There are two rules (that I know of) in CARES regarding $100K distributions from traditional IRAs. If one could combine them, one would have a fantastic loophole on Roth conversions. I don't think it works, though.
First, the basics. As catch noted, no RMDs for 2020. So the rule that "RMD amounts are not eligible to convert to a Roth IRA" doesn't apply this year since there are no RMDs. So you're free to convert any or all money you take out of a traditional IRA this year.
There never is an early withdrawal penalty for doing a Roth conversion.
One of the $100K CARES rules is that instead of being forced to do a rollover within 60 days, you can make an IRA withdrawal and then take up to three years to put the money back into a tax-sheltered account. Even better, you can put it back in parts, e.g. take out $100K, put $50K back in a year, and $50K back two years after that.
CARES Section 2202(a)(3).
I haven't been able to interpret this rule as allowing one to withdraw money from a T-IRA and take three years to put the money into a Roth (i.e. do a 60 day Roth rollover conversion). But I'm not an authority.
The second of the $100K rules says that if you don't put the money back into into a tax-sheltered account: a) you don't pay an early withdrawal penalty, and b) you get to declare the income over three years, 2020, 2021, 2022 ($33.3K/year).
Section 2202(a)(1) - no early withdrawal penalty
Section 2202(a)(5) - spread income over three years
Since there wouldn't be a penalty for a Roth conversion, all that might matter is the ability to spread income over three years. As with the rollover rule, I have a hard time seeing how it could be applied to Roth conversions.
But if you could apply both of these rules to a Roth conversion, you could take $100K from a traditional IRA, play with it for up to three years, deposit it into a Roth, and spread the taxes over three years, 2020-2022. Sweet deal if the law actually allowed that.

Hi VF
This is a very short form of info. Lots of info available, including your (I would hope) accounts web site.
--- When converting a traditional IRA, keep in mind:
If you are required to take a required minimum distribution (RMD) in the year you convert, you must do so before converting to a Roth IRA.
RMD amounts are not eligible to convert to a Roth IRA.
Generally, converted assets in the Roth IRA must remain there for at least five years to avoid penalties and taxes.
A distribution from a Roth IRA is tax-free and penalty-free provided that the five-year aging requirement has been satisfied and at least one of the following conditions has been met: you reach age 59½, die, become disabled, or make a qualified first-time home purchase.
Is the bold above the penalty you're asking about ???
Also, NO RMD for 2020. Waived by the CARES ACT. Perhaps there is more regarding this in the CARES ACT.
Catch

I measure portfolios with max 60% in stocks against my 2 long term funds.
For a portfolio of 30-40% stocks, I use VWIAX.
For 1 portfolio of 60-65 stocks, I use PRWCX.
So VWIAX VS CFTAX shows that VWIAX was a better choice since inception in 2012 (link)
CAGR...VWIAX 5.85%...CFTAX 5.67%
SD.........VWIAX 4.49%...CFTAX 5.1% (lower is better)
Worse year + Max draw...VWIAX leads by a lot
Sharpe+Sortino...VWIAX leads
CFTAX ER=0.69%...VWIAX ER=0.16%
BUT
If you test it for 3 years CFTAX comes ahead (link) with similar performance but only about half of the SD=volatility.

In a recent thread a contributor indicates they don't want to increase their income if it raised their marginal tax rate,I can sort of understand not wanting to work harder doing physicaL LABOR OR WORKING MORE HOURS and have the govt take more money from you but when it comes to investing I don't get it.If the govt takes a bigger share but you make and take home more money are you not better off?

......I'll chime in: we are in a hybrid situation. I'm retired, wife still works. Personal circumstances matter a lot. We could not live HERE in the 50th State without:
a) giving up some privacy
b) effectively getting a subsidy from extended family, who live with us. Rent, food. gas. We share all of that.
We don't want to bump ourselves into a higher tax bracket. For several years, on our tax returns, we have come out OWING ZERO TAX. If we had not very much more income to report, it might negatively affect our ability to even do the little bit of investing we do, for heirs as well as for ourselves. And the dividends and capital gains we get are non-taxable for us, in the lowest bracket.
We've paid-in for years and years. It's time the rules worked to OUR advantage, rather than the billionaires and millionaires: every bit of ALL of my earnings have always been subject to Soc. Tax. For them? They pay-in only until their income reaches the legal upper limit. These days, it's something like $127,000. (Hey, politicians! REMOVE THE CAP!) The crisis with SS is manufactured.

