Santa Mario

“We should not be waiting any longer.”

-Mario Draghi


In one of the more suspicious central planning moves to-date, it appears that the new Italian Chief of Central Planning, Mario Draghi, is working on changing the date of Christmas.


Santa, as you can see, is really red. This whole thing about the Nasdaq and US Small Caps being down for 3 consecutive weeks in November (SP500 down -3%) has Bernanke’s central plan for reaching “escape velocity” from the chimney under fire too.


If Americans and Europeans change all of the rules and all of the dates, there’s really a lot we can do. You see, this is what these people fundamentally believe – they can save us from, well, just about any problem they perpetuate.


The aforementioned quote came from Santa Mario this morning where he started calling out the Germans in Frankfurt. “Where is the implementation of these long standing decisions?” Draghi asked.


Q: Qu’est ce qui ce passe avec Le Bazooka pour les banks? demanded Monsieur Sarkozy.


A: “If politicians believe the ECB can solve the problem of the Euro’s weakness, then they’re trying to convince themselves of something that won’t happen.” –Angela Merkel


Bad German Santa. Bad.


Back to the Global Macro Grind


Yesterday I covered shorts and bought some of our Hedgeye Best Ideas on the long side (ask for the replay of our analyst team’s Best Ideas Call from last Friday), taking my net long position in the Hedgeye Portfolio to one of its most bullish leans in November (12 LONGS, 8 SHORTS).


That doesn’t mean I believe in Le Pere Noel or that a few Keynesians by the name of Mario are going to save me on the long side either. It simply means that I am doing what my risk management process allows me to do – Fade Beta.


Fading Beta means buying on red and selling on green. It’s not as complicated as figuring out the European catalyst calendar. It’s just math. I base these decisions on a model that I’ve built. I don’t have to ask my boss for permission to act on its signals.


The risk management signals aren’t perfect, but they’ve been better than being Bad Beta in November. We’ve booked 13 consecutive gains on the long side of the Hedgeye Portfolio and have gone 17 for 19 in November. Beats believing in Santa too.


Like all of you, I’m proud of my team and process when they are working together. I’m not a whiner. I celebrate winning. And hopefully that message is resonating with your process. At the end of the day, this business is all about the score. Winning matters.


Where do we go from here?


On the bounce, sell on green, again.




All low-volume rallies to lower-highs in Asian, European, and US Equities are to be sold until consensus fundamentally starts to come to grips with what the Germans are saying. 

  1. If any European banks are going to be bailed out, German banks get to go first (Deutsche Bank, Commerzbank, etc).
  2. If any French or Italian banker thinks Lagarde or Draghi are getting them a priority pass ahead of German banks, they should think that through again…
  3. If and when all of these Greek, French, Italian, etc banks prove that they can’t raise money (read: secondaries in the public market), they have to tap their sovereign leaders first, then start begging for the EFSF funding. 

Like intermediate-term tops in markets, the deleveraging of balance sheets is a process, not a point. There have been plenty of points in the last 3 to 24 months where pundits have made the call that “this is it – this is the bottom for the banks”, but the process of marking bank stocks and their equity values to market continues to trump all hopes.


Hope (and begging for Santa Mario), is not a risk management process. And “printing money”, according to Merkel’s spokesman on the economy this morning, “… at the end of the day means inflation…” and “every German is very much scared about inflation.”


As Ben Bernanke anchors on the 1930s (instead of the 1970s Stagflation), the German Zeitgeist is anchoring on the 1920s. Interconnected risk is not managed on one duration to suit the needs of one country’s central banking narrative over another’s. Interconnected risk is multi-duration, multi-factor, and global.


If you don’t get that yet, you probably still believe in Santa coming this November too.


My immediate-term support and resistance ranges for Gold (bought more yesterday), Oil (Bullish Formation and inflationary), French CAC (Bearish Formation), and the SP500 (Bearish TAIL; Bullish TREND) are now $1, $98.12-101.96, 3002-3146, and 1.


Best of luck out there today,



Keith R. McCullough
Chief Executive Officer


Santa Mario - Chart of the Day


Santa Mario - Virtual Portfolio

FL: Q3 Quick Take


FL reported a solid Q3 with EPS of $0.43 vs. $0.39E reflecting continued execution at the company level on top of strength in the athletic specialty channel. The company came in ahead of our expectations on every metric with the exception of SG&A.


