Exhibit 1-3

A line chart that compares actual failure rates to failure rates used by the FRC and two year moving average failure rates for the period 1997-2001. The chart shows the actual failure rate declining over this period and the failure rate used by the FRC increasing. Shaded bands around the two year moving average rate highlight the upper and lower 90% confidence intervals for the moving average failure rate. The chart suggests that restricting the FRC's choice of a failure rate to a value within the 90% confidence interval would improve the accuracy of the FRC's failure probability estimates.