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United States Securities and Exchange Commission
Washington, D.C. 20549
FORM 10-Q
[X] QUARTERLY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES
EXCHANGE ACT OF 1934
For the quarterly period ended June 30, 2003
OR
[_] TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES
EXCHANGE ACT OF 1934
For the transition period from __________ to __________
Commission File Registrant; State of Incorporation; IRS Employer
Number Address and Telephone Number Identification No.
-------------------- ---------------------------------------- ---------------------
333-47938 Consumers Funding LLC 38-3575109
A Delaware limited liability company
One Energy Plaza
Jackson, Michigan 49201
(517) 788-0250
Securities registered pursuant to Section 12 (b) of the Act: None.
Securities registered pursuant to Section 12 (g) of the Act: None.
Indicate by check mark whether the Registrant (1) has filed all reports
required to be filed by Section 13 or 15(d) of the Securities Exchange Act
of 1934 during the preceding 12 months (or for such shorter period that
the Registrant was required to file such reports), and (2) has been
subject to such filing requirements for the past 90 days. YES [X] NO [ ]
Indicate by check mark whether the registrant is an accelerated filer (as
defined in rule 12b-2 of the Exchange Act). YES [ ] NO [X]
Consumers Funding LLC meets the conditions set forth in General
Instruction H(1)(a) and (b) of the Form 10-Q and is, therefore filing this
Form 10-Q with the reduced disclosure format. In accordance with
Instruction H, Part I, Item 2 has been reduced and Parts III, Items 2, 3
and 4 have been omitted.
The aggregate market value of the voting and non-voting common equity held
by non-affiliates of the Registrant: None.
CONSUMERS FUNDING, LLC
FORM 10-Q QUARTERLY REPORT TO
THE SECURITIES AND EXCHANGE COMMISSION
FOR THE QUARTER ENDED JUNE 30, 2003
TABLE OF CONTENTS
Page
PART I: Financial Information
1. Management's Narrative Analysis of Results of Operations................3
2. Financial Statements and Supplementary Data
Statements of Income................................................5
Balance Sheets......................................................6
Statements of Cash Flows............................................7
Statements of Member's Equity.......................................8
Notes to Financial Statements.......................................9
PART II: Other Information
3. Item 1. Legal Proceedings ..............................................13
Item 5. Other Information ..............................................13
Item 6. Exhibits and Reports on Form 8-K................................13
Signatures..............................................................14
Exhibit Index...........................................................15
2
CONSUMERS FUNDING LLC
MANAGEMENT'S NARRATIVE ANALYSIS
OF RESULTS OF OPERATION
This Management's Narrative Analysis (MNA) of the results of operation of
Consumers Funding LLC (Consumers Funding) is an abbreviated format pursuant to
Instruction H of Form 10-Q. The MNA refers to Consumers Funding's Notes to
Financial Statements and should be read in conjunction with such Financial
Statements and Notes.
This Form 10-Q and other written and oral statements from Consumers Funding may
contain forward-looking statements as defined by the Private Securities
Litigation Reform Act of 1995. These forward-looking statements are subject to
various factors that could cause Consumers Funding's actual results to differ
materially from the results anticipated in such statements. Consumers Funding
has no obligation to update or revise forward-looking statements regardless of
whether new information, future events or any other factors affect the
information contained in such statements. Consumers Funding does, however,
discuss certain risk factors, uncertainties and assumptions in this MNA, and in
various public filings it periodically makes with the Securities and Exchange
Commission. Consumers Funding designed this discussion of potential risks and
uncertainties, which is by no means comprehensive, to highlight important
factors that may impact Consumers Funding's outlook.
Consumers Funding, a Delaware limited liability company, whose sole member is
Consumers Energy Company (Consumers), was formed by Consumers on October 11,
2000. Consumers is an electric and gas utility and is a wholly owned subsidiary
of CMS Energy Corporation. Consumers Funding was organized for the sole purpose
of purchasing and owning securitization property (see below), issuing
securitization bonds, pledging its interest in securitization property and other
collateral to the trustee to collateralize the securitization bonds, and
performing activities that are necessary, suitable or convenient to accomplish
these purposes.
