ING US' CEO Presents at Bank of America Merrill Lynch 2014 Insurance Conference (Transcript)

| About: Voya Financial, (VOYA)


Bank of America Merrill Lynch 2014 Insurance Conference Call

February 13, 2014 9:10 AM ET


Rod Martin – Chairman and CEO

Ewout Steenbergen – EVP and CFO

Alain Karaoglan – EVP and COO


Jay Cohen – Bank of America Merrill Lynch

Jay Cohen – Bank of America Merrill Lynch

I will introduce Rod Martin, Chairman and CEO of ING U.S. Prior to get its role at ING U.S. Rod was CEO of American General and had various leadership position at AIG. ING U.S. is the newest public that we cover, that IPOed in May of last year and I believe this is going to be the last time, I introduce rather part of ING U.S. as they’re undergoing a rebranding initiative, rebranding as VOYA Financial, it will officially change its name in April.

With that I’m going to turn it over to Rod for his presentation and then joining him for Q&A, it will be Alain Karaoglan, VOYA’s COO and Ewout Steenbergen, VOYA’s Chief Financial Officer.

Rod Martin

Sir, thank you and good morning everyone. Particularly on a little bit snowy morning in the North, this is a very comfortable place to be. I’m reminded to call to your attention the forward-looking statements and cautionary statements that you’ll see on Slide 2. We will be talking about some non-GAAP measures and some forward-looking information in today’s presentation. So with that as a backdrop, let’s begin.

It’s a pleasure to be with you to share ING U.S’. as investment narrative. Let me highlight some of the key elements of our investment narrative and discuss our focus on execution to drive our ROE improvement. First, we have a leading franchise in attractive markets. Second, we have a strong track record of execution with a 12% compound annual growth rate in operating earnings from 2010 through 2013. Third, we have an experienced management team executing a comprehensive ROE improvement program. In fact, we targeted a 400 to 500 basis point increase in the ROE to 12% to 30% by 2016. And fourth, behind the strength of our Retirement Solutions, Investment Management and Insurance Solutions business, we cast our vision to be Americas Retirement Company.

ING U.S. is dedicated to helping Americans become both financially and emotionally ready for retirement. This vision guides our efforts to provide our customers and finance with all the asset accumulation, protection and distribution products and services plus guidance and advice.

ING U.S. is one of the largest retirement focus companies in the financial services industry. We have more than $511 billion in assets under management and administration. More than 13 million customers, more than 200,000 points of distribution and over 7,000 employees dedicated to helping Americans and our customers with their retirement readiness. Our ongoing business has a diverse earnings profile that generated $1.2 billion in operating income and operating earnings in 2013. And approximately 74% of those earnings came from Retirement Solutions and Investment Management, which are our least capital intensive businesses, the remaining 26% from Insurance Solutions.

2013 was a year of extraordinary transformation and value creation for ING U.S. First, we executed the initial public offering of VOYA and the VOYA stock in May and the secondary offering in October which reduced ING Groups ownerships stake to approximately 57%. For U.S. IPOs larger than a billion dollars. ING U.S. had the second best performance in 2013, increasing by 80%. In fact, only Twitter’s IPO outperformed ING U.S. last year.

Now, we’re pleased with that performance but we’re remained deeply committed to executing our plan and adhering to our financial discipline. Second, we completed our recapitalization plan by accessing the capital markets on five separate occasions. And we did this, while maintaining an RBC ratio above our target of 425% throughout the year including an estimated 504% RBC ratio as of year-end 2013.

And finally, as was just announced or discussed by Sun, we introduced VOYA Financial, our new brand, which is a derivative of the world voyage and symbolizes the journey that all Americans are on to become retirement ready. And we recently announced that ING U.S. would officially change its name to VOYA Financial on April 7. We are excited about the transition to VOYA Financial and it will move in a deliberate manner to ensure seamless transition for our customers, our clients, and our distribution partners.

ING U.S. has identified three sources of value creation. Our first source is our ongoing business; the second is the potential value in our Closed Block Variable Annuity segment and the third is the potential upside in our tax assets. I’m going to highlight the three components of our investment narrative. We established the solid foundation. We have a premier franchise and we’re focused on driving ROE improvement.

