What changed in this filing

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Item 1A. Risk Factors

2022-03-30 compared with 2021-03-31 · 164 added, 131 removed, 127 unchanged (70% of the section changed)

5 unchanged sentences

fluctuate widely in response to (i) relatively minor changes in the supply of and demand for oil and natural gas, (ii) market uncertainty and (iii) a variety of additional factors that are beyond the Trustees control.

there has been a substantial decrease in oil and natural gas prices due in part to significantly decreased demand as a result of the novel coronavirus (COVID-19) pandemic, which is discussed below.

A combination of these factors resulted in the price of oil falling below zero to $(37.63) per barrel of oil on April 20, 2020, recovering the following day to $10.01 per barrel of oil.

there has been volatility in oil and natural gas prices due in part to significantly decreased demand as a result of the novel coronavirus

(COVID-19) pandemic beginning in 2020, followed by increasing prices in 2021 and the first quarter of 2022.

A combination of these factors resulted in the price of oil falling below zero to

$(37.63) per barrel of oil on April 20, 2020, recovering the following day to $10.01 per barrel of oil.

As of March 15, 2022, the price of oil was $96.44.

It is uncertain how the war in Ukraine and resulting sanctions against Russia will

affect oil prices in the coming months.

Factors that may impact future commodity prices, including the price of oil and natural gas, include but are not limited to:

political conditions in major oil producing regions, especially in the Middle East;

worldwide economic conditions;

political conditions in major oil producing regions, especially in the Middle East and Russia;

worldwide economic and geopolitical conditions;

weather conditions;

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If production and development costs attributable to the Royalties exceed the gross proceeds related to

production from the Underlying Properties, the Trust will not receive net proceeds until future proceeds from production exceed the total of the excess costs plus accrued interest during the deficit period.

Development activities may not generate

sufficient additional proceeds to repay the costs.

Trust reserve estimates depend on many assumptions that may prove to be inaccurate, which could cause both

estimated reserves and estimated future net revenues to be too high, leading to write-downs of estimated reserves.

The value of the Units will

depend upon, among other things, the reserves attributable to the Royalties from the Underlying Properties.

production from the Underlying Properties, the Trust will not receive net proceeds until future

proceeds from production exceed the total of the excess costs plus accrued interest during the deficit period.

Development activities may not generate sufficient additional proceeds to repay the

Trust reserve estimates depend on many assumptions that may prove to be inaccurate, which could cause both estimated reserves and estimated future net

revenues to be too high, leading to write-downs of estimated reserves.

The value of the Units will depend upon, among other things, the reserves

attributable to the Royalties from the Underlying Properties.

The calculations of proved reserves and estimating reserves is inherently uncertain.

In addition, the estimates of future net revenues are

based upon various assumptions regarding future production levels, prices and costs that may prove to be incorrect over time.

The accuracy of any

reserve estimate is a function of the quality of available data, engineering interpretation and judgment and the assumptions used regarding the quantities of recoverable crude oil and natural gas and the future prices of crude oil and natural gas.

Petroleum engineers consider many factors and make many assumptions in estimating reserves.

In addition, the estimates of future net revenues are based upon various assumptions regarding future

production levels, prices and costs that may prove to be incorrect over time.

The accuracy of any reserve estimate is a function of the quality of

available data, engineering interpretation and judgment and the assumptions used regarding the quantities of recoverable crude oil and natural gas and the future prices of crude oil and natural gas.

Petroleum engineers consider many factors and make

many assumptions in estimating reserves.

Those factors and assumptions include:

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projects, the future rate of production decline of proved reserves may be higher than the rate currently expected by the Trust.

Because the net

proceeds payable to the Trust are derived from the sale of depleting assets, the portion of distributions to Unit holders attributable to depletion may be considered a return of capital as opposed to a return on investment.

Distributions that are a

return of capital will ultimately diminish the depletion tax benefits available to the Unit holders, which could reduce the market value of the Units over time.

Eventually, the Royalties will cease to produce in commercial quantities and the Trust

will, therefore, cease to receive any distributions of net proceeds therefrom.

Future royalty income may be subject to risks relating to the creditworthiness of

third parties.

The Trust does not lend money and has limited ability to borrow money, which the Trustee believes limits the Trusts risk

from credit markets.

