The risk factors listed in this section and other factors noted herein could cause actual results to differ materially from those contained in any forward-looking statements or could result in a significant or material adverse effect on the Company’s results of operations.
+Added: RISKS RELATED TO THE EFFECTS OF COVID-19 AND OTHER POTENTIAL PANDEMICS, HEALTH CRISES OR OTHER CATASTROPHIC EVENTS
+Added: Our business could be adversely affected by the COVID-19 pandemic or the occurrence of another catastrophic event.
+Added: and other countries continue to experience an outbreak of COVID-19.
+Added: This contagious disease outbreak has continued to spread globally and has resulted in authorities implementing numerous measures to try to contain the virus, such as travel bans and restrictions, quarantines, shelter in place orders, and shutdowns.
+Added: These measures have impacted and may continue to impact the Company’s workforce and operations.
+Added: The spread of COVID-19 has caused the Company to modify its business practices (including employee travel, employee work locations, and cancellation of physical participation in meetings, events and conferences), and the Company may take further actions as may be required by government authorities or that the Company believes is in the best interests of its employees.
+Added: The extent to which COVID-19 impacts the Company's future operations will depend on uncertain developments, including the duration and severity of the pandemic, actions taken to contain the spread of the virus, regulatory actions taken as a result of the outbreak and any deterioration in economic conditions.
+Added: This situation is continually changing, and additional impacts may arise that the Company is not aware of currently.
+Added: It is not currently possible to predict the extent that COVID-19 will impact the Company's financial position or results of operation, although it is possible that it could have a material adverse effect on the Company's business.
+Added: Any other catastrophic events, such as future pandemic diseases, natural disasters and terrorist attacks, could have a material adverse effect on our future results of operations and financial condition.
+Added: The Company’s business operations could be impacted, including availability of key Company personnel and disruptions to the real estate environment, financial markets or the Company's information technology systems.
+Added: RISKS RELATED TO THE COMPANY’S BUSINESS
Adverse changes in economic conditions, especially those related to real estate activity, may negatively impact the Company’s results of operations and financial condition.
6 unchanged sentences
Underwriting agents and approved settlement providers, which can include issuing agents and approved attorneys, perform a significant portion of the work necessary to issue the Company’s title insurance policies.
−Removed: These agents and providers operate with a substantial degree of independence from the Company, and while they are subject to certain contractual limitations designed to mitigate the Company’s risk, there is no guarantee that these limitations will eliminate all associated risks.
+Added: These agents and providers operate with a substantial degree of independence from the Company, subject to certain contractual limitations and reinsurance agreements.
As a result, the Company’s use of title agents and approved providers could result in claims on the Company’s policies and other expenses due to fraud and negligence.
17 unchanged sentences
To the extent that actual claims experience is greater than estimated, the Company could be required to increase the reserve.
−Removed: Breaches and failures of, and other disruptions to, the Company’s information technology systems may disrupt the Company’s operations, result in monetary losses and harm the Company’s reputation.
−Removed: The Company relies on information technology (“IT”) systems for a wide range of activities involved in the delivery of its products and services, including, but not limited to the following:
−Removed: process title insurance applications and policy issuances;
−Removed: perform due diligence on land titles;
−Removed: manage substantial cash, investment assets, bank deposits, trust assets and escrow account balances on behalf of the Company and its customers;
−Removed: manage billing, collections and payables, including insurance premiums and agent commissions;
−Removed: manage accounting and financial reporting;
−Removed: manage payroll and human resources information.
−Removed: The Company’s IT systems may be disrupted or fail, and information stolen or otherwise misappropriated, for a number of reasons, including:
−Removed: hacking, computer viruses, malware, ransomware or other cyberattacks;
−Removed: software “bugs”, hardware defects or human error;
−Removed: natural disasters, like fires, or pandemics;
−Removed: Any of these events could disrupt operations both internally and externally, which may result in the loss of revenues.
−Removed: These events could also result in the unauthorized release of proprietary and/or non-public information, or even defalcation of corporate or client funds.
−Removed: Like all companies, the Company’s IT systems have been, and likely will continue to be the target of computer viruses, cyberattacks, phishing attacks and other malicious activity.
−Removed: To date, the Company has not experienced a known material breach;
−Removed: however, the occurrence or scope of such events is not always immediately apparent.
