Composite
5.3 / 100 percentile
Screener / 015326
A
PARK MANOR HEALTH AND REHABILITATION, LLC
snfAL
2201 MCFARLAND BOULEVARD, NORTHPORT, AL 35476 · CCN 015326 · chain JAMES NORMAN ESTES JR TR
Peer group
snf n = 14,684
Evidence depth
deep
Certified beds
152
Model
v1.2
Reads as: riskier than 5.3% of the 14,684 facilities in the snf peer group. percentile within peer group, 100 = highest risk. Grade bands are fixed percentile cuts (F is the top 5% of peer risk), so a grade is a position, not an absolute level.
Score model4ML signals1Components12CHOW radar1Distress radar1Staffing14Penalties0Deficiencies11Licensure0Ownership25Related party5Transactions0Comps12Market rent34
Composite explanation
4| Component | Percentile | Raw | Weight | Weight share | Contribution | Counts |
|---|---|---|---|---|---|---|
| staffing risk | 72.9 | 72.9 | 0.25 | 0.2500 | 18.23 | in index |
| billing conduct | 16.8 | 20.7 | 0.30 | 0.3000 | 5.04 | in index |
| financial risk | 2.0 | 8.8 | 0.30 | 0.3000 | 0.60 | in index |
| chow risk | 1.4 | 17.7 | 0.15 | 0.1500 | 0.21 | in index |
weighted_contribution sums to pre_rank_index over rows where counts_toward_index is true. The composite is the facility's percentile position of that index within its peer group, so contributions explain the input, and the rank explains the score.
ML signals — parallel engine
1| Kind | Finding | Signal | Subject | First seen |
|---|---|---|---|---|
| connection | Owner spans multiple chains | 6 chains | REGIONS BANK | 63 facilities |
Findings from the always-on scanning layer: anomalies on this facility, connections through its current owners and past buyers. Runs beside the deterministic composite, never inside it. Full board on the ML Lab page.
Component scores and registry models
12| Score type | Score | Grade | Model | Status | Registry model notes |
|---|---|---|---|---|---|
| billing conduct | 20.6 | A | v0.1-pacpuf-snf | default · in composite | R22. PAC PUF SNF 2023. PDPM coding intensity vs acuity, stay length, charge markup. |
| chow risk | 17.7 | A | v0.1-pos | default · in composite | Change-of-ownership footprint in the CMS Provider of Services file: control-family, legal-name and address deltas across quarterly snapshots, plus certification reset recency and Medicare tenure. |
| financial risk | 8.8 | A | v0.5 | default · in composite | R18. |
| p adverse action 12m | 0.0 | — | v0.1 | default · in composite | R23/W4-3. Deterministic logistic p(Medicare termination within 12m), SNF only. Label = first POS termination date (any code: voluntary closure, involuntary termination, merger exit); facilities already terminated by the panel date are excluded, not counted as safe. Trained on panels 2024-07/2024-10/2025-01 (n=46,466, 283 positives), evaluated on the held-out later panel 2025-04 BEFORE shipping: AUC 0.971, top-decile lift 9.5x, top-decile capture 95.4% of the 65 terminations that followed. Separability is high because closures announce themselves in the data: collapsing occupancy is the strongest signal, and the learned NEGATIVE weight on 12m deficiency counts is the surveys-stop signature of a facility winding down, not a claim that clean inspections are dangerous. Same 15 as-of-date features and anti-leakage chassis as p_chow_12m; SFF entry rejected as a label (only one month of SFF history exists, so as-of transitions cannot be reconstructed). Score = probability x 100; grade NULL. Not in any composite. |
| p chow 12m | 3.1 | — | v0.1 | default · in composite | R22/W4-2. Deterministic logistic p(CHOW within 12m), SNF only. Trained on panels 2024-07/2024-10/2025-01 (n=50,700, 1,207 positives), evaluated on the held-out later panel 2025-04 BEFORE shipping: AUC 0.874, top-decile lift 5.0x (top 10% of predictions captured 49.6% of the CHOWs that actually closed in the next 12 months). Shipped coefficients are the evaluated ones; no post-holdout refit. Caveat: holdout positives (133) run below the training base rate because recent CHOWs surface in public records with a lag, so measured lift is conservative. Features are as-of-date public records: PBJ staffing level/trend/contract share (quarterly history to 2022Q1), deficiency and CMP counts (12m), ownership tenure and churn from CHOW-evidenced transactions, beds, occupancy, ownership type, chain size. Chain membership and ownership type are current-state (history not published). SFF and star ratings deliberately excluded (no as-of history). Notable learned direction: long ownership tenure RAISES sale odds and a recent prior CHOW lowers them. Score = probability x 100; grade is NULL because a probability is not a quality letter. Not in any composite. |