The Trusts future royalty income, however, may be subject to risks relating to the creditworthiness of the operators of the Underlying Properties and other purchasers of the crude oil and natural gas produced from the

Underlying Properties, as well as risks associated with fluctuations in the price of crude oil and natural gas.

The market price for the Units may not reflect

the value of the royalty interests held by the Trust.

The public trading price for the Units tends to be tied to the recent and expected levels

of cash distribution on the Units.

The amounts available for distribution by the Trust vary in response to numerous factors outside the control of the Trust, including prevailing prices for crude oil and natural gas produced from the Royalties.

market price is not necessarily indicative of the value that the Trust would realize if it sold those Royalties to a third party buyer.

In addition, such market price is not necessarily reflective of the fact that since the assets of the Trust are

depleting assets, a portion of each cash distribution paid on the Units should be considered by investors as a return of capital, with the remainder being considered as a return on investment.

There is no guarantee that distributions made to a Unit

holder over the life of these depleting assets will equal or exceed the purchase price paid by the Unit holder.

Because the net proceeds payable to the Trust are derived from the sale of depleting assets, the

portion of distributions to Unit holders attributable to depletion may be considered a return of capital as opposed to a return on investment.

Distributions that are a return of capital will ultimately diminish the depletion tax benefits available

to the Unit holders, which could reduce the market value of the Units over time.

Eventually, the Royalties will cease to produce in commercial quantities and the Trust will, therefore, cease to receive any distributions of net proceeds therefrom.

Government action, policies or regulations designed to discourage production of, reduce demand for, or promote alternatives to oil and natural gas could impact

the price of oil and natural gas produced on the Underlying Properties, directly as intended or through unintended consequences.

around the world are considering actions intended to reduce greenhouse gas emissions by decreasing both the supply of and the demand for oil and natural gas products or promote alternatives.

These include the adoption of cap and trade regimes,

carbon taxes, trade tariffs, minimum renewable usage requirements, restrictive permitting, increased mileage and other efficiency standards, mandates for sales of electric vehicles, mandates for use of specific fuels or technologies, and other

incentives or mandates designed to support transitioning to lower-emission energy sources.

Political and other actors and their agents also increasingly seek to advance climate change objectives indirectly, such as by seeking to reduce the

availability or increase the cost of financing and investment in the oil and gas sector.

Depending on how policies are formulated and applied, such policies could impact the ability and costs of the operators of the Underlying Properties supply

products, demand for their products, or the competitiveness of hydrocarbon-based products, which in turn, could reduce royalty income to the Trust Any policy that increases the costs for operators of the Underlying Properties or decreased market

prices could have a material impact on the distributable income of the Trust.

Trustee may be subject to attempted cybersecurity disruptions from a variety of

sources including state-sponsored actors.

The Trustee maintains robust cybersecurity protocols including, but not limited to technological

capabilities that prevent and detect disruptions;

computer workstations and programs protected with passwords and passphrases, as well as employee training throughout the year on banking regulations and cybersecurity followed up by testing of that

Other, non-technical protocols include securing of documents and work areas that could contain person, non-public information.

If the measures taken to

protect against cybersecurity disruptions prove to be insufficient or if proprietary data is otherwise not protected, the Trustee, or customer, employees, or third parties could be adversely affected.

The Trust is also exposed to potential harm from

cybersecurity events that may affect the operations of third-parties, including suppliers, service providers (including providers of cloud-hosting services for our data or applications), and customers.

Cybersecurity disruptions could cause physical

harm to people or the environment, damage or destroy assets;

compromise business systems;

result in proprietary information being altered, lost, or stolen;

result in employee, customer, or third-party information being compromised;

disrupt business operations.

The Trust could incur significant costs to remedy the effects of a major cybersecurity disruption in addition to costs in connection with resulting regulatory actions, litigations, or reputational harm.

Future royalty income may be subject to risks relating to the creditworthiness of third parties.

The Trust does not lend money and has limited ability to borrow money, which the Trustee believes limits the Trusts risk from credit markets.

Trusts future royalty income, however, may be subject to risks relating to the creditworthiness of the operators of the Underlying Properties and other purchasers of the crude oil and natural gas produced from the Underlying Properties, as

well as risks associated with fluctuations in the price of crude oil and natural gas.

The market price for the Units may not reflect the value of the royalty

interests held by the Trust.

The public trading price for the Units tends to be tied to the recent and expected levels of cash distribution on

The amounts available for distribution by the Trust vary in response to numerous factors outside the

control of the Trust, including prevailing prices for crude oil and natural gas produced from the Royalties.

