Retirement Plan And Other Post-Retirement Benefits | Retirement Plan and Other Post-Retirement Benefits The Company has a tax-qualified, noncontributory, defined-benefit retirement plan (Retirement Plan). The Retirement Plan covers certain non-collectively bargained employees hired before July 1, 2003 and certain collectively bargained employees hired before November 1, 2003. Certain non-collectively bargained employees hired after June 30, 2003 and certain collectively bargained employees hired after October 31, 2003 are eligible for a Retirement Savings Account benefit provided under the Company’s defined contribution Tax-Deferred Savings Plans. Costs associated with the Retirement Savings Account were $2.3 million , $1.9 million and $1.2 million for the years ended September 30, 2015, 2014 and 2013, respectively. Costs associated with the Company’s contributions to the Tax-Deferred Savings Plans, exclusive of the costs associated with the Retirement Savings Account, were $5.8 million , $5.2 million , and $4.4 million for the years ended September 30, 2015, 2014 and 2013, respectively. The Company provides health care and life insurance benefits (other post-retirement benefits) for a majority of its retired employees. The other post-retirement benefits cover certain non-collectively bargained employees hired before January 1, 2003 and certain collectively bargained employees hired before October 31, 2003. The Company’s policy is to fund the Retirement Plan with at least an amount necessary to satisfy the minimum funding requirements of applicable laws and regulations and not more than the maximum amount deductible for federal income tax purposes. The Company has established VEBA trusts for its other post-retirement benefits. Contributions to the VEBA trusts are tax deductible, subject to limitations contained in the Internal Revenue Code and regulations and are made to fund employees’ other post-retirement benefits, as well as benefits as they are paid to current retirees. In addition, the Company has established 401(h) accounts for its other post-retirement benefits. They are separate accounts within the Retirement Plan trust used to pay retiree medical benefits for the associated participants in the Retirement Plan. Although these accounts are in the Retirement Plan trust, for funding status purposes as shown below, the 401(h) accounts are included in Fair Value of Assets under Other Post-Retirement Benefits. Contributions are tax-deductible when made, subject to limitations contained in the Internal Revenue Code and regulations. The expected return on Retirement Plan assets, a component of net periodic benefit cost shown in the tables below, is applied to the market-related value of plan assets. The market-related value of plan assets is the market value as of the measurement date adjusted for variances between actual returns and expected returns (from previous years) that have not been reflected in net periodic benefit costs. The expected return on other post-retirement benefit assets (i.e. the VEBA trusts and 401(h) accounts), which is a component of net periodic benefit cost shown in the tables below, is applied to the fair value of assets as of the measurement date. Reconciliations of the Benefit Obligations, Plan Assets and Funded Status, as well as the components of Net Periodic Benefit Cost and the Weighted Average Assumptions of the Retirement Plan and other post-retirement benefits are shown in the tables below. The date used to measure the Benefit Obligations, Plan Assets and Funded Status is September 30 for fiscal years 2015, 2014 and 2013. Retirement Plan Other Post-Retirement Benefits Year Ended September 30 Year Ended September 30 2015 2014 2013 2015 2014 2013 (Thousands) Change in Benefit Obligation Benefit Obligation at Beginning of Period $ 999,499 $ 946,305 $ 1,070,744 $ 465,583 $ 460,634 $ 561,263 Service Cost 12,047 11,987 15,846 2,693 2,939 4,705 Interest Cost 41,217 43,574 36,498 19,285 21,308 19,212 Plan Participants’ Contributions — — — 2,242 2,265 2,141 Retiree Drug Subsidy Receipts — — — 1,338 1,419 1,526 Amendments(1) 7,752 — — — — — Actuarial (Gain) Loss 23,426 53,887 (121,631 ) (1,575 ) 1,087 (104,455 ) Benefits Paid (57,751 ) (56,254 ) (55,152 ) (24,579 ) (24,069 ) (23,758 ) Benefit Obligation at