| staffing risk | 72.9 | D | v0.3 | default · in composite | Cost-report staffing, SNF population. Runs alongside v0.4-pos, which covers ICF/IID from POS. |
| financial risk | 64.8 | C | v0.1 | superseded | Pre-registry model iteration, superseded by a later financial_risk rebuild. Rows retained for audit per project convention (see regulatory_risk v0.4-pos); never consumed because v_cii_api_facility_score and the composite eligibility join both require status = default. Backfilled 2026-07-26 by alert triage on model_registry_integrity. |
| financial risk | 44.8 | B | v0.2 | superseded | Pre-registry model iteration, superseded by a later financial_risk rebuild. Rows retained for audit per project convention (see regulatory_risk v0.4-pos); never consumed because v_cii_api_facility_score and the composite eligibility join both require status = default. Backfilled 2026-07-26 by alert triage on model_registry_integrity. |
| financial risk | 29.4 | B | v0.3 | superseded | Pre-registry model iteration, superseded by a later financial_risk rebuild. Rows retained for audit per project convention (see regulatory_risk v0.4-pos); never consumed because v_cii_api_facility_score and the composite eligibility join both require status = default. Backfilled 2026-07-26 by alert triage on model_registry_integrity. |
| financial risk | 14.6 | A | v0.4 | superseded | Pre-registry model iteration, superseded by a later financial_risk rebuild. Rows retained for audit per project convention (see regulatory_risk v0.4-pos); never consumed because v_cii_api_facility_score and the composite eligibility join both require status = default. Backfilled 2026-07-26 by alert triage on model_registry_integrity. |
| staffing risk | 72.9 | D | v0.1 | superseded | Pre-registry model iteration, superseded by a later staffing_risk rebuild. Rows retained for audit per project convention (see regulatory_risk v0.4-pos); never consumed because v_cii_api_facility_score and the composite eligibility join both require status = default. Backfilled 2026-07-26 by alert triage on model_registry_integrity. |
| staffing risk | 72.9 | D | v0.2 | superseded | Pre-registry model iteration, superseded by a later staffing_risk rebuild. Rows retained for audit per project convention (see regulatory_risk v0.4-pos); never consumed because v_cii_api_facility_score and the composite eligibility join both require status = default. Backfilled 2026-07-26 by alert triage on model_registry_integrity. |
Rows with counts_toward_composite false come from models that are addressable or retracted rather than default. They exist and may be informative, but they did not enter the published composite and must not be summed as though they had.
CHOW radar — 12-month sale probability
full board →p(CHOW, 12m)
3.1%
model v0.1 · computed 2026-07-29
Percentile among SNFs
78.3
100 = most likely to sell
Holdout AUC
0.874
evaluated before shipping, never refit
| Driver | Value | Pull on odds | |
|---|---|---|---|
| For-profit ownership | 1.00 | +0.69 | |
| Never sold on record | 1.00 | +0.62 | |
| Occupancy | 0.91 | -0.62 | |
| Current owner tenure (years) | 25.00 | +0.57 | |
| No PBJ staffing report | 0.00 | +0.42 | |
| Chain size (log) | 3.83 | +0.41 | |
| Ownership changes, last 5 years | 0.00 | +0.20 | |
| Deficiencies, last 12 months | 0.00 | -0.17 |
p_adverse_action_12m: probability the facility's Medicare participation terminates within 12 months (any POS termination code; already-terminated facilities are excluded, not scored safe). Deterministic logistic over as-of-date public records, SNF only. Holdout (2025-04 panel, evaluated before shipping): AUC 0.971, top-decile lift 9.5x. Closures announce themselves: collapsing occupancy dominates, and fewer recent surveys is a winding-down signature. inputs.features holds raw feature values, inputs.contributions each feature's standardized pull on the log-odds. Predictions never enter the composite. See /v1/models. | p_chow_12m: probability of a change of ownership within 12 months. Deterministic logistic over as-of-date public records, SNF only. Holdout (2025-04 panel, evaluated before shipping): AUC 0.874, top-decile lift 5.0x. inputs.features holds raw feature values, inputs.contributions each feature's standardized pull on the log-odds. Predictions never enter the composite. See /v1/models for full notes.
