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January 4, 2011

Mila Kofman
Superintendent of Insurance
Maine Bureau of Insurance
34 State House Station
Augusta, ME 04333-0034

Dear Superintendent:

Pursuant to the provisions of 24 M.R.S.A. §2307 and in conformity with your instructions, a financial examination has been made of the

Maine Dental Service Corporation
d/b/a Delta Dental Plan of Maine

at its primary administrative office in Concord, New Hampshire. The following report is respectfully submitted.

 

 

REPORT OF EXAMINATION

Maine Dental Service Corporation
d/b/a Delta Dental Plan of Maine

AS OF

DECEMBER 31, 2009

 

I hereby certify that the attached report of examination dated January 4, 2011, shows the condition and affairs of the Maine Dental Service Corporation located in Portland, Maine as of December 31, 2009, and has been filed in the Bureau of Insurance as a public document.

 

This report has been reviewed.

 

___________________
Eric Cioppa
Deputy Superintendent

 

Dated this _____ day of _________, 2011

 

 

TABLE OF CONTENTS

SCOPE OF EXAMINATION........................................................................................................................................... 1

SUMMARY OF SIGNIFICANT FINDINGS ................................................................................................................... 1

PRIOR EXAMINATION .......................................................................................................................................... 1
CURRENT EXAMINATION ..................................................................................................................................... 4

SUBSEQUENT EVENTS ............................................................................................................................................... 6

THE COMPANY ........................................................................................................................................................... 6

HISTORY ............................................................................................................................................................ 6
CORPORATE RECORDS ...................................................................................................................................... 6
CORPORATE OWNERSHIP .................................................................................................................................. 6
CORPORATE GOVERNANCE ................................................................................................................................ 7
CODE OF CONDUCT AND CONFLICT OF INTEREST ............................................................................................. 8
FIDELITY BOND AND OTHER INSURANCE ............................................................................................................ 8
TERRITORY & PLAN OF OPERATION .................................................................................................................... 8
TRANSACTIONS WITH AFFILIATES ...................................................................................................................... 8
GROWTH OF COMPANY ....................................................................................................................................... 9
ACCOUNTS AND RECORDS .................................................................................................................................. 9

REINSURANCE ............................................................................................................................................................ 9

LITIGATION ................................................................................................................................................................ 9

FINANCIAL STATEMENTS ........................................................................................................................................... 9

STATEMENT OF ADMITTED ASSETS, LIABILITIES, AND SURPLUS ........................................................................ 10
STATEMENT OF OPERATIONS ............................................................................................................................ 11
STATEMENT OF CAPITAL AND SURPLUS ............................................................................................................. 12
NOTES TO FINANCIAL STATEMENTS .................................................................................................................. 13

CONCLUSION ........................................................................................................................................................... 14

 

 

SCOPE OF EXAMINATION

Maine Dental Service Corporation d/b/a Delta Dental Plan of Maine (hereinafter, “Company”) was last examined as of December 31, 2004, by the State of Maine Bureau of Insurance (hereinafter, “Bureau”).  This examination covers the period from January 1, 2005, to the close of business on December 31, 2009.

This examination was performed pursuant to the risk-focused approach promulgated by the National Association of Insurance Commissioners (hereinafter, “NAIC”), and consisted of a review of the Company’s operations, administrative practices, valuation of assets, and determination of liabilities at December 31, 2009. This examination was performed in accordance with NAIC guidelines, the 2009 NAIC Financial Condition Examiners Handbook, (hereinafter “FCEH”), the 2009 Accounting Practices & Procedures Manual, and the laws, rules, and regulations prescribed or permitted by the State of Maine. To the extent deemed appropriate, this examination utilized the work-papers of the Company’s independent accountants for the year ending December 31, 2009.

Areas reviewed in this examination included corporate minutes, business policies, underwriting practices, aggregate reserves for policy and contract claims, investments, risk-based-capital requirements, and cash flow adequacy. To the extent deemed necessary, transactions occurring subsequent to the examination date were reviewed.

The results of this examination present fairly the financial condition of the Company as of December 31, 2009. Comments, for purposes of this report, may be limited to matters involving clarification, departures from laws, rules and regulations, and/or significant changes in amounts.

