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Evergy, Inc.  (NYSE:EVRG)
Q4 2018 Earnings Conference Call
Feb. 22, 2019, 10:00 a.m. ET

Contents:

Prepared Remarks:

Operator

Good day, ladies and gentlemen, and thank you for standing by. Welcome to the Great Plains Energy Corporation Conference Call. At this time, all participants are in a listen-only mode. Later we will conduct a question-and-answer session and instructions will follow at that time. (Operator Instructions) As a reminder, this conference call is being recorded. I would now like to turn the conference over to Ms. Lori Wright. Ma'am, please begin.

Lori Wright -- Vice President, Corporate Planning, Investor Relations and Treasurer

Thank you, Howard. Good morning everyone and welcome to Evergy's fourth quarter call. Thank you for joining us this morning. Today's discussion will include forward-looking information. Slide 2 and the disclosure in our SEC filings contain a list of some of the factors that could cause future results to differ materially from our expectations. Additional information and non-GAAP financial measures can be found on Slide 3. We issued our fourth quarter 2018 earnings release and 2018 10-K after market close yesterday. These items are available along with today's webcast slides and supplemental financial information for the quarter on the main page of our website at evergyinc.com.

On the call today we have Terry Bassham, President and Chief Executive Officer and Tony Somma, Executive Vice President and Chief Financial Officer. Other members of management are with us and will be available during the question-and-answer portion of the call. As summarized on Slide 4, Terry will recap our 2018 accomplishments, provide a business update and give an outlook on 2019 and beyond. Tony will update you on our financial results, then offer details on our 2018 earnings guidance and other financial projections.

With that, I'll hand the call to Terry.

Terry Bassham -- President and Chief Executive Officer

Thanks, Lori, and good morning everybody. I'll start my comments on Slide 6. 2018 was a very good year for Evergy. The merger took many twists and turns, as you know, over the past few years, but I am extremely pleased with our team's ability to thread the needle on successful regulatory proceedings, operational execution and integration of both business and culture. These accomplishments unlock the value of this combined Company and allowed for the delivery of solid financial and operational results which we reported last night.

Let me touch on some 2018 highlights. As mentioned, closing the merger allowed us to start capturing the benefits for our shareholders, customers and employees for years to come. Our Company is now better positioned to operate efficiently and approach the future from a position of strength. We executed our targeted merger savings over the first seven months of our Company. We were able to achieve constructive regulatory outcomes and settled each of our four rate reviews, which reflect tax reform benefits for all customers; not an easy task especially following the multiyear merger proceeding.

We worked with stakeholders in Missouri to move Senate Bill 564 forward that modernizes the regulatory framework in the state. We've officially implemented the plant-in service accounting benefits of this bill which should improve our ability to earn our allowed return in Missouri for years to come. We grew our dividend with the announcement of an increase last fall to our current indicated annual rate of $1.90 per share.

We successfully executed our capital allocation plan, including the launch of our share repurchase program. By year-end, we retired over 16 million shares, a good start to tackling our totaled 60 million share target by mid-2020. Along with share repurchases, we invested approximately $1.1 billion across our service territory, enabling us to continue to provide the quality service customers expect.

We continued our strategy of transforming our fleet in a sustainable manner, retiring 1,500 megawatts of end-of-life fossil generation while adding 244 megawatts of wind energy through our portfolio. This contribute to a 36% reduction in carbon level since 2005. We are expecting this trend to continue and by 2020 we project carbon reductions of more than 40% from the same 2005 base.

And lastly, we delivered our customers energy in a safe and reliable manner. Our customer reliability metrics were in the first or second quartile for industry ranking, marking the second straight year that each of our utilities has been ranked in the top half of the three major reliability metrics. This is a testament to the continued dedication and commitment of our employees. These highlights helped drive total shareholder return at the top quartile of the index.

Moving now to Slide 7. I'll give you the latest on our regulatory proceedings. Integrating our workforce and following through our merger commitments continue to be a high priority. We're still on track with our target merger savings plan. Actual 2018 savings were ahead of our growth targets. Higher-than-expected severance costs tied to a voluntary exit program caused the net savings to be shy of our target. Including these severance costs, we're in line with our 2018 expectations.

Going forward, this will better position the Company for more efficient operations and will continue to increase our efficiency efforts in 2019 as our saving targets ramp up year-over-year. Much of this increase will come from the annualized benefit of our 2018 savings and the second wave of our supply chain sourcing efforts will also continue.

In December, we officially announced the closing of two end-of-life fossil plants, Montrose, a 330 megawatt coal plant owned by KCP&L and, Sibley, a 400 megawatt coal plant owned by GMO. In addition to merger savings, we will also see the benefit of a full year cost reductions related to these two plant retirements. Related to the closing of our Sibley plant, in early January, Office of Public Counsel and Midwest Energy Consumers Group filed a complaint in Missouri requesting an accounting authority order to defer cost reductions associated with the retirement.

In February, we responded asking the Commission to dismiss the complaint as it fails to meet the standards of a formal complaint under state law. We also disagreed with the mini (ph) allegations in the complaint, including the total O&M savings predictions. The Commission has order that any party wishing to respond to our motion to dismiss do so by February 22. And earlier this week, we made a joint filing with the other parties in the docket proposing a procedural schedule, should the Commission choose to proceed hearing the complaint.

Cost savings aren't the only merger commitment we've been focused on. In the fourth quarter, we distributed $60 million of upfront bill credits to customers as well as met with regulators in both states to provide merger updates. Along with the updates and stipulated in our merger settlement, we opened compliance dockets to track merger-related items and commitments like merger savings, service quality metrics, capital plans and a comprehensive study of Kansas rates.

As the Kansas legislature session ramped up earlier this year, we received some attention on our rate study I just mentioned. The staff of the Kansas corporation commission also produced their own independent Kansas rates study, both yielded similar results which were presented to the Senate and House committees last month.

Now moving to Slide 8, I'll update you on our investment outlook before turning things over to Tony. This morning we introduced our 2019 adjusted earnings guidance range of $2.80 to $3.00 per share. The $2.90 midpoint is the base of our new targeted EPS compounded annual growth rate of 5% to 7% through 2023. Commensurate with earnings growth, we continue to target 60% to 70% dividend payout ratio, growing in line with earnings. We believe these targets and our commitment to no rate reviews for the next four to five years allows us to provide an attractive risk-adjusted total shareholder return profile.

