during the fourth quarter of 2019 , white mountains updated its debt service model for the bam surplus notes to reflect ( i ) the cash payments of principal and interest on the bam surplus notes made in december 2019 and january 2020 , ( ii ) the amendments made to the terms of the bam surplus notes in january 2020 , including an extension of the variable interest rate period , and ( iii ) in light of the current interest rate environment , a more conservative forecast of future operating results for bam . this has resulted in slower modeled future payments on the bam surplus notes and , in turn , a $ 20 million increase to the time value of money discount on the bam surplus notes as reflected in adjusted book value per share as of december 31 , 2019 . 28 nsm reported pre-tax loss of $ 2 million , adjusted ebitda of $ 48 million , and commission and other revenues of $ 233 million in the year ended december 31 , 2019. for the period from may 11 , 2018 , the date white mountains acquired nsm , to december 31 , 2018 , nsm reported pre-tax loss of $ 5 million , adjusted ebitda of $ 18 million , and commission and other revenues of $ 102 million . results for the year ended december 31 , 2019 include the results , from the date of acquisition , of embrace , a nationwide provider of pet health insurance for dogs and cats , which nsm acquired on april 1 , 2019 , and kbk , a specialized mgu focused on the towing and transportation space , which nsm acquired on december 3 , 2018. on april 4 , 2019 , white mountains completed the kudu transaction . for the twelve months ended december 31 , 2019 , kudu deployed $ 203 million , including transaction costs , in seven asset management firms and has now deployed a total of $ 266 million , including transaction costs , in nine asset management firms with combined assets under management of over $ 33 billion , spanning a range of asset classes , including real estate , real assets , wealth management , hedge funds and alternative credit strategies . for the period from april 4 , 2019 , the date of the kudu transaction , through december 31 , 2019 , kudu reported total revenues of $ 21 million and pretax income of $ 11 million . white mountains 's pre-tax total return on invested assets was 20.4 % for 2019 , which included a $ 115 million pre-tax unrealized investment gain from the mediaalpha transaction . excluding the mediaalpha transaction , white mountains 's pre-tax total return on invested assets was 15.5 % for 2019 , compared to -1.7 % for 2018. investment returns for 2019 benefited from the decision to increase white mountains 's equity exposure during the equity rout at the end of 2018 , the strong rally in equity markets over the course of the year , and strong other long-term investments results . the strong other long-term investment results were driven primarily by a $ 65 million increase in the fair value of white mountains 's investment in mediaalpha resulting from increases in profitability metrics since the mediaalpha transaction . investment returns for 2018 were adversely impacted by the sharp decline in equity markets in the fourth quarter . white mountains 's portfolio of common equity securities and other long-term investments returned 36.9 % for 2019 , which included the $ 115 million pre-tax unrealized investment gain from the mediaalpha transaction . excluding the mediaalpha transaction , white mountains 's portfolio of common equity securities and other long-term investments returned 25.7 % for 2019 , compared to -3.6 % for 2018. white mountains 's fixed income portfolio returned 6.1 % for 2019 , compared to 1.2 % for 2018. overview—year ended december 31 , 2018 versus year ended december 31 , 2017 white mountains ended 2018 with book value per share of $ 896 and adjusted book value per share of $ 888 , a decrease of 3.7 % and 2.8 % for the year , including dividends . comprehensive loss attributable to common shareholders was $ 146 million in 2018 compared to comprehensive income attributable to common shareholders of $ 631 million in 2017. the results for 2018 were driven primarily by investment results , which were adversely impacted by the sharp decline in equity markets in the fourth quarter of 2018. the results for 2017 were driven primarily by the $ 557 million gain from the onebeacon transaction . including the estimated gain of $ 55 per share for the mediaalpha transaction , december 31 , 2018 book value per share would have been $ 951 and adjusted book value per share would have been $ 943. had the mediaalpha transaction closed on december 31 , 2018 , white mountains 's book value per share would have increased 2.2 % and adjusted book value per share would have increased 3.2 % in 2018 , including dividends . during 2018 , white mountains repurchased and retired 592,458 of its common shares for $ 519 million at an average share price of $ 877. the average share price paid was approximately 98 % and 99 % , respectively , of white mountains 's december 31 , 2018 book value per share and adjusted book value per share . the average share price paid was approximately 92 % and 93 % , respectively , of white mountains 's december 31 , 2018 book value per share including the estimated gain of $ 55 per share from the mediaalpha transaction and adjusted book value per share including the estimated gain from the mediaalpha transaction . story_separator_special_tag bam 's claims paying resources increased to $ 871 million as of december 31 , 2018 from $ 708 million as of december 31 , 2017. the increase was driven primarily by the $ 100 million reinsurance agreement with fidus re , $ 54 million of msc collected and a $ 52 million increase in the invested assets of the hg re collateral trusts , partially offset by bam 's 2018 statutory net loss of $ 35 million . 