 

SUMMARY OF SIGNIFICANT FINDINGS

PRIOR EXAMINATION
The comments and recommendations included in the report of examination as of December 31, 2004, and the Company’s responses thereto follow:

  1. Comment:
    The Company reported the shared expenses charged through the marketing and administrative agreement with Delta Dental Plan of New Hampshire (hereinafter, “DDPNH”) as a single line item on the underwriting and investment exhibit. Statement of Statutory Accounting Principles (hereinafter, “SSAP”) No. 70, ¶7 requires that these types of expenses be allocated to the expense category as if the Company incurred the expense itself.

    Recommendation:
    The Company should comply with the provisions of SSAP No. 70, ¶7 related to the reporting of expenses on the underwriting and expense exhibit.

    Status:
    The Company has not complied with this recommendation. See comment number 5 in the current examination subsection of this report.

  2. Comment:
    The Company reported net reinsurance balances payable of $1,900 as part of general expense due or accrued. SSAP No. 61, ¶22 requires that these reinsurance balances be reported as a premium balance payable of $347,513 and a paid loss recoverable of $345,613.

    Recommendation:
    The Company should comply with the provisions of SSAP No. 61, ¶22 related to the reporting of reinsurance balances.

    Status:
    This comment related to reinsurance ceded. The Company did not have any ceded reinsurance balances at December 31, 2009. See comment number 5 in the current examination subsection of this report.

  3. Comment:
    The Company has not reduced its claim reserves in the amount of $81,200 for the amount ceded to its reinsurers. The Company recorded this amount as a balance due from its reinsurer. In accordance with SSAP No. 61, ¶22, policy reserves should be reduced by the amount ceded to reinsurers.

    Recommendation:
    The Company should comply with the provisions of SSAP No. 61, ¶22 in reporting reinsurance balances.

    Status:
    This comment related to reinsurance ceded. The Company did not have any ceded reinsurance balances at December 31, 2009. See comment number 5 in the current examination subsection of this report.

  4. Comment:
    The Company amortizes bond premium and bond discount using the straight line method. In accordance with SSAP No. 26, ¶6, the Company should amortize bonds using the scientific method.

    Recommendation:
    The Company should comply with the provisions of SSAP No. 26, ¶6 and use the scientific method to amortize bond premium and bond discount.

    Status:
    The Company has not complied with this recommendation. See comment number 5 in the current examination subsection of this report.

  5. Comment:
    The custodial agreement with H.M. Payson & Company was not in compliance with 13 of the provisions outlined in the FCEH.

    Recommendation:
    The Company should ensure that its custodial agreement is in full and complete compliance with the FCEH.

    Status:
    See comment number 3 in the current examination subsection of this report.

  6. Comment:
    The Company is not complying with the 33 M.R.S.A. chapter 41 “Uniformed Unclaimed Property Act” with regard to eight checks totaling $414.72.

    Recommendation:
    The Company should adopt procedures to comply with all provisions of the 33 M.R.S.A. chapter 41 “Uniformed Unclaimed Property Act”.

    Status:
    The Company has complied with this recommendation.

  7. Comment:
    The Company's investment in New England Dental Administrators, LLC (hereinafter, “NEDA”) was valued using the equity method in accordance with SSAP No. 48. For each of the four years ending December 31, 2004, the Company has recognized an unrealized loss. These declines in value are considered by the examiner to be other than temporary. In accordance with SSAP No. 48, ¶10, an other than temporary impairment shall be written down to fair value as the new cost basis and the amount of the write down shall be accounted for as a realized loss.

    Recommendation:
    The Company should make an adjustment for an other than temporary impairment pursuant to SSAP No. 48, ¶10.

    Status:
    The Company has complied with this recommendation.

  8. Comment:
    The Company is reporting certain uninsured plans as administrative services contract (hereinafter, “ASC”) plans in the notes to the annual statement when they should be reported as administrative services only (hereinafter, “ASO”) plans.

    Recommendation:
    The Company should disclose ASC and ASO activities separately in the notes to the annual statement in accordance with SSAP No. 47.

    Status:
    The Company has complied with this recommendation.

Current Examination
The significant comments and recommendations related to the current examination follow.