On November 8, 2001, Consumers Funding issued $468.6 million of securitization
bonds. Consumers Funding used the proceeds from the securitization bond issuance
to purchase securitization property from Consumers. As discussed in Note 1 to
the Financial Statements, securitization property represents the irrevocable
right of Consumers to collect a nonbypassable securitization charge
(Securitization Charge) from customers in accordance with a financing order
issued by the Michigan Public Service Commission (MPSC). In 2003, the
securitization property, which is classified as a securitization receivable,
along with earnings on cash deposited with the trustee, resulted in Consumers
Funding recording $5.6 million and $5.8 million of interest income for the three
months ended June 30, 2003 and 2002, respectively. Interest income for the six
months ended June 30, 2003 and 2002 totaled $11.2 million and $11.5 million,
respectively. Interest expense associated with the securitization bonds totaled
$5.5 million and $5.8 million for the three months ended June 30, 2003 and 2002,
respectively. Interest expense for the six months ended June 30, 2003 and 2002
totaled $11.2 million and $11.5 million, respectively.
Consumers, as servicer, began billing a Securitization Charge to electric
customers beginning with its December 2001 billing cycle, totaling $.001427 per
kilowatt-hour, per customer, per billing cycle. A request for adjustment was
submitted on October 15, 2002 and approval by the MPSC was granted on November
7, 2002. The new surcharge became effective with the December 2002 billing cycle
and is $0.001328 per kilowatt-hour, per customer, per billing cycle. In the
servicing agreement between Consumers Funding and Consumers, Consumers is
required to remit its Securitization Charge collections to the trustee each
business day. Under the servicing agreement, Consumers is required to request
periodic Securitization Charge adjustments from the MPSC. The request for an
adjustment must be submitted at least 45 days before the adjustment may take
place. Adjustments will be made annually, and then quarterly beginning
approximately one year before the expected final payment date of the last
maturing class of securitization bonds. Adjustments to the Securitization Charge
are based, among other things, on actual Securitization Charge
3
revenue collections and updated assumptions by Consumers as to projected future
deliveries of electricity to customers.
For the three months ended June 30, 2003, Consumers Funding collected $5.9
million in surcharge revenues, a decrease of approximately $300,000 compared to
2002. Included in the $5.9 million is $5.6 million of interest income and
approximately $300,000 of other operating income. The decrease in surcharge
revenues for the three-month period is primarily the result of the reduced
Securitization Charge mentioned above.
For the six months ended June 30, 2003, Consumers Funding collected $11.8
million in surcharge revenues, a decrease of approximately $500,000 compared to
2002. Included in the $11.8 million is $11.2 million of interest income and
approximately $600,000 of other operating income. The decrease in surcharge
revenues for the six-month period is primarily the result of the reduced
Securitization Charge mentioned above.
For the three months ended June 30, 2003, Consumers Funding incurred $5.9
million of operating expenses, a decrease of approximately $300,000 compared to
2002. Included in the $5.9 million is $5.6 million of interest expense and
approximately $300,000 of servicing, administration and other expenses. The
decrease in operating expenses for the three-month period is primarily the
result of reduced debt levels.
For the six months ended June 30, 2003, Consumers Funding incurred $11.8 million
of operating expenses, a decrease of $500,000 compared to 2002. Included in the
$11.8 million is $11.2 million of interest expense and approximately $600,000 of
servicing, administration and other expenses. The decrease in operating expenses
for the six-month period is primarily the result of reduced debt levels.
4
CONSUMERS FUNDING LLC
STATEMENTS OF INCOME
(UNAUDITED)
THREE MONTHS ENDED SIX MONTHS ENDED
JUNE 30 2003 2002 2003 2002
- ------------------------------------------------------------------------------------------------------------------------
In Thousands
OPERATING REVENUES
Interest Income -- Consumers Energy $ 5,547 $5,665 $ 11,166 $11,395
Interest Income - 112 - 137
Other Operating Revenue -- Consumers Energy 295 412 594 747
Other Operating Revenue 19 5 35 5
----------------------------------------------------------
Total Operating Revenues 5,861 6,194 11,795 12,284
- ------------------------------------------------------------------------------------------------------------------------
OPERATING EXPENSES
Interest Expense 5,547 5,754 11,166 11,509
Service Fee -- Consumers Energy 275 388 554 703
Administration Fee -- Consumers Energy 20 24 40 44
Other 19 16 35 16
----------------------------------------------------------
Total Operating Expenses 5,861 6,182 11,795 12,272
- ------------------------------------------------------------------------------------------------------------------------
NET INCOME $ - $12 $ - $12
- ------------------------------------------------------------------------------------------------------------------------
The accompanying notes are an integral part of these statements.