Based on our model, we have Fx accounting for ~$7mm of the SG&A increase with the other $26mm reflecting a 9% increase in core organic spending and a continued sequential acceleration.


We’ll need to drill down exactly where these dollars went. If it was higher investment spend at the store level or into marketing initiatives like Champs and Europe to fuel growth, then we’re perfectly cool with that. But if it was deferred maintenance or higher incentive comp, then we’re not quite as jazzed.


Comps of +7.4% came in above consensus…again – though in-line with our 7.5% estimate. We’ll learn more about the composition of sales and just how Europe fared relative to e-commerce on tomorrow’s conference call.


Gross margins of +220bps came in better than expected and better than our above consensus +160bps estimate. With our model suggesting just over 100bps in occupancy leverage, we assume the balance can be chalked up to higher merchandise margins coming in better than the +90bps contribution realized in Q2. Having just faced the toughest comp of the year and with inventory growth in check, this is positive for FL’s Q4 outlook.


As for inventories, this is the first time since the company was renamed Foot Locker from Venator that the Sales/Inventory spread was positive seven quarters in a row. Having previously been what we called ‘Nike’s best off-balance-sheet asset’ FL was perennially in a position with a negative sales/inventory spread, and down gross margins.


Cycle or no cycle, this is a different company.


We’ll have more to add following the call.





Casey Flavin



FL: Q3 Quick Take - FL SIGMA




DNKN announced the pricing of its secondary today at $25.62.


This announcement is very convenient as whispers point to same-store sales trends continuing to accelerate in the fourth quarter.  We have been hearing that K-Cups are partly responsible for the improvement in trends.  A skeptical analyst would say the timing is perfect for the insiders to sell.


Insiders are selling into strong top-line trends following Dunkin’ Brands reporting what seemed to be a strong quarter but in truth was boosted by one-time gains.  While same-store sales are important, they are less important for DNKN, which is a predominantly franchised business, than growth in points of distribution (PODs).  On this metric the company has not updated the investment community on the backlog trends in 2011.  We only know what happened in 2010.  Again, a skeptical analyst would question why there is not more disclosure on this important metric.


Going back to the IPO, the timing of the sale of DNKN by insiders could not have been done at a better time.  The IPO was initially priced at the peak of the coffee bubble see chart below.  At that time the bubble was accented by the staggering valuation of GMCR which has since seen its multiple drop by 66%.   


Do you think the collapse of the coffee bubble prompted "the insiders" to ask the underwriters to waive the 180 day lockup restriction.  Do you think the collapse in GMCR valuation had anything to do with it?  I do!  The Green Mountain story turned out to be based on less-solid foundations than initially thought and we believe that Dunkin Brands will play out the same way over time. 


If you are buying the secondary you are paying 15x NTM EBITDA for DNKN.  This represents a 46% and 30% premium to GMCR and SBUX, respectively. 


Given that SBUX is a far superior company with a proven track record and global growth coming from multiple channels of distribution, I believe that SBUX should trade at a premium to DNKN not the other way around.  If DNKN were to trade at a 10% discount to SBUX it would suggest there is 49.6% downside in DNKN today to $12.91.  Even trading at the same EV/EBITDA (NTM) multiple as SBUX would imply an almost 40% decline to roughly $16.


The DNKN premium is due to what the Street believes is "white space" growth west of the Mississippi.  To accomplish this goal, management must build a backlog of stores that will allow them to open 500 stores per year beginning in 2013, up from a projected range of 220-240 in 2011.  Importantly, the company has not updated the investment community about the backlog.


Prior to the secondary, only 21% of the company was in the hands of the public.  After tonight, roughly 37.5% of the company will be freely traded.  


Following the secondary there are a few reasons to be concerned. 

  1. There will be less pressure on the massive numbers of underwriters to prop up this stock - the fees have been collected
  2. The increased liquidity will make it easier to short the stock
  3. Financial performance will become a focus and to date it's been marginal at best. 

The K-Cup story is stealing the limelight at the moment when it comes to Dunkin’ but once the focus turns to other topics, specifically of the growth strategy, execution will be what matters most and for that fact we remain bearish.





Howard Penney

Managing Director


Rory Green


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We’re more concerned with the potential for a junket commission war between the operators.