If I am making more money I expect to be paying more taxes. I can think of far worse things to worry about in the prime of my career than whether I'm bumped into a higher tax bracket this year or not. Being debt-free, living within my means, and not being flamboyant with my money goes a long way to retirement savings, even if I might take an income hit at some point down the road if/when I retire from the uni.
Sure, I try to offset cap gains/losses year-to-year, but I find that more about prudent investing than tax planning per se. Besides, it's kind of fun.

I think of net income in terms of total return. Investment gains are often part of taxable income. Marginal tax brackets do increase the drag on total return or better said marginal tax brackets diminish total return.
Most of us need a certain income to afford our life style. Recent data shows that ninety percent of income earners spend more than 100% of their earning so they need to take on additional debt as a means of affording their lifestyle. That math doesn't work.
Income graph:
https://screencast.com/t/rUJS2IeZ6ah
To your second point:
I remember having a conversation with a colleague who couldn't understand why I chose to retire early. My point to him was that he was working for the difference between what he would make (his work income) and what he would receive in retirement (pension income). I further pointed out that he could go elsewhere and work another full time or part time job making his total return (net taxes) much higher. Obviously by staying with his job he was adding years of service to his pension making his eventual pension income higher.
I consider taxes with regard to tax loss harvesting, Roth conversions, and potential qualifications for various benefits (HSA contributions, ACA Insurance subsidies, etc)
Taxes and tax brackets do have many nuisances (tax rules) beyond the marginal taxes brackets. I have always thought a simple flat tax would level the playing field.

If you have room in your income tax bracket to add income to that bracket (the 12% federal income tax bracket is my threshold) consider doing Roth conversions with some of your deferred IRAs.
A dropped of 12% (we have already experience this from the market high) or more in these holdings would allow you to lock in this "paper loss" by doing a roth conversion.
State and Federal taxes are paid on these conversions 1 year from now (April 2021) providing time for those investments to potentially recover and these gains would be tax free gains from the date of conversion.
I consider this similar to the tax loss harvesting strategy used in taxable accounts, but instead you are managing market temporary pullbacks as "Market Loss Harvesting" in your tax deferred accounts.
Manage taxes will help you manage your total return.

https://www.sec.gov/Archives/edgar/data/277751/000168386320003065/f3426d1.htm
97 1 f3426d1.htm 497
Janus Investment Fund
Janus Henderson Value Plus Income Fund
Supplement dated April 14, 2020
to Currently Effective Prospectuses
Effective immediately, the prospectuses for Janus Henderson Value Plus Income Fund (the “Fund”) are amended as follows:
1.Under “Management” in the Fund Summary section of the Fund’s prospectuses, the following paragraph replaces the corresponding paragraph in its entirety:
Portfolio Managers: Theodore M. Thome, CFA, is Portfolio Manager of the equity portion of the Fund, which he has managed or co-managed since July 2010. John Kerschner, CFA, is Executive Vice President and Co-Portfolio Manager of the fixed-income portion of the Fund, which he has co-managed since August 2018. John Lloyd is Executive Vice President and Co-Portfolio Manager of the fixed-income portion of the Fund, which he has co-managed since August 2018. Seth Meyer, CFA, is Executive Vice President and Co-Portfolio Manager of the fixed-income portion of the Fund, which he has co-managed since August 2018.
2.Under “Investment Personnel” in the Management of the Funds section of the Fund’s prospectuses, the following information replaces the corresponding information in its entirety:
Janus Henderson Value Plus Income Fund
Equity Investments
Theodore M. Thome, CFA, is Co-Portfolio Manager of Janus Henderson Value Plus Income Fund, which he has co-managed since July 2010. He joined Perkins in September 2002 as a research analyst covering the healthcare industry. Mr. Thome holds a Bachelor of Science degree in Life Science from the United States Military Academy at West Point and a Master of Business Administration with concentrations in finance and accounting from the University of Chicago Booth School of Business. Mr. Thome holds the Chartered Financial Analyst designation.
Effective immediately, all references to Alec Perkins are deleted from the Fund’s prospectuses.