End of Period $ 1,026,190 $ 999,499 $ 946,305 $ 464,987 $ 465,583 $ 460,634 Change in Plan Assets Fair Value of Assets at Beginning of Period $ 869,791 $ 799,307 $ 701,676 $ 497,601 $ 472,392 $ 414,134 Actual Return on Plan Assets (13,370 ) 93,238 98,783 534 44,898 61,715 Employer Contributions 36,200 33,500 54,000 2,161 2,115 18,160 Plan Participants’ Contributions — — — 2,242 2,265 2,141 Benefits Paid (57,751 ) (56,254 ) (55,152 ) (24,579 ) (24,069 ) (23,758 ) Fair Value of Assets at End of Period $ 834,870 $ 869,791 $ 799,307 $ 477,959 $ 497,601 $ 472,392 Net Amount Recognized at End of Period (Funded Status) $ (191,320 ) $ (129,708 ) $ (146,998 ) $ 12,972 $ 32,018 $ 11,758 Amounts Recognized in the Balance Sheets Consist of: Non-Current Liabilities $ (191,320 ) $ (129,708 ) $ (146,998 ) $ (11,487 ) $ (4,494 ) $ (11,016 ) Non-Current Assets — — — 24,459 36,512 22,774 Net Amount Recognized at End of Period $ (191,320 ) $ (129,708 ) $ (146,998 ) $ 12,972 $ 32,018 $ 11,758 Accumulated Benefit Obligation $ 968,984 $ 940,068 $ 886,942 N/A N/A N/A Weighted Average Assumptions Used to Determine Benefit Obligation at September 30 Discount Rate 4.25 % 4.25 % 4.75 % 4.50 % 4.25 % 4.75 % Rate of Compensation Increase 4.75 % 4.75 % 4.75 % 4.75 % 4.75 % 4.75 % Retirement Plan Other Post-Retirement Benefits Year Ended September 30 Year Ended September 30 2015 2014 2013 2015 2014 2013 (Thousands) Components of Net Periodic Benefit Cost Service Cost $ 12,047 $ 11,987 $ 15,846 $ 2,693 $ 2,939 $ 4,705 Interest Cost 41,217 43,574 36,498 19,285 21,308 19,212 Expected Return on Plan Assets (59,615 ) (59,974 ) (57,346 ) (34,089 ) (37,424 ) (32,872 ) Amortization of Prior Service Cost (Credit) 183 210 238 (1,913 ) (2,138 ) (2,138 ) Amortization of Transition Amount — — — — — 8 Recognition of Actuarial Loss(2) 36,129 36,007 52,776 4,148 2,645 20,892 Net Amortization and Deferral for Regulatory Purposes 7,739 8,151 (10,406 ) 20,322 23,263 11,844 Net Periodic Benefit Cost $ 37,700 $ 39,955 $ 37,606 $ 10,446 $ 10,593 $ 21,651 Weighted Average Assumptions Used to Determine Net Periodic Benefit Cost at September 30 Discount Rate 4.25 % 4.75 % 3.50 % 4.25 % 4.75 % 3.50 % Expected Return on Plan Assets 7.50 % 8.00 % 8.00 % 7.00 % 8.00 % 8.00 % Rate of Compensation Increase 4.75 % 4.75 % 4.75 % 4.75 % 4.75 % 4.75 % (1) In fiscal 2015, the Company passed an amendment which updated the mortality table used in the Retirement Plan's definition of "actuarially equivalent" effective July 1, 2015. This increased the benefit obligation of the Retirement Plan. (2) Distribution Corporation’s New York jurisdiction calculates the amortization of the actuarial loss on a vintage year basis over 10 years , as mandated by the NYPSC. All the other subsidiaries of the Company utilize the corridor approach. The Net Periodic Benefit Cost in the table above includes the effects of regulation. The Company recovers pension and other post-retirement benefit costs in its Utility and Pipeline and Storage segments in accordance with the applicable regulatory commission authorizations. Certain of those commission authorizations established tracking mechanisms which allow the Company to record the difference between the amount of pension and other post-retirement benefit costs recoverable in rates and the amounts of such costs as determined under the existing authoritative guidance as either a regulatory asset or liability, as appropriate. Any activity under the tracking mechanisms (including the amortization of pension and other post-retirement regulatory assets and liabilities) is reflected in the Net Amortization and Deferral for Regulatory Purposes line item above. In addition to the Retirement Plan discussed above, the Company also has Non-Qualified benefit plans that cover a group of management employees designated by the Chief Executive Officer of the Company. These plans provide for defined benefit payments upon retirement of the management employee, or to the spouse upon death of the management employee. The net periodic benefit cost associated with these plans were $7.0 million , $7.5 million and $9.6 million in 2015, 2014 and 2013, respectively. The accumulated benefit obligations for the plans were $66.0 million , $65.7 million and $57.2 million at September 30, 2015, 2014 