We believe LVS may have struck a sweetheart deal with Neptune which may be more attractive (to Neptune) than the best junket deals with Galaxy, MPEL, or MGM.   Whether other junkets demand the same deal from other concessionaires (there are no secrets) remains to be seen.  It seems likely, however, that market wide commissions and commission advancement are likely to escalate.  How much will that constrict margins?  Will Wynn follow suit?  Could the junkets negotiate as more of a consortium?   We will try and answer these questions in a later note.  This note deals with another area of concern:  receivables. 


After Genting Singapore reported a large spike in their provision for bad debts last week (as seen in the chart below), credit issues once again became the topic de jour amongst the gaming community.  Existing fears of a VIP slowdown have made investors already on edge.  We’re not dismissing either issue but the numbers don’t provide a lot of basis for concern.  In addition, we think it’s interesting that the investment community only seems concerned with these charges when they occur at an Asian-based operator.  Wynn has several quarters with large spikes in their provision for doubtful accounts but no one seems to lose a wink of sleep over these.   Namely in 4Q 2010, Wynn Macau took a $10MM charge which they simply explained “was a function of business volumes… in particular in our direct program in the fourth quarter.”  In 3Q08, Wynn Macau took a provision of $19MM as well.   




As the chart below shows, MPEL’s receivables as a % of direct play, while decreasing, are higher than the comp set.  We believe that this is a direct reflection of the lending that goes on in their premium mass segment. 




The 3rd chart shows that while Genting’s receivables as a % of direct play have been increasing, they do not look out of whack with what MBS reports, although we would be concerned if the upward trend continues.



Range Rover: SP500 Levels, Refreshed

POSITION: Long Utilities (XLU) and Healthcare (XLV); Short Housing (ITB)


Into the close yesterday, I got longer. On this morning’s rally off the lows, I tightened that net exposure right back up. Managing risk around a range is the process. That’s not new.


What is new (every day) is the uncertainty implied in the range. In order to handicap uncertainty, we use a multi-duration, multi-factor approach that helps us contextualize what different investors across different durations are most likely to do next.


As of 11AM EST, here’s what I see in the SP500: 

  1. The long-term TAIL remains entrenched (1269)
  2. The Intermediate-term TREND range (1) is trade-able
  3. The Immediate-term TRADE is under selling pressure (no support to 1221) 

Going long into a weekend with no European catalyst that I can see isn’t for me – but that’s just me. I currently have 10 LONGS and 9 SHORTS.



Keith R. McCullough
Chief Executive Officer


Range Rover: SP500 Levels, Refreshed - SPX


Below we're re-publishing our Financial team's conference call with Peter Atwater last week and a transcript of his key takeaways. By way of introduction, Peter has run JPMorgan's asset-backed securities business, has been Treasurer of Bank One, CEO of Bank One Private Client Services, and CFO of Juniper Financial among other high-profile roles through the Financial Services Industry. 


On the call Peter offers his view on such topics as the EU debt crisis, ratings downgrade ramifications both at home and abroad, and various other trends within the Financial sector.  


If you'd like to learn more about the work of our Financials team, headed by Josh Steiner, please contact


The ideas below are Peter Atwater's.



Key Takeaways From Our Call Yesterday with Peter Atwater


For those interested in listening to the replay of yesterday's call, click the following link:

Materials (slide deck) from yesterday's call:





  • It's the willingness, stupid! EFSF and other mechanisms are predicated on the willingness, not just ability, of Germany et al. to support them.  Willingness is increasingly at risk, at the same time that ability is threatened by ratings downgrades. 
  • EFSF leverage isn’t a realistic option at this point.  Things are moving too fast to get the necessary approvals. 
  • No risk has been mitigated by actions so far – only moved.
  • EBA capital shortfall numbers are a pipe dream.  They assume a pan-European deposit insurance scheme, which doesn’t exist.  Moreover, since the end of September, sovereign debt prices have deteriorated significantly, further reducing the validity of the shortfall estimates. 
  • China as bailor! China is better served by picking up assets at fire-sale prices after Euro breakup than preventing it.
  • Banks will concentrate on lending in their home countries and may walk away from foreign branches.  There’s no reason to think that a withdrawal has to be orderly.
  • Bailouts are bailouts of creditors (not debtors). That’s now the view, and it changes the debate.
  • What’s ahead?  A period of extreme turbulence, followed by significant opportunity on the other side. 
  • Ratings contagion: sovereign downgrades lead to bank downgrades, and back again in a vicious cycle.
  • Both Greece and Italy will leave the Eurozone in short order.
  • What would be a positive sign?  An unconditional support agreement.


