SEC Company Response from ALLSTATE LIFE INSURANCE CO OF NEW YORK (CIK 0000839759) — Apr 21, 2021
ALLSTATE LIFE INSURANCE CO OF NEW YORK (CIK 0000839759)
Date: April 21, 2021 · CIK: 0000839759 · Accession: 0001628280-21-007302
AI Filing Summary & Sentiment
File numbers found in text: 333-203177, 333-224078, 333-254871
Letter
Disclosure Review and Accounting Office U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549
Dear Mr. Oh,
Please see our responses below addressing your comments on Allstate Life Insurance Company of New York’s (“ALNY”) Form S-1 Registration Statement (File No. 333-254871) given over the phone on April 13, 2021. We have included the applicable comments you provided over the phone, followed by our response in bold.
Comment 1: Please provide your plans for how you will be complying with the new summary prospectus rule (Rule 498A) since the ALNY S-1 contains a combined prospectus?
Response: As we discussed, we acknowledge the Staff’s comments and will be making changes to ensure compliance with the new summary prospectus rules. We will inform the Staff of our specific plans in the near future and prior to the compliance date.
Comment 2: In the “Calculation of Registration Fee” table on the Form S-1 cover page, please include the amount to be registered.
Response: We updated the table accordingly by adding the amount that is being carried over, as reflected in the table’s footnote, to the amount to be registered column. (see revised cover page attached).
Comment 3: Within Part II, please include Item 17. Undertakings.
Response: We updated Part II to include Item 17. Undertakings. (see revised Part II, Item 17 attached).
Comment 4: Please include the date of the supplement and list the applicable prospectuses.
Response: We updated to include the supplement date and the list of applicable contracts (see revised supplement document attached).
We trust that these responses address your comments. If you have any questions, please let me know.
/s/ Efie Vainikos
Efie Vainikos
Senior Counsel
(847) 402-2759
Efie.Vainikos@allstate.com
ALLSTATE LIFE INSURANCE CO OF NEW YORK
As filed with the Securities and Exchange Commission on April __, 2021
FILE NO. 333-254871
_____________________________________________________________________________________________________________
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
_____________________
PRE-EFFECTIVE AMENDMENT NO. 1
TO FORM S-1
REGISTRATION STATEMENT
UNDER
THE SECURITIES ACT OF 1933
_____________________
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
(Exact Name of Registrant as specified in its charter)
NEW YORK (State or Other Jurisdiction of Incorporation or Organization) 36-2608394
(I.R.S. Employer Identification Number)
(Primary Standard Industrial Classification Code Number)
878 VETERAN’S MEMORIAL HIGHWAY SUITE 400
HAUPPAUGE, NEW YORK 11788
(631) 357-8920
(Address, including zip code, and telephone Number, including area code, of registrant’s Principal Executive Offices)
_____________________
CT CORPORATION SYSTEM 111 EIGHTH AVENUE
13TH FLOOR NEW YORK, NY 10011
(212) 894-8800
(Name, address, including zip code, Address and Telephone Number, including area code, of Agent for Service)
_____________________
COPIES TO:
ANGELA K. FONTANA
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
2775 SANDERS ROAD SUITE A2E
NORTHBROOK, IL 60062
_____________________
Approximate date of commencement of proposed sale to the Public: As soon as practicable after the effective date of this registration statement.
If any of the securities being registered on this Form are to be offered on a delayed or continuous basis pursuant to Rule 415 under the Securities Act of 1933, check the following box. ☒
If this Form is filed to register additional securities for an offering pursuant to Rule 462(b) under the Securities Act, please check the following box and list the Securities Act registration statement number of the earlier effective registration statement for the same offering. ☐
If this Form is a post-effective amendment filed pursuant to Rule 462(c) under the Securities Act, check the following box and list the Securities Act registration statement number of the earlier effective registration statement for the same offering. ☐
If this Form is a post-effective amendment filed pursuant to Rule 462(d) under the Securities Act, check the following box and list the Securities Act registration statement number of the earlier effective registration statement for the same offering. ☐
Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, smaller reporting company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange Act. ☐
Large accelerated filer
☐
Accelerated filer
☐
Non-accelerated filer
☒
Smaller reporting company
☐
Emerging growth company
☐
If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 7(a)(2)(B) of the Securities Act.