and 2013, respectively. The projected benefit obligations for the plans were $85.8 million , $85.5 million and $77.1 million at September 30, 2015, 2014 and 2013, respectively. At September 30, 2015, $4.5 million of the projected benefit obligation is recorded in Other Accruals and Current Liabilities and the remaining $81.3 million is recorded in Other Deferred Credits on the Consolidated Balance Sheets. At September 30, 2014, $6.6 million of the projected benefit obligation was recorded in Other Accruals and Current Liabilities and the remaining $78.9 million was recorded in Other Deferred Credits on the Consolidated Balance Sheets. At September 30, 2013, the projected benefit obligations are recorded in Other Deferred Credits on the Consolidated Balance Sheets. The weighted average discount rates for these plans were 3.50% , 3.50% and 3.75% as of September 30, 2015, 2014 and 2013, respectively and the weighted average rate of compensation increase for these plans were 7.75% , 7.50% and 7.75% as of September 30, 2015, 2014 and 2013, respectively. The cumulative amounts recognized in accumulated other comprehensive income (loss), regulatory assets, and regulatory liabilities through fiscal 2015, the changes in such amounts during 2015, as well as the amounts expected to be recognized in net periodic benefit cost in fiscal 2016 are presented in the table below: Retirement Plan Other Post-Retirement Benefits Non-Qualified Benefit Plans (Thousands) Amounts Recognized in Accumulated Other Comprehensive Income (Loss), Regulatory Assets and Regulatory Liabilities(1) Net Actuarial Loss $ (287,180 ) $ (59,914 ) $ (24,929 ) Prior Service (Cost) Credit (8,425 ) 5,027 — Net Amount Recognized $ (295,605 ) $ (54,887 ) $ (24,929 ) Changes to Accumulated Other Comprehensive Income (Loss), Regulatory Assets and Regulatory Liabilities Recognized During Fiscal 2015(1) Increase in Actuarial Loss, excluding amortization(2) $ (96,412 ) $ (31,980 ) $ (4,321 ) Change due to Amortization of Actuarial Loss 36,129 4,148 2,925 Prior Service (Cost) Credit (7,569 ) (1,913 ) — Net Change $ (67,852 ) $ (29,745 ) $ (1,396 ) Amounts Expected to be Recognized in Net Periodic Benefit Cost in the Next Fiscal Year(1) Net Actuarial Loss $ (32,248 ) $ (5,530 ) $ (3,295 ) Prior Service (Cost) Credit (1,234 ) 912 — Net Amount Expected to be Recognized $ (33,482 ) $ (4,618 ) $ (3,295 ) (1) Amounts presented are shown before recognizing deferred taxes. (2) Amounts presented include the impact of actuarial gains/losses related to return on assets, as well as the Actuarial (Gain) Loss amounts presented in the Change in Benefit Obligation. In order to adjust the funded status of its pension (tax-qualified and non-qualified) and other post-retirement benefit plans at September 30, 2015, the Company recorded a $76.7 million increase to Other Regulatory Assets in the Company’s Utility and Pipeline and Storage segments and a $22.3 million (pre-tax) decrease to Accumulated Other Comprehensive Income. The effect of the mortality assumption change for the Retirement Plan in 2015 was to increase the projected benefit obligation of the Retirement Plan by $24.2 million . In 2015, other actuarial experience decreased the projected benefit obligation for the Retirement Plan by $0.8 million . The effect of the discount rate change for the Retirement Plan in 2014 was to increase the projected benefit obligation of the Retirement Plan by $53.7 million . The effect of the discount rate change for the Retirement Plan in 2013 was to decrease the projected benefit obligation of the Retirement Plan by $147.9 million . The Company made cash contributions totaling $36.2 million to the Retirement Plan during the year ended September 30, 2015. The Company expects that the annual contribution to the Retirement Plan in 2016 will be in the range of $5.0 million to $10.0 million . The following Retirement Plan benefit payments, which reflect expected future service, are expected to be paid by the Retirement Plan during the next five years and the five years thereafter: $61.1 million in 2016; $62.1 million in 2017; $63.0 million in 2018; $63.7 million in 2019; $64.4 million in 2020; and $332.1 million in the five years thereafter. The effect of the discount rate change in 2015 was to decrease the other