5
CONSUMERS FUNDING LLC
BALANCE SHEETS
ASSETS
JUNE 30 DEC. 31 JUNE 30
2003 2002 2002
(UNAUDITED) (UNAUDITED)
- ----------------------------------------------------------------------------------------------------
In Thousands
CURRENT ASSETS
Restricted Cash $ 16,762 $ 17,411 $ 27,859
Securitization Receivable -- Consumers Energy 27,475 26,402 19,290
---------------------------------------------
Total Current Assets 44,237 43,813 47,149
NON-CURRENT ASSETS
Securitization Receivable -- Consumers Energy 402,396 416,245 439,587
---------------------------------------------
Total Non-current Assets 402,396 416,245 439,587
- ----------------------------------------------------------------------------------------------------
TOTAL ASSETS $ 446,633 $ 460,058 $ 486,736
====================================================================================================
LIABILITIES AND MEMBER'S EQUITY
CURRENT LIABILITIES
Securitization Bonds Payable $ 27,399 $ 26,905 29,005
Accounts Payable -- Consumers Energy 309 314 887
Accounts Payable -- Other 34 2 4
Interest Payable 4,360 4,457 14,898
---------------------------------------------
Total Current Liabilities 32,102 31,678 44,794
- ----------------------------------------------------------------------------------------------------
NON-CURRENT LIABILITIES
Securitization Bonds Payable 412,188 426,037 439,587
---------------------------------------------
Total Non-current Liabilities 412,188 426,037 439,587
- ----------------------------------------------------------------------------------------------------
MEMBER'S EQUITY
Total Member's Equity 2,343 2,343 2,355
---------------------------------------------
TOTAL LIABILITIES AND MEMBER'S EQUITY $ 446,633 $ 460,058 $ 486,736
====================================================================================================
The accompanying notes are an integral part of these Balance Sheets.
6
CONSUMERS FUNDING LLC
STATEMENTS OF CASH FLOWS
(UNAUDITED)
SIX MONTHS ENDED
JUNE 30 2003 2002
- -----------------------------------------------------------------------------------------------
In Thousands
CASH FLOWS FROM OPERATING ACTIVITIES
Net income $ - $ 12
Changes in Current Assets and Liabilities:
Interest Receivable -- Consumers Energy - 2,257
Interest Payable (97) 11,509
Accounts Payable -- Consumers Energy (5) 758
Accounts Payable -- Other 32 4
----------------------------
NET CASH PROVIDED BY/(USED IN) OPERATING ACTIVITIES (70) 14,540
- -------------------------------------------------------------------------------------------------
CASH FLOWS FROM INVESTING ACTIVITIES
Reduction of Securitization Receivable 12,776 9,715
----------------------------
NET CASH PROVIDED BY INVESTING ACTIVITIES 12,776 9,715
- -----------------------------------------------------------------------------------------------
CASH FLOWS FROM FINANCING ACTIVITIES
Securitization Bonds Payable (13,355) -
----------------------------
NET CASH USED IN FINANCING ACTIVITIES (13,355) -
- -----------------------------------------------------------------------------------------------
NET INCREASE/(DECREASE) IN CASH AND CASH EQUIVALENTS (649) 24,255
CASH AND CASH EQUIVALENTS, BEGINNING OF PERIOD 17,411 3,604
----------------------------
CASH AND CASH EQUIVALENTS, END OF PERIOD $ 16,762 $ 27,859
===============================================================================================
The accompanying notes are an integral part of these statements.
7
CONSUMERS FUNDING LLC
STATEMENTS OF MEMBER'S EQUITY
(UNAUDITED)
THREE MONTHS ENDED SIX MONTHS ENDED
JUNE 30 2003 2002 2003 2002
- ----------------------------------------------------------------------------------------------------------------
In Thousands
BALANCE AT BEGINNING OF PERIOD $ 2,343 $ 2,343 $ 2,343 $ 2,343
Add:
Net Income - 12 - 12
------------------------------------------------------
BALANCE AT END OF PERIOD $ 2,343 $ 2,355 $ 2,343 $ 2,355
======================================================
The accompanying notes are an integral part of these statements.