So let’s talk about our solid foundation. Our management team is transforming the culture from a past that was focused on top line measured by lead tables to a company focused on value creation and today our value creation philosophy emphasizes efficient capital management, improving the profitability of the ongoing business, maximizing the synergies between the operating segments and increasing operating efficiencies. And our value creation philosophy is anchored in three key metrics, risk-adjusted returns, distributable earnings and sales at or above our targeted IRRs.

We’ve established a solid foundation to create long-term value for our shareholders and at the center of our value creation philosophy is, our plan to improve our ROE to 12% to 30% by 2016. And we’re currently executing on over 30 ROE improvement initiatives. In 2013, we improved our ROE by 200 basis points. Two, 10.3% from 8.3% in 2012.

In addition, we strengthened our balance sheet, stabilized our ratings and ratings outlook, de-risked our investment portfolio and prudently managed our Closed Block Variable Annuity segment with a hedge program designed to protect regulatory and rating agency capital.

With respect to our Closed Block Variable Annuity segment, we’ve undertaken some very decisive actions over the past several years. For instance, ING ceased sales in early 2010 of variable annuities. We’ve increased reserved. We developed a hedged program designed to protect capital for market movements and we’re proactively managing this closed block to optimize value for our stakeholders.

With that as an overview, I want to turn to the growth of our premier franchise, which we managed from one ING U.S. perspective. While each of our businesses are strong on its own. It’s the power of those businesses coming together that allows us to deliver a differentiated value proposition. Our Retirement, Investment, and Insurance businesses are the foundational building blocks of our franchises. With these three businesses we are able to offer our customers and our clients’ quality asset accumulation, protection and distribution products and services in addition to guidance and advice.

Our entire organization is committed to helping Americans become both financially and emotionally ready for the retirement years as retirement readiness is one of the most daunting financial challenges facing Americans today.

Retirement Solutions is our largest earnings contributor. We are one of the largest defined contribution retirement plan providers in the U.S. In our business profile converges with some very powerful demographic trends to present us solid growth prospects. Investment Management is our fastest growing business. The key to profitable growth of our Investment Management platform is to convert our strong investment track record into scale on our higher margin asset management categories. In fact, 93% of our fixed income assets and 84% of our equity assets outperformed their benchmark returns on a five year basis in 2013.

Insurance Solutions is our refocused businesses and we’re focused on product segments of the market that best match our lower capital, higher return approach to the market such as our Indexed Universal Life product portfolio. And while, we scaled back our presence in individual life, we see opportunities to expand our employee benefit business particularly in stop loss, group life and voluntary benefit areas.

Retirement Solutions is a market leading platform and franchise that will drive our long-term growth. We’re well positioned in all segments of the defined contribution market 401(k), 403(b) and 457, in fact there are very few retirement plan providers with a scale presence in each of these market segments. We offer a comprehensive suite of retirement income solutions to meet plan participant needs and we have access to these individuals through more than 50,000 plan sponsor relationships.

In fact the breadth of our expertise can be demonstrated by a case win that occurred in late 2013, it was a multi-employer plan arrangement that included $2 billion of assets, 2,800 plan sponsors and 57,000 participants. We also earned $1 billion investment management mandate with that case win, which demonstrates to us the synergies between Retirement Solutions and Investment Management.

As I mentioned a moment ago, we have over 30 ROE initiatives underway. Specifically with the Retirement Solutions, we’re benefiting from initiatives such as improving the economies of our full service corporate markets book through re-pricing and lowering of crediting rates, we’re running off less profitable business like our multiyear guarantee and our annual reset blocks and we’re driving growth of our individual markets business through investments in people, products and technology.

Our Investment Management business has a scalable platform that leverages its strong investment performance. So our key growth initiatives include growing our third party business, improving our sales force productivity, expanding our share in higher fee asset categories, as I mentioned just a moment ago, our strong investment performance 93% of our fixed income assets, 84% of our equity assets, outperformed their benchmark returns on a five year basis in 2013.

In Insurance Solutions, we’re focused on capital efficient products and aligning our cost with our new targeted level of sales. For example, with an individual life segment, we’ve shifted our sales focus to the index product portfolio and we’ve cut at our administrative expenses by over 13% into 2013 from 2012. Our key initiatives in addition to that include improving our loss ratio for stop loss, expanding our voluntary benefit business and adjusting crediting rates where possible.