  1. Comment:
    Claim forms do not comply with 24-A M.R.S.A. §2186 (3)(A).

    Recommendation:
    The Company should amend all claim forms in order to comply with 24-A M.R.S.A. §2186 (3)(A). The claims forms should include the following language: "It is a crime to knowingly provide false, incomplete or misleading information to an insurance company for the purpose of defrauding the company. Penalties may include imprisonment, fines or a denial of insurance benefits.”

  2. Comment:
    It was observed that the Company reports related party payables on page 3, line 9 of the annual statement.

    Recommendation:
    Pursuant to annual statement instructions, the Company should report related party payables on page 3, line 15.

  3. Comment:
    Review of the custodial agreements indicated certain areas of noncompliance with the FCEH. Specifically, the FCEH prescribed clauses were not included in the custodial agreements:
    • If a custodial agreement has been terminated or if 100% of the account assets in any one custody account have been withdrawn, the custodian shall provide written notification, within three business days of termination or withdrawal, to the insurer’s domiciliary commissioner.
    • During regular business hours, and upon reasonable notice, an officer or employee of the insurance company, an independent accountant selected by the insurance company, and a representative of an appropriate regulatory body shall be entitled to examine, on the premises of the custodian, its records relating to securities, if the custodian is given written instructions to that effect from an authorized officer of the insurance company.

    Recommendation:
    The Company should ensure that the custodial agreements conform to the requirements of the FCEH.

  4. Minutes to Meetings Comment:

    Review of the board of directors meeting minutes, the Company’s annual members meetings, and committee meetings indicated the following deficiencies:

    • Board of Directors.
      A majority of the minutes provided by the Company were either in draft form or were not signed.
    • Annual Meeting of Members.
      All sets of minutes provided by the Company were either in draft form or were not signed.
    • Finance Committee.
      A majority of the minutes provided by the Company were either in draft form or were not signed. Additionally, minutes for the February 3, 2009, teleconference meeting were never approved by the committee.
    • Corporate Governance Committee.
      All sets of minutes provided by the Company were either in draft form or were not signed. Two additional observations follow. First, the August 18, 2006, meeting minutes indicated that the committee approved minutes from the June 19, 2006, meeting and the July 17, 2006, meeting; however, the Company could not provide minutes for the June and July meetings and the Company does not appear to have a record of the June and July meetings. Second, the minutes for March 24, 2006, meeting and the July 19, 2007, meeting were never approved by the committee.

    Recommendation:
    The Company should ensure that board of directors/trustees and board committee meeting minutes are complete, properly approved, and signed.

  5. Comment:
    The examination identified other findings, that depart from statutory accounting principles. These findings have been included as comments in a separate letter provided to the Company’s management team.

    Recommendation:
    The Company should develop a corrective action plan for all of the comments included in the related management letter.


SUBSEQUENT EVENTS

During 2010, the Company and DDPNH agreed to purchase up to $840,000 of Delta Dental Plan of Vermont’s (hereinafter, “DDPVT”) common stock investment in Red Tree Holdings, Inc. (hereinafter, “RTH”).  The agreement is valid through September 2015.

Effective January 19, 2010, the Company provided a guarantee to maintain Red Tree Insurance Company, Inc. (hereinafter, “RTI”) shareholders’ surplus at a level no less than $2,000,000. This guarantee was a Bureau requirement.  The DDPNH and DDPVT boards of directors have voted to share in any surplus contributions needed to meet the $2,000,000 minimum requirement.

Effective December 31, 2010, the Company, DDPNH, and DDPVT each sold their one-third ownership interest in NEDA to RTH for $19,535 each.

THE COMPANY

HISTORY
The Company was incorporated in the State of Maine on April 28, 1965, under Special Statute and is now subject to 13-B M.R.S.A. Conditions of the Company’s licensure were set forth in a letter dated May 19, 1987.

The Company, along with DDPNH and DDPVT, does business under the trade name Northeast Delta Dental.

The Company’s statutory home office is in Portland, Maine. The Company maintains a marketing office in Saco, Maine.

CORPORATE RECORDS
The Company’s articles of incorporation, by-laws, and minutes of the board of directors’ meetings held during the period under examination were reviewed.

CORPORATE OWNERSHIP
During 1997, the Company, DDPNH, and DDPVT formed NEDA whose purpose is to provide third party administrative services for employers wishing to obtain cost efficient, self funded employee dental benefit plans for their employees. The Company, DDPNH, and DDPVT each own a one-third interest in NEDA.