Distress radar — 12-month termination probability
full board →p(termination, 12m)
0.0%
model v0.1 · computed 2026-07-29
Percentile among SNFs
33.6
100 = most likely to lose certification
Holdout AUC
0.971
top decile caught 95% of actual exits
| Driver | Value | Pull on odds | |
|---|---|---|---|
| Deficiencies, last 12 months | 0.00 | +1.43 | |
| Chain size (log) | 3.83 | -1.03 | |
| For-profit ownership | 1.00 | -0.69 | |
| Occupancy | 0.91 | -0.68 | |
| No PBJ staffing report | 0.00 | +0.39 | |
| Fine amount, 12m (log) | 0.00 | +0.18 | |
| Facility size (log beds) | 5.03 | -0.14 | |
| Never sold on record | 1.00 | +0.12 |
Probability the facility's Medicare participation ends within 12 months, from public records only. Red bars raise exit odds. A negative pull from deficiencies is the winding-down signature — surveys stop as a facility empties — not evidence that clean inspections are dangerous.
Staffing vs peers
14| 2025Q4 HPRD | This facility | AL median | National median | National p25–p75 |
|---|---|---|---|---|
| Total nurse | 2.94 | 3.37 | 3.28 | 2.90–3.77 |
| RN | 0.39 | 0.43 | 0.39 | 0.25–0.58 |
| Weekend total | 2.38 | 3.04 | 3.11 | — |
| Weekday total | 3.16 | 3.50 | 3.35 | — |
| Quarter | Days | Avg census | Total HPRD | RN | LPN | CNA | Weekend | Contract % |
|---|---|---|---|---|---|---|---|---|
| 2025Q4 | 92 | 138.5 | 2.94 | 0.39 | 0.60 | 1.95 | 2.38 | 0.0% |
| 2025Q3 | 92 | 136.5 | 3.01 | 0.44 | 0.59 | 1.98 | 2.39 | 0.0% |
| 2025Q2 | 91 | 139.9 | 3.08 | 0.42 | 0.64 | 2.03 | 2.41 | 0.0% |
| 2025Q1 | 90 | 142.7 | 2.97 | 0.49 | 0.58 | 1.89 | 2.29 | 0.0% |
| 2024Q4 | 92 | 146.0 | 2.89 | 0.50 | 0.51 | 1.88 | 2.24 | 0.0% |
| 2024Q3 | 92 | 143.3 | 3.07 | 0.51 | 0.57 | 1.98 | 2.41 | 0.0% |
| 2024Q2 | 91 | 145.4 | 2.96 | 0.48 | 0.59 | 1.89 | 2.41 | 0.0% |
| 2024Q1 | 91 | 145.9 | 2.75 | 0.44 | 0.53 | 1.78 | 2.26 | 0.0% |
| 2023Q4 | 92 | 141.8 | 2.67 | 0.46 | 0.47 | 1.73 | 2.26 | 0.0% |
| 2023Q3 | 92 | 138.0 | 2.37 | 0.45 | 0.52 | 1.40 | 1.88 | 0.0% |
| 2023Q2 | 91 | 135.0 | 2.41 | 0.43 | 0.56 | 1.42 | 1.92 | 0.0% |
| 2023Q1 | 90 | 137.4 | 2.32 | 0.42 | 0.51 | 1.39 | 1.83 | 0.0% |
| 2022Q4 | 92 | 131.8 | 2.35 | 0.52 | 0.50 | 1.34 | 1.81 | 0.0% |
| 2022Q2 | 91 | 134.2 | 2.41 | 0.38 | 0.62 | 1.41 | 2.01 | 0.0% |
HPRD is census-weighted: total hours over the quarter divided by total resident-days, not an average of daily ratios. Source is CMS Payroll-Based Journal daily records; only SNFs report PBJ, so other settings legitimately return zero rows.
