investment were carried at fair value within loans held at fair value in our consolidated balance sheets, with changes in fair value recorded through earnings.

We evaluate our loans on a quarterly basis and fair value is determined by our Board through its independent Audit and Valuation Committee.

We use an independent third-party valuation firm to provide input in the valuation of all of our unquoted investments, which we consider along with other various subjective and objective factors in making our evaluations.

Our loans are typically valued using a yield analysis, which is typically performed for non-credit impaired loans to borrowers.

To determine fair value using a yield analysis, a current price is imputed for the loan based upon an assessment of the expected market yield for a similarly structured loan with a similar level of risk.

In the yield analysis, we consider the current contractual interest rate, the maturity and other terms of the loan relative to risk of the borrower and the specific loan.

A key determinant of risk, among other things, is the leverage through the loan relative to the enterprise value of the borrower.

As loans held by us are substantially illiquid with no active transaction market, we depend on primary market data, including newly funded loans, as well as secondary market data with respect to high-yield debt instruments and syndicated loans, as inputs in determining the appropriate market yield, as applicable.

Changes in market yields may change the fair value of certain of our loans.

Generally, an increase in market yields may result in a decrease in the fair value of certain of our loans, however this is mitigated to the extent our loans bear interest at a floating rate.

Due to the inherent uncertainty of determining the fair value of loans that do not have a readily available market value, the fair value of our loans may fluctuate from period to period.

Additionally, the fair value of our loans may differ significantly from the values that would have been used had a ready market existed for such loans and may differ materially from the values that we may ultimately realize.

Further, such loans are generally subject to legal and other restrictions on resale or otherwise are less liquid than publicly traded securities.

If we were required to liquidate our investment in a loan in a forced or liquidation sale, we could realize significantly less than the value at which we had recorded such loan investment.

Changes in Market Interest Rates and Effect on Net Interest Income

Interest rates are highly sensitive to many factors, including fiscal and monetary policies and domestic and international economic and political

considerations, as well as other factors beyond our control.

Interest rates are highly sensitive to many factors, including fiscal and monetary policies and domestic and international economic and political considerations, as well as other factors beyond our control.

We are subject to interest rate risk in connection with our assets and our related financing obligations.

Our operating results depend in large part on differences between the income earned on our assets and our cost of borrowing.

The cost of our borrowings

generally will be based on prevailing market interest rates.

During a period of rising interest rates, our borrowing costs generally will increase (a) while the yields earned on our leveraged fixed-rate loan assets will remain static, and (b) at a

faster pace than the yields earned on our leveraged floating-rate loan assets, which could result in a decline in our net interest spread and net interest margin.

The severity of any such decline would depend on our asset/liability composition at the

time as well as the magnitude and duration of the interest rate increase.

The cost of our borrowings generally will be based on prevailing market interest rates.

During a period of rising interest rates, our borrowing costs generally will increase (a) while the yields earned on our leveraged fixed-rate loan assets will remain static, and (b) at a faster pace than the yields earned on our leveraged floating-rate loan assets, which could result in a decline in our net interest spread and net interest margin.

The severity of any such decline would depend on our asset/liability composition at the time as well as the magnitude and duration of the interest rate increase.

Further, an increase in short-term interest rates could also have a negative impact on the market value of our target investments.

If any of these events happen, we could

experience a decrease in net income or incur a net loss during these periods, which could adversely affect our liquidity and results of operations.

If any of these events happen, we could experience a decrease in net income or incur a net loss during these periods, which could adversely affect our liquidity and results of operations.

We are exposed to market risks in the ordinary course of our business.

These risks primarily relate to fluctuations in interest rates.

Our loans are typically valued using a yield analysis, which is typically performed for non-credit impaired loans to borrowers.

in market yields may change the fair value of certain of our loans.

Generally, an increase in market yields may result in a decrease in the fair value of certain of our loans, however this is mitigated to the extent our loans bear interest at a

floating rate.

Changes in market yields may change the fair value of certain of our loans.

Generally, an increase in market yields may result in a decrease in the fair value of certain of our loans;

however, this is mitigated to the extent our loans bear interest at a floating rate.

As of December 31, 2022, a decrease of 50 bps or increase of 50 bps of the market yield would have resulted in a change in unrealized gain (loss) of approximately $0.5 million and $(0.5) million, respectively.

As of December 31, 2021

we had six floating-rate loans, representing approximately 35% of our portfolio based on aggregate outstanding principal balances, subject to a weighted average LIBOR floor of approximately 1.0% with LIBOR quoted as 0.101%.