Now, let’s turn to our ROE improvement program. We’re making steady progress towards our ROE target of 12% to 13% by 2016. We have a comprehensive plan with clear goals to improve profitability, efficiently manage our capital and focus on ROE and ROC as the key measures of our success. We developed our plan in 2011 with our executive committee, McKenzie and Willamette. We executed a series of business performance reviews and diagnostics to better understand the profitability and capital intensity of our products and our businesses. And during this assessment phase, more than 30 ROE initiatives were identified and a detailed roadmap was created for executing our plan. We have clearly defined projects, milestones, deadlines and reporting tools in each of these initiatives so there would be an infrastructure in place to track and measure the success.

We have established a robust governance structure that involves actively managing each one of those work experience. We identified a baseline ROE up 8.3% in 2012 and we established our goal to reach an ROE of 12% to 30% by 2016, which is a 400 to 500 basis points of improvement. We focus on ROC for the businesses because we did not allocate debt to the business units. We established our goal. We identified a baseline of ROC of 7.2% in 2012, and we established our goal to reach in ROC of 10% to 11% by 2016, which is 300 to 400 basis points of improvement.

To achieve these goals, we need and expect tangible improvement each year which equates to approximately 110 basis points of ROE improvements on average per year. And what I really like about our plan it’s really all about our execution. We’re also making steady progress with our ROC. Our ROC improved 140 basis points to 8.6% in 2013, up from 7.2% in 2012 and we’re making steady progress toward our 2016 ROC of 10% to 11%. Our margin growth and capital initiatives, each contributed to the ROC improvement.

Our margin initiatives were the primary drivers contributing 112 basis points of improvement. They included repricing actions, the run-off of less profitable assets, , our costs with lower sales in certain capital intensive products. And in 2013, we also achieved $30 million of cost savings as part of our long-term plan to reduce cost by a $100 million by 2016. Included in the margin initiatives were several notable items that contributed 42 basis points, it includes limited partnership income, prepayment fee income and record keeping change orders in excess of our normalized run rate.

Second, our growth initiatives contributed 39 basis points; these partially reflects higher fee base margins on assets under management and administration which were due in part to positive net flows from both the Retirement and our Investment Management businesses. Third, our capital initiatives contributed 40 basis points, these include reinsurance actions and progress and shifting the composition of our product portfolio to less capital intensive products. And finally, low interest rates negatively affected our ROC by 44 basis points.

While the effective low interest rates were factored into our plan. The plan, the increase of rates following the IPO has mitigated some of that expected impact through 2016. Each of our businesses contributed to our ROE and ROC improvement. Reaching our 2016 ROE and ROE targets involves all of our businesses and functions; there is no silver bullet. If we achieve our targets, we would expect to generate $1.2 billion to $1.4 billion in excess capital by 2016 after funding new business stream and holding company expenses. And we expect to provide you an update on our capital position at the latest during our first quarter 2014 earnings call. Let me quickly recap our investment narrative for you.

We’re pleased with our steady progress that we’re making with our transformation. ING U.S. is a premier franchise with leading positions in attractive markets. The management team is committed to continuing executing on our ROE improvement program. We’ll build on our solid foundation which is based on a recapitalized and de-risked balance sheet. We have three solid businesses offering quality products and services to meet our customers and client’s needs, for asset accumulation, protection and distribution. We’ve got an exciting new brand. We have a lot of confidence as we head into 2014 based on our track record and continued focus on execution.

And with that I will ask, Alain our Chief Operating Officer and Ewout our Chief Financial Officer to join me on stage as we begin the Q&A segment of our session. Thank you.

If you have question, you can raise your hand.

Question-and-Answer Session

Unidentified Analyst

Quite a few, but open of course for everyone else, maybe we could start just to talk about the closed block VA and you laid out the ROE progression plan for the ongoing book of business, and of course the overall ROE is somewhat pressured by capital allocated to closed block. What options are you considering for capital release going forward there and how had the change in capital markets and higher equity markets or higher interest rate which has actually changed pretty sharply within the IPO impacted those options?

Ewout Steenbergen

Yes. Let me start with a few of the statistics around the block and then we can speak of upwards about some of the strategic options. So if you look at the risk of the block, you can measure that in different ways so one of the metrics we use very often is called the net amount of risk for living benefit. So this is basically what kind of exposure do we have above the accounting values in terms of potential payouts we have to do to the customers. If you look where the block was one and a half years ago there was a number somewhere between $5 billion to $6 billion, where we are today or at the end of 2013, the net amount of risk came down to $2.2 billion so we’re very sharp drop of the net amount of risk.