To summarize, 2018 was a good year for Evergy and we're even more excited about 2019. So with that, I'll now turn the call over to Tony.

Tony Somma -- Executive Vice President, Chief Financial Officer

Thanks, Terry, and good morning everyone. I will take us through full year results, review our capital allocation plans and then finish up with the details on our 2019 and beyond outlook.

Now turning to Slide 10, I'll start with pro forma results, which excludes non-merger-related items and compares results as if Evergy were formed on January 1st of 2017. Fourth quarter pro forma EPS were $0.08 a share compared to a $0.25 loss for the same period last year. The large increase is due primarily to the revaluation of non-utility deferred income taxes in 2017 as a result of tax reform. This pickup was partially offset by higher O&M and depreciation expense in the quarter. The increase in O&M was driven by $7 million of severance costs due to a voluntary employee exit program as well as $19 million of inventory write-offs associated with plant retirements in Missouri. Additionally, we had about $8 million in COLI proceeds in the fourth quarter.

GAAP earnings for the quarter were $0.07 a share, $0.01 lower than pro forma with the difference all coming from merger-related expenses. For the quarter, pro forma residential sales were up around 4.6% and commercial sales were up 1.2%. Weather was slightly favorable, we estimate it helped about $0.02 when compared to normal. Pro forma industrial sales were up about 3.6%, lower than the same period last year. The decrease was mainly driven by three of our largest industrial customers within chemical and oil sector had a multi-week outages within the quarter, some of which were unplanned.

Moving on to full year results on Slide 11. Full-year 2018 pro forma EPS were $2.67 a share compared to $1.73 last year. The primary driver of the year-over-year increase was due to a decrease in tax expense, mainly from the revaluation of non-utility deferred tax liability that I mentioned. Other items contributing to pickup include increased sales due primarily to favorable weather, which helped by $0.37 compared to last year, $0.19 from Westar's deferred income tax reevaluation based on the new composite tax rate upon closing the merger and about $0.03 of other. Providing an offset to these items were $0.08 of increased depreciation and amortization expense and $0.05 of higher O&M, which includes $23 million of voluntary severance expense and $31 million of plant inventory write-offs.

Full year GAAP results were $2.50 a share, includes merger-related costs that aren't in pro forma results and reflect lower shares outstanding. Also GAAP will -- includes KCPL and GMO results for the period post merger closed, whereas pro forma includes them for the full period. On a pro forma basis, 2018 residential sales were up 10% while our commercial sales were up 3% compared to last year. Sales were driven by a favorable weather which when compared to normal we estimate helped about $0.31 for full year pro forma results. Industrial was down about 1.5%, mostly due to some of our large customers returning to normal levels in 2018, as well as the extensive outages that I mentioned in the fourth quarter.

Moving to Slide 12. I'll give an update on our recent financing activities and the progress we've made on share repurchase program in the fourth quarter. In November, we entered into another accelerated share repurchase and continued with open market purchases. For the year, we repurchased more than 16 million total shares or a little over a quarter of our two-year 60 million share target. We've continued to chip away in 2019, still focusing on the same measured approach of dollar-cost averaging over time. We expect our repurchases to total around 19 million shares by early March. We project a little issue of around $1.5 billion of holding company debt in 2019 to help with our rebalancing activities. The ultimate amount of that will vary based on share price timing and total number of shares repurchased. As I mentioned before, the 60 million shares by mid-2020 continues to be our target. The cadence and ultimate number of shares repurchased are subject to market factors and the financial outlook of the Company.

Now let me give you some details on our guidance on Slide 13. As Terry mentioned, our 2019 adjusted EPS guidance range is $2.80 to $3.00 per share. This range does not include merger-related costs for severance and rebranding expenses, which totaled $0.10 a share as we do not expect these transition expenses to be incurred after this year, certainly not in any meaningful amount.

Additionally, embedded within our guidance is the impacts of a major ice storm in January, the worst we've experienced since 2002, costing us about $30 million of which over half was O&M. Now, here are some of the drivers of our earnings guidance. We expect sales anywhere from flat to 50 basis points of growth. Our focus on merger savings will help reduce O&M expense which we're targeting at $1.2 billion plus or minus 2%, excluding transition expenses and severance -- for severance and rebranding.

Depreciation and amortization will increase $80 million to $90 million compared to our 2018 pro forma amounts. Now, as far as interest expense goes, we plan to refinance about $700 million in long-term debt maturities at our utilities plus we'll issue approximately $1.5 million of holding company debt. Lastly, we'll continue to make progress on our share repurchase goal and expect the average annual share count to be about 240 million shares, plus or minus 2%.

Now looking beyond this year, we've updated our capital expenditure forecast for 2019 through 2023. The five-year plan is relatively consistent with our previous forecast, totaling over $6 billion of infrastructure investment. It should be noticed, our plan includes viable projects and no placeholders. Should investment opportunity arise outside of our current project list, we would certainly review its merits. We'll continue to evaluate the incremental infrastructure opportunities that provide value to customers like grid modernization and renewables. This CapEx plan does take advantage of PISA in Missouri and we'll continue to evaluate opportunities for additional PISA qualified spend that would deliver value to our customers.

The capital plan supports our previously disclosed 3% to 4% rate base growth using 2017 as a base year. However, by moving the base year to 2018, the capital plan will now drive rate base growth in the 2% to 3% range over the next five years. This implant investment plan reduces lag while -- base rates stay out for the next four to five years. We're being very intentional with our investment in giving preferences to earnings certainty as we're zeroed in on the earning (inaudible) returns during this time. This five-year investment cycle balances the interest of shareholders and customers, aligning long-term sustainability of both stakeholder groups.

We've also updated our five-year EPS forecast, targeting a 5% to 7% CAGR through 2023, based of the $2.90 midpoint of 2019 guidance. The new CAGR answers the questions many of you has posed to us as to what the EPS CAGR would be if we updated to start from our current period rather than stay at 2016 and take it beyond 2021. Additionally, this new trajectory is a result of rebasing on a year which will include many of the advantages of our merger like the near-term impact of the cost reductions and share repurchases and now fully reflects the imputed savings that are agreed to in our 2018 regulatory settlements.