We estimate that a

hypothetical 100 basis points increase in LIBOR would result in an increase in annual interest income of approximately $0.1 million and a decrease in LIBOR would not affect our interest income due to the LIBOR floor on our loans.

This assumes that

the weighted average LIBOR floor of our floating-rate loans remains at approximately 1.0%.

As of December 31, 2022, we had six floating-rate loans, representing approximately 54% of our portfolio based on aggregate outstanding principal balances.

These floating benchmark rates include one-month LIBOR subject to a weighted average floor of 1.0% and quoted at 4.392%, one-month Secured Overnight Financing Rate (“SOFR”) subject to a weighted average floor of 1.0%, and quoted at 4.358% and U.S.

prime rate subject to a weighted average floor of 4.9% quoted at 7.500%.

We estimate that a hypothetical 100 basis points increase in the floating benchmark rate would result in an increase in annual interest income of approximately $2.2 million and a hypothetical 100 basis points decrease in the floating benchmark rate would result in a decrease in annual interest income of approximately $(2.2) million.

Interest Rate Cap Risk

Through our Manager, we originate both fixed and floating rate loans and going forward, we intend to have the majority of our loans by aggregate commitments

accrue at floating rates.

Through our Manager, we originate both fixed and floating rate loans and going forward, we intend to have the majority of our loans by aggregate commitments accrue at floating rates.

These are assets in which the loans may be subject to periodic and lifetime interest rate caps and floors, which limit the amount by which the asset’s interest yield may change during any given period.

However, our borrowing

costs pursuant to our financing agreements may not be subject to similar restrictions.

Therefore, in a period of increasing interest rates, interest rate costs on our borrowings could increase without limitation by caps, while the interest-rate

yields on our floating-rate assets would effectively be limited.

However, our borrowing costs pursuant to our financing agreements may not be subject to similar restrictions.

Therefore, in a period of increasing interest rates, interest rate costs on our borrowings could increase without limitation by caps, while the interest-rate yields on our floating-rate assets would effectively be limited.

In addition, floating-rate assets may be subject to periodic payment caps that result in some portion of the interest being deferred and added to the principal outstanding.

result in our receipt of cash income from such assets in an amount that is less than the amount that we would need to pay the interest cost on our related borrowings.

These factors could lower our net interest income or cause a net loss during

periods of rising interest rates, which would harm our financial condition, cash flows and results of operations.

The FCA and IBA also announced the cessation of the publication of LIBOR for one-week and tw o-month U.S.-dollar LIBOR tenors starting

after December 31, 2021, and the cessation of the remaining tenors of U.S.-dollar LIBOR settings starting after June 30, 2023.

On July 29, 2021, the ARRC formally recommended the adoption of CME Group Inc.’s forward-looking SOFR term rates as the

replacement for U.S.-dollar LIBOR.

Although a transition towards various alternative reference rates, such as SOFR or the Sterling Over Night Index Average, appears to be in progress, it is unknown whether any of these alternative reference rates

will attain market acceptance as replacements for LIBOR.

If LIBOR is no longer available, our applicable loan documents generally allow us to choose a new index based upon comparable information Any of these proposals or consequences could have a

material adverse effect on our interest expenses.

For further information on the risks associated with the elimination of LIBOR, please see “ Risk Factors—Risks Related to Our Business and Growth Strategy—Changes to,

or the elimination of, LIBOR may adversely affect interest expense related to our loans and investments .”

This could result in our receipt of cash income from such assets in an amount that is less than the amount that we would need to pay the interest cost on our related borrowings.

These factors could lower our net interest income or cause a net loss during periods of rising interest rates, which would harm our financial condition, cash flows and results of operations.

Potential Impact of LIBOR Transition

As of December 31, 2022, six of our loans, representing approximately 54% of our portfolio based on aggregate outstanding principal balances, paid interest at a variable rate tied to either LIBOR, SOFR, or U.S.

If one of these floating benchmarks are no longer available, our applicable loan documents generally allow us to choose a new index based upon comparable information.

However, if each of these benchmarks are no longer available, we may need to renegotiate some of our agreements to determine a replacement index or rate of interest.

As such, the potential effect of any such event on our cost of capital and net investment income cannot yet be determined and any changes to benchmark interest rates could increase our financing costs, which could impact our results of operations, cash flows and the market value of our loans.

In addition, the elimination of LIBOR and/or changes to another index could result in mismatches with the interest rate of loans that we are financing.

For further information on the risks associated with the elimination of LIBOR, please see “ Risk Factors—Risks Related to Our Business and Growth Strategy—Changes to, or the elimination of, LIBOR may adversely affect interest expense related to our loans and investments .”

