VCC 2026-4 ABS-15G

 

Exhibit 99.13

 

 

 

VCC 2026-4

 

Velocity Commercial Capital, LLC4

 
Opus Capital Markets Consultants, LLC

 

5599 San Felipe Street - Suite 420| Houston, TX 77056 | www.opuscmc.com | 224.632.1300 
 

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Executive Narrative

 

September 23, 2026

 

Performed by

Opus Capital Markets Consultants, LLC

 

For

Velocity Commercial Capital, LLC

 

This report summarizes the results of a due diligence review performed on (631) loans provided by Velocity Commercial Capital, LLC (“Client” or “VCC”) who provided Opus Capital Markets Consultants, LLC (Consultant) with a data tape, from which 100% of the loan sample was chosen and loaded into the LauraMac underwriting software. Consultant performed a Guideline credit review on three hundred fifty-nine (359) of the loans.

 

Opus conducted a review of the origination appraisal documentation for each loan and property not included in the Guideline Review. This encompassed six hundred thirty-one (631) loans representing six hundred sixty-one (661) properties.

 

For each loan and property, Opus reviewed the applicable appraisal to determine what the property condition was and if the appraiser indicated any damage or safety concerns at the time of the inspection.

 

Review Below Average Property Grade Properties with Visible Damage Properties with Health or Safety Issues
Property Review 2 9 0

 

As detailed herein, the Review Population contains 92 small balance commercial loans and 267 Investor 1-4 Family. The loans were re-underwritten in accordance with the lender guidelines in terms of Exhibit A. The review was conducted between July 9, 2025 through September 17, 2026, via imaged files and provided by the Client (the “Review.”)

 

The Review totals for mortgage loans within the final securitization population, were as follows:

 

Property Type Review Population Pool Population % Population Reviewed
Small Bal CRE 92 132 69.70%
Investor 1-4 Family 267 499 53.51%
Total 359 631 56.89%

 

The SBA loans below are a subset of the previous table.

 

Review Program Type Loan Type Review Population Pool Population % Population Reviewed
Guideline Review (Including Data Integrity) 504 1st SBA 6 6 100.00%
         
Total Guideline Review     6 6 100.00%

 

Notes: All of the loans in the guideline review received a Non-Owner Occupancy review

 

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Review Property Type Review Population Pool Population % Population Reviewed
Non-Owner Occupancy ("NOO") Investor 1-4 Family (not included in Guideline Review 232 499 46.49%
Total NOO Review   232 499 46.49%

 

DBRS, Inc. (“DBRS”) who is the NRSRO providing a rating on the transaction at the time of this disclosure, does not have published guidelines for this asset class.

 

The valuation review was split based on the underlying property type, either residential or commercial. All commercial mortgage loans were assigned an “A” NRSRO valuation grade. For this review, Opus did not order any secondary valuation products. However, the client requested a secondary valuation for 267 residential mortgage loans.

 

EXHIBIT A

 

Scope of Services:

 

Guideline Review

Opus will review the loan file for conformity of the items listed below to the underwriting guidelines that were provided to Opus by Client.

 

In the Guideline Review Population there were six (6) SBA mortgage loans. Opus conducted a review of the 6 SBA loans in accordance with the established guidelines. Our review process aligned with the same criteria used for the guidelines review.

 

Guideline Review: Opus will review each mortgage loan originated in accordance with guidelines provided by the Client to include if applicable:

 

Transaction type:

Borrower characteristicsLTV/CLTV/HTLTVProperty type
Loan characteristicsRepresentative credit score,Property usage
DSCR (if applicable)Asset reservesOccupancy 

 

Credit Application: For the Credit Application, Opus will review the application for: (i) was signed by all listed borrowers, (ii) was substantially filled out, and (iv) included the borrower’s employment history.

 

Credit Report: Opus’s review will include: the presence of a credit report for each borrower and that such borrower’s credit profile & representative credit score adhered to guidelines. 

 

Borrower Experience: Opus will review documentation provide, such as REO Schedule or Track Record and compare to guideline requirements, as applicable.  

 

Property Management Experience: Opus will review the property management questionnaire or other documentation to support the experience necessary per guidelines. 