And had we not adjusted the book ends of our guidance range and stayed with the 2016 through 2021 EPS CAGR, we'd still affirm the 6% to 8% CAGR but would guide you to the middle or lower end of the range primarily due to the higher cost of the share repurchase plan. It should be noted, the new EPS CAGR is not linear, but we expect a jump going into 2020 above the 7% CAGR. We remain confident in the opportunity in front of us and continue to believe in our compelling investment thesis that offers a competitive and attractive risk-adjusted shareholder return.

With that, I'll turn the call back over to Terry.

Terry Bassham -- President and Chief Executive Officer

All right. Thank you for joining us this morning. We'll take questions.

Questions and Answers:

Operator

(Operator Instructions) Our first question or comment comes from the line of Julien Dumoulin-Smith from Bank of America. Your line is open.

Julien Dumoulin-Smith -- Bank of America -- Analyst

Hey, good morning.

Terry Bassham -- President and Chief Executive Officer

Good morning, Julien.

Julien Dumoulin-Smith -- Bank of America -- Analyst

Hey, just a follow up on those last questions as part of the conversation here. When you say that it's not linear and there's a jump going into '20 above the 7%, can you help elaborate a little bit more on '20 and '21 and how you're thinking about that, obviously there's up-front-end loaded benefits of the CapEx and the rate savings synergies as well as rate cases here, can you just give us a little bit more detail on '20 and '21 versus the later years where obviously CapEx seems to slow.

And then maybe let me jump to it and ask the second question on the same time, how do you think about backfilling CapEx, I mean, it's fairly consistent across the sector that we see sort of CapEx trailing off in the later years and that's subsequently filled in. How do you think about that right now given the specifics of your rate case timing expectations and the ability to recover or not recover as it may be longer-dated CapEx in '22 and '23 specifically?

Tony Somma -- Executive Vice President, Chief Financial Officer

Good morning, Julien, this is Tony. As far as the EPS goes, given the share buybacks and the ramp up of the synergies, which is consistent with what we said all along, the near-terms earnings ramp would be steeper than the out years and this is consistent even though we rebased it off of a current 2019 adjusted EPS CAGR midpoint of $2.90 per share. So those two items, the share repurchases, the ramp up of the synergies will drive EPS at a steeper rate than when you get to the outer years post 2021.

As far as backfilling the CapEx, the investment thesis from the get-go over the merger was that we weren't going to be a rate base growth story that both legacy companies had spent large amounts of capital growing rate base and the value of the merger was in combining these two companies and harvesting efficiencies for both customers and investors. We certainly have opportunities being in the Midwest, located in the breadbasket of the wind tunnel, if you will, to invest more but at this time we would have to look at refreshing our RPS and some other things and we've laid out there what we see today as viable projects.

Julien Dumoulin-Smith -- Bank of America -- Analyst

Got it. And let me just clarify what you said, you would still be in the 6% to 8% range in the low to mid-end of that for -- through the entire period that you had previously?

Tony Somma -- Executive Vice President, Chief Financial Officer

Through 2021.

Julien Dumoulin-Smith -- Bank of America -- Analyst

2021?

Tony Somma -- Executive Vice President, Chief Financial Officer

Recall, when we announced the deal, a 6% to 8% CAGR of Westar's 2016 earnings and we took that out to 2021. And as we're on the road, folks have said that's a little stale and so, we're updating it off of a more current period.

Julien Dumoulin-Smith -- Bank of America -- Analyst

So that would be for '21, somewhere between $3.25 and $3.41 if you took the low to mid-end of that range?

Tony Somma -- Executive Vice President, Chief Financial Officer

Yeah, I'm not going to argue with your math, if that's what you came up with, then yes.

Julien Dumoulin-Smith -- Bank of America -- Analyst

Got it. All right, I'll leave it there. Thank you very much.

Tony Somma -- Executive Vice President, Chief Financial Officer

You're welcome.

Terry Bassham -- President and Chief Executive Officer

Thank you.

Operator

Thank you. Our next question or comment comes from the line of Michael Sullivan from Wolfe Research. Your line is open.

Michael Sullivan -- Wolfe Research -- Analyst

Yeah, hey guys, good morning.

Terry Bassham -- President and Chief Executive Officer

Good morning.

Michael Sullivan -- Wolfe Research -- Analyst

Just wanted to follow-up on a couple of those questions and then your comments at the end there. So I guess just to start on the 2019, can you just directly quantify what the O&M hit was worth and then the share repurchase costing a little more on an EPS basis and kind of where you would have been otherwise?

Terry Bassham -- President and Chief Executive Officer

I'm not sure I understand, your question, Michael. As far as the O&M hit, what you mean by the O&M hit?

Michael Sullivan -- Wolfe Research -- Analyst

The storms (Multiple Speakers).

Terry Bassham -- President and Chief Executive Officer

Yeah. So the guidance includes updating the storm, the storm is roughly $30 million bucks and we're still tallying the O&M piece of that, it's probably a little more than half.

Michael Sullivan -- Wolfe Research -- Analyst

Okay. And then what about the repurchase program costing more than you guys would have otherwise thought, how much of a drag is that?

Tony Somma -- Executive Vice President, Chief Financial Officer

So obviously, we when we announced the deal and if you can look in testimony filed, we are probably thinking we are going to issue around $1.1 billion, $1.2 billion holdco debt. Tax reform put a little bit of a prep on that as that hurts cash flows and just overall values of utilities relative to 10 years, they hung in pretty stout. And obviously it makes the share repurchase program more expensive, but it's obviously still accretive and the right thing to do to rebalance the capital structure.

Michael Sullivan -- Wolfe Research -- Analyst

Okay. And just to kind of put a point on that, as far as relative to your initial expectations and what you've kind of looked at since the merger closed, these are really the only things that have changed or just these storm costs this year and then the repurchase program costing more than you would have otherwise expected?

Tony Somma -- Executive Vice President, Chief Financial Officer

Since we announced, (inaudible) tax reform. I mean there's lots of pluses and minuses that go on, but those are kind of the bigger ones.

Michael Sullivan -- Wolfe Research -- Analyst

Okay. And then the last one, just on '19 guidance, can you just explain the tax rate assumption and why that's so low?

Tony Somma -- Executive Vice President, Chief Financial Officer

The 12% to 14%. It's a couple of factors. The legacy Westar has a COLI plant and so I think embedded within the guidance is about $23 million of COLI proceeds. Additionally, we have large quantities of wind resources, which as you know produce production tax credits which will lower your effective tax rate. That's our estimate going into the year.

Michael Sullivan -- Wolfe Research -- Analyst

Okay, thank you.

