10. Capital and Reserve Requirement Information

As a broker-dealer registered with the SEC, our subsidiary VP Distributors, LLC ("VPD") is subject to certain rules regarding minimum net capital. VPD operates pursuant to Rule 15c3-1, paragraph (a) of the Securities Exchange Act of 1934 and, accordingly, is required to maintain a ratio of "aggregate indebtedness" to "net capital" (as those items are defined in the rule) which may not exceed 15.0 to 1.0.

Aggregate indebtedness, net capital, and the resultant ratio for VPD were as follows:


	December 31,
	2011		2010		2009
*($ in thousands)*
Aggregate indebtedness	$	17,527	$	19,315	$	13,142
Net capital		10,874		4,812		5,802
Ratio of aggregate indebtedness to net capital		1.6 to 1		4.0 to 1		2.3 to 1

VPD's minimum required net capital at December 31, 2011 and 2010 based on its aggregate indebtedness on those dates was $1.2 million and $1.3 million, respectively.

The operations of VPD do not include the physical handling of securities or the maintenance of open customer accounts. Accordingly, VPD is exempt from the reserve provisions of Rule 15c3-3 under the exemption allowed by paragraph (k)(2)(i) of such rule.