US Ratings

  • Supercommittee failure will trigger “at minimum, cautionary words, if not a further downgrade” at the same time that further spending (supporting banks, boosting economy, stemming European contagion) will be increasingly necessary.


US Housing

  • Migration to a nation of renters – 50% homeownership looks more stable in the long term (vs. 66% today)
  • Many questions remain on the structure of housing finance in 5 years.  Congress will pressure a re-syndication of risk back to the private sector.  Expect a fight around the GSEs when their Treasury Support Agreement expires at YE 2012.  Fannie/Freddie now the release valve on the housing market.


US Banks

  • Stay away from deeply interconnected "Empire" financials.
  • Consumer product pricing (e.g. debit card fees) increasingly political. 
  • Market no longer accepting “net hedged” for an answer.  The importance and focus on gross exposures is growing – just look at Jefferies.  “Net hedged” assume orderly & liquid collateral markets – which may not be there.
  • Nations will secede from Basel when it becomes inconvenient to comply. Nationalism will increase in bank regulation.
  • The market will demand subsidiary-level and geography-level loan and derivative disclosures from corporates and banks, as capital restrictions mount. 


The Following are More Detailed Notes from Our Call



Europe in flux

  • Stepping back – October breakthrough “merely whack-a-mole” – risk was only moved, not eliminated
  • Lots of conditionality behind promises; don’t underestimate that going forward
  • G-20 and IMF support will come with significant strings attached (progress payments, conditions)
  • Binary outcome – it works or it doesn’t, since all the efforts to stem contagion have been risk-transfer, not risk reduction. 
  • Since October, the question of a disorderly disintegration looks very real

Hardwired Ratings Contagion

  • Can’t emphasize enough the hardwired ratings contagion between sovereigns and banks. Bank ratings drop due to elimination of ratings uplift/moral hazard; recognition that countries are less willing even if able (and some are unable).
  • Willingness to implement austerity is not growing – leaders will require a populist component or referendum to support their policies
  • EFSF and other mechanisms are predicated on ongoing willingness of France, Germany, Netherlands to support the system. Willingness is increasingly at risk, and AAA rating vulnerability puts ability at risk with a downward-spiraling “ratings vortex”

 US Ratings

  • Supercommittee gridlock will bring ratings agencies back out with “at minimum, cautionary words, if not a further downgrade” – meanwhile, the US economic situation will provoke requests for fiscal action (domestically or in Europe) and will see need for bank support and FDIC support
  • AA is a certainty  - the question is what happens then. How do depositors view FDIC insurance in AA US?
  • Bank assets, bank liabilities – all woven into US debt ratings
  • Over 30% of bank assets reflect US government obligations, directly or indirectly.

 US Housing

  • We’ve made “baby steps” in terms of what needs to happen.  We need a “comprehensive solution” and re-syndication of risk.  Nothing seems final yet. You’ll see pressure from Congress & the agencies to come to a resolution where risk is placed in the private sector.  How that syndication takes place is critically important for bond investors.  Right now, GSE Treasury support agreement expires at YE 2012.  What happens then to US support of agencies?
  • We are witnessing the beginning of a significant migration to a nation of renters, including homeownership rates well below current levels.  50% seems more likely and more sustainable.
  • Litigation – still an operating expense.  Until the markets bottom, volumes of litigation will continue to expand. 
  • Most vulnerable: home equity lenders and bondholders most exposed to financial repression/public policy intervention.  Lots of D.C. hostility towards preference to keep HE lines current – will start to see credit card flows be impacted as well.  Card DQs are historically low, yet mortgage delinquencies are well above that. 


Becoming more nationalistic, and Basel is a great example.