Tony Somma -- Executive Vice President, Chief Financial Officer

You're welcome.

Operator

Thank you. Our next question or comment comes from the line of Greg Gordon from Evercore ISI. Your line is open.

Greg Gordon -- Evercore ISI -- Analyst

Hey, good morning guys.

Terry Bassham -- President and Chief Executive Officer

Good morning, Greg.

Greg Gordon -- Evercore ISI -- Analyst

So, sorry that I'm going to beat the dead horse a little more here, but a few questions around the guidance revision. First, just mathematically, if I do use $2.43 as like the quote-unquote even if a stale base I get that, but if I use that and I just do a CAGR to the new guidance range that's implied by guidance for '21, that's basically 5.5% to 6.5% CAGR off of the $2.43 number, which is a $0.05 to $0.25 reduction in the low end and the high end of the range. So it's not a rebase guys, it's a significant reduction in expected earnings outcomes. That's why the stock's down 6%.

So I just want to understand from your perspective, and I know, Tony, you just said, there are a lot of moving parts, but what are the key things that took $0.25 off the high end of the range? Was it higher assumed share purchase price, higher interest expense because of tax reform at the parent level? What are the big structural drivers that took the $0.25 off the high end?

Tony Somma -- Executive Vice President, Chief Financial Officer

So let me first state, you're correct. Those are coming from -- some of the bigger ones, Greg. The tax reform obviously reduce cash flows and when tax reform came out, we said this obviously will move us in the range and we never said where we were in the range originally. We said the original range was 6% to 8% of the $2.43. And additionally the valuations in our sector, as well as interest rates rising is making the share repurchase program more expensive, but it's still accretive and the right thing to do to rebalance the balance sheet.

Greg Gordon -- Evercore ISI -- Analyst

Okay. But do you still expect, as we're thinking about modeling here that a combination of the rate settlements and your ability to harvest synergies would allow you to earn at or near your authorized returns across the different regulated business units and should we model accordingly?

Tony Somma -- Executive Vice President, Chief Financial Officer

Yes. And recall, we never said the thesis was us over earning. The thesis was earning our allowed returns and staying there.

Terry Bassham -- President and Chief Executive Officer

Greg, we're on track with our synergy expectations and we expect to earn our allowed returns. We've said before, we don't really expect to over earn, but we expect to be able to earn our allowed returns.

Greg Gordon -- Evercore ISI -- Analyst

Great. Okay. So we need to contemplate in our models earning at the authorized returns and really the leakage here in the growth comes around really the financing costs and the impact of tax reform and all that, how that sort of flows through your financial outcomes. Is that a fair summary?

Tony Somma -- Executive Vice President, Chief Financial Officer

Yes, fair summary. The earnings power of the Company is the $14.2 billion of rate base that we have today, right. That's what rates are set at and then us harvesting the synergies going forward.

Greg Gordon -- Evercore ISI -- Analyst

Okay. Is there anything in the articulated range built in for potentially earning back the rate credits in Kansas or getting into the sharing bands? Or if you were to be able to harvest a little bit of higher earned ROE above your authorized through executing and getting into the sharing bands, like where would that put you inside this range?

Terry Bassham -- President and Chief Executive Officer

You're asking contemplating earning above on the bands in Kansas, which would kick in the sharing mechanism, am I understanding it right?

Greg Gordon -- Evercore ISI -- Analyst

Yes, basically saying like if I assume the midpoint is that your earning -- is the midpoint that you're earning at your authorized returns, I mean, because you do have and I know that you're telling us don't assume we over earn, assume we just earn our authorized returns, but you have the ability to harvest more synergies and potentially flow back to customers significant incremental benefits and then keep something for shareholders. Is that at all contemplated in the guidance range?

Tony Somma -- Executive Vice President, Chief Financial Officer

Well, it certainly is possible Greg. But there's a lot of pluses and minuses that will go into a forecast particularly going out five years and the whole -- one thing, constant, we generally avoid that. Again the thesis behind the merger is us earning our allowed returns and staying there and if we do earn above those in Kansas and there is a mechanism in place that we can share those and that would obviously help us on the EPS CAGR.

Terry Bassham -- President and Chief Executive Officer

Yes, I mean, to your point, I think if I understand, what you're saying is that we were earning toward the top end or even into the sharing ranges, that would push us up in the range of our earnings guidance. That aren't you suggesting?

Greg Gordon -- Evercore ISI -- Analyst

Yes. I'm just asking whether the range contemplates the ability to do that or whether if you achieved that, it would be above the range. So you're saying that it would just push you up inside the range.

Terry Bassham -- President and Chief Executive Officer

Yes.

Greg Gordon -- Evercore ISI -- Analyst

Okay. I've taken up too much time in Q&A guys. I'll go to the back of the queue. Thanks.

Terry Bassham -- President and Chief Executive Officer

Thank you.

Operator

Thank you. Our next question or comment comes from the line of Michael Lapides from Goldman Sachs. Your line is open.

Michael Lapides -- Goldman Sachs -- Analyst

Hey guys, thanks for taking my question. Real quick on the docket in Missouri that OPC in the industrials follow. Can you just talk to us about how that process will work from here?

Terry Bassham -- President and Chief Executive Officer

Yes. We've filed a motion to dismiss kind of based on our prior practice where we've asked for accounting orders on different things that we don't believe the request meets the standard. So thus the Commission's set up timeline for other folks to comment on that issue. We'll either get a ruling (inaudible) on the dismissal and if it's not -- if it is dismissed, obviously we're off and running, if it's not dismissed, then we would work with the parties and the Commission staff ultimately to establish a time frame for hearings and briefing and all that kind of stuff. And that could run through the summer, those processes don't move extremely quickly.

Michael Lapides -- Goldman Sachs -- Analyst

Or what the complainants basically seeking is to pick for customers to get the economic benefit of the O&M savings from the plant retirements. Was that originally embedded in as part of the merger agreement or is what they're seeking that the retirement benefit is actually greater than what was originally disclosed during merger process?

Terry Bassham -- President and Chief Executive Officer

No, it's the former. Again, we were very transparent about all of these business matters while we were doing our negotiations, so they were well aware this was happening. Their position is even though it occurred after the test year and after the effect of new rate, they want those savings accounted for and flowed back later. I will say that even in the context of that request, we don't believe their numbers right. They just kind of assume every dollar allocated to the plant goes away and some of those employees were reassigned other things. So the total number they alleged is higher than we believe, but it's the former, not the latter of your question.