CALCULATION OF REGISTRATION FEE
Title of each class of securities being registered
Amount to be
registered
Proposed maximum offering price per unit(1)
Proposed
maximum aggregate offering price
Amount of registration fee(2)
Deferred annuity interests and participating interests therein
$11,668,648.00
$1.00
$0 $0
1.The Contract does not provide for a predetermined amount or number of units.
2.This filing is being made under the Securities Act of 1933 to register $11,668,648 of deferred annuity interests and participating interests therein. The interests being registered herein are carried over, as unsold securities, from an existing Form S-1 registration statement of the same issuer (333-224078) filed on April 2, 2018. Because a filing fee of $1,539 previously was paid with respect to those securities, there is no filing fee due under this registration statement. In accordance with Rule 415(a)(6), the offering of securities on the earlier registration statement will be deemed terminated as of the effective date of this Registration Statement.
This Registration Statement contains a combined prospectus under Rule 429 under the Securities Act of 1933 which relates to the Form S-1 registration statement (File Nos. 333-224078 and 333-203177), filed on April 2, 2018 and April 1, 2015, respectively, by Allstate Life Insurance Company of New York. Upon effectiveness, this Registration Statement, which is a new Registration Statement, will also act as a post-effective amendment to such earlier Registration Statements.
_____________________________
Registrant hereby amends this Registration Statement on such date or dates as may be necessary to delay its effective date until the Registrant shall file a further amendment which specifically states that this Registration Statement shall thereafter become effective in accordance with Section 8(a) of the Securities Act of 1933 or until the Registration Statement shall become effective on such date as the Commission, acting pursuant to Section 8(a), may determine.
Neither the Securities and Exchange Commission nor any State securities commission has approved or disapproved of these securities or passed upon the adequacy or accuracy of this prospectus. Any representation to the contrary is a criminal offense.
Allstate Distributors, L.L.C. (“ADLLC”) serves as distributor of the securities registered herein. The securities offered herein are sold on a continuous basis, and there is no specific end date for the offering. ADLLC, an affiliate of Allstate Life Insurance Company of New York, is a wholly owned subsidiary of Allstate Life Insurance Company. ADLLC is a registered broker dealer under the Securities and Exchange Act of 1934, as amended, and is a member of the Financial Industry Regulatory Authority. ADLLC is not required to sell any specific number or dollar amount of securities, but will use its best efforts to sell the securities offered. Commissions earned by ADLLC are described in the notes to the insurer financial statements, under the heading “Broker-Dealer Agreements.” The prospectuses, dated as of the date indicated therein, by which the securities registered in this Form S-1 are described, are included in this registration statement.
ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
Supplement Dated April 30, 2021
To the following Prospectuses, as supplemented
ALLSTATE PROVIDER PROSPECTUS DATED MAY 1, 2002
SELECT DIRECTIONS PROSPECTUS DATED APRIL 30, 2005
AIM LIFETIME PLUS PROSPECTUS DATED APRIL 30, 2005
AIM LIFETIME PLUS II PROSPECTUS DATED APRIL 30, 2005
CUSTOM PORTFOLIO PROSPECTUS DATED APRIL 30, 2005
The following information supplements the prospectus for your variable annuity contract issued by Allstate Life Insurance Company of New York.