−Removed: The Company invests resources in maintaining the security of its systems and adapting to evolving security threats.
−Removed: There is, however, no guarantee that its security measures will be adequate to prevent all cyberattacks.
−Removed: There is similarly no guarantee that the Company’s backup systems or disaster recovery procedures will be adequate to mitigate losses due to IT system disruptions in a timely fashion, and the Company may incur significant expense in correcting IT system emergencies.
−Removed: The Company’s reputation may also be damaged in the event of a serious IT breach or failure.
−Removed: Furthermore, as technology develops, and as cybercriminals become more capable, the difficulty and expense of maintaining IT security and redundancy may increase.
−Removed: To the extent the Company’s IT systems store non-public personal information, and information about its employees, security breaches may expose the Company to other serious liabilities and reputational harm if such data is misappropriated.
−Removed: Non-public personal information may include, but is not limited to, names, addresses, social security numbers, and banking information.
−Removed: Furthermore, the Company is required by law and by certain contracts, particularly contracts with financial institutions, to notify various parties, consumers and customers in the event that confidential or personal information may have been or was accessed by unauthorized third parties.
−Removed: Such an event could potentially result in a breach of contract, and any required notifications could result in, among other things, the loss of customers, negative publicity, distraction of management, fines, lawsuits for breach of contract, regulatory inquiries or involvement and a decline in sales.
−Removed: The Company seeks to mitigate the financial risk associated with unauthorized disclosure of non-public information by maintaining cyber liability insurance coverage.
−Removed: As cybercriminals continue to become more sophisticated, the costs to insure against cyberattacks may rise.
+Added: Competition affects the Company’s results of operations .
+Added: The title insurance industry is highly competitive with only a few insurers comprising a large percentage of the market.
+Added: Key competitive factors are quality of service, price within regulatory parameters, expertise, timeliness and the financial strength and size of the insurer.
+Added: Title insurance underwriters compete for premiums by choosing various distribution channels which may include company-owned operations, independent agents and agency relationships with real estate attorneys, subsidiaries of community and regional lending institutions, realtors, builders and other settlement service providers.
+Added: Title insurance underwriters compete for agents on the basis of service, technology and commission levels.
+Added: Some title insurers currently have greater financial resources, larger distribution networks and more extensive computerized databases of property records and information than the Company.
+Added: The number and size of competing companies varies in the different geographic areas in which the Company operates, and any reductions to current regulatory barriers within any of the different geographic areas could increase the number of competitors entering into the title insurance market.
+Added: Competition among the major providers of title insurance or the acceptance of alternative products to traditional title products by the regulatory authorities and the marketplace could adversely affect the Company’s operations and financial condition.
+Added: The Company may encounter difficulties managing growth, which could adversely affect its operating results.
+Added: The Company’s future growth plans involve expansion into new geographic locations and further penetration into established markets through new or existing agents, or through acquisitions.
+Added: Such growth may subject the Company to associated risks, such as diverting management’s attention, incurring unanticipated liabilities from an acquired business, difficulty integrating an acquired entity, or retaining its employees or customers and realization of synergies.
+Added: The occurrence of any of these risks may deprive the Company of some or all of the anticipated value of an acquisition or other growth initiatives, resulting in lower returns on investments and result in a negative impact on the Company’s results of operations.
+Added: These risks could be particularly significant if the Company incurs significant costs in pursuing an acquisition or other initiatives.
+Added: The Company depends on its ability to attract and retain key personnel and agents, and its inability to do so could adversely affect its business.
+Added: Competition for skilled and experienced personnel in the Company’s industry is high, and the success of the Company is substantially dependent on its ability to attract and retain such personnel.
+Added: The Company may have difficulty hiring and retaining the necessary marketing and management personnel to support future growth plans.
+Added: Also, the Company’s results of operations and financial condition could be adversely affected if it is unsuccessful in attracting and retaining new agents.
+Added: Mortgage lending is highly concentrated and changes in relationships with lenders or reform of government-sponsored entities could adversely affect the Company.
+Added: Refusal by major market lenders to accept our product offerings could have a material adverse effect on the Company.
+Added: Furthermore, government-sponsored entities, the Federal National Mortgage Association (“Fannie Mae”) and the Federal Home Loan Mortgage Corporation (“Freddie Mac”), often require the purchase of title insurance for home loans they securitize.