Michael Lapides -- Goldman Sachs -- Analyst

Got it, OK. And then one question just on the merger savings and cost savings in general. Do you look at it and think there is upside to the original merger cost savings that you laid out. And if so, what areas, like if I were to go back to Steve Busser's testimony during the merger process, what area or what bucket within the various buckets of cost savings do you think the greatest opportunities exist for you guys?

Terry Bassham -- President and Chief Executive Officer

I don't think we really identified a lot of upside to where we've already outlined and what was in Steve Busser testimony. Obviously every time you make an estimate like that, you drive to your goal and hope that you can find others, but I would say this early in the process we are implementing the charters in the plans that we put in place to achieve those targets and then we would hope over time we find more, but I would say at this point we've identified any additional opportunities that are material.

Tony Somma -- Executive Vice President, Chief Financial Officer

We are finding some, obviously we consolidating the back office at Wolf Creek.

Michael Lapides -- Goldman Sachs -- Analyst

Got it, OK. Last one and I know you've gotten the gazillion questions on kind of the earnings growth. Is it safe to assume you're above the 5% to 7% just in 2020 or do you think that's a 2020 and '21 as well that you're above that range and therefore you'd obviously mathematically have to be at the probably closer what's your rate base growth would be in like '22 and '23?

Tony Somma -- Executive Vice President, Chief Financial Officer

So in the near term, obviously the the savings ramp up and the share repurchases, Michael will drive the ramp-up from '19 to '20. I haven't looked at '20 to '21, we've not given '20 guidance today or '21 guidance, but we are telling you that the five-year EPS CAGR is not linear and it's going to ramp up in the early years.

Michael Lapides -- Goldman Sachs -- Analyst

Got it. Thank you, guys. Much appreciated.

Tony Somma -- Executive Vice President, Chief Financial Officer

You're welcome.

Operator

Thank you. Our next question or comment comes from the line of Ali Agha from SunTrust. Your line is open.

Ali Agha -- SunTrust -- Analyst

Thank you. Good morning.

Terry Bassham -- President and Chief Executive Officer

Good morning.

Ali Agha -- SunTrust -- Analyst

Tony, I just wanted to clarify on comments you've already made just to make sure I'm understanding it right. First off, coming back to the growth rate outlook, so once the share buyback impacts are fully factored in, which as you say, are '20 and '21, then we should look at the growth rate beyond that really as a function of rate base growth since you're already earning your authorized returns, presumably there's not that much more upside from an earned ROE basis. So is rate base growth then a good proxy once the share buyback plan is fully factored in?

Tony Somma -- Executive Vice President, Chief Financial Officer

Well, it depends, right, depend on numerous factors and what we're saying today is the ramp up is happening here early because of the share repurchases and the merger synergies (ph) that you outlined, but it won't be the same slope of the line, if you will, probably once you get past '20, '21.

Terry Bassham -- President and Chief Executive Officer

Yeah. And just to be clear on the issue, I mean we've not tried to place placeholders in later years that will then work to necessarily to drive a greater growth rate, that doesn't mean that we don't have other opportunities, and as we begin to move toward the end of our time period for a freeze and there's a test year involved and we're working toward what is our future generation needs and plans that we won't have additional CapEx opportunities. What we haven't done is suggest to you that we're going to work to apply and target in the later years just to increase the growth rate. We're trying to be very transparent here.

Ali Agha -- SunTrust -- Analyst

Okay. Then on the share buyback, again, I wanted to clarify, Tony, your comment. So you had bought back 16 million shares through the end of the year and did I hear it right that based on the accelerated and other programs that by early March that 16 million would become 19 million, so in other words, another 3 million would have been bought by early March, did I hear that right?

Tony Somma -- Executive Vice President, Chief Financial Officer

That's correct.

Ali Agha -- SunTrust -- Analyst

So that would imply, I mean, if I just looked at the run rate from the last three months or the fourth quarter which was about 8 million or so, that would be a pretty sizable slowdown in your buyback between Jan 1 and early March. Any reason for that and as suggested given the pullback in your stock price, I mean is that a motivation to potentially accelerate this and maybe do it before mid-2020?

Tony Somma -- Executive Vice President, Chief Financial Officer

Well, there a potential there, but we'll have to see. We want to keep our options available and we've kind of been pretty transparent that we prefer to dollar-cost average over time and if we think valuations utilities are cheap and our stock is cheap, yeah, naturally we would like to step on the gas a little bit more.

Ali Agha -- SunTrust -- Analyst

Okay. And then lastly, also to clarify on this point you've made about the cost of the buyback has gone up and now you're looking at issuing $1.5 billion of debt, previously, it was about $1.1 million, $1.2 million. Also for modeling purposes, when should we assume that debt needs to be issued. Is that also happening now earlier than expected in the context of how '19 numbers maybe shaping up that interest expense may be also higher because the debt needs to be issued a bit earlier as well?

Tony Somma -- Executive Vice President, Chief Financial Officer

Yes. So, clearly the debt and associated interest would put pressure on our earnings. It depends on the cadence of the share repurchases to when we issue that debt. There'd be sometime later this year, third quarter or so.

Ali Agha -- SunTrust -- Analyst

So -- we should assume...

Tony Somma -- Executive Vice President, Chief Financial Officer

(Multiple Speakers) fourth quarter.

Ali Agha -- SunTrust -- Analyst

For modeling purposes, it's third or fourth quarter?

Tony Somma -- Executive Vice President, Chief Financial Officer

Yes.

Ali Agha -- SunTrust -- Analyst

Okay, thank you. I appreciate that.

Tony Somma -- Executive Vice President, Chief Financial Officer

You're welcome.

Operator

Thank you. Our next question or comment comes from the line of Paul Ridzon from KeyBanc. Your line is open.

Paul Ridzon -- KeyBanc -- Analyst

Good morning.

Terry Bassham -- President and Chief Executive Officer

Good morning.

Paul Ridzon -- KeyBanc -- Analyst

Just a quick question, just if you could review the interplay of the rate freeze and opportunities under Senate Bill 564, kind of how we should be thinking about that, are you, somehow constrained for opportunities because of the rate freeze?

Terry Bassham -- President and Chief Executive Officer

(inaudible) Missouri piece (inaudible) Paul?

Paul Ridzon -- KeyBanc -- Analyst

Sorry, what?