If you look at the resources we have put aside for this block at the end of year and now I'm looking at that from a statutory basis or the statutory resources we have put aside. At the end of the year we were at $4.1 billion, so $4.1 billion of resources and these are statutory reserves as we announced yesterday during our earnings call for the living benefits, for the death benefits in cash flow testing reserves of $3.3 billion and then we have another $800 million of additional assets aside from a statutory basis point of block. So in other words, clearly very good improvement, the risk profile is coming down, we have a significant asset still aside to deal with the block so all very positive.

We are focusing for this block in terms of the prime objective to project regulatory and rating agency capital because the most important is that this block doesn’t create any capital surprise and therefore we are very comfortable where we are today and the capital surprises on the statutory basis so therefore we are so focused on a statutory basis.

If you look at the GAAP capital what is allocated to this block is very interesting if you would look at where we were at the IPO of ING U.S. approximately 36% of the overall company’s capital was allocated to the closed block variable annuity. In the meantime our total capital has gone up, our book value has been growing since by over $1 billion and of that higher book value now 21% is back into closed block variable annuity. So in other words, more capital and lesser or much lower percentage that is now needed for the Closed Block, so another very positive sign how this book is developing. Rod would you like to speak about the strategic options?

Rod Martin

Sure. So as we discussed during the road show. We put a significant amount of capital behind this book as you put it out back with your question. And we’re asked frequently and quite understandably what alternatives are you contemplating and kind of on what basis would that thought process be evaluated. And the piece of that we’ve signaled for the market is, we will give an update first no later than the end of the first quarter on the cash flow analysis that we did and we shared with the investment community and investors during the road show. So we’ll update that as of yearend numbers and give you that no later than the first quarter result that’s step one.

Step two, given the amount of resources we’ve committed to this, we’re going to do something that’s economic for all stakeholders. This business and block has improved significantly as Ewout has pointed out. So we are open to and believe we are evaluating kind of all alternatives and ideas that you would expect us to be looking at in the course of anyone that has a block of business and looks at these alternatives you all know we have a large book of business and there is not likely a singular silver bullet to the solution. So we’re going to doing something that makes sense and one of the points of value that I talked about was the amount of capital we’ve committed to this so we signaled during the IPO road show do not expect a return of that capital on this book of business sooner than five years.

We did that to be conservative. We are highly motivated and aligned I think with our shareholders, if we can find a solution that makes sense we would certainly consider that but we, given that we put a lot of resources behind this business we’re going to smart about it for all stakeholders as we go through this and I think the first step is to update that cash flow analysis give you a perspective on the first quarter call on where we are and the alternatives we’ll consider.

Jay Cohen – Bank of America Merrill Lynch

May be one follow up on that, given the size of the block and I think it’s about $40 billion in terms of the EBITDA balances. Would it need to be one singular solution is there anything about the block that makes it, needs it to be one singular solution or there solutions available for reinsuring or offloading portions of the block?

Rod Martin

I don’t think it absolutely needs to be one single solution it could be a combination of ideas and we’re certainly looking at those. So we are, please don’t look at Closed Block I said this during our road show this is passive management. We have a substantial amount of capital behind this book of business, we take this every bit seriously and managing that capital as we do the ongoing business. And we’re going to do, we’re going to behave in a smart and predictable economic way for this book of business and as we think we -- given the amount of resources within the two that makes sense.

Jay Cohen – Bank of America Merrill Lynch

I just had a question on the brand name VOYA, should be expecting a temporary slowdown in sales because of it and really you’re spending incrementally more on advertising to promote the new brand?

Rod Martin

So let’s take it in two steps. We’ve been very thoughtful about how we run about this process as you probably would expect. And by the way of example we very intensely at the listing wanted to pick a stock ticker simple that wouldn’t change when we move to a new name and that was VOYA. We also wanted the stock ticker symbol to be not some interpretation of our name, so again the VOYA.

We also promised our distribution partners and our institutional plans that we would give them a long runway in terms of the process and so at the time we announced the name which was some period of time ago in fact right before or right at the IPO, we’ve had very active communications with both stakeholders our distribution partners and our institutional investors. And at this point, this is the kind of season that you have meetings with those take holders. And I’ve been through a number of them just recently.