In January 2009, the Company, DDPNH, and DDPVT formed a holding company, RTH, for the purpose of pursuing other investment opportunities. Each entity initially invested $1,415,000 in RTH and each entity agreed to lend up to an additional $125,000. In May 2009, RTH formed a wholly owned subsidiary, RTI, which is licensed to provide vision insurance in the states of Maine and New Hampshire. In December 2009, RTH purchased sole membership interest in Combined Services LLC (hereinafter, “CS”). CS provides employee benefit brokerage services, flexible employee benefit plan administrative services, and COBRA administrative services.

CORPORATE GOVERNANCE
The Company is governed and overseen by its board of directors and the management team of the Company.

At December 31, 2009, the Company’s board of directors, listed in the 2009 statutory annual statements, consisted of fifteen individuals all of whom were outside directors and were elected by the members, in accordance with 13-B M.R.S.A. §702.

Name Title
Kevin C Baack, Ph. D Director
David L Bagdasarian, DDS Director
Maryellen Beaulieu, Ed.D Director
Fred Bechard, D.Ed. Director
Jeffrey B. Doss, DDS Director
Michael P. Goldberg, DMD Director
Cynthia H. Hamilton Director
Clifford B. Larlee JR, DMD Director
Martha M. Lawrence, DDS Director
Stephen G. Morse, DMD Director
Michael W. Pardue Director
Barry C. Saltz, DDS Director
Douglas C. Terp Director
Cheryl Bascomb Director
Daniel Thayer Director

 

The Company’s board of directors approves the strategic direction of the Company’s business and financial objectives, monitors the effectiveness of management’s implementation of policies and plans, and provides oversight and support in achieving corporate objectives.

The Company’s board of directors has five standing committees. These committees include finance, corporate governance, dental access, professional services, and long range planning. In addition, the Company, DDPNH, and DDPVT have formed tri-state committees which focus on finance, long range planning, compensation, and professional relations. Each committee consists of three or more members, and all report to the board of directors.

At December 31, 2009, the Company’s officers, listed in the 2009 statutory annual statements, are:

Name Title
Thomas Raffio President
Benjamin E. Marcus, Esq Clerk
Barry C. Saltz, DDS Treasurer
Helen T. Biglin Vice President

 

The Company provided an organizational chart for all officers and key employees. The following is a list of the officers interviewed:

Name Title
Thomas Raffio President & CEO
Linda Roche Director Strategy Management
Gene Emery Vice President Marketing
Ken Robinson General Counsel
Connie Roy-Czyzowski Vice President Human Resources
Helen Biglin Senior Vice President Finance
Laurence Weissbrot Director Actuarial & Research
Mike Bourbeau Vice President Information Systems
William Lambrukos Senior Vice President Operatiions

 

CODE OF CONDUCT AND CONFLICT OF INTEREST
Title 24-A M.R.S.A. §3413 identifies areas of potential conflicts of interest. As such, the Company requires that each director and officer of the Company complete a conflict of interest statement, annually, to disclose any material interest or affiliations which are likely to be in conflict with his/her official duties and responsibilities to the Company.

The conflict of interest guidelines are included in the Company’s code of business conduct and ethics. All directors, officers, and employees are required to sign a compliance certificate when hired/appointed that certifies that they have read, understand, and will adhere to the code of business conduct and ethics, and the conflict of interest policy. All directors and officers are required to also sign a compliance certificate annually.

FIDELITY BOND AND OTHER INSURANCE
The Company is protected by a fidelity bond, and the bond amount was reviewed and was determined to be substantially in compliance with the NAIC recommended levels of coverage. The Company maintains other insurance policies including property and equipment, automobiles, general liability, and directors and officers' liability.

TERRITORY & PLAN OF OPERATION
The Company is a not for profit, tax exempt organization under 24 M.R.S.A chapter 19 which was established to provide dental benefit programs for employers and individuals through a network of participating member dentists in the State of Maine. Covered individuals can submit claims for certain dental services which are provided for under written policies. Dental service related benefits are paid up to a maximum amount per covered individual, as defined by the various programs. The Company also provides dental service plan administration for other groups.