Terry Bassham -- President and Chief Executive Officer

You're talking about Missouri piece, right?

Paul Ridzon -- KeyBanc -- Analyst

Yes.

Terry Bassham -- President and Chief Executive Officer

The constraint is in the Bill itself and remember in Missouri there is a cap there. Remember, in Missouri we don't have a technical rate freeze on the merger itself. It's related to the Bill. So there's no additional constraint from the merger perspective. That was the settlement part of the Kansas piece. Does that makes sense?

Paul Ridzon -- KeyBanc -- Analyst

Yes, thank you for the clarification.

Operator

Thank you. Our next question or comment comes from the line of Charles Fishman from Morningstar Research. Your line is open.

Charles Fishman -- Morningstar Research -- Analyst

Good morning. Just one question on merger savings. Slide 20, that does not include the $200 million total of merger savings from the closing the Montrose assembly, is that correct?

Tony Somma -- Executive Vice President, Chief Financial Officer

Good morning. This is Tony, Charles. Yes, that's correct.

Charles Fishman -- Morningstar Research -- Analyst

So that is -- I guess what keeps that because you controlled it, you've already closed those plants. What keeps that $200 million going from potential to realized?

Tony Somma -- Executive Vice President, Chief Financial Officer

I don't understand (inaudible) simple question. Let me say that (inaudible) made us help to answer the question. Remember that ultimately the closing of the plant that you just mentioned for KCP&L were already announced and they weren't merger savings. So those aren't considered merger savings for the purposes of that merger saving discussion. It was the closing on the Westar side that sped (ph) those closings up and therefore considered merger savings. Does that makes sense?

Charles Fishman -- Morningstar Research -- Analyst

Yeah, OK. But I mean, I guess the $200 million has been baked into your guidance and obviously...

Tony Somma -- Executive Vice President, Chief Financial Officer

Yeah, it is. The savings associated with shutting the plants down is all part of our expectation going forward, absolutely.

Charles Fishman -- Morningstar Research -- Analyst

Okay. So I could have done a better job of asking the question. That's all I had. Thank you.

Tony Somma -- Executive Vice President, Chief Financial Officer

You're welcome.

Operator

Thank you. Our next question or comment comes from the line of Paul Patterson from Glenrock Associates. Your line is open.

Paul Patterson -- Glenrock Associates -- Analyst

Hey, good morning.

Terry Bassham -- President and Chief Executive Officer

Good morning.

Paul Patterson -- Glenrock Associates -- Analyst

So just back on the complaint case in Missouri, what is the cost savings? I mean, you mentioned that you guys think it is less than what you guys are suggesting. Could you tell us what you think it is?

Tony Somma -- Executive Vice President, Chief Financial Officer

So I think they -- in their pleading they said $22 million -- $27 million. And I'd say we probably think it's half or a little more that actually could be related to specific costs, again if you take them out, it should be allocated that and were actual outcomes were given, (inaudible). So I don't know that we've quantified the exact number but...

Paul Patterson -- Glenrock Associates -- Analyst

Okay, but roughly thinking about about half or maybe a little bit more than that number?

Tony Somma -- Executive Vice President, Chief Financial Officer

Yes.

Paul Patterson -- Glenrock Associates -- Analyst

Okay. And then -- and your guidance basically assumes that basically that you guys have -- as you guys have indicated before it's your position that basically this is already announced and therefore should not be clawed back or anything like that. Is that correct?

Terry Bassham -- President and Chief Executive Officer

Yes, not just that, but in past years we have sought accounting orders for costs such as taxes and other things, pretty straightforward that we asked to be accounted for. And it was (inaudible) pretty clearly and the parties involved here that are asking for this argued that they were not extraordinary and shouldn't be and this very similar if not exact kinds of costs. So we think it's pretty clear under the orders of the commission in past cases that we should not be provided for (inaudible).

Paul Patterson -- Glenrock Associates -- Analyst

Okay, understood. And then the Kansas legislative study, could you comment a little bit further on that in terms of the issue of competitive rates and where you see, if you see anything happening with respect to the legislature or the KCC or whatever regarding this topic (inaudible)?

Terry Bassham -- President and Chief Executive Officer

Yes. So we are in lockstep with the Commission staff. We've actually testified on one of the Bills early on and we and the staff are in agreement. We provided our rate study and the Commission staff provided theirs that we had agreed to provide and they were very similar. The Bills have been filed now, cover a range of things, but the one specifically on the rate study does more than just ask for study, what it does is an attempt to change the law that would address how you look at those things and we think that's clearly not the intent of the rate study language and again the Commission staff agrees with us.

So I think in the end what we expect to come out of the discussion is that we would have additional rate study around in particular larger customers that we would have, it's been the next year or two depending on how it all comes out, looking at how we compare to other regional costs. This is a reminder, 10 years ago we were well below the national average and currently we're right at above the national average, after about 10 years of both EPA and infrastructure spend. It speaks exactly to why we've done the merger and exactly why we've agreed to the process over the next four, five years without rate increase.

Paul Patterson -- Glenrock Associates -- Analyst

Okay. And then with respect to the rate base growth and it being more modest perhaps than other areas -- other companies, I guess is there any potential for opportunities with respect to perhaps that you might be exploring that would be in addition to your rate base growth, that could be seen as potentially reducing operating costs or fuel costs or what have you. Is there any opportunity that you guys are exploring in that and how might that impact your rate base growth other than what you guys are providing here?

Tony Somma -- Executive Vice President, Chief Financial Officer

So -- this is Tony good morning. I think we jokingly say, we're the Saudi Arabia of wind and so there's always opportunities for renewables. In fact, you know, many of our customers like to go greener and those would be some things that we would look at, we would be providing more renewable resources to our customers.

Terry Bassham -- President and Chief Executive Officer

(Multiple Speakers) Now in the near term, we've got a very specific plan, obviously we've talked about. As we get in the later years, we're obviously always looking at opportunities, Tony mentioned, kind of opportunities he talked about, but we haven't put anything in the forecast that shows a bucket of opportunity dollars that we will be working to analyze those as we go in. We will be updating investors as we become more firm in plans as we're providing (inaudible) and other things to our Commission.

Paul Patterson -- Glenrock Associates -- Analyst

Okay, great, thanks a lot.

Operator

Thank you. Our next question or comment comes from the line of Shahriar Pourreza from Guggenheim Partners. Your line is open.