INDEX
Item 3(c) Risk Factors 1
Item 11(a) Description of Business 8
Item 11(b) Description of Property 9
Item 11(c) Legal Proceedings 9
Item 11(e) Financial Statements and Notes to Financial Statements 9
Item 11(f) Selected Financial Data 53
Item 11(h) Management’s Discussion and Analysis of Financial Condition and Results of Operations 54
Item 11(i) Changes in and Disagreements with Accountants on Accounting and Financial Disclosure 78
Item 11(j) Quantitative and Qualitative Disclosures About Market Risk 78
Item 11(k) Directors, Executive Officers, Promoters and Control Persons 78
Item 11(l) Executive Compensation 80
Item 11(m) Security Ownership of Certain Beneficial Owners and Management 80
Item 11(n) Transactions with Related Persons, Promoters and Certain Control Persons 81
Other Information 83
Item 3(c). Risk Factors
Forward-Looking Statements
This document contains “forward-looking statements” that anticipate results based on our estimates, assumptions and plans that are subject to uncertainty. These statements are made subject to the safe-harbor provisions of the Private Securities Litigation Reform Act of 1995. Forward-looking statements do not relate strictly to historical or current facts and may be identified by their use of words like “plans,” “seeks,” “expects,” “will,” “should,” “anticipates,” “estimates,” “intends,” “believes,” “likely,” “targets” and other words with similar meanings. These statements may address, among other things, our strategy for growth, product development, investment results, regulatory approvals, market position, expenses, financial results, litigation and reserves. We believe that these statements are based on reasonable estimates, assumptions and plans. Forward-looking statements speak only as of the date on which they are made, and we assume no obligation to update any forward-looking statements as a result of new information or future events or developments. In addition, forward-looking statements are subject to certain risks or uncertainties that could cause actual results to differ materially from those communicated in these forward-looking statements.
Risks are categorized by (1) insurance and financial services, (2) business, strategy and operations and (3) macro, regulatory and risk environment. Many risks may affect more than one category and are included where the impact is most significant. Consider these cautionary statements carefully together with other factors discussed elsewhere in this document, in filings with the Securities and Exchange Commission (“SEC”) or in materials incorporated therein by reference.
Insurance and financial services
Changes in reserve estimates and amortization of deferred acquisition costs (“DAC”) could materially affect our results of operations and financial condition
We use long-term assumptions, including future investment yields, mortality, morbidity, persistency and expenses in pricing and valuation. If experience differs significantly from assumptions, adjustments to reserves and amortization of DAC may be required that could have a material adverse effect on our results of operations and financial condition.
We may not be able to mitigate the capital impact associated with statutory reserving and capital requirements
Regulatory capital and reserving requirements affect the amount of capital required. Changes to capital or reserving requirements or regulatory interpretations may result in holding additional capital and could require us to increase prices, reduce our sales of certain products, and/or accept a return on equity below original levels assumed in pricing.
A downgrade in financial strength ratings may have an adverse effect on our business
Financial strength ratings are important factors in establishing the competitive position of insurance companies. Rating agencies could downgrade or change the outlook on our ratings due to:
•Changes in statutory capital
•Changes in a rating agency’s determination of the amount of capital required to maintain a particular rating
•Increases in the perceived risk of our investment portfolio, a reduced confidence in management or our business strategy, as well as a number of other considerations that may or may not be under our control
•Changes in ownership resulting from divestiture of business
A downgrade in our ratings could have a material effect on our sales, competitiveness, retention, the marketability of our product offerings, liquidity, results of operations and financial condition.
Changes in tax laws may adversely affect profitability of life insurance products
Changes in taxation of life insurance products could reduce sales and result in the surrender of some existing contracts and policies, which may have a material effect on our profitability and financial condition.
Our investment portfolio is subject to market risk and declines in quality which may adversely affect or create volatility in our investment income and cause realized and unrealized losses
We continually evaluate investment management strategies since we are subject to risk of loss due to adverse changes in interest rates, credit spreads, equity prices, real estate values, currency exchange rates and liquidity. Adverse changes may occur due to changes in monetary and fiscal policy and the economic climate, liquidity of a market or market segment, investor return expectations or risk tolerance, insolvency or financial distress of key market makers or participants, or changes in market perceptions of credit worthiness. Adverse changes in market conditions could cause the value of our investments to decrease significantly and impact our results of operations and financial condition.