For example it’s really where at least I wanted it to be and that’s get 100. I mean we know it’s coming, we’re there, we’re mentally prepared for this to get on with it and so we’ve got a staged approach as we just announced. The holding company on April 7th investment management and our employee benefit on May 1 the rest of business on September 1st. And we’re doing that in a strange way so we can just be deliberative and thoughtful and not missing any -- miss any deadlines or some awful a lot of and you’ve all been through this with other companies, but I call wiring and plumbing that’s needed to just change all of those things.

So we signaled it I think very comfortably well a year in advance Juan and Glover [ph] in our branding team has done a terrific job of -- I think the communication process with all stakeholders and people are excited about. We’re really ready to move on to this. So I don’t think there will be and I'm not expecting any drop off from sales as we go through this.

The expense fees, there is two components of that. We talked about actually both of those on the earnings call yesterday. One is the operational re-branding piece think about that as the plumbing and wiring that you have to do to change all the legal entities and all of the stuff on websites to get that done. That cost alone is $50 million that is of 2014, 2015 expense and that number hasn’t changed we’ve been discussing that number for some period of time. The amount of additional marketing we’re going to do we’re still debating and maybe Alain, you want to just talk a little bit about that.

Alain Karaoglan

Yes. So we haven’t announced yet the number in terms of dollar amount on advertising that we’re going to spend. It is costly to re-ramp but we will do so at the appropriate time. And one of things that we want to make sure is that every dollar we spend we get tremendous value. In fact, Jay, what we’d like to do is not to see a slowdown in sales but a pickup in sales as we advertise. We have very well stage in terms of investment management employee benefits and in September the rest of the business and a lot of our customers are also institutional customers where you get a chance to have a conversation. And so the impact of the re-branding may not be as significant as the retail brand that have the re-brand.

But we will announce at some point in time this year what are our expectation in terms of advertising we will make sure that we get enough out of it and that our awareness score – brand awareness score as high as better as anyone else that has rebranded before.

Unidentified Analyst

Yes. Concerning the Closed Block from a credit perspective, I understand what you’re doing is to try to have the hedge program protect rate capital and rating agency capital, could you may be give us a broad brush view of what would cause a tail risk outcome. What would cause the hedging program to kind of go off the rails what macro factors or external factors [indiscernible] and also I have a follow up.

Ewout Steenbergen

So, let me explain a bit what is exactly this different components of our hedging program. So the hedging program is stated around the movements of the liability in case of a market short both for equity markets and interest rate risk. And the most important is that our equity hedges which are more short future positions as well as our growth hedges which are more swaps positions that they are able to offset the liability movements in case the market turns negative that the hedges provide sufficient offset for the additional statutory reserves we have to pose all the additional rating agency requirements we have to hold in such a situation. So it’s more of a shock kind of offset that we are able to come from.

If you look at the hedge effect its very positive, it’s very strong, we are showing at every quarter you see the difference between how the hedges has moved as well as how the reserves on a statutory basis have moved. And over the last few quarters the hedge program is having a very high hedge effectiveness. If you speak about what is really the tail risk that is more of a secondary order of that. So what is happening in case markets go down or markets go up let me speak about the up scenario it is more of the secondary order effect that is then going to help.

So markets go up, we’ll see higher fee income over our assets balances so the growth fee income is going up. We see the hedge notionals that come down in such scenario because the policies get more out of the money so the hedge costs are coming down.

If the policies get more out of the money we see a pickup in the lapse rates and so the lapse just go up because the lapses are dynamic and we expect higher lapses whether it’s lower in [indiscernible] so the book is running off faster and that is the optimal positive development. So, the hedge program is really focused on the short-term impact and to deal with it, whether long-term impact with respect to positive markets as we have seen over the last half year three quarters that is really helpful for the book and if, for example if you look at the lapse rates for the last quarter for the fourth quarter of 2013 that was for the first time over 10% on an annualized basis. So we’re very, another very positive development.

Unidentified Analyst

All right. But that’s what I’m trying to get to, it has been a positive development now. What would you -- has there been any sort of thinking about what would cause it to be maybe de-link or go the other way what would we -- I mean are you saying intentional circumstances, what sort of extreme scenario we have to see to go up what kind of trouble here?