TRANSACTIONS WITH AFFILIATES
The Company, DDPNH, and DDPVT conduct business under the trade name Northeast Delta Dental. All processing of premiums, claims, provider contracts, and subscriber group services is performed by DDPNH employees and the costs are allocated to the two other plans through a marketing and administrative agreement.

GROWTH OF COMPANY
Premium revenue was $50 million in 2005 and $53 million in 2009. During this same period, the Company has expanded its role as a dental benefits administrator with gross revenue of $6.0 million in 2005 and $21.8 million in 2009. Total capital and surplus was $14.5 million at December 31, 2004, and $27.6 million at December 31, 2009. Unfavorable economic conditions, market saturation, federal health reform uncertainty, and competition from multiline healthcare providers continue to exert pressure on the Company to maintain its market share. Management believes that emphasis on quality of service and on community outreach are the keys to preserving the Company’s market position.

ACCOUNTS AND RECORDS
As part of the information systems review, reliance was placed on review of the Company’s response to the NAIC prescribed Information Systems Questionnaire. Interviews with Company staff were conducted to gather supplemental information and to corroborate the Company’s responses to the questionnaire. Included in the scope of this review were management and organization controls, logical and physical security controls, changes to applications, system and program development, contingency planning, and operations and processing controls.

REINSURANCE

Through the Company’s association with the Delta Dental Plan Association’s Federal Marketing Group, the Company entered into two reinsurance transactions wherein it assumes some minimal reinsurance from Renaissance Life & Health Insurance Company of America and Delta Dental Insurance Company. Reinsurance amounts assumed are not considered material.

The Company does not have any ceded reinsurance arrangements.

LITIGATION

Based on inquiries of management and a review of legal confirmations furnished by outside legal counsel, it appears that the Company is not involved in any actual, pending, or threatened litigation that would result in a material judgment against the Company.

FINANCIAL STATEMENTS

The accompanying financial statements present fairly, in all material respects, the Company’s statutory financial position as of December 31, 2009, and statutory results of operations for the period then ended. The financial statements as of December 31, 2008, 2007, 2006, and 2005 are unexamined and are presented for comparative purposes only.

STATEMENT OF ADMITTED ASSETS, LIABILITIES AND SURPLUS
as of December 31, 2009, 2008, 2007, 2006, and 2005

 

  2009 2008 2007 2006 2005
Assets   (unexamined) (unexamined) (unexamined) (unexamined)
Bonds $ 17,736,827 $ 17,426,601 $ 16,739,871 $ 15,639,848 $ 11,650,176
Common stocks 7,937,054 4,581,206 7,489,770 5,128,442 4,820,082
Cash & cash equivalents 5,983,503 7,155,319 5,630,826 5,155,264 4,464,480
Aggregate write-ins 21,089 25,941 35,141 38,527 25,640
Accrued investment income 11,314 154,819 172,354 175,578 123,765
Premiums receivable 1,487,187 1,377,961 1,410,946 1,391,135 1,255,789
Uninsured plan receivables 1,395,490 592,581 594,508 243,771 356,509
Reinsurance receivable - 2,004 - - -
Total assets $ 34,572,464 $ 31,316,432 $ 32,073,416 $ 27,772,565 $ 22,696,441
Liabilities and Surplus          
Liabilities:          
Claims unpaid $ 1,797,100 $ 1,777,700 $ 1,832,000 $ 2,033,600 $ 2,160,400
Accrued adjustment expenses 230,000 230,000 272,000 296,000 346,000
Unearned premium 625,327 638,446 491,699 562,242 594,626
General expenses accrual 2,456,433 2,586,246 1,021,865 790,803 820,592
Amounts withheld for others 428,625 689,269 988,007 831,986 441,821
Uninsured plan accruals 1,480,900 792,500 681,300 681,700 169,200
Total liabilities 7,018,385 6,714,161 5,286,871 5,196,331 4,532,639
           
Surplus          
Unassigned funds 27,554,079 24,602,271 26,786,545 22,576,234 18,163,802
Total surplus 27,554,079 24,602,271 26,786,545 22,576,234 18,163,802
           
Liabilities and surplus $ 34,572,464 $ 31,316,432 $ 32,073,416 $ 27,772,565 $ 22,696,441

 

STATEMENT OF OPERATIONS
Years Ended December 31, 2009, 2008, 2007, 2006 and 2005

 

