Winn-Dixie Stores, Inc. and Subsidiaries - Page 11




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               Under the constant loan interest rate scenario, the                    
          projections assumed that the interest rate paid by petitioner on            
          policy loans remained constant at 11.06 percent3 for the life of            
          the pool.  Amounts to be credited to petitioner on borrowed cash            
          value were set at 40 basis points below the 11.06 percent being             
          charged to petitioner.4  Thus, the borrowed cash value would be             
          credited at 10.66 percent.  The remaining cash value was credited           
          at 4 percent.  The January 27, 1993, memorandum explains that "A            
          COLI Pool generally works best when the interest rate on policy             
          loans is highest."5  The projections under the constant loan                
          interest rate scenario were also based on the following                     
          assumptions:                                                                
               Corporate tax bracket                   38%                            
               Population (number of insured                                          
               employees)                              38,000                         
               Premium                                 $3,000 per life                
               Mortality assumption                    100% of 1983 GAM1              
               Fee                                     $8 per participant             
                                                       annually                       
                    1The mortality assumption "GAM" was not defined in the proposal.  
               Ultimately, petitioner and AIG agreed upon using the 1980 Commissioners
               Standard Ordinary Mortality Table B to estimate mortality.             


               3The 11.06-percent rate was based on Moody's Baa rate from             
          November 1992, which was 8.96 percent.  Coventry converted it to            
          an arrears rate and added 1 percent to reach 11.06 percent.                 
               4This is referred to as "loan spread".  The Jan. 27, 1993,             
          memorandum explains:  "An effective COLI Pool should have a small           
          'spread' between the interest rate charged on policy loans and              
          the amounts credited to borrowed cash values."                              
               5The rate in effect for the MSP policies was 8.41 percent.             





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Last modified: May 25, 2011