Shahriar Pourreza -- Guggenheim Partners -- Analyst

Hey guys.

Terry Bassham -- President and Chief Executive Officer

Good morning.

Shahriar Pourreza -- Guggenheim Partners -- Analyst

Sorry, I hopped on a few minutes late. On sort of the civil complaint, you don't have an outcome or a potential outcome in that case in your outlook. Correct?

Tony Somma -- Executive Vice President, Chief Financial Officer

Well, assumed as if there is no order granting that the deferral of those costs, that they remain as we closed the last rate case.

Shahriar Pourreza -- Guggenheim Partners -- Analyst

Got it, OK. And then just, obviously this is -- been hit on way too much, but the growth profiles obviously a little bit rate. So you've got the back, the front-end loaded, the back-ends somewhat tepid especially as you guys sort of wait to file rate cases. Can you -- I know you've talked about wind and renewables, but clearly there is capital spending that's sort of been withheld while you've gone through this entire process. I'm curious as you think about the next wave of rate cases outside of the incremental items around renewables, is there any other sort of capital opportunities you see on the base business and then it's likely going to be somewhat of a healthy ask in the various states and obviously your synergies and efficiencies are helping, what sort of is the outlook for rates when you sort of go through this next wave of rate cases and curious if the profile of that growth can reemerge closer to what people's past expectations were when you file for a new set of proceedings?

Terry Bassham -- President and Chief Executive Officer

Well, certainly as we get closer to our test year work, that will ultimately lead to rate cases, we'll have a better feel for what kind of increases there are. We will also be working to streamline and manage our O&M kinds of costs. The idea's been able to spend more on rate base and less so on (inaudible) O&M strategy, but as we get closer to that, we will certainly and are now looking at opportunities that customers may want from a renewable perspective. And other than generation, yes, we are a very reliable T&D system and so opportunities from both the transmission and distribution perspective on ongoing basis, whether it would be grid modernization or just stability of the system or both opportunities that continue.

Shahriar Pourreza -- Guggenheim Partners -- Analyst

And so when you go through that revisit of that capital program and whether it's renewables or your base spending needs, do you guys feel like you've got enough efficiencies out there as they're building to mitigate sort of a massive amount of rate inflation?

Terry Bassham -- President and Chief Executive Officer

Yes. I think -- if I understand your question, I mean the notion would be, we think our system is in good shape. We think we have opportunities from both as we have more recently with coal plants retiring and opportunities with wind that we can continue that transition of being a Tier 1 type T&D company with more and more clean renewable type energy without having to raise rates dramatically, but continue to give us the ability to invest in our systems.

Shahriar Pourreza -- Guggenheim Partners -- Analyst

Yes, that's sort of what I was trying to get. Okay, great, thanks guys.

Terry Bassham -- President and Chief Executive Officer

Thank you.

Operator

Thank you. Our next question or comment comes from the line of Ashar Khan from Verition. Your line is open.

Ashar Khan -- Verition -- Analyst

Most of my questions have been answered. Can I just ask you, can you share with us what the synergy levels are say, increase from '19 to '20. Is there anything you can provide on guidance on that, how the synergies improve year-over-year from '19 to '20 and '21, is there anything you can provide?

Tony Somma -- Executive Vice President, Chief Financial Officer

Yes, it's Slide 20 in the deck. In '19 there's is a target of about $110 million, in '20 it ramps up to $145 million. And this would exclude obviously the power plants savings that we talked about earlier.

Ashar Khan -- Verition -- Analyst

And so I can just take that delta in between those and after tax it -- what tax rate, Tony?

Tony Somma -- Executive Vice President, Chief Financial Officer

About 25%, Lori, all in?

Ashar Khan -- Verition -- Analyst

Okay. So I can just take the delta and after-tax 25% and that would be incremental year-over-year earnings, right?

Terry Bassham -- President and Chief Executive Officer

All other things been equal, yes, we obviously -- we've got other things happening but that would be the relationship (inaudible).

Ashar Khan -- Verition -- Analyst

Okay, thank you so much.

Operator

Thank you. Our next question or comment comes from the line of Andrew Levi from ExodusPoint. Your line is open.

Andrew Levi -- ExodusPoint -- Analyst

Hi, good morning guys.

Terry Bassham -- President and Chief Executive Officer

Good morning, Andy.

Andrew Levi -- ExodusPoint -- Analyst

How are you?

Terry Bassham -- President and Chief Executive Officer

Good.

Andrew Levi -- ExodusPoint -- Analyst

Just two questions. First one, I just want to make sure I heard correctly or maybe I misinterpreted it. Just on the stock buyback itself, you're not deviating at all from the amounts dollar wise, so you're buying back, or are you because of what you said about tax reform...

Tony Somma -- Executive Vice President, Chief Financial Officer

Yes, the target is still 60 million.

Andrew Levi -- ExodusPoint -- Analyst

Okay.

Terry Bassham -- President and Chief Executive Officer

No change in plan.

Andrew Levi -- ExodusPoint -- Analyst

Okay. Just want to make sure that if I heard correctly. And then the other thing too, so obviously we've met a several times so -- in the last couple of months. So basically, what you're saying is in the outer years, so you're saying there's 2%, 3% rate base growth based on your '19 base, however, if in time as you kind of get through this stock buyback and you kind of look at opportunities in the future, that rate base last CapEx numbers in the outer years should grow or are you not saying that?

Tony Somma -- Executive Vice President, Chief Financial Officer

I'd say there's certainly opportunity there. Obviously what we're describing is what's in our guidance, but as we move through that time period, we move toward our upcoming rate cases and we continue to work on issues such as customer growth, integrated resource planning. Yes, we would expect every opportunity to evaluate opportunities.

Andrew Levi -- ExodusPoint -- Analyst

Okay. And that probably is -- probably still -- 2020 type timeframe or '21?

Tony Somma -- Executive Vice President, Chief Financial Officer

Yeah. I mean...

Andrew Levi -- ExodusPoint -- Analyst

Not the actual dollars that we will get that kind of update.

Terry Bassham -- President and Chief Executive Officer

Yeah, we'll continue to update you along the way as we go with the plan and again we're not going to put placeholders to work toward. We are going to put in what we're working on at the time and be transparent about that.

Andrew Levi -- ExodusPoint -- Analyst

Okay, that's terrific. Thank you. Have a great weekend.

Terry Bassham -- President and Chief Executive Officer

Thank you.