Our investments are subject to risks associated with economic and capital market conditions and factors that may be unique to our portfolio, including:
•General weakening of the economy, which is typically reflected through higher credit spreads and lower equity and real estate valuations
•Declines in credit quality
•Declines in market interest rates, credit spreads or sustained low interest rates could lead to further declines in portfolio yields and investment income
•Increases in market interest rates, credit spreads or a decrease in liquidity could have an adverse effect on the value of our fixed income securities that form a substantial majority of our investment portfolio
•Weak performance of general and joint venture partners and underlying investments unrelated to general market or economic conditions could lead to declines in investment income and cause realized losses in our limited partnership interests
•Concentration in any particular issuer, industry, collateral type, group of related industries, geographic sector or risk type
The amount and timing of net investment income, capital contributions and distributions from our performance-based investments, which primarily include limited partnership interests, can fluctuate significantly due to the underlying investments’ performance or changes in mar
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CORRESP 1 filename1.htm correspcombo April 21, 2021 Sonny Oh Senior Counsel Disclosure Review and Accounting Office U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Dear Mr. Oh, Please see our responses below addressing your comments on Allstate Life Insurance Company of New York’s (“ALNY”) Form S-1 Registration Statement (File No. 333-254871) given over the phone on April 13, 2021. We have included the applicable comments you provided over the phone, followed by our response in bold. Comment 1: Please provide your plans for how you will be complying with the new summary prospectus rule (Rule 498A) since the ALNY S-1 contains a combined prospectus? Response: As we discussed, we acknowledge the Staff’s comments and will be making changes to ensure compliance with the new summary prospectus rules. We will inform the Staff of our specific plans in the near future and prior to the compliance date. Comment 2: In the “Calculation of Registration Fee” table on the Form S-1 cover page, please include the amount to be registered. Response: We updated the table accordingly by adding the amount that is being carried over, as reflected in the table’s footnote, to the amount to be registered column. (see revised cover page attached). Comment 3: Within Part II, please include Item 17. Undertakings. Response: We updated Part II to include Item 17. Undertakings. (see revised Part II, Item 17 attached). Comment 4: Please include the date of the supplement and list the applicable prospectuses. Response: We updated to include the supplement date and the list of applicable contracts (see revised supplement document attached). We trust that these responses address your comments. If you have any questions, please let me know. /s/ Efie Vainikos Efie Vainikos Senior Counsel (847) 402-2759 Efie.Vainikos@allstate.com ALLSTATE LIFE INSURANCE CO OF NEW YORK As filed with the Securities and Exchange Commission on April __, 2021 FILE NO. 333-254871 _____________________________________________________________________________________________________________ UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 _____________________ PRE-EFFECTIVE AMENDMENT NO. 1 TO FORM S-1 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 _____________________ ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK (Exact Name of Registrant as specified in its charter) NEW YORK (State or Other Jurisdiction of Incorporation or Organization) 36-2608394 (I.R.S. Employer Identification Number) 6311 (Primary Standard Industrial Classification Code Number) 878 VETERAN’S MEMORIAL HIGHWAY SUITE 400 HAUPPAUGE, NEW YORK 11788 (631) 357-8920 (Address, including zip code, and telephone Number, including area code, of registrant’s Principal Executive Offices) _____________________ CT CORPORATION SYSTEM 111 EIGHTH AVENUE 13TH FLOOR NEW YORK, NY 10011 (212) 894-8800 (Name, address, including zip code, Address and Telephone Number, including area code, of Agent for Service) _____________________ COPIES TO: ANGELA K. FONTANA ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK 2775 SANDERS ROAD SUITE A2E NORTHBROOK, IL 60062 _____________________ Approximate date of commencement of proposed sale to the Public: As soon as practicable after the effective date of this registration statement. If any of the securities being registered on this Form are to be offered on a delayed or continuous basis pursuant to Rule 415 under the Securities Act of 1933, check the following box. ☒ If this Form is filed to register additional securities for an offering pursuant to Rule 462(b) under the Securities Act, please check the following box and list the Securities Act registration statement number of the earlier effective registration statement for the same offering. ☐ If this Form is a post-effective amendment filed pursuant to Rule 462(c) under the Securities Act, check the following box and list the Securities Act registration statement number of the earlier effective registration statement for the same offering. ☐ If this Form is a post-effective amendment filed pursuant to Rule 462(d) under the Securities Act, check the following box and list the Securities Act registration statement number of the earlier effective registration statement for the same offering. ☐ Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, smaller reporting company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange Act. ☐ Large accelerated filer ☐ Accelerated filer ☐ Non-accelerated filer ☒ Smaller reporting company ☐ Emerging growth company ☐ If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 7(a)(2)(B) of the Securities Act. CALCULATION OF REGISTRATION FEE Title of each class of securities being registered Amount to be registered Proposed maximum offering price per unit(1) Proposed maximum aggregate offering price Amount of registration fee(2) Deferred annuity interests and participating interests therein $11,668,648.00 $1.00 $0 $0 1.The Contract does not provide for a predetermined amount or number of units. 