https://www.sec.gov/Archives/edgar/data/1657267/000089418920002691/millerhowardfundstrust497e.htm
497 1 millerhowardfundstrust497e.htm 497E
Miller/Howard Income-Equity Fund
Class Ticker Symbol
Class I MHIEX
Adviser Share Class MHIDX
(A series of Miller/Howard Funds Trust)
Supplement dated April 14, 2020 to the Prospectus, Summary Prospectus and
Statement of Additional Information (“SAI”) dated February 28, 2020
______________________________________________________________________________________________________
Based upon a recommendation by MHI Funds, LLC (the “Adviser”), the Board of Trustees (the “Board”) of Miller/Howard Funds Trust (the “Trust”) has approved a plan of liquidation for the Miller/Howard Income-Equity Fund (the “Fund”) as a series of the Trust, pursuant to which the Fund will be liquidated on or around June 15, 2020 (the “Liquidation” or the “Liquidation Date”). The Adviser has determined that the Fund has limited prospects for meaningful growth. As a result, the Adviser and the Board believe that the Liquidation of the Fund is in the best interests of shareholders.
In anticipation of the Liquidation, effective as of the close of trading on the New York Stock Exchange (“close of business”) on April 14, 2020, the Fund will be closed to new investments. In addition, effective April 15, 2020, the Adviser may begin an orderly transition of the Fund’s portfolio securities to cash and cash equivalents and the Fund may cease investing its assets in accordance with its investment objective and policies.
Shareholders may voluntarily redeem shares of the Fund, as described in the Fund’s Prospectus, before the Liquidation Date. Shareholders remaining in the Fund just prior to the Liquidation Date may bear increased transaction fees in connection with the disposition of the Fund’s portfolio holdings. If the Fund has not received your redemption request or other instruction by the close of business on June 15, 2020, your shares will be automatically redeemed on the Liquidation Date. Shareholders will receive a liquidating distribution in an amount equal to the net asset value of their Fund shares, less any required withholding. For shareholders that hold their shares in a taxable account, the redemption of Fund shares will generally be treated as any other redemption of shares (i.e., a sale that may result in a gain or loss for federal income tax purposes). Your net cash proceeds from the Fund, less any required withholding, will be sent to the address of record.
If you hold your shares in an individual retirement account (an “IRA”), you have 60 days from the date you receive your proceeds to reinvest or “rollover” your proceeds into another IRA in order to maintain their tax-deferred status. You must notify the Fund’s transfer agent at 1-845-684-5730 prior to June 15, 2020 of your intent to rollover your IRA account to avoid withholding deductions from your proceeds.
If the redeemed shares are held in a qualified retirement account, such as an IRA, the redemption proceeds may not be subject to current income taxation. You should consult with your tax advisor on the consequences of this redemption to you. Checks will be issued to all shareholders of record as of the close of business on the Liquidation Date.
Please contact the Fund at 1-845-684-5730 if you have any questions.
This supplement should be retained with your Prospectus, Summary Prospectus and SAI for future reference.

Hi @MikeM,
I'm thinking there are ways a retired investor, like myself, can manage their portfolio through troubling times and still over time come out ahead. No doubt, you have been exploring ideas and thoughts as to how you might better govern. I'm by no means throwing cold water on your idea. I encourage you if you feel this is a better way for you to govern then back test your idea. This might not be as hard as you think. You know where you stand with current positions and your portfolio's performance. Now, all you have to do is figure out how your portfolio would have performed if it was configured based upon the sell stop orders on the proposed selected etf's incorporated within the portfolio.
For me, I'm still with my multi fund sleeve management system and using my operating base asset allocation of 20% cash, 40% income and 40% equity which in order to play the anticipated rebound from the recent downdraft I have moved to a temporary allocation of 10% cash, 45% income and 45% equity with a rebalance threshold set at +(or -) 2% from the neutral weightings. Thus far, I'm performing pretty much like a conservative asset allocation fund. As I write, I am now down less than 10% from my 52 week high and my portfolio is generating a good income stream. I plan to let my overweight equity allocation (now at 48%) run until my barometer scores the S&P 500 Index as overbought.
A fund that many like on the board, but I do not own, is VWINX. It is down ytd -3.84% with a five year average retrun of +5.24% with a yield of 3.1%. For me, come June when CFTAX makes it's mid year distribution ... I'm going to increase my position in it as I have a CD maturing towards the end of May. CTFAX ytd is up 6.55% with a five year return of 5.71%. It generates its distributions from both its bond positions along with capital gain distributions coming mostly from moving in and out of stock positions. You might wish to study this fund because it uses a similar strategy as to what you have described; but with a little different twist.
Best of luck to you. I'm sure you will come up with something tailored to fit your style of investing.
Skeet