+Added: The federal government has had discussions about the possible reform of Fannie Mae and Freddie Mac.
+Added: Changes to these entities could impact the entire mortgage loan process and as a result, could impact the demand for title insurance.
+Added: The timing and results of reform are currently unknown;
+Added: however, changes to these entities could adversely impact the Company and its results of operations.
+Added: Unfavorable economic or other conditions could cause the Company to record impairment charges for all or a portion of its goodwill and other intangible assets.
+Added: As a result of acquisition activity, the Company has goodwill and other intangible assets that comprise approximately 3.5% of total assets as of December 31, 2020.
+Added: Quarterly, the Company performs an impairment analysis that reviews changes in events or circumstances that could lead to the carrying value not being recoverable.
+Added: Economic downturns or poor performance of the acquisitions could result in the Company recognizing an impairment of a portion or all of the goodwill and intangible assets on the Company’s books and could have a material adverse effect on the Company’s results of operations.
+Added: RISKS RELATED TO REGULATORY AND COMPLIANCE MATTERS
The Company’s insurance subsidiaries are subject to complex government regulations.
26 unchanged sentences
New regulations, or differing interpretations of existing laws, could change business processes, products and services and have a negative impact on the Company’s results of operations and financial condition.
−Removed: Competition affects the Company’s results of operations .
−Removed: The title insurance industry is highly competitive with only a few insurers comprising a large percentage of the market.
−Removed: Key competitive factors are quality of service, price within regulatory parameters, expertise, timeliness and the financial strength and size of the insurer.
−Removed: Title insurance underwriters compete for premiums by choosing various distribution channels which may include company-owned operations, independent agents and agency relationships with real estate attorneys, subsidiaries of community and regional lending institutions, realtors, builders and other settlement service providers.
−Removed: Title insurance underwriters compete for agents on the basis of service, technology and commission levels.
−Removed: Some title insurers currently have greater financial resources, larger distribution networks and more extensive computerized databases of property records and information than the Company.
−Removed: The number and size of competing companies varies in the different geographic areas in which the Company operates, and any reductions to current regulatory barriers within any of the different geographic areas could increase the number of competitors entering into the title insurance market.
−Removed: Competition among the major providers of title insurance or the acceptance of alternative products to traditional title products by the regulatory authorities and the marketplace could adversely affect the Company’s operations and financial condition.
−Removed: Deterioration in financial markets may cause a decline in the performance of the Company’s investments and could have a material adverse impact on net income.
−Removed: The Company derives a substantial portion of its income from its investment portfolio that primarily includes fixed maturity securities and equity securities.
−Removed: The Company’s investment policy is designed to comply with regulatory requirements and to balance the competing objectives of asset quality and investment returns.
−Removed: The Company’s investment portfolio is subject to risk from changes in general economic conditions, prices of marketable fixed maturity securities and equity securities, interest rates, liquidity, credit markets, and other external factors.
−Removed: The risk of loss is increased during periods of economic uncertainty and tight credit markets as these factors could limit the ability of some issuers to repay their debt obligations.
−Removed: Fixed maturity securities and equity securities are carried at estimated fair value on the Company’s Consolidated Balance Sheets.
−Removed: Changes in the estimated fair value of securities in the Company’s investment portfolio could have a material adverse effect on the Company’s results of operations and financial condition.
−Removed: Changes in the estimated fair value of fixed maturity securities are recorded as a component of accumulated other comprehensive income.
−Removed: If the carrying value of the Company’s fixed maturity securities exceeds the estimated fair value, and the decline in estimated fair value is deemed to be other-than-temporary, the Company will be required to write down the value of its investments.
−Removed: Effective January 1, 2018, unrealized holding gains and losses are reported in the Consolidated Statements of Income as changes in the estimated fair value of equity security investments, without regard as to whether a decline in value is deemed to be temporary or other-than-temporary.
−Removed: The Company’s net income may in turn experience more volatility as changes in fair value will more immediately affect the Consolidated Statement of Income.
A downgrade from a rating agency could result in a loss of underwriting business.
2 unchanged sentences
The Company’s title insurance subsidiaries are currently rated by A.M.
−Removed: Best Company, Kroll Bond Rating Agency and Demotech, Inc.
+Added: Best Company and Demotech, Inc.