  • Sovereign nations will secede from Basel and develop their own risk-weighting schema. 
  • Financial repression across capital/labor/goods mounting in Europe and will continue. 
  • Consumer product pricing is increasingly political – BAC had material Washington oversight to their debit card fee
  • Empire banks most vulnerable politically & socially – don’t underestimate Bank Transfer Day last weekend.  There’s underlying sentiment that benefits small, local, mutually owned institutions. 
  • Don’t underestimate the MF Global/Jefferies message either – what it means for hedging.
  • 3Q earnings jargon du jour was “net hedged.”  Moved pretty quickly away from that on gross disclosure mandates (e.g. Jefferies). Just as banks had to disclose mortgage exposure in greater granularity, same thing will happen with derivatives and sovereign exposure.
  • Sovereign and super-sovereign intervention will make hedging questionable as hedges don’t pay out.  Don’t underestimate the potential for disorderly collateral markets – “net hedged” assumes liquid and orderly collateral markets.
  • Potential for interruption of intercompany flows within companies themselves.  Look at Dexia’s de-consolidated balance sheets to see the mismatch in assets and liabilities.  Consequences will flow into non-financial space, as corporates may decide that bearing market risk is better than trying to explain to analysts what their exposure is like. 


3Q earnings fundamentals

  • PTPP earnings are extremely vulnerable
  • Limited opportunity for further cost-cutting
  • Credit cycle has peaked - don’t discount the message coming out of HSBC today.  They were early in recognizing issues in 2007, and they’re forward in risk management.
  • Earnings since 2009 show little improvement – it appears random.
  • Prior issues on credit front (litigation, etc.) will come back to bite them
  • Little to prevent deterioration in credit from flowing straight through (no room for Fed cutting, etc.)
  • Deterioration in social mood decreases GDP and economic activity, and it also makes collective solutions in Europe difficult and engenders need for further bailouts from the strong.  Generosity is more a function of confidence of the donor than the need of the recipient – US investors have underestimated this point.  Germany’s willingness to help was finished in October, and it’s hard to imagine Germany stepping up again given what happened immediately afterward with Greece calling for a referendum.


Europe & European banks - Capital shortfalls

A: EBA capital numbers – figures were as of the end of October, and merely looking at the market since then, that number is something like 50% light already.  Further, the EBA assumed in those figures that Europe would come up with some pan-European deposit insurance plan.  That appears very unrealistic at this point.  The EBA numbers are “unfortunately a pipe dream.”  The reality will be dramatic reshifting of priority to home country lending support by European banks.  Massive garage sale and/or actual departure from foreign markets.  We’ve all expected orderly disengagement like HSBC’s retreat from the US, but it doesn’t have to be so – the banks could just cut their losses and walk away.  Don’t underestimate the national pressure that may exist for banks to do that – political expedience


France’s AAA & ratings agencies

Question for Sarkozy is “how would you like to be downgraded? On your own merits, or because you stepped up to support Europe?” In this political environment, there’s a disincentive to trigger a ratings default tied to stepping up support for other countries.  “They’re going to be downgraded … the EFSF will be downgraded to AA+ as a consequence.”  Does that ultimately bother people, or is AA the new AAA?

Ratings themselves are vulnerable – Europe may “go black” on ratings altogether, which would also facilitate dropping Basel.


With Draghi’s appointment, Italians needed to raise some amount of capital.  But at this point, sovereigns will allocate funds to support their banks – can they capitalize them enough to decouple them from the sovereign?  I don’t think that’s likely, without major contractions in the banking system.


Will countries be allowed to leave?

Greece is leaving.  Italy is leaving.  There are WSJ articles about how to prepare for Greek secession. The question is whether it’s orderly or in a “crisis weekend.”


Plans to expand or leverage EFSF/China to the rescue

Leveraging the EFSF isn’t a realistic solution at this point – Italy is moving too fast.  Given the political constraints, you just can’t get the approvals in place to do that.  On China, I wonder if they realize that the real opportunities are after a country’s exit from Europe.  Expect them to aggressively extend credit to countries that have exited.  And you bet China is looking at assets to purchase. 


Which banks are most vulnerable?

All are vulnerable to uplift reversals – uplifts were “hallucinogenic.”  Do banks simply cut the ties to their southern European affiliates?  We’ve operated with a banking system with global branches and capital and liquidity sitting elsewhere.  Worry about the French banks, and Belgian financial institutions still dwarf GDP – ditto the Netherlands. 


What would make you more optimistic?