Reading is one of our main forms of entertainment these days. Reading Financial News comes with bias that frames are thinking.
https://blogs.cfainstitute.org/investor/2020/04/06/how-to-read-financial-news-coronavirus-confirmation-bias-and-political-bias/

Here is link to reference prescient article:
https://alphaarchitect.com/2020/02/13/price-etfs-and-bond-market-liquidity/

Acutely painful to watch.
https://twitter.com/alphaarchitect/status/1249705104795750400?s=20
or
https://alphaarchitect.com/2020/04/13/compound-your-knowledge-ep-28-bond-etf-discussion-with-jon-seed/

I remember Cinnamon very well from years ago. His fund looked good when the market crashed and then it looks pretty bad. How long can a high % in cash works?
The following is from the last report. As expected PVCMX had over 92% in cash on 1/1/2020 and probably in 2019 too.
The Palm Valley Capital Fund gained 0.79% for the quarter ending March 31, 2020, while the S&P Small Cap 600 and the Morningstar Small Cap Indexes lost 32.65% and 31.61%, respectively. The Fund began the quarter with 92.4% of its assets held in cash and equivalents and ended the period with 52.0% cash.
I will pass on this fund..."fool me once, shame on you. fool me twice, shame on me."

It is hard to imagine a more backward conclusion than this. Who on earth does he think is offering active, non-transparent ETFs? Oh, yes, the mutual fund companies.
American Century, Fidelity, T. Rowe Price ... The mutual fund companies have faced two major impediments. One, an antiquated regulatory system designed in 1940 and periodically patched since then. That system imposes a series of direct and indirect expenses on OEFs (state registration fees and taxation of realized capital gains, e.g.) that ETF regulations do not. One fund company president who is looking to transition one of his smaller funds directly into a non-transparent ETF estimates that regulation and the fee structure for middlemen represent over half of all of the expenses his firm bears. Two, the "mutual funds are dinosaurs" mantra that caught on with the media, anxious for stories, and advisers anxious to "add value."
There are 656 ETFs that are three years old or less; dozens more were launched and liquidated or "repurposed" (the Drone ETF becoming the Cloud Economy ETF) in the same period. Of those 656, nearly 400 are no economically sustainable. That cutoff there, established by people who study ETF liquidations, is $30M AUM.
And whose funds are rolling in the cash? Looking just at these younger funds that have drawn $1B or more: JPMorgan, State Street, Vanguard, Deutsche, Franklin, BlackRock, Principal. Which is to say, old-line mutual fund companies. (As an aside, most also have a captive adviser workforce whose "recommended" list of ETFs are in-house products.)
Among the 25 largest newer ETFs, only two come from the upstart community: GraniteShares Gold (BAR) and GlobalX US Preferred (PFFD). Global X is owned by Mirae Asset, a Seoul-based firm that also owned Brown Brothers Harrison and the BBH Funds.
I don't know whether, a generation hence, PRWCX will be structured as an OEF under the '40 Act, an ETF under the Precidian Rule, both or neither. But I do know that the firms with the global reach, global recognition and multi-trillion asset bases that dominate the fund industry are more likely to cast the CNBC favorites of the world into deep shadow than vice versa.