Penalties
0No penalties on record for this facility. Absence of a record here means the sources CII ingests contain none, not that none exists anywhere.
Deficiencies
11D × 5E × 3F × 3
deficiencies by survey year
| Survey | Type | Tag | Deficiency | Scope | Corrected |
|---|---|---|---|---|---|
| 2019-06-21 | Health | F0761 | Ensure drugs and biologicals used in the facility are labeled in accordance with currently accepted professional principles; and all drugs and biologicals must be stored in locked compartments, separately locked, compartments for controlled drugs. | D | 2019-07-26 |
| 2019-06-21 | Health | F0812 | Procure food from sources approved or considered satisfactory and store, prepare, distribute and serve food in accordance with professional standards. | F | 2019-07-26 |
| 2019-06-21 | Health | F0835 | Administer the facility in a manner that enables it to use its resources effectively and efficiently. | E | 2019-07-26 |
| 2019-06-21 | Health | F0867 | Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action. | E | 2019-07-26 |
| 2019-06-21 | Health | F0880 | Provide and implement an infection prevention and control program. | D | 2019-07-26 |
| 2019-06-21 | Health | F0921 | Make sure that the nursing home area is safe, easy to use, clean and comfortable for residents, staff and the public. | D | 2019-07-26 |
| 2019-06-21 | Health | F0925 | Make sure there is a pest control program to prevent/deal with mice, insects, or other pests. | E | 2019-07-26 |
| 2018-07-19 | Health | F0644 | Coordinate assessments with the pre-admission screening and resident review program; and referring for services as needed. | D | 2018-08-23 |
| 2018-07-19 | Health | F0812 | Procure food from sources approved or considered satisfactory and store, prepare, distribute and serve food in accordance with professional standards. | F | 2018-08-23 |
| 2018-07-19 | Health | F0814 | Dispose of garbage and refuse properly. | F | 2018-08-23 |
| 2018-07-19 | Health | F0880 | Provide and implement an infection prevention and control program. | D | 2018-08-23 |
scope_severity uses the CMS letter grid: A is least serious, L most. J, K and L are immediate jeopardy. Rows are the surveyor's findings of record, not the model's opinion.
Licensure actions
0No licensure actions on record for this facility. Absence of a record here means the sources CII ingests contain none, not that none exists anywhere.
Ownership
25| Owner | Role | Pct | From | Status | Source |
|---|---|---|---|---|---|
| NHS OPERATIONS LLC | 5% OR GREATER DIRECT OWNERSHIP INTEREST | 100% | 2002-11-08 | current | pecos_ownership |
| PARK MANOR HEALTH REALTY LLC | Individual has financial interest in both related organization and provider | 100% | 2023-07-01 | current | hcris_a_8_1 |
| PARK MANOR HEALTH REALTY LLC | Individual has financial interest in both related organization and provider | 100% | 2024-07-01 | current | hcris_a_8_1 |
| ESTES, JAMES | 5% OR GREATER INDIRECT OWNERSHIP INTEREST | 89% | 2002-11-08 | current | pecos_ownership |
| JAMES NORMAN ESTES JR TR | 5% OR GREATER INDIRECT OWNERSHIP INTEREST | 5% | 2002-11-08 | current | pecos_ownership |
| JENNIFER LEE ESTES TR 031093 | 5% OR GREATER INDIRECT OWNERSHIP INTEREST | 5% | 2002-11-08 | current | pecos_ownership |
| BOYD, CASEY | OPERATIONAL/MANAGERIAL CONTROL | — | 2023-04-28 | current | pecos_ownership |
| DUFFY, MARCIA | OPERATIONAL/MANAGERIAL CONTROL | — | 2003-12-12 | current | pecos_ownership |
| LONG, PHILLIP | CORPORATE OFFICER | — | 2019-10-01 | current | pecos_ownership |