post-retirement benefit obligation by $14.3 million . Other actuarial experience increased the other post-retirement benefit obligation in 2015 by $12.8 million primarily attributable to the change in mortality assumption. The effect of the discount rate change in 2014 was to increase the other post-retirement benefit obligation by $26.4 million . Other actuarial experience decreased the other post-retirement benefit obligation in 2014 by $25.3 million primarily attributable to a revision in assumed per-capita claims cost, premiums and participant contributions based on actual experience. The effect of the discount rate change in 2013 was to decrease the other post-retirement benefit obligation by $75.9 million . Other actuarial experience decreased the other post-retirement benefit obligation in 2013 by $28.6 million as the increase in obligation attributable to the change in mortality assumption was more than offset by the decrease in obligation attributable to a revision in assumed per-capita claims cost, premiums and participant contributions based on actual experience. The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 provides for a prescription drug benefit under Medicare (Medicare Part D), as well as a federal subsidy to sponsors of retiree health care benefit plans that provide a benefit that is at least actuarially equivalent to Medicare Part D. The estimated gross other post-retirement benefit payments and gross amount of Medicare Part D prescription drug subsidy receipts are as follows (dollars in thousands): Benefit Payments Subsidy Receipts 2016 $ 25,728 $ (1,786 ) 2017 $ 26,942 $ (1,935 ) 2018 $ 28,059 $ (2,094 ) 2019 $ 29,038 $ (2,259 ) 2020 $ 30,079 $ (2,405 ) 2021 through 2025 $ 161,958 $ (14,197 ) Assumed health care cost trend rates as of September 30 were: 2015 2014 2013 Rate of Medical Cost Increase for Pre Age 65 Participants 6.93 % (1) 7.10 % (1) 7.28 % (1) Rate of Medical Cost Increase for Post Age 65 Participants 6.68 % (1) 6.73 % (1) 6.78 % (1) Annual Rate of Increase in the Per Capita Cost of Covered Prescription Drug Benefits 7.17 % (1) 7.47 % (1) 7.78 % (1) Annual Rate of Increase in the Per Capita Medicare Part B Reimbursement 6.68 % (1) 6.73 % (1) 6.78 % (1) Annual Rate of Increase in the Per Capita Medicare Part D Subsidy 6.65 % (1) 6.79 % (1) 7.03 % (1) (1) It was assumed that this rate would gradually decline to 4.5% by 2028. The health care cost trend rate assumptions used to calculate the per capita cost of covered medical care benefits have a significant effect on the amounts reported. If the health care cost trend rates were increased by 1% in each year, the other post-retirement benefit obligation as of October 1, 2015 would increase by $53.9 million . This 1% change would also have increased the aggregate of the service and interest cost components of net periodic post-retirement benefit cost for 2015 by $2.9 million . If the health care cost trend rates were decreased by 1% in each year, the other post-retirement benefit obligation as of October 1, 2015 would decrease by $45.2 million . This 1% change would also have decreased the aggregate of the service and interest cost components of net periodic post-retirement benefit cost for 2015 by $2.4 million . The Company made cash contributions totaling $2.0 million to its VEBA trusts and 401(h) accounts during the year ended September 30, 2015. In addition, the Company made direct payments of $0.2 million to retirees not covered by the VEBA trusts and 401(h) accounts during the year ended September 30, 2015. The Company expects that the annual contribution to its VEBA trusts and 401(h) accounts in 2016 will be in the range of $2.0 million to $5.0 million . Investment Valuation The Retirement Plan assets and other post-retirement benefit assets are valued under the current fair value framework. See Note F — Fair Value Measurements for further discussion regarding the definition and levels of fair value hierarchy established by the authoritative guidance. The inputs or methodologies used for valuing securities are not necessarily an indication of the risk associated with investing in those securities. Below is a listing of the major categories of plan assets held as of September 30, 2015 and 2014, as well as the associated level within the