The market price is not necessarily indicative of the value that the Trust would

realize if it sold those Royalties to a third party buyer.

In addition, such market price is not necessarily reflective of the fact that since the assets of the Trust are depleting assets, a portion of each cash distribution paid on the Units should

be considered by investors as a return of capital, with the remainder being considered as a return on investment.

There is no guarantee that distributions made to a Unit holder over the life of these depleting assets will equal or exceed the

purchase price paid by the Unit holder.

Operational risks and hazards associated with the development of the Underlying Properties may decrease Trust

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concerns about climate change and environmental sustainability.

There is considerable debate as to global warming and the environmental effects

of greenhouse gas emissions and associated consequences affecting global climate, oceans, and ecosystems.

There is considerable debate as to the environmental effects of greenhouse gas

emissions and associated consequences affecting global climate, oceans, and ecosystems.

We are not in a position to validate or repudiate the existence of climate change or various aspects of the scientific debate.

climate change is occurring, it could have an impact on the operation of the Underlying Properties.

However, if climate change is

occurring, it could have an impact on the operation of the Underlying Properties.

Underlying Properties in areas with limited water availability may be impacted if droughts become more frequent or severe.

Changes in climate or

weather may hinder exploration and production activities or increase or decrease the cost of production of oil and natural gas resources and consequently affect demand.

Changes in climate or weather may also affect consumer demand for energy or

alter the overall energy mix.

However, we are not in a position to predict the precise effects of climate change on energy markets or the physical effects of climate change.

We are providing this disclosure based on publicly available information on

Finally, it should be noted that, recently, activists concerned about the potential effects of climate change have directed their

attention at sources of funding for fossil-fuel energy companies, which has resulted in certain financial institutions, funds and other sources of capital restricting or eliminating their investment in oil and

natural gas activities.

Similarly, more extreme weather events such

as ice storms or extended periods of freezing temperatures could disrupt operation and production of the Underlying Properties.

Changes in climate or weather may hinder exploration and production activities or increase or decrease the cost of

production of oil and natural gas resources and consequently affect demand.

Changes in climate or weather may also affect consumer demand for energy or alter the overall energy mix.

However, we are not in a position to predict the precise effects of

climate change on energy markets or the physical effects of climate change.

We are providing this disclosure based on publicly available information on the matter.

Finally, it should be noted that, recently, activists concerned about the potential effects of climate change have directed their attention at sources

of funding for fossil-fuel energy companies, which has resulted in certain financial institutions, funds and other sources of capital restricting or eliminating their investment in oil and natural gas

In addition, spurred by increasing concerns regarding climate change, the oil and gas industry faces growing demand for corporate transparency and a demonstrated commitment to sustainability goals.

Environmental, social, and

governance (ESG) goals and programs, which typically include extralegal targets related to environmental stewardship, social responsibility, and corporate governance, have become an increasing focus of investors and shareholders across

the industry.

While reporting on ESG metrics remains voluntary, access to capital and investors is likely to favor companies with robust ESG programs in place.

Ultimately, these initiatives could make it more difficult for companies, including the

companies that operate the Underlying Properties, to secure funding for exploration and production activities.

Notwithstanding potential risks related to climate change, the International Energy Agency estimates that global energy demand will

continue to rise and will not peak until after 2040 and that oil and natural gas will continue to represent a substantial percentage of global energy use over that time.

Terrorism and continued hostilities in the Middle East could decrease Trust distributions or the market price of

Terrorist attacks and the threat of terrorist attacks, whether domestic or foreign, as well as the military or other actions taken in

response, cause instability in the global financial and energy markets.

Terrorism and sustained military campaigns could adversely affect Trust distributions or the market price of the Units in unpredictable ways, including through the disruption of

fuel supplies and markets, increased volatility in crude oil and natural gas prices, or the possibility that the infrastructure on which the operators developing the Underlying Properties rely could be a direct target or an indirect casualty of an

act of terror.

Unit holders and the Trustee have no influence over the operations on, or future development of, the Underlying Properties.

Neither the Trustee nor the Unit holders can influence or control the operations on, or future development of, the Underlying Properties.

The failure of

an operator to conduct its operations, discharge its obligations, deal with regulatory agencies or comply with laws, rules and regulations, including environmental laws and regulations, in a proper manner could have an adverse effect on the net

proceeds payable to the Trust.