The ratings issued by independent rating agencies are not credit ratings, but represent the opinion of the individual rating agency regarding the title insurance subsidiaries’ financial strength, operating performance, and ability to meet policyholder obligations.
6 unchanged sentences
This regulation could impact the Company’s ability to adjust prices in the face of rapidly changing market conditions, which could adversely affect results of operations.
−Removed: The Company may encounter difficulties managing system or technological changes, which could adversely affect its financial and operating results.
−Removed: Technological changes in the title insurance industry are driven primarily by evolution in technology, competitive factors and regulatory changes.
−Removed: These changes have resulted in faster information delivery and efficient, highly automated production processes.
−Removed: The inability of the Company to manage, develop or successfully implement new systems or technological changes could negatively impact profitability.
−Removed: Financial institution failures could adversely affect the Company.
−Removed: The Company has substantial deposits with financial institutions, including fiduciary deposits that are owned by third parties.
−Removed: There is no guarantee the Company, whether through the Federal Deposit Insurance Corporation or otherwise, would recover the funds it has deposited should one or more of the financial institutions at which the Company maintains deposits fail.
−Removed: The Company may encounter difficulties managing growth, which could adversely affect its operating results.
−Removed: The Company’s future growth plans involve expansion into new geographic locations and further penetration into established markets through new or existing agents, or through acquisitions.
−Removed: Such growth may subject the Company to associated risks, such as diverting management’s attention, incurring unanticipated liabilities from an acquired business, difficulty integrating an acquired entity, or retaining its employees or customers and realization of synergies.
−Removed: The occurrence of any of these risks may deprive the Company of some or all of the anticipated value of an acquisition or other growth initiatives, resulting in lower returns on investments and result in a negative impact on the Company’s results of operations.
−Removed: These risks could be particularly significant if the Company incurs significant costs in pursuing an acquisition or other initiatives.
−Removed: The Company depends on its ability to attract and retain key personnel and agents, and its inability to do so could adversely affect its business.
−Removed: Competition for skilled and experienced personnel in the Company’s industry is high, and the success of the Company is substantially dependent on its ability to attract and retain such personnel.
−Removed: The Company may have difficulty hiring and retaining the necessary marketing and management personnel to support future growth plans.
−Removed: Also, the Company’s results of operations and financial condition could be adversely affected if it is unsuccessful in attracting and retaining new agents.
−Removed: Policies and procedures for the mitigation of risk may not be sufficient.
−Removed: The Company has policies and procedures in place to help identify, analyze, and measure the risks associated with the issuance of title insurance policies, investment risks, interest rate risks and legal risks, among others.
−Removed: In evaluating risks, the Company considers enterprise risk management, information technology risk management, disaster recovery, business continuity, and vendor risk management.
−Removed: Because a significant degree of judgment is involved with the establishment of policies and processes as well as the measurement of risks, it is possible not all risks have been identified or anticipated.
−Removed: Misidentified or unanticipated risks could adversely impact the Company and its results of operations.
Regulatory investigations of the title insurance industry by governmental entities could adversely impact the Company’s results of operations.
3 unchanged sentences
The results of future inquiries could adversely affect the Company’s results of operations and financial condition.
−Removed: Mortgage lending is highly concentrated and changes in relationships with lenders or reform of government-sponsored entities could adversely affect the Company.
−Removed: Refusal by major market lenders to accept our product offerings could have a material adverse effect on the Company.
−Removed: Furthermore, government-sponsored entities, the Federal National Mortgage Association (“Fannie Mae”) and the Federal Home Loan Mortgage Corporation (“Freddie Mac”), often require the purchase of title insurance for home loans they securitize.
−Removed: The federal government has had discussions about the possible reform of Fannie Mae and Freddie Mac.
−Removed: Changes to these entities could impact the entire mortgage loan process and as a result, could impact the demand for title insurance.
−Removed: The timing and results of reform are currently unknown;
−Removed: however, changes to these entities could adversely impact the Company and its results of operations.
The Company relies on distributions from its insurance subsidiaries .
5 unchanged sentences
Additionally, these subsidiaries are required to maintain minimum amounts of capital, surplus and reserves.
−Removed: As of December 31, 2019 , approximately $103.5 million of consolidated stockholders’ equity represented the net assets of the Company’s subsidiaries that cannot be transferred in the form of dividends, loans or advances to the Company.