Now they tell me!!!!
This summary prospectus change just came in my email. It is very specific for just a summary prospectus. More than I can ever recall. Seems more appropriate in a commentary or letter from the fund rather than a summary prospectus.
March 23, 2020
This information supplements certain disclosures contained in the Summary Prospectus of the
AlphaCentric Income Opportunities Fund, dated August 1, 2019, and the Prospectus and
Statement of Additional Information (“SAI”) for the Funds, each dated August 1, 2019, as
supplemented January 24, 2020.
____________________________________________________________________
AlphaCentric Income Opportunities Fund - Only
The paragraph under the section of the AlphaCentric Income Opportunities Fund’s
Summary Prospectus and Prospectus entitled “FUND SUMMARY - Principal Risks of
Investing in the Fund – Liquidity Risk” is replaced in its entirety with the following:
Liquidity Risk. Liquidity risk exists when particular investments of the Fund would be difficult
to purchase or sell, possibly preventing the Fund from selling such illiquid securities at an
advantageous time or price, or possibly requiring the Fund to dispose of other investments at
unfavorable times or prices in order to satisfy its obligations. The global impact of the coronavirus
on the economic and financial markets have caused severe market dislocations and liquidity
constraints in fixed income markets including many of the securities the Fund holds. To satisfy
shareholder redemptions, it is more likely the Fund will be required to dispose of portfolio
investments at unfavorable prices compared to their intrinsic value.
All Funds
The section of the Funds’ Prospectus entitled “ADDITIONAL INFORMATION ABOUT
THE FUNDS’ PRINCIPAL INVESTMENT STRATEGIES AND RELATED RISKS -
Principal and Non-Principal Investment Risks – Market Risk” is replaced with the following:
Market Risk. Overall market risks may also affect the value of the Fund. Factors such as domestic
economic growth and market conditions, interest rate levels and political events affect the
securities markets. Local, regional or global events such as war, acts of terrorism, the spread of
infectious illnesses or other public health issues, recessions and depressions, or other events could
have a significant impact on the Fund and its investments and could result in increased premiums
or discounts to the Fund’s net asset value, and may impair market liquidity, thereby increasing
liquidity risk. The Fund could lose money over short periods due to short-term market movements
and over longer periods during more prolonged market downturns. During a general market
downturn, multiple asset classes may be negatively affected. Changes in market conditions and
interest rates can have the same impact on all types of securities and instruments. In times of severe
market disruptions you could lose your entire investment.
An outbreak of infectious respiratory illness caused by a novel coronavirus known as COVID-19
was first detected in China in December 2019 and has now been detected globally. This
coronavirus has resulted in travel restrictions, closed international borders, enhanced health
screenings at ports of entry and elsewhere, disruption of and delays in healthcare service
preparation and delivery, prolonged quarantines, cancellations, supply chain disruptions, and
lower consumer demand, as well as general concern and uncertainty. The impact of COVID-19,
and other infectious illness outbreaks that may arise in the future, could adversely affect the
economies of many nations or the entire global economy, individual issuers and capital markets in
ways that cannot necessarily be foreseen. In addition, the impact of infectious illnesses in emerging
market countries may be greater due to generally less established healthcare systems. Public health
crises caused by the COVID-19 outbreak may exacerbate other pre-existing political, social and
economic risks in certain countries or globally. The duration of the COVID-19 outbreak and its
effects cannot be determined with certainty.

With American Century launching Wall Street’s first two actively managed, nontransparent exchange-traded funds, some investors are wondering what the implications could be for competing actively managed mutual funds.
“There’s going to be a point where they become a level playing field, and ETFs, with their benefits, could outweigh those of mutual funds in the long term,” Rosenberg said.

https://cnbc.com/2020/04/09/mutual-funds-are-in-trouble-as-nontransparent-etfs-arrive-investor.html

This article paints a dark picture. It discusses what the author sees as being a very fragile global economy and a very uncertain path moving forward. Some of the concerns it expresses may help explain the Feds aggressive recent actions. Here are a few excerpts...

The latest U.S. data proves the world is in its steepest freefall ever—and the old economic and political playbooks don’t apply....There has never been a crash landing like this before. There is something new under the sun. And it is horrifying.
Thursday’s news confirms that the Western economies face a far deeper and more savage economic shock than they have ever previously experienced. The coronavirus lockdown directly affects services—retail, real estate, education, entertainment, restaurants—where 80 percent of Americans work today. Thus the result is immediate and catastrophic.
...this year, for the first time since reasonably reliable records of GDP began to be computed after World War II, the emerging market economies will contract. An entire model of global economic development has been brought skidding to a halt.
...we are witnessing the largest combined fiscal effort launched since World War II. Its effects will make themselves felt in weeks and months to come. It is already clear that the first round may not be enough.
We are engaged in the largest-ever surge in public debt in peacetime....Some have suggested it would be simpler for the central banks to cut out the business of buying debt issued by the government and instead simply to credit governments with a gigantic cash balance....And on 9 April that is exactly what the Bank of England announced it would be doing. For all intents and purposes, this means the central bank is simply printing money.
We now know what truly radical uncertainty looks like. A huge part of the world’s population has had the basic functioning of its life radically disrupted. None of us can confidently predict when we will be able to return to our pre-coronavirus lives.