| MURPHY, VICKIE | OPERATIONAL/MANAGERIAL CONTROL | — | 2023-06-29 | current | pecos_ownership |
| PARK MANOR HEALTH REALTY, LLC | 5% OR GREATER SECURITY INTEREST | — | 2003-01-01 | current | pecos_ownership |
| RASCO, LYNN | CORPORATE DIRECTOR | — | 2022-07-01 | current | pecos_ownership |
| REGIONS BANK | 5% OR GREATER SECURITY INTEREST | — | 2012-08-27 | current | pecos_ownership |
| JAMES ESTES | CORPORATE OFFICER | 100% | 2002-11-08 | ended 2026-05-18 | pecos_ownership |
| PARK MANOR HEALTH REALTY LLC | Individual has financial interest in both related organization and provider | 100% | 2022-07-01 | ended 2023-06-30 | hcris_a_8_1 |
| PARK MANOR HEALTH REALTY LLC | Individual has financial interest in both related organization and provider | 100% | 2021-07-01 | ended 2022-06-30 | hcris_a_8_1 |
| PARK MANOR HEALTH REALTY LLC | Individual has financial interest in both related organization and provider | 100% | 2020-07-01 | ended 2021-06-30 | hcris_a_8_1 |
| VICKIE MURPHY | W-2 MANAGING EMPLOYEE | 100% | 2023-06-29 | ended 2026-05-18 | pecos_ownership |
| CASEY BOYD | CORPORATE DIRECTOR | 33% | 2023-04-28 | ended 2026-05-18 | pecos_ownership |
| LYNN RASCO | OPERATIONAL/MANAGERIAL CONTROL | 33% | 2022-07-01 | ended 2026-05-18 | pecos_ownership |
| MARCIA DUFFY | CORPORATE DIRECTOR | 33% | 2003-12-12 | ended 2026-05-18 | pecos_ownership |
| BRANDON AGEE | OTHER | 11% | 2022-01-01 | ended 2026-05-18 | pecos_ownership |
| PHILLIP LONG | OTHER | 11% | 2022-01-01 | ended 2026-05-18 | pecos_ownership |
| NHS MANAGEMENT LLC | OTHER | 0% | 2007-06-01 | ended 2026-05-18 | pecos_ownership |
| PHILLIP LONG | CORPORATE OFFICER | — | 2019-10-01 | ended 2026-05-18 | pecos_ownership |
PECOS ownership and managing-control associations. Current edges have no end date in the source; historical edges are retained.
Transactions
0No transactions on record for this facility. Absence of a record here means the sources CII ingests contain none, not that none exists anywhere.
Comparable trades — AL snf
12| Close | Facility | Price | $/bed | Cap rate | Beds | Buyer |
|---|---|---|---|---|---|---|
| 2025-01-01 | THE HEALTH CENTER AT RESEARCH PARK | — | — | — | 91 | SAND CREEK HEALTHCARE, INC. |
| 2024-12-01 | ROCKET CITY REHABILITATION AND HEALTHCARE CENTER | — | — | — | 159 | WHITESBURG SNF OPERATIONS LLC |
| 2024-11-15 | Greenway Health and Rehabilitation Center, LLC | — | — | — | 92 | ARABELLA HEALTH & WELLNESS OF GRAND BAY OPCO LLC |
| 2024-10-01 | THE PINE OF CAMDEN, LLC | — | — | — | 95 | THE PINES OF CAMDEN LLC |
| 2024-07-01 | EXTENDICARE HEALTH AND REHAB | — | — | — | 170 | NOLAND EXTENDICARE, LLC |
| 2024-02-01 | GADSDEN HEALTH AND REHAB CENTER | — | — | — | 168 | GADSDEN HC OPERATIONS LLC |
| 2023-11-17 | ST MARTIN'S IN THE PINES | — | — | — | 128 | PINES BIRMINGHAM OPCO LLC |
| 2023-08-25 | TIMBERLAND HEALTH AND WELLNESS CENTER | — | — | — | 120 | ARABELLA HEALTH & WELLNESS OF BUTLER OPCO LLC |
| 2023-06-20 | CAMELLIA HEALTH AND REHABILITATION CENTER | — | — | — | 170 | ARABELLA HEALTH & WELLNESS OF MOBILE OPCO LLC |
| 2023-05-01 | CAVALIER HEALTHCARE OF TRUSSVILLE | — | — | — | 125 | CAVALIER HEALTHCARE OF TRUSSVILLE LLC |
| 2023-03-24 | FALKVILLE REHABILITATION AND HEALTHCARE CENTER | — | — | — | 116 | FALKVILLE SNF OPERATIONS LLC |
| 2023-03-24 | DECATUR HEALTH & REHAB CENTER | — | — | — | 119 | DECATUR SNF OPERATIONS LLC |
Most recent same-state, same-setting trades. Most CHOW-derived trades carry no disclosed consideration, so price, $/bed, and cap rate show only where a sale price was resolved from a deed or filing — blanks are honest, not missing data.