+Added: As of December 31, 2020, approximately $104.1 million of consolidated shareholders’ equity represented the net assets of the Company’s subsidiaries that cannot be transferred in the form of dividends, loans or advances to the Company.
In general, dividends in excess of prescribed limits are deemed “extraordinary” and require prior approval by the appropriate regulatory body.
1 unchanged sentence
These dividend restrictions could limit the Company’s ability to pay dividends to its shareholders or fund growth opportunities.
−Removed: Unfavorable economic or other conditions could cause the Company to record impairment charges for all or a portion of its goodwill and other intangible assets.
−Removed: As a result of acquisition activity, the Company has goodwill and other intangible assets that comprise approximately 3.9% of total assets as of December 31, 2019 .
−Removed: Quarterly, the Company performs an impairment analysis that reviews changes in events or circumstances that could lead to the carrying value not being recoverable.
−Removed: Economic downturns or poor performance of the acquisitions could result in the Company recognizing an impairment of a portion or all of the goodwill and intangible assets on the Company’s books and could have a material adverse effect on the Company’s results of operations.
−Removed: Certain provisions of the Company’s shareholder rights plan may deter or discourage a takeover of the Company.
−Removed: The Company has adopted a shareholder rights plan.
−Removed: The rights set forth in the plan are not intended to prevent a takeover of the Company, and we believe the rights would be beneficial to the Company and its shareholders in the event of negotiations with a potential acquirer.
−Removed: However, the shareholder rights plan could discourage transactions involving actual or potential changes of control, including transactions that may involve payment of a premium over prevailing market prices to the Company’s common shareholders.
+Added: RISKS RELATED TO INVESTMENTS AND DEPOSITS
+Added: Deterioration in financial markets may cause a decline in the performance of the Company’s investments and could have a material adverse impact on net income.
+Added: The Company derives a substantial portion of its income from its investment portfolio that primarily includes fixed maturity securities and equity securities.
+Added: The Company’s investment policy is designed to comply with regulatory requirements and to balance the competing objectives of asset quality and investment returns.
+Added: The Company’s investment portfolio is subject to risk from changes in general economic conditions, prices of marketable fixed maturity securities and equity securities, interest rates, liquidity, credit markets, and other external factors.
+Added: The risk of loss is increased during periods of economic uncertainty and tight credit markets as these factors could limit the ability of some issuers to repay their debt obligations.
+Added: Fixed maturity securities and equity securities are carried at estimated fair value on the Company’s Consolidated Balance Sheets.
+Added: Changes in the estimated fair value of fixed maturity securities are recorded as a component of accumulated other comprehensive income.
+Added: If the carrying value of the Company’s fixed maturity securities exceeds the estimated fair value, and the decline in estimated fair value is deemed to be other-than-temporary, the Company will be required to write down the value of its investments.
+Added: Unrealized holding gains and losses on equity securities are reported in the Consolidated Statements of Operations as changes in the estimated fair value of equity security investments, without regard as to whether a decline in value is deemed to be temporary or other-than-temporary.
+Added: Changes in the estimated fair value of securities in the Company’s investment portfolio could have a material adverse effect on the Company’s results of operations and financial condition.
+Added: Financial institution failures could adversely affect the Company.
+Added: The Company has substantial deposits with financial institutions, including fiduciary deposits that are owned by third parties.
+Added: There is no guarantee the Company, whether through the Federal Deposit Insurance Corporation or otherwise, would recover the funds it has deposited should one or more of the financial institutions at which the Company maintains deposits fail.
+Added: RISKS RELATED TO CYBERSECURITY, TECHNOLOGY AND RISK MANAGEMENT
+Added: Breaches and failures of, and other disruptions to, the Company’s information technology systems may disrupt the Company’s operations, result in monetary losses and harm the Company’s reputation.
+Added: The Company relies on information technology (“IT”) systems for a wide range of activities involved in the delivery of its products and services, including, but not limited to the following:
+Added: • process title insurance applications and policy issuances;
+Added: • perform due diligence on land titles;
+Added: • manage substantial cash, investment assets, bank deposits, trust assets and escrow account balances on behalf of the Company and its customers;
+Added: • manage billing, collections and payables, including insurance premiums and agent commissions;
+Added: • manage accounting and financial reporting;
+Added: • manage payroll and human resources information.