 

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Business Entity Documents: Opus will review the Business Entity documentation provided as outlined and required per guidelines, which could include Articles of Incorporation, Articles of Organization, Operating Agreement, By-Laws, Certificate of Good Standing, Members Consent, or other documentation required by guidelines. 

 

Rent and/or Lease: Opus will review the lease or other acceptable documentation to support the rental amount as outline in the guidelines. 

 

Guarantor: Opus will review the guarantor as outlined in the guidelines

 

Asset Review: Opus will review the asset documentation provided in the loan files to the guideline requirements. Utilizing this documentation, Opus will complete a review of the reserve calculation. 

 

Hazard/Flood Insurance/Taxes: Opus will review the insurance present on the mortgage loan. During this review, as applicable per guidelines.

 

Occupancy Review: Opus will review the property occupancy is consistent with the mortgage loan approval and borrowers’ application disclosure based solely on information contained in the mortgage loan file and any fraud report obtained in connection with the mortgage loan. 

 

Business Purpose Affidavit: Opus will review for the present of affidavit confirming the property will be for commercial/investment purpose, including any cash out and they the subject property or any proceeds will not be for personal use. 

 

Environment Report: Reviewing environmental reporting, Flood Certification, and Evidence of Insurance to confirm accuracy and adherence to MCP requirements.

 

Background or Fraud Report: Opus will review the background or fraud report results in each mortgage loan file, to the extent present, in conjunction with source documents found in the mortgage loan file to assess the likelihood of any misrepresentations associated with the origination of the mortgage loan. If the mortgage loan file did not contain a fraud report and the counterparty did not produce one, Opus will condition the mortgage loan for the missing fraud report product.

 

Closing Document Review: Opus will review the closing documents are present, Borrower(s) names, Subject Property Address, Legal Description, Signed by Borrowers

 

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Loan File Documentation

 

Each loan file submitted to Opus for review should contain all documents used to underwrite, review, and close the loan.  This would include but not limited to the following (*where applicable): 

 

1008

1003 – Applications Initial

1003 – Application Final

AUS (DU/LP)

Loan Approvals

Underwriting worksheets

Income worksheets

Rate Lock

Change of Circumstances

Loan Estimates (LE)

Closing Disclosures (CD)

FACTA Disclosures

State Required Disclosures

Federal Required Disclosures

Signature tracking

Net Tangible Benefit Disclosure

Credit Report(s)

Fraud Report

OFAC Report (if not on credit)

Letter of Explanations

Borrower Identification

Business License*

Income Documentations

Asset Documentation

Appraisal(s)

Third Party Valuation (Desk Review/AVM/BPO/Field Review)

Purchase Contract

Environmental Reports

Non Owner Certification & Identification

Final CD/HUD1/Settlement Statement

Flood Insurance

Flood Certification

Mortgage Insurance

Right of Recession

Mortgage/Deed of Trust & Riders

Note & Addendums

Power of Attorney

Entity Documentation

Insurance

RE Tax Certification

Occupancy Affidavit

Business/Investment Purpose Affidavit

Title

Closing Protection Letter

HOA Information

Condo Documents

Guaranty Agreements*

Business P&L*

Business P&L*

Purchase Agreement*

Occupancy & Business Purpose LOI

Rent Roll *

Business Purpose Certification

Cash Out Letter

Verification of Mortgage/Rent

RE Taxes Information

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Non-Owner Occupancy Review

 

Occupancy Review: Opus will review the property occupancy is consistent with the mortgage loan approval and borrowers’ application disclosure based solely on information contained in the mortgage loan file and any fraud report obtained in connection with the mortgage loan. Additionally, Opus will complete the following:

 

Review the provided Note and Guaranty Agreement(s) to determine the identity and quantity of individuals serving as either Borrower, Co-borrower, or Guarantor, as well as to confirm whether the borrower and/or co-borrower is a legal business entity (LLC, INC, Corporation, Partnership) or an Individual(s).

 

Reviewing appraisal reports to determine if the property type is consistent with the underwritten property type, and evaluating the reports for evidence/indication of either owner or tenant occupancy.

