The North West Life Assurance Company of Canada - Page 10

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            3.    Schedule D of NAIC form 1A reflects deposits and withdrawals                         
                  of securities from a trust account at book value, whereas                            
                  NAIC form 1 reflects purchases and sales of bonds and stocks                         
                  at transaction prices;                                                               
            4.    NAIC form 1A does not include a reconciliation of capital                            
                  and surplus from the prior year to the current year, but                             
                  NAIC form 1 does include such a reconciliation.                                      
                  The Office of the Superintendent of Financial Institutions                           
            Canada (OSFI), Ottawa, Canada, also requires petitioner to file                            
            an annual statement (OSFI statement) reflecting its total                                  
            business in both Canada and the United States.  The reporting and                          
            accounting requirements for assets, liabilities, income, and                               
            expenses for purposes of the OSFI statement are different in a                             
            number of respects from those for NAIC forms.                                              
                  G.    Petitioner's Assets and Surplus                                                
                  Petitioner reports on its NAIC form 1A the following                                 
            percentage distribution of assets relating to its U.S.                                     
            operations:                                                                                
                                          1988        1989        1990                                 
            Bonds                         11.6%       15.0%       20.6%                                
            Mortgage loans                58.8        58.3        63.5                                 
            Real estate                  1.2         2.0       2.3                                    
            Cash                          15.5        12.7        6.1                                  
            Policy loans                  12.9        12.0        7.4                                  
            Stocks                        0.0       0.0           0.1                                  
                              Total    100.0     100.0     100.0                                       
                  Based on its OFSI statements, petitioner has the following                           
            percentage distribution of assets in connection with its                                   
            worldwide operations:                                                                      






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