  2009 2008 2007 2006 2005
    (unexamined) (unexamined) (unexamined) (unexamined)
Net premium income $ 53,218,665 $ 53,227,007 $ 50,913,339 $ 52,713,438 $ 49,963,096
           
Underwriting deductions:          
Other professional services 44,766,084 44,068,063 40,233,550 41,720,417 39,270,625
Claims adjustment expenses 1,901,088 1,939,152 1,958,859 2,078,619 2,150,132
General administrative expenses 6,300,249 7,990,428 5,823,260 5,798,199 5,345,759
Total underwriting deductions 52,967,421 53,997,643 48,015,669 49,597,235 46,766,516
           
Total underwritng gain (loss) 251,244 (770,636) 2,897,670 3,116,203 3,196,580
           
Net investment income earned 727,448 1,013,431 1,004,312 855,035 617,227
Net realized capital gains (losses) 232,320 (1,021,355) 15,132 70,104 (107,400)
Net investment gain (loss) 959,768 (7,924) 1,019,444 925,139 509,827
           
Aggregate write-ins (567) (8,974) (32,114) (29,600) (13,323)
           
Income before federal income taxes 1,210,445 (787,534) 3,885,000 4,011,742 3,693,084
           
Federal income taxes - - - - -
Net income (loss) $ 1,210,445 $ (787,534) $ 3,885,000 $ 4,011,742 $ 3,693,084

 

STATEMENT OF CAPITAL AND SURPLUS
Years Ended December 31, 2009, 2008, 2007, 2006 and 2005

 

  2009 2008 2007 2006 2005
    (unexamined) (unexamined) (unexamined) (unexamined)
Surplus, December 31 prior year $ 24,602,271 $ 26,786,545 $ 22,576,234 $ 18,163,802 $ 14,495,447
           
Net income 1,210,445 (787,534) 3,885,000 4,011,742 3,693,084
Net unrealized capital gain/(loss) 1,719,502 (1,455,805) 369,645 397,069 20,288
Change in nonadmitted assets 21,861 59,066 (44,333) 3,619 (45,019)
Aggregate write-ins - (1) (1) 2 2
Net change in surplus 2,951,808 (2,184,274) 4,210,311 4,412,432 3,668,355
           
Surplus, December 31 current year $ 27,554,079 $ 24,602,271 $ 26,786,545 $ 22,576,234 $ 18,163,802

 

NOTES TO FINANCIAL STATEMENTS

Claim Reserves
The Company, DDPNH, and DDPVT record all unpaid claims as incurred, but not reported (IBNR). The Company, DDPNH, and DDPVT write mono-line business that is short-tailed in nature. As such, a majority of claims are settled within three months of receipt. Accordingly, an actuary was not utilized for this examination. Paid claim detail was reviewed by the examiners for the period under examination through the six month period ending June 30, 2010. This review provided reasonable assurance that the reserves reported as of at December 31, 2009, were adequate.

The methodology employed by the Company, DDPNH, and DDPVT for estimating unpaid claim adjustment expense was reviewed by the examiners for accuracy and reasonableness. This review provided reasonable assurance that the unpaid claim adjustment expense reported as of at December 31, 2009, was adequate.

CONCLUSION

The Company’s financial condition, as reported by management, is reflected in the statements contained in this report.

Acknowledgment of cooperation and assistance extended to the examiners by all Company personnel is hereby expressed.


STATE OF MAINE
COUNTY OF KENNEBEC, SS

Stuart E. Turney, Director of Examination, being duly sworn according to law deposes and says that, in accordance with authority vested in him by Mila Kofman, Superintendent of Insurance, pursuant to the Insurance Laws of the State of Maine, he has made an examination of the condition and affairs of the

Maine Dental Service Corporation

of Portland, Maine as of December 31, 2009, and that the foregoing report of examination subscribed to by him is true to the best of his knowledge and belief. The following examiners from the Maine Bureau of Insurance and the New Hampshire Department of Insurance assisted:

Maine:
Graham S. Payne
Vanessa J. Leon
Arias Wan

New Hampshire:
Alan P. Goode
Kurt Gillies
Tom Begeal

 

________________________
Stuart E. Turney, CPA, AFE

 

Subscribed and sworn to before me
This _____day of _________, 2011

 

_______________________
Notary Public
My Commission Expires:

 

Last Updated: October 22, 2013