 

For loans made to Individual borrowers, reviewing the LOI/LOE for the presence of an un-qualified statement of intent not to occupy the property, affirmation that the LOI/LOI cited address is consistent with the subject property address, and that signator(s) are consistent with the identified of the borrower(s)/guarantor(s). For loans made to Business Entity borrowers, the LOI/LOE is not a required document and loan file will not be cited if missing.

 

Reviewing the Final Form 1003/Loan application to ensure that the subject property listed is consistent with the subject property for the loan, and that the listed residence for the Individual(s) is an address other than the subject property.

 

For loans made to Individual borrowers, reviewing the Certification of Non-Owner Occupancy and Indemnity for the presence of a completed Primary Residence address including a verification that that the handwritten Primary Residence address differs from the subject property address, and is signed/dated as required. For loans made to Business Entity borrowers, the Certification of Non-Owner Occupancy and Indemnity is not a required document and loan file will not be cited if missing.

 

For loans made to Individual borrowers, verifying the presence of a complete Certification of Non-Owner Occupancy and Indemnity document for each individual borrower/co-borrower/guarantor identified within the subject note/guaranty agreement, including whether individual certifications or one certificate containing all required signatures is present. For loans made to Business Entity borrowers, the Certification of Non-Owner Occupancy and Indemnity is not a required document and loan file will not be cited if missing.

 

Confirming that the Primary Residence address(es) listed are compared for consistency between the Final Form 1003/Loan application(s) and the Certification(s) of Non-Owner Occupancy and Indemnity.

 

Documenting any exceptions and/or inconsistencies and reporting and/or marking such items for further dialogue.

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Valuation Review

 

Opus’s review will include a review of the valuation materials utilized during the origination of the loan and in confirming the value of the underlying property. 

 

Opus’s review will include:

●the appropriate form,

●materially complete

●the address matched the mortgage note,

●in conformity with the guideline requirements for the property type in question,

●completed by an appraiser that was actively licensed to perform the valuation,

●completed such that the named client on the appraisal report is the lender or a related entity that is permitted to engage the lender per Title XI of FIRREA,

●made and signed prior to the final approval of the mortgage loan application,

●completed and dated within the guideline restrictions,

●the current use of the property is legal or legal non-conforming (grandfathered)

●Photos present for Subject property and comparables

●the appraisal report does not include any apparent environmental problems

●made on an “as is” basis or provides satisfactory evidence of completion of all material conditions including all inspections, licenses, and certificates (including certificates of occupancy) to be made or issued with respect to all occupied portions of the mortgaged property and with respect to the use and occupancy of the same, have been made or obtained from the appropriate authorities.

 

FIRREA Title XI – Check for the presence of the appraiser’s license and review for the presence of any red flags that may pose a risk to the property or occupants

 

USPAP – Review the appraiser’s certification is present and executed within the original appraisal. 

 

Valuation Waterfall

 

Loan originated with a full Appraisal will review to the following:

 

●CU Score = < 2.5, no additional valuation required

●To comply with Rating Agency criteria of inspection, photos and supporting valuation, Client may require an AVM and/or 2055 Drive By Appraisal. Client will provide written notification to Opus of any additional valuation products required. 

●CU Score . 2.5 or not applicable, desk review or like product to support Appraisal value within a 10% tolerance

●If value is supported within 10% tolerance, nothing further is needed

●If value is not supported within 10% tolerance, additional valuations products may be used to support the value, such as but not limited to: Field Review, BPO, Reconciliation, 2055 or 2nd Appraisal

 

Only at Clients request and at Client’s expense, Opus can order any requested products for a Third Party Vendor that is currently set up to accept business from Opus. Alternately, Client may cause a third party velation products to be independently obtains by Opus from Client’s third party provider. If products are provided directly from Client and Opus does not have independent access, this will be noted in the Narrative.  

 

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Client expressly understands and agrees that Opus makes no representation or warrant as to the value of the subject property. Opus is not acting as an Appraisal Management Company and therefore it does not opine on the actual value of the subject property. Opus is not a ‘creditor’ within the meaning of ECOA or other lending laws and regulations, and therefore Opus will not have any communication with or responsibility to any individual consumer concerning property valuation.