8
CONSUMERS FUNDING LLC
NOTES TO FINANCIAL STATEMENTS
1. ORGANIZATION AND NATURE OF OPERATIONS
Consumers Funding, a Delaware limited liability company, whose sole member is
Consumers, was formed by Consumers on October 11, 2000. On January 22, 2001,
Consumers completed a $1,000 equity contribution to Consumers Funding. Consumers
is an electric and gas utility and is a wholly owned subsidiary of CMS Energy
Corporation. Consumers Funding was organized for the sole purpose of purchasing
and owning securitization property (see below), issuing securitization bonds,
pledging its interest in securitization property and other collateral to the
trustee to collateralize the securitization bonds, and performing activities
that are necessary, suitable or convenient to accomplish these purposes.
Securitization property represents the irrevocable right of Consumers, or its
successor or assignee, to collect a nonbypassable Securitization Charge from
customers in accordance with an October 24, 2000 MPSC Financing Order (MPSC
Financing Order). As modified by rehearing on January 4, 2001, the MPSC
Financing Order authorizes the Securitization Charge to be sufficient to recover
$468.6 million aggregate principal amount of securitization bonds, plus an
amount sufficient to provide for any credit enhancement, to fund any reserves
and to pay interest, redemption premiums, if any, servicing fees and other
expenses relating to the securitization bonds. For financial reporting purposes,
the purchase of the securitization property has been accounted for as a
financing arrangement by Consumers Funding in the amount of $468.6 million.
Accordingly, Consumers Funding has classified the purchase of securitization
property as a securitization receivable from Consumers in the financial
statements.
Consumers Funding's organizational documents require it to operate in a manner
so that it would not be consolidated into the bankruptcy estate of Consumers in
the event Consumers becomes subject to a bankruptcy proceeding. Consumers and
Consumers Funding have agreed that in the event of Consumers' bankruptcy, the
parties will treat the transfer of the securitization property to Consumers
Funding as a true sale. The securitization bonds are treated as debt obligations
of Consumers Funding. For financial reporting, Federal income tax and State of
Michigan income and franchise tax purposes, the transfer of securitization
property to Consumers Funding is treated as part of a financing arrangement and
not as a sale. Furthermore, the results of operations of Consumers Funding are
consolidated with Consumers for financial and income tax reporting purposes.
Consumers Funding is legally separate from Consumers. The assets and income of
Consumers Funding, including without limitation, the securitization property,
are not available to creditors of Consumers or CMS Energy Corporation.
On November 8, 2001, Consumers Funding issued $468.6 million of securitization
bonds, Series 2001-1, in six different classes. Consumers Funding used the
proceeds to fund the purchase of securitization property from Consumers. The
principal amount of the securitization bonds, interest, fees and required
overcollateralization for the securitization bonds, will be recovered through
Securitization Charges collected from electric retail customers taking delivery
of electricity from Consumers or its successor based on MPSC approved rate
schedules and as permitted by contracts between Consumers and certain specific
customers.
Consumers, as servicer, collects Securitization Charges from its customers and
deposits collections daily into the General Subaccount held by the trustee (The
Bank of New York). The trustee is required to use these funds to make principal
and interest payments on the securitization bonds and to pay certain fees and
expenses of Consumers Funding.
Consumers Funding has no employees. Under the servicing agreement with
Consumers, Consumers is required to manage and administer the securitization
property and to collect Securitization Charges on Consumers Funding's behalf.
Consumers receives a monthly servicing fee of one twelfth times 0.25 percent
9
of the principal amount of securitization bonds outstanding as of the payment
date. The servicing agreement also requires Consumers to file annual
Securitization Charge adjustment requests with the MPSC. These Securitization
Charge adjustment requests are based on actual Securitization Charge revenue
collections and Consumers' updated assumptions as to projected future deliveries
of electricity to customers, expected delinquencies and write-offs, future
payments and expenses relating to securitization property and the securitization
bonds, any deficiency in the Capital or Overcollateralization Subaccounts and
any amounts on deposit in the Reserve Subaccount.