Environmental, social, and governance

(ESG) goals and programs, which typically include extralegal targets

related to environmental stewardship, social responsibility, and corporate governance, have become an increasing focus of investors and shareholders across the industry.

While reporting on ESG

metrics remains voluntary, access to capital and investors is likely to favor companies with robust ESG programs in place.

Ultimately, these initiatives could make it more difficult for companies, including the companies that operate the Underlying

Properties, to secure funding for exploration and production activities.

Notwithstanding potential risks related to climate change, the International Energy Agency (IEA) estimates that global energy demand will continue to rise and will

not peak until after 2040 and that oil and natural gas will continue to represent a substantial percentage of global energy use over that time.

However, for the first time, the IEAs World Energy Outlook for 2021 estimated that aggregate fossil

fuel demand will slow to a plateau in the 2030s and fall slightly by 2050.

Terrorism and continued hostilities in the Middle East could decrease Trust

distributions or the market price of the Units.

Terrorist attacks and the threat of terrorist attacks, whether domestic or foreign, as well as

the military or other actions taken in response, cause instability in the global financial and energy markets.

Terrorism and sustained military campaigns could adversely affect Trust distributions or the market price of the Units in unpredictable

ways, including through the disruption of fuel supplies and markets, increased volatility in crude oil and natural gas prices, or the possibility that the infrastructure on which the operators developing the Underlying Properties rely could be a

direct target or an indirect casualty of an act of terror.

Unit holders and the Trustee have no influence over the operations on, or future development of, the

Underlying Properties.

Neither the Trustee nor the Unit holders can influence or control the operations on, or future development of, the

Underlying Properties.

The failure of an operator to conduct its operations, discharge its obligations, deal with regulatory agencies or comply with laws, rules and regulations, including environmental laws and regulations, in a proper manner could

have an adverse effect on the net proceeds payable to the Trust.

The current operators developing the Underlying Properties are under no obligation to continue operations on the Underlying Properties.

Neither the Trustee nor the Unit holders have the right to replace an operator.

The operators developing the Texas Royalty properties have no duty to protect the interests of the Unit holders and do not have sole discretion regarding

development activities on the Underlying Properties.

Under the terms of a typical operating agreement relating to oil and gas properties, the

operator owes a duty to working interest owners to conduct its operations on the properties in a good and workmanlike manner and in accordance with its best judgment of what a prudent operator would do under the same or similar circumstances.

Blackbeard is currently the operator of record of the Waddell Ranch overriding royalty interests and in such capacity owes the Trust a contractual duty under the conveyance agreement for that overriding royalty interest to operate the Waddell Ranch

properties in good faith and in accordance with a prudent operator standard.

The operators of the properties burdened by the Texas Royalty properties overriding royalty interests, however, have no contractual or fiduciary duty to protect the

interests of the Trust or the Unit holders other than indirectly through its duty of prudent operations to the unaffiliated owners of the working interests in those properties.

Neither the Trustee nor the Unit holders have

the right to replace an operator.

The operators developing the Texas Royalty properties have no duty to protect the interests of the Unit holders and do not

have sole discretion regarding development activities on the Underlying Properties.

Under the terms of a typical operating agreement relating to

oil and gas properties, the operator owes a duty to working interest owners to conduct its operations on the properties in a good and workmanlike manner and in accordance with its best judgment of what a prudent operator would do under the same or

similar circumstances.

operate the Waddell Ranch properties in good faith and in accordance with a prudent operator standard.

The operators of the properties burdened by the Texas Royalty properties overriding royalty interests, however, have no contractual or

fiduciary duty to protect the interests of the Trust or the Unit holders other than indirectly through its duty of prudent operations to the unaffiliated owners of the working interests in those properties.

In addition, even if an operator, including Blackbeard in the current case of the Waddell Ranch properties (as defined herein on page 10), concludes

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Even if the Trust concludes that such activities in respect of any of its overriding royalty interests would be in its best interests, it has no right to cause those activities to be undertaken.

The operator developing any Underlying Property may transfer its interest in the property without the consent of the Trust or the Unit holders.

Any operator developing any of the Underlying Properties may at any time transfer all or part of its interest in the Underlying Properties to another

The operator developing any Underlying Property may transfer its interest in the property without the consent of

the Trust or the Unit holders.