Market rent context
34| Geo | Kind | BR | Amount | As of | Source |
|---|---|---|---|---|---|
| county 01125 | acs median gross | 0 | $857 | 2024-12-31 | CENSUS_ACS5 |
| county 01125 | fmr | 0 | $966 | 2025-10-01 | HUD_USER_FMR |
| county 01125 | acs median gross | 1 | $892 | 2024-12-31 | CENSUS_ACS5 |
| county 01125 | fmr | 1 | $972 | 2025-10-01 | HUD_USER_FMR |
| county 01125 | acs median gross | 2 | $1,032 | 2024-12-31 | CENSUS_ACS5 |
| county 01125 | fmr | 2 | $1,169 | 2025-10-01 | HUD_USER_FMR |
| county 01125 | acs median gross | 3 | $1,162 | 2024-12-31 | CENSUS_ACS5 |
| county 01125 | fmr | 3 | $1,490 | 2025-10-01 | HUD_USER_FMR |
| county 01125 | acs median gross | 4 | $1,295 | 2024-12-31 | CENSUS_ACS5 |
| county 01125 | fmr | 4 | $1,548 | 2025-10-01 | HUD_USER_FMR |
| county 01125 | acs median gross | 5 | $1,338 | 2024-12-31 | CENSUS_ACS5 |
| county 01125 | acs median gross | $1,037 | 2024-12-31 | CENSUS_ACS5 | |
| county 01125 | acs recent mover gross | $1,177 | 2024-12-31 | CENSUS_ACS5 | |
| zcta 35476 | acs median gross | 1 | $932 | 2024-12-31 | CENSUS_ACS5 |
| zcta 35476 | acs median gross | 2 | $953 | 2024-12-31 | CENSUS_ACS5 |
| zcta 35476 | acs median gross | 3 | $1,105 | 2024-12-31 | CENSUS_ACS5 |
| zcta 35476 | acs median gross | 4 | $1,131 | 2024-12-31 | CENSUS_ACS5 |
| zcta 35476 | acs median gross | $963 | 2024-12-31 | CENSUS_ACS5 | |
| zcta 35476 | acs recent mover gross | $1,333 | 2024-12-31 | CENSUS_ACS5 | |
| zip 35476 | payment standard 110 | 0 | $1,023 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | payment standard 90 | 0 | $837 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | safmr | 0 | $930 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | payment standard 110 | 1 | $1,034 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | payment standard 90 | 1 | $846 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | safmr | 1 | $940 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | payment standard 110 | 2 | $1,243 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | payment standard 90 | 2 | $1,017 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | safmr | 2 | $1,130 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | payment standard 110 | 3 | $1,584 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | payment standard 90 | 3 | $1,296 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | safmr | 3 | $1,440 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | payment standard 110 | 4 | $1,650 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | payment standard 90 | 4 | $1,350 | 2025-10-01 | HUD_USER_SAFMR |
| zip 35476 | safmr | 4 | $1,500 | 2025-10-01 | HUD_USER_SAFMR |
ACS median gross rents and HUD FMR/SAFMR for the facility's county and ZIP. Context for underwriting, not facility pricing.