 

Property Condition Review

 

The purpose of the Property Condition Review is to assess the overall condition of the subject property and identify any material concerns or red flags. This review is conducted using valuation products provided by the Client, with a focus on the following key areas:

 

Property Condition Assessment

●The Consultant shall verify that the property is reported to be in average or better condition

 

●If the property is identified as being in below average or worse condition, a Finding shall be issued

 

Property Damage Evaluation

●The Consultant shall review the Appraiser’s comments and photos to determine if any significant damage is present

 

●A Finding shall be issued if the estimated cost to cure exceeds 5% of the loan amount, up to a maximum of $20,000, or as otherwise specified in the applicable guidelines

 

Health and Safety Review

●Key Safety Aspects

 

Structural Integrity:

▪The home must be structurally sound, with no visible signs of major issues in the foundation, roof, or walls

 

Hazardous Materials:

●The property must be free of hazardous materials like asbestos and peeling lead-based paint, especially in older homes

 

Pest Infestations:

▪Evidence of termites or other pest infestations

 

Electrical Systems:

●There should be no exposed electrical wires or loose wiring, and outlets must be properly installed

 

Consultant will identify potential safety hazards, including:  

●Broken windows or doors

 

●Lack of handrails on stairs

 

●Signs of significant water damage or mold

 

Properties with cited health and safety/damage/deferred maintenance outside of VCC’s guideline allowance can be graded with a property condition “B” if there is an escrow holdback listed on the Settlement Statement/CD that covers the cost to cure for repairs.

 

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Data Comparison

 

Opus will perform a data compare review of data fields provided by the Client via loan tape mutually agreed upon by the Parties to the applicable source documents found in the actual file.  Opus will notate discrepancies in accordance with the tolerance levels provided by the Client. 

 

Number of Units Next Interest Rate Change Date Occupancy
Amortization Term ARM Initial Interest Rate Cap Interest Rate
Amortization Type ARM Initial Interest Rate Maximum Qualifying Loan Amount
Primary Appraised Property Value ARM Initial Interest Rate Minimum Qualifying LTV
Borrower First Name ARM Subsequent Interest Rate Cap Initial Monthly P&I Or IO Payment
Borrower Last Name ARM Lifetime Interest Rate Maximum Term
Property City ARM Lifetime Interest Rate Minimum Prepayment Penalty Total Term
Sales Price Property Type Prepayment Penalty Calculation
Calculated DSCR Lien Position Loan Purpose
First Interest Rate Change Date Final Qualifying Property Value Purpose of Refinance
First Payment Change Date Margin Qualifying FICO
ARM Rate Index Type Maturity Date Property State
Interest Only Flag Modification Flag Property Address
ARM Subsequent Interest Rate Change Frequency Note Date Property Zip Code

 

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Multiple Loans to One Borrower: TPR firm reviewed common identifiers for all loans in the population and confirmed there were sixteen (16) obligors with multiple loans in the pool.

 

Guideline Review

 

Tape Discrepancies

 

Data Element Count Accuracy
Amortization Term 5 98.61%
Total Number of Loans 359  

 

Loan Grading Definitions

 

Credit

 

S&P Moody’s Fitch Kroll DBRS Definition
A A A  A  A Loan conforms to all applicable guidelines, no conditions noted
B B B  B  B Loan does not meet every applicable credit guideline.  However, most of the loan characteristics are within the guidelines and there are documented and significant compensating factors
C C C  C  C The loan does not meet every applicable credit guideline, and most of the loan characteristics are outside of guidelines; or there are weak or no compensating factors
D D D  D  D The loan file is missing critical documentation required to perform the review

 

Property Valuation

 

Moody’s Fitch Kroll DBRS Definition
A A  A  A Value is within a 10% variance of third-party product. Appraisal meets lender guidelines. Subject property is 100% complete. Property condition is average or better. Standard GSE form was utilized. Appraiser is licensed. Appraisal is complete.
B B  B  B Meets all terms for an A, but property requires cosmetic or minor repairs that do not affect value or habitability
C C  C  C Any of the following items: Origination value and third-party valuation product value has a variance of 10% or greater, cannot validate value, property is incomplete, property condition is less than average, GSE form was not utilized, and/or the appraisal and/or does not meet guidelines
D D  D  D The loan file was missing the appraisal and/or other valuations products needed to complete the review