Any operator developing any of the Underlying Properties may at any time transfer all or part of its interest in

the Underlying Properties to another party.

Neither the Trust nor the Unit holders are entitled to vote on any transfer of the properties underlying the Royalties, and the Trust will not receive any proceeds of any such transfer.

Following any transfer, the transferred property will

continue to be subject to the Royalties, but the net proceeds from the transferred property will be calculated separately and paid by the transferee.

The transferee will be responsible for all of the transferors obligations relating to

calculating, reporting and paying to the Trust the Royalties from the transferred property, and the transferor will have no continuing obligation to the Trust for that property.

The operator developing any Underlying Property may abandon the property, thereby terminating the Royalties payable

to the Trust.

The operators developing the Underlying Properties, or any transferee thereof, may abandon any well or property without the

consent of the Trust or the Unit holders if they reasonably believe that the well or property can no longer produce in commercially economic quantities.

This could result in the termination of the Royalties relating to the abandoned well or

Following any

transfer, the transferred property will continue to be subject to the Royalties, but the net proceeds from the transferred property will be calculated separately and paid by the transferee.

The transferee will be responsible for all of the

transferors obligations relating to calculating, reporting and paying to the Trust the Royalties from the transferred property, and the transferor will have no continuing obligation to the Trust for that property.

The operator developing any Underlying Property may abandon the property, thereby terminating the Royalties payable to the Trust.

The operators developing the Underlying Properties, or any transferee thereof, may abandon any well or property without the consent of the Trust or the

Unit holders if they reasonably believe that the well or property can no longer produce in commercially economic quantities.

This could result in the termination of the Royalties relating to the abandoned well or property.

The Royalties can be sold and the Trust would be terminated.

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The financial statements of the Trust are prepared on a modified cash basis of accounting, which is a comprehensive basis of accounting other than

accounting principles generally accepted in the United States (GAAP).

accounting principles generally accepted in the United States

Although this basis of accounting is permitted for royalty trusts by the U.S.

Securities and Exchange Commission the (SEC), the financial statements

of the Trust differ from GAAP financial statements mainly because revenues are not accrued in the month of production and cash reserves may be established which would not be accrued in GAAP financial statements.

Further, Trust expenses are recorded

when paid and not in the month they were incurred.

Securities and Exchange Commission the (SEC), the financial statements of the

Trust differ from GAAP financial statements mainly because revenues are not accrued in the month of production and cash reserves may be established which would not be accrued in GAAP financial statements.

Further, Trust expenses are recorded when

paid and not in the month they were incurred.

The limited liability of the Unit holders is uncertain.

2 unchanged sentences

While the Trustee is

liable for any excess liabilities incurred if the Trustee fails to insure that such liabilities are

to be satisfied only out of Trust assets, under the laws of Texas, which are unsettled on this point, a holder of Units may be jointly and severally liable for any liability of the Trust if the

satisfaction of such liability was not contractually limited to the assets of the Trust and the assets of the Trust and the Trustee are not adequate to satisfy such liability.

As a result, Unit holders may be exposed to personal liability.

The tax treatment of an investment in Trust Units could be affected by recent and potential legislative changes, possibly on a retroactive basis.

federal tax reform legislation informally known as the Tax Cuts and Jobs Act (the TCJA) was enacted December 22, 2017, and makes

significant changes to the federal income tax rules applicable to both individuals and entities, including changes to the effective tax rate on a Unit holders allocable share of certain income from the Trust.

The TCJA is complex and lacks

administrative guidance, thus, Unit holders should consult their tax advisor regarding the TCJA and its effect on an investment in Trust Units.

In addition, President Bidens administration has generally proposed repealing fossil fuel tax

subsidies, which could impact certain tax benefits available to Trust Unit holders.

Any modification to the U.S.

federal income tax laws or

interpretations thereof (including administrative guidance relating to the TCJA) may be applied retroactively and could adversely affect the Trusts business, financial condition or results of operations.

The Trust is unable to predict whether

any changes or other proposals will ultimately be enacted, or whether any adverse interpretations will be issued.

Any such changes or interpretations could negatively impact the value of an investment in the Trust Units.

The recent spread of COVID-19, or the novel coronavirus, and the measures taken to mitigate the impact of the COVID-19 pandemic, are likely adversely affecting the business and operations of the operators of the Waddell Ranch properties and the Texas royalty properties, which in turn could have an adverse effect on trust

distributions.