The fiscal union many leaders are discussing isn’t a necessity.  What I think Europe needs to demonstrate isunconditional support for each other, rather than this “mother may I” process featuring big headlines but footnotes full of preconditions.  If Europe is serious about saving itself, it’s got to have “a bazooka that can actually be fired.”  There’s nothing like that on the horizon now, nor from the G-20 or IMF. 


Disorder in counterparty netting

Doesn’t necessarily require failure of a major bank.  What we’ve seen in JEF was “a strip search at gunpoint by the market” (quoting WSJ article) – we are now operating without net hedged as an underlying principle.  The days of clamoring for gross data is now upon us, and financial institutions need to be prepared to provide it. You don’t need another failure. 


Dexia – had exceptionally poor ALCO risk management.  They were operating as a consolidated entity amid dis-integration of firms left and right.  Much like “net hedged,” we should start to see demand of investors at a legal entity/geographic level – funding, capital, liquidity. 

Liabilities come out of the woodwork, and investors demand greater granularity, and big companies have trouble coping with these kinds of information requests.


Change in leadership in Greece & Italy – how does it alter the outcome?

In both cases, what we have is an interim government in a protracted period of re-formation not unlike what we see in Egypt, Libya, etc.  Ousting an existing regime is easy – coming back together has any number of risks.  In Western Europe, for the last 20 years there’s been a belief that political leaders could commit their populations to various things (sovereign debt, austerity, etc.)  The real message from Europe is that political leaders can make a commitment but it might be different tomorrow depending on the political will.  I don’t think the raters of sovereign debt considered willingness.  What’s the value of AAA (EFSF) if tomorrow the willingness to support it just evaporates?

Iceland – be careful what you ask for.  What we have in Italy today is far greater uncertainty. 


Near-term catalysts

What we’re seeing in Italy is more likely to result in a Euro dissolution.  Barrosso talking about “euro deviance” – members of EU who are not Euro users – there’s little to stop that kind of departure.   The expectation was that Greece would go first, but now it looks like Italy might go first, and Greece thereafter.  Bailouts are bailouts of creditors.  That recognition skews the debate from here.

Mechanism – countries lie, lie, lie, devalue.  If you look at currency flows, they’ve become unsustainable.  To slow the process, FX controls within the EU would have to develop – but that’s a momentary lapse before dissolution. 


US growth

Growth we’ve seen has been much more commodity price inflation and less actual growth.  There hasn’t really been growth since 2009.  High correlation between markets (denominated in Gold) and consumer confidence back to 2000.  Bright spot to the economy is at the high end.  Risk now (flowing back to banks) is a very asymmetric, barbelled economy.  Dependence on high end since 2009 has only grown in both real economy and in bank portfolios.  Just look at card – spending huge money on acquisition side. 


US Housing

Lobbies entrenched – housing finance policy changes?

PA: policymakers need to look less at homeownership and more at home occupancy.  Alternatives that encourage rent-to-own, rental solutions need to be developed.  We don’t want to own homes now even with record affordability – we want a roof over our head.  Can’t keep people in a mortgage even cutting the rate in half – they’re thinking like owners, not renters


Financial repression and burden-sharing in housing

2008 was a clear public policy decision to support existing mortgage industry infrastructure.  Relief valve became the balance sheet of Fannie and Freddie.  That’s an unsustainable sinkhole for losses.  You can’t have mortgage default rates rising concurrent with record-low credit card default rates. I expect a dramatic change in consumer default laws – the reallocation of funds within a failing consumer’s portfolio.  Student loans will also come into that equation.  Mounting nationalism will encourage policies that shift risk & losses out of the country. 


Underappreciated indicators

Consumer confidence – worry that right now we’re 11 years into a recession for the average American. 

Metrics of generosity/selfishness on the government level – much more protective of funds – it now appears to be a zero-sum game.  Look at growing hostility to military spending. Also pay attention to consumer credit extension (G.19)


Black swans

Vulnerability of FDIC – how do depositors react to FDIC fund backed by a Government with a falling credit rating? 



What we have is a “relatively short period of extreme turbulence” to get through – we can’t drag this one out a la 2008.  So what will the opportunities be on the other side of this?  The thunderstorm is bearing down, so put up the umbrellas, but also consider what’s on the other side. Prudently managing risk will be paramount in the next 9-12 months.   I’m much more hopeful about opportunities on “main street” than I have been in a long time- we’re going local. 



Joshua Steiner, CFA


Allison Kaptur

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