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S&P Definition
A First Level Review Value is within a 10% variance to the original appraisal. Appraisal meets lender guidelines. Subject property is 100% complete. Property condition is average or better. Standard GSE form was utilized. Appraiser is licensed. Appraisal is complete.
B First Level Review Value is greater than a 10% variance to the original appraisal, but the second level review value is within 10% variance of the original appraised value. In addition, property requires cosmetic or minor repairs that do not affect value or habitability
C Any of the following items: Second Level Review Value is greater than a 10% variance to the original appraisal, cannot validate value, property is incomplete, property condition is less than average, GSE form was not utilized, and/or the appraisal and/or does not meet guidelines
D The loan file was missing the appraisal and/or other valuations products needed to complete the review

 

Loan Review Findings

 

The following summarizes Consultant’s final loan securitization and event grades assigned to the final reviewed loan pool and reported in the Agency Grading Report dated September 23, 2026.

 

Overall Grade Summary    
DBRS and Kroll NRSRO Grade # of Loans % of Loans
A 149 41.50%
B 202 56.27%
C 8 2.23%
D 0 0.00%
     
     
Credit Grade Summary    
DBRS and Kroll NRSRO Grade # of Loans % of Loans
A 151 42.06%
B 206 57.38%
C 2 0.56%
D 0 0.00%
     
     
Property Grade Summary    
DBRS and Kroll NRSRO Grade # of Loans % of Loans
A 351 97.77%
B 2 0.56%
C 6 1.67%
D 0 0.00%

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GUIDELINE CREDIT REVIEW RESULTS

Of the three hundred fifty-nine (359) mortgage loans reviewed by Opus, two hundred six (206) were assigned a Credit grade of “B” and involved lender-issued guideline exceptions. A total of three hundred four (304) credit exceptions were granted.

 

Of the three hundred fifty-nine (359) mortgage loans reviewed by Opus, two (2) were assigned a Credit grade of “C”.

 

Additionally, 42.06% of the mortgage loans reviewed received a Credit grade of “A”.

 

GUIDELINE VALUATION REVIEW RESULTS

Of the three hundred fifty-nine (359) mortgage loans reviewed by Opus, two (2) were assigned a Valuation grade of “B” and involved lender-issued guideline exceptions. A total of two (2) valuation exceptions were granted.

 

Of the three hundred fifty-nine (359) mortgage loans reviewed by Opus, six (6) were assigned a Valuation grade of “C”.

 

Additionally, 97.77% of the mortgage loans reviewed received a Valuation grade of “A”.

 

Non-Owner Occupancy Review

 

Tape Discrepancies

 

Data Element Count Accuracy
Amortization Term 9 96.12%
Total Number of Loans 232  

 

Loan Grading

 

Overall Grade Summary    
DBRS and Kroll NRSRO Grade # of Loans % of Loans
A 232 100.00%
B 0 0.00%
C 0 0.00%
D 0 0.00%
     
     
Credit Grade Summary    
DBRS and Kroll NRSRO Grade # of Loans % of Loans
A 232 100.00%
B 0 0.00%
C 0 0.00%
D 0 0.00%

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N/O/O CREDIT REVIEW RESULTS

 

Of the two hundred thirty-two (232) mortgage loans reviewed by Opus, none (0) were assigned a property grade of “C”.

 

Additionally, 100.00% of the mortgage loans reviewed received a Credit grade of “A”.

 

Loans Reviewed: 631

 