2.This filing is being made under the Securities Act of 1933 to register $11,668,648 of deferred annuity interests and participating interests therein. The interests being registered herein are carried over, as unsold securities, from an existing Form S-1 registration statement of the same issuer (333-224078) filed on April 2, 2018. Because a filing fee of $1,539 previously was paid with respect to those securities, there is no filing fee due under this registration statement. In accordance with Rule 415(a)(6), the offering of securities on the earlier registration statement will be deemed terminated as of the effective date of this Registration Statement. This Registration Statement contains a combined prospectus under Rule 429 under the Securities Act of 1933 which relates to the Form S-1 registration statement (File Nos. 333-224078 and 333-203177), filed on April 2, 2018 and April 1, 2015, respectively, by Allstate Life Insurance Company of New York. Upon effectiveness, this Registration Statement, which is a new Registration Statement, will also act as a post-effective amendment to such earlier Registration Statements. _____________________________ Registrant hereby amends this Registration Statement on such date or dates as may be necessary to delay its effective date until the Registrant shall file a further amendment which specifically states that this Registration Statement shall thereafter become effective in accordance with Section 8(a) of the Securities Act of 1933 or until the Registration Statement shall become effective on such date as the Commission, acting pursuant to Section 8(a), may determine. Neither the Securities and Exchange Commission nor any State securities commission has approved or disapproved of these securities or passed upon the adequacy or accuracy of this prospectus. Any representation to the contrary is a criminal offense. Allstate Distributors, L.L.C. (“ADLLC”) serves as distributor of the securities registered herein. The securities offered herein are sold on a continuous basis, and there is no specific end date for the offering. ADLLC, an affiliate of Allstate Life Insurance Company of New York, is a wholly owned subsidiary of Allstate Life Insurance Company. ADLLC is a registered broker dealer under the Securities and Exchange Act of 1934, as amended, and is a member of the Financial Industry Regulatory Authority. ADLLC is not required to sell any specific number or dollar amount of securities, but will use its best efforts to sell the securities offered. Commissions earned by ADLLC are described in the notes to the insurer financial statements, under the heading “Broker-Dealer Agreements.” The prospectuses, dated as of the date indicated therein, by which the securities registered in this Form S-1 are described, are included in this registration statement. ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK Supplement Dated April 30, 2021 To the following Prospectuses, as supplemented ALLSTATE PROVIDER PROSPECTUS DATED MAY 1, 2002 SELECT DIRECTIONS PROSPECTUS DATED APRIL 30, 2005 AIM LIFETIME PLUS PROSPECTUS DATED APRIL 30, 2005 AIM LIFETIME PLUS II PROSPECTUS DATED APRIL 30, 2005 CUSTOM PORTFOLIO PROSPECTUS DATED APRIL 30, 2005 The following information supplements the prospectus for your variable annuity contract issued by Allstate Life Insurance Company of New York. INDEX Item 3(c) Risk Factors 1 Item 11(a) Description of Business 8 Item 11(b) Description of Property 9 Item 11(c) Legal Proceedings 9 Item 11(e) Financial Statements and Notes to Financial Statements 9 Item 11(f) Selected Financial Data 53 Item 11(h) Management’s Discussion and Analysis of Financial Condition and Results of Operations 54 Item 11(i) Changes in and Disagreements with Accountants on Accounting and Financial Disclosure 78 Item 11(j) Quantitative and Qualitative Disclosures About Market Risk 78 Item 11(k) Directors, Executive Officers, Promoters and Control Persons 78 Item 11(l) Executive Compensation 80 Item 11(m) Security Ownership of Certain Beneficial Owners and Management 80 Item 11(n) Transactions with Related Persons, Promoters and Certain Control Persons 81 Other Information 83 Item 3(c). Risk Factors Forward-Looking Statements This document contains “forward-looking statements” that anticipate results based on our estimates, assumptions and plans that are subject to uncertainty. These statements are made subject to the safe-harbor provisions of the Private Securities Litigation Reform Act of 1995. Forward-looking statements do not relate strictly to historical or current facts and may be identified by their use of words like “plans,” “seeks,” “expects,” “will,” “should,” “anticipates,” “estimates,” “intends,” “believes,” “likely,” “targets” and other words with similar meanings. These