Interest Rate Mismatch Risk

We may fund a portion of our origination of loans, or of loans that we may in the future acquire, with borrowings that are based on LIBOR, while the interest rates on these assets may be fixed or

indexed to LIBOR or another index rate.

Accordingly, any increase in LIBOR will generally result in an increase in our borrowing costs that would not be matched by fixed-rate interest earnings and may not be matched by a corresponding increase in

floating-rate interest earnings.

Any such interest rate mismatch could adversely affect our profitability, which may negatively impact distributions to our stockholders.

We may fund a portion of our origination of loans, or of loans that we may in the future acquire, with borrowings that are based on various benchmarks, while the interest rates on these assets may be fixed or indexed to LIBOR, SOFR, U.S.

prime rate, or another index rate.

Accordingly, any increase in an index rate will generally result in an increase in our borrowing costs that would not be matched by fixed-rate interest earnings and may not be matched by a corresponding increase in floating-rate interest earnings.

Any such interest rate mismatch could adversely affect our profitability, which may negatively impact distributions to our shareholders.

Our analysis of risks is based on our Manager’s experience, estimates, models and assumptions.

These analyses rely on models which utilize estimates of fair

value and interest rate sensitivity.

Actual economic conditions or implementation of decisions by our Manager and our management may produce results that differ significantly from the estimates and assumptions used in our models and the projected

Market Conditions

We believe that favorable market conditions, including an imbalance in supply and demand of credit to cannabis operating companies, have provided attractive

opportunities for non-bank lenders, such as us, to finance commercial real estate loans and other loans that exhibit strong fundamentals but also require more customized financing structures and loan products than regulated financial institutions can

presently provide.

Additionally, to the extent that additional states legalize cannabis, our addressable market will increase.

While we intend to continue our track record of capitalizing on these opportunities and growing the size of our portfolio,

we are aware that the competition for the capital we provide is increasing.

See “ Risk Factors—Risks Related to Our Business and Growth Strategy—Competition for the capital that we provide may reduce the return of our

loans, which could adversely affect our operating results and financial condition.

These analyses rely on models which utilize estimates of fair value and interest rate sensitivity.

We are subject to varying degrees of credit risk in connection with our loans and interest receivable.

Our Manager seeks to mitigate this risk by seeking to

originate loans, and may in the future acquire loans, of higher quality at appropriate prices given anticipated and unanticipated losses, by employing a comprehensive review and selection process and by proactively monitoring originated and acquired

Our Manager seeks to mitigate this risk by seeking to originate loans, and may in the future acquire loans, of higher quality at appropriate prices given anticipated and unanticipated losses, by employing a comprehensive review and selection process and by proactively monitoring originated and acquired loans.

Nevertheless, unanticipated credit losses could occur that could adversely impact our operating results.

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We expect to be subject to varying degrees of credit risk in connection with holding our portfolio of loans.

We will have exposure to credit risk on our

commercial real estate loans and other targeted types of loans.

Our Manager will seek to manage credit risk by performing deep credit fundamental analysis of potential assets and through the use of non-recourse financing, when and where available and

Credit risk will also be addressed through our Manager’s on-going review, and loans will be monitored for variance from expected prepayments, defaults,

severities, losses and cash flow on a quarterly basis.

Other than the acquisition of our initial portfolio of loans and certain loan commitments relating to Private Company A, we, through our Manager, have

originated substantially all of our loans and intend to continue to originate our loans, but we have previously and may in the future acquire loans from time to time.

Our Investment Guidelines are not subject to any limits or proportions with respect

to the mix of target investments that we make or that we may in the future acquire other than as necessary to maintain our exemption from registration under the Investment Company Act and our qualification as a REIT.

Our investment decisions will

depend on prevailing market conditions and may change over time in response to opportunities available in different interest rate, economic and credit environments.

As a result, we cannot predict the percentage of our capital that will be invested in

any individual target investment at any given time.

Our loan portfolio as of December 31, 2021 was concentrated with the top four borrowers representing approximately 58.2% of the

aggregate outstanding principal balances and approximately 59.1% of the total loan commitments.

Additionally, the industry is experiencing significant consolidation, which we expect to increase, among cannabis operations and certain of our

borrowers may combine, increasing the concentration of our borrower portfolio with those consolidated operators.

See “ Risk Factors—Risks Related to Our

Business and Growth Strategy—Our Existing Portfolio is, and our future portfolio may be, concentrated in a limited number of loans, which subjects us to an increased risk of significant loss if any asset declines in value or if a particular

borrower fails to perform as expected.