532833 433700 750635 922777 814469 569416 210144 350011 796411
835582 243561 552717 572844 876761 387301 237696 428726 842389
820805 950407 718640 366258 134363 484909 809856 175498 333476
824536 608845 374856 658341 123605 606008 878905 765760 688017
292384 580943 298374 570644 426844 799270 673743 288407 198679
414003 584342 163986 975862 377381 766441 347047 505753 574784
898618 171417 354634 479413 397275 950117 152010 641231 688637
297211 956350 236847 162233 565519 677374 976136 613034 712925
188391 137019 168323 222912 543707 222404 653945 169190 794844
683931 141730 868081 483121 504423 536787 903364 270335 628767
989728 207694 498726 309187 919320 873956 936239 434766 353441
354283 205756 310159 651914 781207 643271 238471 723649 363251
961721 711504 623974 751843 296549 584295 378689 338305 115332
339702 359175 743477 191663 771758 359592 490828 346707 380644
403826 871443 411135 116016 954755 266797 983856 930106 580233
152528 318310 984024 213213 796675 236601 559243 305066 291573
117180 804460 292536 393509 712992 628642 397083 427484 419819
168719 963364 947729 889152 459372 772831 457324 526129 980245
423770 749666 171008 602708 202936 477331 706898 142036 530824
441168 475957 576357 329350 861803 591476 548748 463606 434363
758361 422913 974805 822923 845425 579402 136395 969211 840736
412061 905848 551643 600961 426480 300784 100815 164028 559340
724255 183267 275631 341660 839959 158989 986567 185934 903433
900540 120755 291010 956855 696939 885003 411362 384906 352595
228806 892933 302829 113094 928396 816954 905357 144686 297092
911775 729649 605801 749033 886579 245877 126833 566213 347497
315529 967580 603789 223442 220312 385560 108214 345127 694526
119491 615725 558739 618320 207786 640573 386949 433301 896829
642850 116984 219068 900414 577625 826446 390312 564532 974791
726053 292882 907018 659445 236072 909647 764213 960887 233485
885244 818550 894837 787520 743270 824511 281609 964486 873177
167176 762115 241037 400031 709193 400474 718028 586022 495856
409778 187232 858436 562634 830533 242031 450209 104560 428247
538783 698673 944456 430234 156327 243181 297409 646973 461423
458842 746410 869057 512760 920014 249479 941348 464825 676821
860020 473605 861042 127474 164881 515016 798733 402272 693173
800548 139185 617132 362748 496114 897523 469492 906565 519330
769378 550059 560487 855728 511790 886793 207765 845637 739297
714071 522714 920624 254405 102579 890387 613651 478646 522601
602103 267231 322840 266860 753161 514045 220554 436532 865094
662999 431793 117307 626665 884630 762350 950603 971393 126729
506220 634268 862101 832305 435346 538611 911861 327865 764080
506672 240080 591241 205847 204688 723077 288694 976274 532722
965492 403093 535618 326652 326901 251334 361857 470774 484060
868333 926900 578627 776651 495676 568434 395487 455637 823855
453912 551181 255240 377192 881592 146122 923828 400507 553635
149001 383149 425282 806467 406542 149710 379707 948073 191042
686386 106051 422523 941824 276475 347887 395978 926080 899963
751115 263138 804267 563904 973031 249457 614062 612449 190620
509465 952223 511354 587188 802472 478928 618765 227371 526852
944336 794086 463423 418631 365573 959240 239429 609964 454560
586389 622045 383173 582964 738804 664472 400823 101951 160121
137415 144483 826112 334736 658844 507041 699745 960443 837672
980927 773372 944716 849886 554225 596444 141459 917320 867055
649611 849592 811017 787264 907468 821064 974385 618782 411403
394672 510922 359793 937298 977863 183204 506333 886703 514918
364330 108590 836259 526448 425339 123721 414016 846377 292590
682717 318573 148926 806136 560436 617967 722189 371401 740656
425351 554016 808639 579517 665643 768344 426421 396142 169874
217343 825250 561338 547854 541834 527344 207847 368702 771323
972489 166303 803060 724550 666936 998820 442139 980182 197402
476755 921162 638295 888416 429217 516426 373024 571194 456669
304692 239287 728855 666249 852885 319214 497464 677956 952924
422519 650694 221751 397964 383767 989675 500431 111364  
863661 380102 441197 150289 139345 266294 834164 874383  
940468 639810 490519 542043 980281 141142 588162 904277  
753046 389433 314338 959205 293369 300178 207265 918997  
495169 543846 649701 399550 896053 670411 885391 524836  
310797 866906 934575 443547 662508 549753 578408 805344  
380752 845506 885850 973276 757952 426585 171875 538887  
942198 821158 800940 630870 603723 965842 333731 675001  

 

If you have any questions, please contact Uriah Clavier at Uriah.Clavier@opuscmc.com.

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