fair value hierarchy in which the fair value measurements in their entirety fall, based on the lowest level input that is significant to the fair value measurement in its entirety (dollars in thousands): Total Fair Value Amounts at September 30, 2015 Level 1 Level 2 Level 3 Retirement Plan Investments Domestic Equities(1) $ 229,811 $ 170,166 $ 59,645 $ — International Equities(2) 96,478 — 96,478 — Global Equities(3) 112,802 — 112,802 — Domestic Fixed Income(4) 303,508 1,539 301,969 — International Fixed Income(5) 883 883 — — Global Fixed Income(6) 86,773 — 86,773 — Hedge Fund Investments 26,490 — — 26,490 Real Estate 4,724 — — 4,724 Cash and Cash Equivalents 27,723 — 27,723 — Total Retirement Plan Investments 889,192 172,588 685,390 31,214 401(h) Investments (53,686 ) (10,420 ) (41,381 ) (1,885 ) Total Retirement Plan Investments (excluding 401(h) Investments) $ 835,506 $ 162,168 $ 644,009 $ 29,329 Miscellaneous Accruals, Interest Receivables, and Non-Interest Cash (636 ) Total Retirement Plan Assets $ 834,870 Total Fair Value Level 1 Level 2 Level 3 Retirement Plan Investments Domestic Equities(1) $ 268,649 $ 171,979 $ 96,670 $ — International Equities(2) 80,957 1,969 78,988 — Global Equities(3) 104,238 — 104,238 — Domestic Fixed Income(4) 299,494 63,187 236,307 — International Fixed Income(5) 1,240 508 732 — Global Fixed Income(6) 93,704 — 93,704 — Hedge Fund Investments 45,213 — — 45,213 Real Estate 3,792 — — 3,792 Cash and Cash Equivalents 33,544 — 33,544 — Total Retirement Plan Investments 930,831 237,643 644,183 49,005 401(h) Investments (54,921 ) (14,105 ) (37,907 ) (2,909 ) Total Retirement Plan Investments (excluding 401(h) Investments) $ 875,910 $ 223,538 $ 606,276 $ 46,096 Miscellaneous Accruals, Interest Receivables, and Non-Interest Cash (6,119 ) Total Retirement Plan Assets $ 869,791 (1) Domestic Equities include mostly collective trust funds, common stock, and exchange traded funds. (2) International Equities include mostly collective trust funds and common stock. (3) Global Equities are comprised of collective trust funds. (4) Domestic Fixed Income securities include mostly collective trust funds, corporate/government bonds and mortgages, and exchange traded funds. (5) International Fixed Income securities include mostly collective trust funds and exchange traded funds. (6) Global Fixed Income securities are comprised of a collective trust fund. Total Fair Value Level 1 Level 2 Level 3 Other Post-Retirement Benefit Assets held in VEBA Trusts Collective Trust Funds — Domestic Equities $ 128,336 $ — $ 128,336 $ — Collective Trust Funds — International Equities 48,857 — 48,857 — Exchange Traded Funds — Fixed Income 233,471 233,471 — — Cash Held in Collective Trust Funds 13,119 — 13,119 — Total VEBA Trust Investments 423,783 233,471 190,312 — 401(h) Investments 53,686 10,420 41,381 1,885 Total Investments (including 401(h) Investments) $ 477,469 $ 243,891 $ 231,693 $ 1,885 Miscellaneous Accruals (Including Current and Deferred Taxes, Claims Incurred But Not Reported, Administrative) 490 Total Other Post-Retirement Benefit Assets $ 477,959 Total Fair Value Level 1 Level 2 Level 3 Other Post-Retirement Benefit Assets held in VEBA Trusts Collective Trust Funds — Domestic Equities $ 148,219 $ — $ 148,219 $ — Collective Trust Funds — International Equities 54,881 — 54,881 — Exchange Traded Funds — Fixed Income 236,513 236,513 — — Cash Held in Collective Trust Funds 6,412 — 6,412 — Total VEBA Trust Investments 446,025 236,513 209,512 — 401(h) Investments 54,921 14,105 37,907 2,909 Total Investments (including 401(h) Investments) $ 500,946 $ 250,618 $ 247,419 $ 2,909 Miscellaneous Accruals (Including Current and Deferred Taxes, Claims Incurred But Not Reported, Administrative) (3,345 ) Total Other Post-Retirement Benefit Assets $ 497,601 The fair values disclosed in the above tables may not be indicative of net realizable value or reflective of future fair values. Furthermore, although the Company believes its valuation methods are appropriate and consistent with other market participants, the use of different methodologies or assumptions to determine the fair value of certain financial instruments could result in a different fair value measurement at the reporting date. The following tables provide a reconciliation of the