” The largest credit facility represented approximately 15.6% of our total loan commitments and approximately 12.8% of the aggregate outstanding principal balances of our portfolio as of December 31,

2021 and the borrower under this credit facility is Subsidiary of Private Company G, a multi-state operator that pledged certain of its assets in New Jersey and Pennsylvania as collateral for its senior term loan with us.

Our portion of the senior

term loan provided to such borrower had an aggregate principal amount of $46.7 million outstanding as of December 31, 2021 and is secured by substantially all assets of the borrower.

This senior term loan accrues interest at a blended rate of 12.5%

per annum, payable in cash, plus a blended PIK interest rate of 1.8% per annum across the three tranches of the senior term loan facility.

This senior term loan contains certain representations and warranties, affirmative covenants, negative

covenants and conditions that are customarily required for similar financings, including covenants that limit the borrower’s ability to incur, create, or assume certain indebtedness, borrower’s ability to make distributions, and borrower’s ability

to engage in certain mergers, consolidations, and asset sales.

This senior term loan also requires borrower to comply with certain financial maintenance covenants (measured at the end of each fiscal quarter) including a minimum adjusted EBITDA,

minimum free cash flow, maximum total leverage ratio, minimum fixed charge coverage ratio and minimum cash balance.

This senior term loan also contains customary events of default (subject, in certain instances, to specified grace periods)

including, but not limited to, the failure to make payments of interest or premium, if any, on, or principal under the loans, the failure to comply with certain covenants and agreements specified in the credit agreement, defaults in respect of

certain other indebtedness and certain events relating to bankruptcy or insolvency.

If any event of default occurs, the principal, premium, if any, interest and any other monetary obligations on all the then outstanding amounts under the senior

term loans may become due and payable immediately.

Upon the occurrence of an event of default, a default interest rate of an additional 5.0% may be applied to the outstanding principal balance, and the Manager may declare all outstanding

obligations immediately due and payable (subject, in certain instances, to specified grace periods) and take such other actions as set forth in the credit agreement.

Upon the occurrence of certain bankruptcy and insolvency events, the obligations

under the credit agreement would automatically become due and payable.

We will have exposure to credit risk on our commercial real estate loans and other targeted types of loans.

Our Manager will seek to manage credit risk by performing deep credit fundamental analysis of potential assets and through the use of non-recourse financing, when and where available and appropriate.

Credit risk will also be addressed through our Manager’s on-going review, and loans will be monitored for variance from expected prepayments, defaults, severities, losses and cash flow on a quarterly basis.

Other than the acquisition of our initial portfolio of loans and certain loan commitments relating to Private Company A, we, through our Manager, have originated substantially all of our loans and intend to continue to originate our loans, but we have previously and may in the future acquire loans from time to time.

Our Investment Guidelines are not subject to any limits or proportions with respect to the mix of target investments that we make or that we may in the future acquire other than as necessary to maintain our exemption from registration under the Investment Company Act and our qualification as a REIT.

Our investment decisions will depend on prevailing market conditions and may change over time in response to opportunities available in different interest rate, economic and credit environments.

As a result, we cannot predict the percentage of our capital that will be invested in any individual target investment at any given time.

Our loan portfolio as of December 31, 2022 was concentrated with the top four borrowers representing approximately 70.8% of the aggregate outstanding principal balances and approximately 69.7% of the total loan commitments.

Additionally, the industry is experiencing significant consolidation, which we expect to increase, among cannabis operations and certain of our borrowers may combine, increasing the concentration of our borrower portfolio with those consolidated operators.

Our largest credit facility represented approximately 18.7% of the aggregate outstanding principal balances of our portfolio and approximately 20.1% of the total loan commitments as of December 31, 2022.

The borrower under this credit facility is a Subsidiary of Public Company H, a multi-state operator with real estate assets in several states, certain of which have been included as collateral in connection with the senior term loan.

Our portion of the senior term loan provided to such borrower had a principal amount of $75.0 million outstanding as of December 31, 2022 and $15.0 million unfunded.

This senior term loan accrues interest at a variable rate of U.S.

prime rate plus 5.8%, subject to a U.S.

prime rate floor of 5.5%.

In June 2016, the FASB issued Accounting Standards Update (“ASU”) No.

2016-13, which replaced the incurred loss impairment methodology pursuant to GAAP with a

methodology that reflects current expected credit losses (“CECL”) on both the outstanding balances and unfunded commitments on loans held for investment and requires consideration of a broader range of historical experience adjusted for current

conditions and reasonable and supportable forecast information to inform credit loss estimates (the “CECL Reserve”).

2016-13, which replaced the incurred loss impairment methodology pursuant to GAAP with a methodology that reflects CECL on both the outstanding balances and unfunded commitments on loans held for investment and requires consideration of a broader range of historical experience adjusted for current conditions and reasonable and supportable forecast information to inform credit loss estimates (the “CECL Reserve”).