2. SIGNIFICANT ACCOUNTING POLICIES
USE OF ESTIMATES
The preparation of financial statements in conformity with accounting principles
generally accepted in the United States requires management to make estimates
and assumptions. These estimates and assumptions affect the reported amount of
revenues, expenses, assets, and liabilities and disclosure of contingencies.
Actual results could differ from these estimates.
INCOME TAXES
Consumers Funding has elected not to be taxed as a corporation for Federal
income tax purposes. Consumers Funding is treated as a division of Consumers,
and accordingly, will not be treated as a separate taxable entity.
Consumers and its subsidiaries file a consolidated federal income tax return
with CMS Energy. Income taxes are generally allocated based on each company's
separate taxable income. As of June 30, 2003 and 2002, Consumers Funding had no
tax related payables or receivables.
RESTRICTED CASH
The trustee has established the following subaccounts for the securitization
bonds.
GENERAL SUBACCOUNT: The General Subaccount is comprised of Securitization Charge
collections and interest earned from short-term investments. These amounts
accumulate until the trustee pays principal, interest, service and
administration fees and other expenses. At June 30, 2003, and June 30, 2002, the
General Subaccount totaled $11.3 million and $25.5 million, respectively. These
funds are used by the trustee for the scheduled payments of principal and
interest to bondholders and to pay expenses of Consumers Funding.
RESERVE SUBACCOUNT: The Reserve Subaccount includes any Securitization Charge
collections in excess of the amounts required in the General,
Overcollateralization and Capital Subaccounts. The trustee will draw funds from
this subaccount if the General Subaccount is insufficient to make scheduled
payments. At June 30, 2003, the Reserve Subaccount totaled approximately $2.9
million. There was no balance in the Reserve Subaccount at June 30, 2002.
OVERCOLLATERALIZATION SUBACCOUNT: On each payment date, the trustee will deposit
in the Overcollateralization Subaccount a predetermined, specified amount so
that the account balance ultimately reaches the required amount of $2.3 million,
which represents 0.5 percent of the initial outstanding principal balance of the
securitization bonds. If amounts available in the General Subaccount and the
Reserve Subaccount are not sufficient on any payment date to make scheduled
payments to the securitization bondholders and to pay the required expenses,
fees and charges, the trustee will draw on the amounts in the
Overcollateralization Subaccount to make those payments. At June 30, 2003, the
Overcollateralization Subaccount totaled approximately $253,000. There was no
balance in the Overcollateralization Subaccount at June 30, 2002.
CAPITAL SUBACCOUNT: The Capital Subaccount was established on November 8, 2001.
Consumers deposited $2.3 million into the Capital Subaccount, an amount equal to
0.5 percent of the initial principal balance of the securitization bonds. If
amounts available in the General Subaccount, the Reserve Subaccount and the
Overcollateralization Subaccount are not sufficient on any payment date to make
scheduled payments of principal and interest to the securitization bondholders
and to pay the expenses, fees and charges of Consumers
10
Funding, the trustee will draw on amounts in the Capital Subaccount to make
those payments. At June 30, 2003, and June 30, 2002, the Capital Subaccount
contained a balance of $2.3 million and $2.4 million, respectively.
3. LONG-TERM DEBT
On November 8, 2001, Consumers Funding issued $468.6 million of securitization
bonds, in six classes at interest rates ranging from 2.59 percent to 5.76
percent. Consumers Funding used the proceeds from the securitization bonds to
purchase securitization property from Consumers. As scheduled, as of June 30,
2003, Consumers Funding has retired $29 million of the class A-1 and A-2
securitization bonds. As scheduled, on July 21, 2003, approximately $6.0 million
of securitization bonds were also retired.
Scheduled maturities and interest rates for the remaining securitization bonds
at June 30, 2003 are as follows:
Expected
Principal Final Final
Bond Balance Payment Maturity
Class Rate (in thousands) Date Date
--------------------------------------------------------------------------------------
A-2 3.80% 80,995 4/20/2006 4/20/2008
A-3 4.55% 31,000 4/20/2007 4/20/2009
A-4 4.98% 95,000 4/20/2010 4/20/2012
A-5 5.43% 117,000 4/20/2013 4/20/2015
A-6 5.76% 115,592 10/20/2015 10/20/2016
-------
Total $439,587
Current Maturities (27,399)
--------
Long-Term Debt $412,188
========
The amortization schedule for the securitization bonds provided for an initial
payment to bondholders on July 20, 2002 and then quarterly thereafter. The
following table provides the expected principal retirement of the securitization
bonds over the next five calendar years (in thousands).