The business of the operators of the Waddell Ranch properties and the Texas Royalty properties is likely being adversely affected

by the COVID-19 pandemic and measures being taken to mitigate its impact.

As the coronavirus pandemic and government responses are rapidly evolving, the extent of the impact on domestic sales of crude oil and

natural gas remains unknown and is constantly evolving.

The oil and gas industry experienced a sharp and rapid decline in the demand for crude oil and natural gas as the U.S.

and global economy, and commodity prices, were negatively impacted as

economic activity is curtailed in response to the COVID-19 pandemic.

Prices have rebounded somewhat but continue to fluctuate.

Official restrictions on non-essential

activities, including shelter in place and stay at home orders, have been introduced and re-introduced throughout the U.S.

and the world, and the length of time for which they will

remain continues to be unknown, which may impact production activities by the operators of the Underlying Properties, and the length of time such measures are in place may further adversely affect the income the Trust receives from the Royalties.

Fewer businesses than normal are open and fewer people are going to work which has reduced the demand for oil and natural gas, plus reliance by the operators of the Underlying Properties on third-party suppliers, contractors, and service providers

exposes them to possibility of delay or interruption of operations.

At this time, the full extent to which COVID-19 will negatively impact the global economy and the oil and gas industry is uncertain, but

pandemics or other significant public health events will most likely have a material adverse effect on the operators business and financial condition which would likely have an adverse effect on trust distributions.

liable for any excess liabilities incurred if the Trustee fails to insure that such liabilities are to be satisfied only out of Trust assets, under the laws of Texas, which are unsettled on this point, a holder of Units may be jointly and severally

liable for any liability of the Trust if the satisfaction of such liability was not contractually limited to the assets of the Trust and the assets of the Trust and the Trustee are not adequate to satisfy such liability.

As a result, Unit holders

may be exposed to personal liability.

The tax treatment of an investment in Trust Units could be affected by recent and potential legislative changes, possibly

on a retroactive basis.

federal tax reform legislation known as the Tax Cuts and Jobs Act (the TCJA) was enacted

December 22, 2017, and made significant changes to the federal income tax rules applicable to both individuals and entities, including changes to the effective tax rate on a Unit holders allocable share of certain income from the Trust.

The TCJA is complex and lacks administrative guidance in certain areas, thus, Unit holders should consult their tax advisor regarding the TCJA and its effect on an investment in Trust Units.

In addition, President Bidens administration has

generally proposed repealing fossil fuel tax subsidies, which could impact certain tax benefits available to Trust Unit holders.

Any modification

federal income tax laws or interpretations thereof (including administrative guidance relating to the TCJA) may be applied retroactively and could adversely affect the Trusts business, financial condition or results of operations.

The Trust is unable to predict whether any changes or other proposals will ultimately be enacted, or whether any adverse interpretations will be issued.

Any such changes or interpretations could negatively impact the value of an investment in the

The recent spread of COVID-19, or the novel coronavirus, and the measures taken to mitigate the impact of

the COVID-19 pandemic, are likely adversely affecting the business and operations of the operators of the Waddell Ranch properties and the Texas Royalty properties, which in turn could have an adverse effect

on trust distributions.

Demand for oil and gas, and the business and operations of the operators of the properties underlying the net profits

interests, had and may in the future be adversely impacted by the different variants of the COVID-19 pandemic and measures being taken to mitigate its impact.

As past coronavirus outbreaks and government

responses escalated and de-escalated regionally and sporadically, the extent of the impact on domestic sales of crude oil and natural gas remains unknown.

The industry experienced a sharp and rapid decline in

the demand for crude oil and natural gas as the U.S.

and global economy in 2020, and commodity prices, were negatively impacted as economic activity was curtailed in response to the COVID-19 pandemic, as well

as due to other geopolitical factors.

At this time, the full extent to which COVID-19 will negatively impact the global economy and the oil and gas industry is uncertain, but pandemics or other significant

public health events will most likely have a material adverse effect on the operators business and financial condition which would likely have an adverse effect on trust distributions.

Unresolved Staff Comments

The Trust has not received any written comments from the Securities and Exchange Commission staff regarding its periodic or current reports under the Act

not less than 180 days before December 31, 2020,

which comments remain unresolved.

not less than 180 days before December 31, 2021, which comments remain unresolved.

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 1A. Risk Factors