We adopted ASU No.

2016-13 as of July 31, 2020, the date of our commencement of operations.

Subsequent period increases and decreases

to expected credit losses impact earnings and are recorded within provision for current expected credit losses in our consolidated statement of operations.

The CECL Reserve related to outstanding balances on loans held for investment required under

Subsequent period increases and decreases to expected credit losses impact earnings and are recorded within provision for current expected credit losses in our consolidated statement of operations.

The CECL Reserve related to outstanding balances on loans held for investment required under ASU No.

2016-13 is a valuation account that is deducted from the amortized cost basis of our loans held at carrying value and loans receivable at carrying value in our consolidated balance sheet.

The CECL Reserve related to unfunded commitments on

loans held at carrying value is recorded within accounts payable and other liabilities in our consolidated balance sheet.

Refer to Note 6 to our annual consolidated financial statements December 31, 2021 consolidated financial statements titled “ Current Expected Credit Losses ” for more information on CECL.

We provide loans to established companies operating in the cannabis industry which involves significant risks, including the risk of strict enforcement against

our borrowers of the federal illegality of cannabis, our borrowers’ inability to renew or otherwise maintain their licenses or other requisite authorizations for their cannabis operations, and such loans lack of liquidity, and we could lose all or

part of any of our loans.

Our ability to grow or maintain our business depends on state laws pertaining to the cannabis industry.

New laws that are adverse to our borrowers may be

enacted, and current favorable state or national laws or enforcement guidelines relating to cultivation, production and distribution of cannabis may be modified or eliminated in the future, which would impede our ability to grow and could materially

adversely affect our business.

The CECL Reserve related to unfunded commitments on loans held at carrying value is recorded within current expected credit loss reserve as a liability in our consolidated balance sheet.

Refer to Note 6 to our annual consolidated financial statements for the year ended December 31, 2022 titled “ Current Expected Credit Losses ” for more information on CECL.

We primarily provide loans to companies operating in the cannabis industry which involves significant risks, including the risk of strict enforcement against our borrowers of the federal illegality of cannabis, our borrowers’ inability to renew or otherwise maintain their licenses or other requisite authorizations for their cannabis operations, and such loans lack of liquidity, and we could lose all or part of any of our loans.

Our ability to grow or maintain our core business depends on state laws pertaining to the cannabis industry.

New laws that are adverse to our borrowers may be enacted, and current favorable state or national laws or enforcement guidelines relating to cultivation, production and distribution of cannabis may be modified or eliminated in the future, which would impede our ability to grow and could materially adversely affect our business.

Management’s plan to mitigate risks include monitoring the legal landscape as deemed appropriate.

Also, should a loan default or otherwise be seized, we may be

prohibited from owning cannabis assets and thus could not take possession of collateral, in which case we would look to sell the loan, which could result in us realizing a loss on the transaction.

Also, should a loan default or otherwise be seized, we may be prohibited from owning cannabis assets and thus could not take possession of collateral, in which case we would look to sell the loan, which could result in us realizing a loss on the transaction.

Real Estate Risk

Commercial real estate loans are subject to volatility and may be affected adversely by a number of factors, including, but not limited to, national, regional

and local economic conditions (which may be adversely affected by industry slowdowns and other factors);

Commercial real estate loans are subject to volatility and may be affected adversely by a number of factors, including, but not limited to, national, regional and local economic conditions (which may be adversely affected by industry slowdowns and other factors);

local real estate conditions;

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construction quality, age and design;

demographic factors;

and retroactive changes to building or similar codes.

In addition, decreases in property values reduce the value of the collateral and the potential proceeds available to a borrower to repay the underlying loan or loans, as the case may be,

which could also cause us to suffer losses.

In addition, decreases in property values reduce the value of the collateral and the potential proceeds available to a borrower to repay the underlying loan or loans, as the case may be, which could also cause us to suffer losses.

Consolidated Financial Statements and Supplementary Data

See our Consolidated Financial Statements and the Notes thereto together with the report thereon of CohnReznick LLP dated March 10, 2022, beginning on page F-1

of this report included in Item 15, which are incorporated herein by reference in this Item 8.

See our Consolidated Financial Statements and the Notes thereto together with the report thereon of CohnReznick LLP dated March 7, 2023, beginning on page F-1 of this report included in Item 15, which are incorporated herein by reference in this Item 8.

Changes In and Disagreements With Accountants on Accounting and Financial Disclosure

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 7A. Quantitative and Qualitative Disclosures About Market Risk