Ewout Steenbergen

So the hedge is again is to protect the downside. So if there is a sudden shock of 10%, 15% equity market growth today for whatever reason and the hedge program is there that’s why we have the hedge program to deal with it and to offset these additional southern capital requirements that we have to post.

But let’s say the opposite of what I just said in the up market is happening in the down market. So if markets go down we will see a higher [indiscernible] levels, lower lapses, lower fees so that effect will permitting gradually over time and that is still an exposure we have on the book.

Unidentified Analyst

Okay. And then the follow up you talked about the 500 plus RBC ratio, the target 425. But from what I understand the build-in capital that’s a blend in rate right which includes Closed Block Variable Annuity are down.

Ewout Steenbergen


Unidentified Analyst

So how should we think about then the repatriation or the give back, the progress to the target RBC often time 500 or 425 or should we think about it that way, is that kind of a plan?

Ewout Steenbergen

Yes. Let me explain a bit of different components of our capital structure. So the RBC ratio relates to our regulated insurance entity so our five prime insurance entities that are having their accounts on a statutory basis. So 504% RBC relates to approximately in total terms $1.1 billion excess over the 425% RBC target level that we’re aiming at. And of the $1.1 billion we expect that we can take out in terms of ordinary dividend capacity $800 million so $800 million will be available ordinary dividend from the $1.1 billion.

The RBC does not include our reinsurance entities, future life of them international whereas most of the [indiscernible] book reinsure, I just gave you a dose in capital numbers so shortly on the statutory basis, we are very comfortable where we are today. It doesn’t include our investment management entity so that is an entity where all the profits are available for upswing to the holding. And it doesn’t include your holding company itself, and the holding company itself at the end of the year had a liquidity position of $600 million. So overall if you look at the different components we are very comfortable where we are from a capital perspective to each of the different areas.

We have now to determine which part of that capital position is excess capital, we will go through the following process, we will first close our statutory accounts at the end of this month. So the statutory financial statements will be ready at the end of February then we will get our operating plans for the next few years, we will make a determination what is the best way to do with excess capital, how much is available and what is the most value enhancing way to return it to shareholders, have a discussion with our Board and then we will come back to you at the latest when we announce our first quarter results so that will be early May of this year.

Unidentified Analyst

Thank you very much. Sorry to go back to the VA block again but I wondered if you could speak to the effectiveness of the hedge program in the event that bear flattener is the scenario that proves out over the next two to three quarters?

Rod Martin

Can you repeat the question, what scenario?

Unidentified Analyst

What’s the vulnerability of the hedge program now particularly the interest rate portion if you get a bear flattener yield curve over the next two to three quarters?

Ewout Steenbergen

So our swap positions are very long positions and they really match the duration of the liabilities so the average duration of the swaps is approximately 18 years. So we think from a hedge program overall risk perspective, we are sufficiently covered. If rates do not move a lot we also don’t see a local movement in the statutory reserve, so in that case the hedge also is not contributing a lot neither in a gain because the reserve doesn’t move or in a loss the reserve, I have someone showing. In more or less at flat rate scenario, the hedge doesn’t do a lot, the hedge is really helping the rates will fall back and the hedge is having some negative run rates will move up but again that’s been offset by some of the short releases we see at the same time.

Unidentified Analyst

And just a brief follow up, I don’t know if this is disclosed in prior discussions, but if it’s at all possible to know just on the interest rate portion what is the gross notional value and what is the mark-to-market value of replacement cost relative to each other in the last quarterly close day?

Ewout Steenbergen

We do disclose in our Qs and Ks some of our hedges notional position, so you should be able to see the development of that in terms of direction while it is very clear that the hedge notional have to come down off the last 12 months in line with the markets we’re at and the effect that we have to hold less hedge positions because the risk in terms of the book is from now.

Jay Cohen – Bank of America Merrill Lynch

I think we’re going to have to stop there. Let’s thank Rod, Alain and Ewout for their time.

Rod Martin

Thank you.

Copyright policy: All transcripts on this site are the copyright of Seeking Alpha. However, we view them as an important resource for bloggers and journalists, and are excited to contribute to the democratization of financial information on the Internet. (Until now investors have had to pay thousands of dollars in subscription fees for transcripts.) So our reproduction policy is as follows: You may quote up to 400 words of any transcript on the condition that you attribute the transcript to Seeking Alpha and either link to the original transcript or to All other use is prohibited.


If you have any additional questions about our online transcripts, please contact us at: Thank you!