https://foreignpolicy.com/2020/04/09/unemployment-coronavirus-pandemic-normal-economy-is-never-coming-back/
Here is an article that explains the Bank of England's recent actions:
https://theguardian.com/business/2020/apr/09/bank-of-england-to-finance-uk-government-covid-19-crisis-spending

I have reasonably positive views on Mr. Cinnamond. I made money on ARIVX; and , when he liquidated the fund because he couldn't find any small cap stocks worth buying, I decided that I would try to limit my new purchases until he reentered the game. I followed his Absolute Value blog and tried to keep my powder dry. When he and his associates started Palm Valley Capital, I bought the smallest position allowed through Vanguard, but their ER of 2% for a fund 90% in money markets wasn't encouraging. Since he had very few holdings, and sold some of them when they hit his targets, buying the funds' few holdings seemed a bit risky.
Admittedly, his fund is the only one of my holdings with a positive return so far this year (probably because he had mostly cash - but there were a few down days), and I do think this is his kind of market. While it might be difficult to buy his purchases in a timely fashion, this probably is a good entry point for the fund, if one can stand the ER. (I think I've convinced myself to buy some more, but I do hate the ER.)

FXAIX didn't perform better because it didn't have a lower ER all these years. The main difference between me and others is that I supply numbers and not just narrative;-)

It would be very time consuming to find ER for previous years but from memory, Fidelity lowered ER for their index funds years ago to compete with VG.
From M*, for 5 years average annual as of (04/08/2020) [...]
It's a surprise that VOO with lower ER had lower performance than VFIAX

VOO is a bit of a distraction, because it introduces an additional layer of differentiation (ETF share class vs. OEF share class) and because its ER was lower by just 1 basis point for one year. Amortized over five years that amounts to nothing more than a rounding error. Still, it's good to see an acknowledgement that an S&P 500 index fund with a lower stated ER can have lower returns.
That's important because it puts lie to the statement that "FXAIX didn't perform better because it didn't have a lower ER". Certainly ERs affect relative returns, but they're not dispositive, especially when the magnitude of a difference between funds is small.
"It would be very time consuming to find ER for previous years." So sometimes you don't "supply numbers". That's okay. But you presented a numeric claim, viz. that FXAIX had a higher ER all these years, without checking the numbers. That calls into question numbers posted without citations and links.
VFINX ER from current prospectus and from 1998 prospectus
2019: 0.14%
2018: 0.14%
2017: 0.14%
2016: 0.14%
2015: 0.16%
2014: 0.17%
1999-2013: between 0.17% and 0.19% (interpolation)
1998: 0.19%
1997: 0.19%
1996: 0.20%
1995: 0.20%
1994: 0.19%
1993: 0.19%
1992: 0.19%
1991: 0.20%
1990: 0.22%
1989: 0.21%
1998: 0.22%
FXAIX (and predecessor fund) ERs from:
current prospectus [On July 1, 2016, FMR reduced the management fee ... from 0.025% to 0.015%],
2011 prospectus [On February 1, 2011, FMR reduced the management fee ... from 0.07% to 0.025% ],
2005 prospectus [Fund shares purchased prior to October 1, 2005 and not subsequently converted to Fidelity Advantage Class are deemed Investor Class shares]
2004 prospectus [Effective April 18, 1997, FMR has voluntarily agreed to reimburse the fund to the extent that total operating expenses ... exceed 0.19%.]
1997 prospectus (showing actual expenses for 1988-1996)
2019:       0.015%
2018:       0.015% (per 2019 note)
2017:       0.015% (per 2019 note)
2016:       0.020% (per 2019 note and averaging over half year)
2015:       0.025% (per 2011 note)
2014:       0.025% (per 2011 note)
2013:       0.025% (per 2011 note)
2012:       0.025% (per 2011 note)
2011:       0.025%
2006-2010: 0.070% (per 2011 note and 2005 prospectus showing YE 0.07% ER)
2005:       0.090% (per 2005 note, weighted avg of share class ERs)
1998-2004: 0.190% (per 2004 note)
1997:       0.190%
1996:       0.280%
1995:       0.280%
1994:       0.280%
1993:       0.280%
1992:       0.280%
1991:       0.280%
1990:       0.280%
1989:       0.280%
1988:       0.280%