statements may address, among other things, our strategy for growth, product development, investment results, regulatory approvals, market position, expenses, financial results, litigation and reserves. We believe that these statements are based on reasonable estimates, assumptions and plans. Forward-looking statements speak only as of the date on which they are made, and we assume no obligation to update any forward-looking statements as a result of new information or future events or developments. In addition, forward-looking statements are subject to certain risks or uncertainties that could cause actual results to differ materially from those communicated in these forward-looking statements. Risks are categorized by (1) insurance and financial services, (2) business, strategy and operations and (3) macro, regulatory and risk environment. Many risks may affect more than one category and are included where the impact is most significant. Consider these cautionary statements carefully together with other factors discussed elsewhere in this document, in filings with the Securities and Exchange Commission (“SEC”) or in materials incorporated therein by reference. Insurance and financial services Changes in reserve estimates and amortization of deferred acquisition costs (“DAC”) could materially affect our results of operations and financial condition 1 We use long-term assumptions, including future investment yields, mortality, morbidity, persistency and expenses in pricing and valuation. If experience differs significantly from assumptions, adjustments to reserves and amortization of DAC may be required that could have a material adverse effect on our results of operations and financial condition. We may not be able to mitigate the capital impact associated with statutory reserving and capital requirements Regulatory capital and reserving requirements affect the amount of capital required. Changes to capital or reserving requirements or regulatory interpretations may result in holding additional capital and could require us to increase prices, reduce our sales of certain products, and/or accept a return on equity below original levels assumed in pricing. A downgrade in financial strength ratings may have an adverse effect on our business Financial strength ratings are important factors in establishing the competitive position of insurance companies. Rating agencies could downgrade or change the outlook on our ratings due to: •Changes in statutory capital •Changes in a rating agency’s determination of the amount of capital required to maintain a particular rating •Increases in the perceived risk of our investment portfolio, a reduced confidence in management or our business strategy, as well as a number of other considerations that may or may not be under our control •Changes in ownership resulting from divestiture of business A downgrade in our ratings could have a material effect on our sales, competitiveness, retention, the marketability of our product offerings, liquidity, results of operations and financial condition. Changes in tax laws may adversely affect profitability of life insurance products Changes in taxation of life insurance products could reduce sales and result in the surrender of some existing contracts and policies, which may have a material effect on our profitability and financial condition. Our investment portfolio is subject to market risk and declines in quality which may adversely affect or create volatility in our investment income and cause realized and unrealized losses We continually evaluate investment management strategies since we are subject to risk of loss due to adverse changes in interest rates, credit spreads, equity prices, real estate values, currency exchange rates and liquidity. Adverse changes may occur due to changes in monetary and fiscal policy and the economic climate, liquidity of a market or market segment, investor return expectations or risk tolerance, insolvency or financial distress of key market makers or participants, or changes in market perceptions of credit worthiness. Adverse changes in market conditions could cause the value of our investments to decrease significantly and impact our results of operations and financial condition. Our investments are subject to risks associated with economic and capital market conditions and factors that may be unique to our portfolio, including: •General weakening of the economy, which is typically reflected through higher credit spreads and lower equity and real estate valuations •Declines in credit quality •Declines in market interest rates, credit spreads or sustained low interest rates could lead to further declines in portfolio yields and investment income •Increases in market interest rates, credit spreads or a decrease in liquidity could have an adverse effect on the value of our fixed income securities that form a substantial majority of our investment portfolio •Weak performance of general and joint venture partners and underlying investments unrelated to general market or economic conditions could lead to declines in investment income and cause realized losses in our limited partnership interests •Concentration in any particular issuer, industry, collateral type, group of related industries, geographic sector or risk type The amount and timing of net investment income, capital contributions and distributions from our performance-based investments, which primarily include limited partnership interests, can fluctuate significantly due to the underlying investments’ performance or changes in mar