Principal
Year Retirement
---- ----------
2003 26,905
2004 27,786
2005 28,646
2006 29,591
2007 30,763
4. FAIR VALUE OF FINANCIAL INSTRUMENTS
Restricted cash is on deposit with the trustee and, by definition, is carried at
its fair value. At June 30, 2003, and 2002, Consumers Funding had a financial
asset (representing its securitization receivable from Consumers) of
approximately $430 million and $459 million, respectively, and financial
liabilities (representing the securitization bonds) with a cost basis of
approximately $440 million and $469 million respectively. The securitization
receivable and securitization bonds are carried at cost, which approximates fair
value. Fair value is estimated based on quoted market prices, or, in the absence
of specific market prices, on quoted market prices of similar investments or
other valuation techniques.
11
5. SIGNIFICANT AGREEMENTS AND RELATED PARTY TRANSACTIONS
Consumers Funding has a securitization receivable with Consumers in the amount
of approximately $430 million and $467 million, as of June 30, 2003, and June
30, 2002, respectively. Accordingly, Consumers Funding recognized interest
income totaling $5.6 million and $5.7 million for the three months ended June
30, 2003, and 2002, respectively. In addition, Consumers Funding recognized
other operating income from Consumers totaling approximately $300,000 for the
three months ended June 30, 2003, and approximately $400,000 for the comparable
time period in 2002.
For the six months ended June 30, 2003, and 2002, Consumers Funding recognized
interest income totaling $11.2 and $11.4 million, respectively. In addition,
Consumers Funding recognized other operating income from Consumers totaling
approximately $600,000 for the six months ended June 30, 2003, and approximately
$700,000 for the comparable time period in 2002.
Consumers Funding has a securitization payable with Consumers in the amount of
approximately $300,000 and $900,000, as of June 30, 2003 and June 30, 2002,
respectively.
Under the servicing and administration agreements, Consumers is required to
manage and administer the securitization property of Consumers Funding, and to
collect the Securitization Charge on Consumers Funding's behalf. Consumers
Funding pays Consumers a servicing fee (see Note 1) and an annual administrative
fee. These fees are payable to Consumers on each scheduled quarterly payment
date beginning July 20, 2002. For the three months ended June 30, 2003,
Consumers Funding has recorded total expenses associated with these fees of
approximately $300,000, and approximately $400,000 for the comparable time
period in 2002.
For the six months ended June 30, 2003, Consumers Funding has recorded total
expenses associated with these fees of approximately $600,000, and approximately
$700,000 for the comparable time period in 2002.
12
CONSUMERS FUNDING LLC
PART II OTHER INFORMATION
ITEM 1. LEGAL PROCEEDINGS
NONE.
ITEM 5. OTHER INFORMATION
NONE.
ITEM 6. EXHIBITS AND REPORTS ON FORM 8-K
(a) Exhibits.
See Exhibit Index that appears following the Signature page
to this report.
(b) Reports on Form 8-K:
None
13
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the
Registrant has duly caused this report to be signed on its behalf by the
undersigned, thereunto duly authorized.
CONSUMERS FUNDING LLC
By: /s/Laura L. Mountcastle Date: August 14, 2003
----------------------------
Laura L. Mountcastle
President, Chief Executive Officer,
Chief Financial Officer and Treasurer
By: /s/Glenn P. Barba Date: August 14, 2003
----------------------
Glenn P. Barba
Chief Accounting Officer and Controller
14
INDEX TO EXHIBITS
EXHIBIT
NO. DESCRIPTION
-------- -----------------------------------------------------
10(a) Monthly Servicer's Certificate dated May 20, 2003
10(b) Monthly Servicer's Certificate dated June 19, 2003
10(c) Monthly Servicer's Certificate dated July 18, 2003
10(d) Quarterly Servicer's Certificate dated July 18, 2003
31 Consumers Funding, LLC's certification pursuant to Section
302 of the Sarbanes-Oxley Act of 2002
32
Consumers Funding, LLC's certification pursuant to Section
906 of the Sarbanes-Oxley Act of 2002
15