+Added: The Company’s IT systems may be disrupted or fail, and information stolen or otherwise misappropriated, for a number of reasons, including:
+Added: • hacking, computer viruses, malware, ransomware or other cyberattacks;
+Added: • software “bugs”, hardware defects or human error;
+Added: • natural disasters, like fires, or pandemics;
+Added: • power loss.
+Added: Any of these events could disrupt operations both internally and externally, which may result in the loss of revenues.
+Added: These events could also result in the unauthorized release of proprietary and/or non-public information, or even defalcation of corporate or client funds.
+Added: Like all companies, the Company’s IT systems have been, and likely will continue to be the target of computer viruses, cyberattacks, phishing attacks and other malicious activity.
+Added: To date, the Company has not experienced a known material breach;
+Added: however, the occurrence or scope of such events is not always immediately apparent.
+Added: The Company invests resources in maintaining the security of its systems and adapting to evolving security threats.
+Added: There is, however, no guarantee that its security measures will be adequate to prevent all cyberattacks.
+Added: There is similarly no guarantee that the Company’s backup systems or disaster recovery procedures will be adequate to mitigate losses due to IT system disruptions in a timely fashion, and the Company may incur significant expense in correcting IT system emergencies.
+Added: The Company’s reputation may also be damaged in the event of a serious IT breach or failure.
+Added: Furthermore, as technology develops, and as cybercriminals become more capable, the difficulty and expense of maintaining IT security and redundancy may increase.
+Added: To the extent the Company’s IT systems store non-public personal information, and information about its employees, security breaches may expose the Company to other serious liabilities and reputational harm if such data is misappropriated.
+Added: Non-public personal information may include, but is not limited to, names, addresses, social security numbers, and banking information.
+Added: Furthermore, the Company is required by law and by certain contracts, particularly contracts with financial institutions, to notify various parties, consumers and customers in the event that confidential or personal information may have been or was accessed by unauthorized third parties.
+Added: Such an event could potentially result in a breach of contract, and any required notifications could result in, among other things, the loss of customers, negative publicity, distraction of management, fines, lawsuits for breach of contract, regulatory inquiries or involvement and a decline in sales.
+Added: The Company seeks to mitigate the financial risk associated with unauthorized disclosure of non-public information by maintaining cyber liability insurance coverage.
+Added: As cybercriminals continue to become more sophisticated, the costs to insure against cyberattacks may rise.
+Added: The Company may encounter difficulties managing system or technological changes, which could adversely affect its financial and operating results.
+Added: Technological changes in the title insurance industry are driven primarily by evolution in technology, competitive factors and regulatory changes.
+Added: These changes have resulted in faster information delivery and efficient, highly automated production processes.
+Added: The inability of the Company to manage, develop or successfully implement new systems or technological changes could negatively impact profitability.
+Added: Policies and procedures for the mitigation of risk may not be sufficient.
+Added: The Company has policies and procedures in place to help identify, analyze, and measure the risks associated with the issuance of title insurance policies, investment risks, interest rate risks and legal risks, among others.
+Added: In evaluating risks, the Company considers enterprise risk management, information technology risk management, disaster recovery, business continuity, and vendor risk management.
+Added: Because a significant degree of judgment is involved with the establishment of policies and processes as well as the measurement of risks, it is possible not all risks have been identified or anticipated.
+Added: Misidentified or unanticipated risks could adversely impact the Company and its results of operations.
+Added: RISKS RELATED TO OWNING THE COMPANY’S COMMON STOCK
+Added: Certain provisions in the Company’s organizational law, North Carolina law, organizational documents, and the Company’s shareholder rights plan may deter or discourage a takeover of the Company.
+Added: The Company’s articles of incorporation and bylaws contain certain provisions that could delay, prevent or discourage transactions involving actual or potential changes of control, including transactions that may involve payment of a premium over prevailing market prices to the Company’s common shareholders.
+Added: In addition, the Company has adopted a shareholder rights plan (the “Plan”).
+Added: The provisions in the Company’s organizational documents and the rights set forth in the Plan are not intended to prevent a takeover of the Company, and the Company believes these protective measures are beneficial to the Company and its shareholders in the event of negotiations with a potential acquirer.
+Added: These provisions are described in further detail in “Description of the Company’s Securities” incorporated by reference as Exhibit 4.1 to this Annual Report on Form 10-K.
UNRESOLVED STAFF COMMENTS
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.