beginning and ending balances of the Retirement Plan and other post-retirement benefit assets measured at fair value on a recurring basis where the determination of fair value includes significant unobservable inputs (Level 3). Note: For the years ended September 30, 2015 and September 30, 2014, there were no transfers from Level 1 to Level 2. In addition, as shown in the following tables, there were no transfers in or out of Level 3. Retirement Plan Level 3 Assets (Thousands) Hedge Funds Real Estate Excluding 401(h) Investments Total Balance at September 30, 2013 $ 42,027 $ 2,723 $ (2,606 ) $ 42,144 Realized Gains/(Losses) — 62 (4 ) 58 Unrealized Gains/(Losses) 3,186 (10 ) (239 ) 2,937 Purchases — 1,111 (65 ) 1,046 Sales — (94 ) 5 (89 ) Balance at September 30, 2014 45,213 3,792 (2,909 ) 46,096 Realized Gains/(Losses) 2,284 — (135 ) 2,149 Unrealized Gains/(Losses) 317 871 (103 ) 1,085 Purchases — 82 (5 ) 77 Sales (21,324 ) (21 ) 1,267 (20,078 ) Balance at September 30, 2015 $ 26,490 $ 4,724 $ (1,885 ) $ 29,329 Other Post-Retirement Benefit Level 3 Assets (Thousands) VEBA Trust Investments Including 401(h) Investments Other Post-Retirement Benefit Investments Real Estate Balance at September 30, 2013 $ 55 $ 2,606 $ 2,661 Realized Gains/(Losses) (40 ) 4 (36 ) Unrealized Gains/(Losses) — 239 239 Purchases — 65 65 Sales (15 ) (5 ) (20 ) Balance at September 30, 2014 — 2,909 2,909 Realized Gains/(Losses) — 135 135 Unrealized Gains/(Losses) — 103 103 Purchases — 5 5 Sales — (1,267 ) (1,267 ) Balance at September 30, 2015 $ — $ 1,885 $ 1,885 The Company’s assumption regarding the expected long-term rate of return on plan assets is 7.25% (Retirement Plan) and 6.75% (other post-retirement benefits), effective for fiscal 2016. The return assumption reflects the anticipated long-term rate of return on the plan’s current and future assets. The Company utilizes projected capital market conditions and the plan’s target asset class and investment manager allocations to set the assumption regarding the expected return on plan assets. The long-term investment objective of the Retirement Plan trust, the VEBA trusts and the 401(h) accounts is to achieve the target total return in accordance with the Company’s risk tolerance. Assets are diversified utilizing a mix of equities, fixed income and other securities (including real estate). The target allocation for the Retirement Plan and the VEBA trusts (including 401(h) accounts) is 40 - 60% equity securities, 40 - 60% fixed income securities and 0 - 15% other. Risk tolerance is established through consideration of plan liabilities, plan funded status and corporate financial condition. The assets of the Retirement Plan trusts, VEBA trusts and the 401(h) accounts have no significant concentrations of risk in any one country (other than the United States), industry or entity. Investment managers are retained to manage separate pools of assets. Comparative market and peer group performance of individual managers and the total fund are monitored on a regular basis, and reviewed by the Company’s Retirement Committee on at least a quarterly basis. The discount rate used to present value the future benefit payment obligations of the Retirement Plan is 4.25% at September 30, 2015. The discount rate used to present value the future benefit payment obligations of the Company’s other post-retirement benefits is 4.50% as of September 30, 2015. The discount rate used to present value the future benefit payment obligations of the Non-Qualified benefit plans is 3.50% as of September 30, 2015. The Company utilizes the Mercer Yield Curve Above Mean Model to determine the discount rate. The yield curve is a spot rate yield curve that provides a zero-coupon interest rate for each year into the future. Each year’s anticipated benefit payments are discounted at the associated spot interest rate back to the measurement date. The discount rate is then determined based on the spot interest rate that results in the same present value when applied to the same anticipated benefit payments. In determining the spot rates, the model will exclude coupon interest rates that are in the lower 50 th percentile based on the assumption that the Company would not utilize more expensive (i.e. lower yield) instruments to settle its liabilities. |