Operator

Thank you. Our next question or comment comes from the line of Kevin Fallon from Citadel. Your line is open.

Kevin Fallon -- Citadel -- Analyst

Good morning. I just wanted to clarify that when you guys are looking at the rate base rolling forward that your assumption is, you're earning your authorized on your actual current year rate base. Correct?

Tony Somma -- Executive Vice President, Chief Financial Officer

Well, there's lot of pluses and minuses, but yes, that's the whole idea is that the merger savings will hopefully offset whatever spend there is on the capital side.

Kevin Fallon -- Citadel -- Analyst

Okay. But the base is moving higher...

Tony Somma -- Executive Vice President, Chief Financial Officer

I understand you want to make it very precise, but there's a lot pluses and minuses that go into the forecast and a lot of levers that move.

Kevin Fallon -- Citadel -- Analyst

No, that I can definitely appreciate. I just want to make sure that as the rate base is moving up 2% to 3% that you're opportunity set and your target is to have earn on that growing rate base?

Tony Somma -- Executive Vice President, Chief Financial Officer

Yes.

Kevin Fallon -- Citadel -- Analyst

Okay. Exactly. The other thing, just in terms of clarity on the back-end in terms of the CapEx for all these other things like wind and grid mod and whatnot, what is it that you need to wait for to start to have like line of sight to be able to update those plans. Like, do you have like PPAs rolling off or is there something under the legislation in Missouri, what drives the timing in terms of updating that?

Terry Bassham -- President and Chief Executive Officer

Well, it's traditional utility planning. On the front end where we've just started the merger, the strategy is to build earn on our spend without increasing rates for customers, that's what we've agreed for the (inaudible) the near-term, not have rate increases. As we work through our planning for the test year and hopefully those cases, we'll have an update on what's happening with our different units. We will be working with customers on their needs and wants around additional wind and opportunities for wind, which just simply reduce overall costs, which we've done in the past.

It gives us the opportunity at that point to look at whether we want to own those in rate base or whether we want to have PPAs. Remember that in the past both companies tended to lean on PPAs because from a capital perspective, we were spending on environmental and other things that need additional CapEx or rate base spend. The only other kind of limitation might be as PISA as we look at PISA on Missouri side, there's opportunity there, but there's also limits in the legislation and so we'll be watching that as well. Does that makes sense?

Kevin Fallon -- Citadel -- Analyst

Yeah, it does. Just as follow-on, is there a certain timeframe in terms of when you have these PPAs rolling off, is it a kind of a front like -- when you look out to 2023 in your deck, is that the timeframe when you start to have PPAs rolling off or is that kind of further out in the future?

Tony Somma -- Executive Vice President, Chief Financial Officer

This is Tony, it'd be further out, I think both legacy companies probably put wind on those 708 timeframe, their own wind resources we put on some more, but -- and those are 20 year PPAs.

Kevin Fallon -- Citadel -- Analyst

Okay. That's very helpful. Thank you.

Terry Bassham -- President and Chief Executive Officer

You're welcome.

Operator

Thank you. We have a follow-up question from Ali Agha from SunTrust. Your line is open.

Ali Agha -- SunTrust -- Analyst

Thanks, just a very quick one. Coming back to the Sibley compliant, I know Terry you mentioned that the Commission has asked for comments to your filing for dismissal today, but just given that schedule, when would you expect the Commission to rule whether to dismiss this or not?

Terry Bassham -- President and Chief Executive Officer

You know, they've put a deadline for filing comments for/against, I guess, but comments around it. They (inaudible) typically a deadline around when the Commission would make a decision. Once they get them all in, they will review everybody as said and it will depend on kind of (inaudible) meeting schedule, which happens every week, but until they put it on the docket for us to see, we wouldn't know how quickly that would happen.

Ali Agha -- SunTrust -- Analyst

Understood, but we're thinking weeks or months, I mean just a rough sense?

Terry Bassham -- President and Chief Executive Officer

Probably weeks, on the move forward, don't move forward and then if they don't dismiss the case, probably months in terms of how to process (inaudible).

Ali Agha -- SunTrust -- Analyst

Got it. Thank you.

Operator

Thank you. We have a follow-up question from Mr. Paul Ridzon from KeyBanc. Your line is open.

Paul Ridzon -- KeyBanc -- Analyst

I just -- can you review kind of what the potential blackouts are on the buyback and could you (inaudible) taking advantage of this weakness?

Tony Somma -- Executive Vice President, Chief Financial Officer

So as we've said before, the intent is to have the infrastructure in place to be able to buy back shares through blackout periods.

Paul Ridzon -- KeyBanc -- Analyst

And then what does guidance contemplate as far as the savings from the plant closings, is that embedded in guidance or is that upside?

Tony Somma -- Executive Vice President, Chief Financial Officer

It is embedded in guidance.

Paul Ridzon -- KeyBanc -- Analyst

Okay, thank you very much.

Tony Somma -- Executive Vice President, Chief Financial Officer

You're welcome.

Operator

Thank you. I'm showing no additional questions in the queue at this time. I'd like to turn the conference over to Mr. Terry for any closing remarks.

Terry Bassham -- President and Chief Executive Officer

Okay. Thanks, Howard. And thank you everybody for joining the call this morning. I know we've got a lot of information we provided today and we appreciate you being on the call and participate with, have a good weekend. Thank you.

Operator

Ladies and gentlemen, thank you for participating in today's conference. This concludes the program. You may now disconnect. Everyone, have a wonderful day.

Duration: 60 minutes

Call participants:

Lori Wright -- Vice President, Corporate Planning, Investor Relations and Treasurer

Terry Bassham -- President and Chief Executive Officer

Tony Somma -- Executive Vice President, Chief Financial Officer

Julien Dumoulin-Smith -- Bank of America -- Analyst

Michael Sullivan -- Wolfe Research -- Analyst

Greg Gordon -- Evercore ISI -- Analyst

Michael Lapides -- Goldman Sachs -- Analyst

Ali Agha -- SunTrust -- Analyst

Paul Ridzon -- KeyBanc -- Analyst

Charles Fishman -- Morningstar Research -- Analyst

Paul Patterson -- Glenrock Associates -- Analyst

Shahriar Pourreza -- Guggenheim Partners -- Analyst

Ashar Khan -- Verition -- Analyst

Andrew Levi -- ExodusPoint -- Analyst

Kevin Fallon -- Citadel -- Analyst

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