In April 2006, Standard&Poor's Ratings Services began to expand its analytical approach for assessing the trading risk management (TRM) practices of U.S. energy companies and to incorporate this analysis more formally into our ratings in this sector. The expansion focuses on the companies' risk management policies, infrastructure, and methodologies, or PIM. This analytical tool is one of three that we use to assess an energy company's trading risk position. The other two parts are our well established liquidity survey, which focuses on liquidity adequacy given certain market stresses, and our capital adequacy methodology, which measures the discrete risks of market, credit, and operational events and estimates capital needed for these exposures. We have completed PIM reviews for 10