37 hg global/bam balance sheets the following table presents amounts from hg global , which includes hg re and its other wholly-owned subsidiaries , and bam that are contained within white mountains 's consolidated balance sheet as of december 31 , 2019 and 2018 : replace_table_token_18_th ( 1 ) under gaap , the bam surplus notes are classified as debt by the issuer . under u.s. statutory accounting , they are classified as policyholders ' surplus . ( 2 ) under gaap , interest accrues daily on the bam surplus notes . under u.s. statutory accounting , interest is not accrued on the bam surplus notes until it has been approved for payment by insurance regulators . ( 3 ) hg global preferred dividends payable to white mountains 's subsidiaries is eliminated in white mountains 's consolidated financial statements . for segment reporting , the hg global preferred dividends payable to white mountains 's subsidiaries included within the hg global/bam segment are eliminated against the offsetting receivable included within the other operations segment , and therefore are added back to white mountains 's common shareholders ' equity within the hg global/bam segment . 38 replace_table_token_19_th ( 1 ) under gaap , the bam surplus notes are classified as debt by the issuer . under u.s. statutory accounting , they are classified as policyholders ' surplus . ( 2 ) under gaap , interest accrues daily on the bam surplus notes . under u.s. statutory accounting , interest is not accrued on the bam surplus notes until it has been approved for payment by insurance regulators . ( 3 ) hg global preferred dividends payable to white mountains 's subsidiaries is eliminated in white mountains 's consolidated financial statements . for segment reporting , the hg global preferred dividends payable to white mountains 's subsidiaries included within the hg global/bam segment are eliminated against the offsetting receivable included within the other operations segment , and therefore are added back to white mountains 's common shareholders ' equity within the hg global/bam segment . 39 nsm the following table presents the components of gaap net loss and adjusted ebitda included in white mountains 's nsm segment for the year ended december 31 , 2019 and the for the period of may 11 , 2018 to december 31 , 2018 : replace_table_token_20_th ( 1 ) see “ non-gaap financial measures ” on page 58 . 40 nsm results—year ended december 31 , 2019 versus the period from may 11 , 2018 to december 31 , 2018 for the year ended december 31 , 2019 , nsm reported gaap pre-tax loss of $ 2 million , adjusted ebitda of $ 48 million , and commission and other revenues of $ 233 million . for the period from may 11 , 2018 , the date white mountains acquired nsm , to december 31 , 2018 , nsm reported pre-tax loss of $ 5 million , adjusted ebitda of $ 18 million , and commission and other revenues of $ 102 million . nsm 's pre-tax loss included interest expense of $ 17 million and amortization of other intangible assets of $ 19 million in 2019 , compared to $ 8 million and $ 8 million , respectively , for the period from may 11 , 2018 to december 31 , 2018. broker commission expenses and general and administrative expenses were $ 65 million and $ 132 million for 2019 , compared to $ 28 million and $ 59 million , respectively , for the period from may 11 , 2018 to december 31 , 2018. nsm 's general and administrative expenses for 2019 included a $ 2 million impairment of intangible assets related to fresh insurance . nsm business trends the following is a discussion of the trends in nsm 's business including periods prior to white mountains 's ownership of nsm . white mountains believes this is useful in understanding the newly acquired business . nsm 's business consists of a number of active programs that are broadly categorized into six market verticals . the following table presents the controlled premium and commission and other revenues by vertical for the years ended december 31 , 2019 , 2018 and 2017 : replace_table_token_21_th ( 1 ) controlled premium are total premiums placed by nsm during the period . ( 2 ) controlled premium and commission and other revenue includes results prior to white mountains 's ownership of nsm . year ended december 31 , 2019 versus year ended december 31 , 2018 specialty transportation : nsm 's specialty transportation controlled premium and commission and other revenues increased significantly in 2019 , compared to 2018 , driven primarily by the acquisition of kbk in the fourth quarter of 2018 and an increase in contingent commissions and fees in 2019. kbk contributed $ 160 million of controlled premium and $ 32 million of commission and other revenues in 2019. real estate : nsm 's real estate controlled premium increased 16 % in 2019 , compared to 2018 , driven primarily by organic growth in both rate and units . the organic growth was driven by rate increases in the champ program , which offers insurance coverage for wind-exposed coastal condominium associations , combined with significant unit growth in nsm 's excess and surplus habitational program . nsm 's real estate commission and other revenues increased 15 % in 2019 , compared to 2018 , driven primarily by the increase in controlled premium , increases in rate and an

cash flows detailed information concerning white mountains 's cash flows during 2019 , 2018 and 2017 follows : cash flows from continuing operations for the years ended 2019 , 2018 and 2017 net cash flows used for continuing operations was $ 121 million , $ 31 million and $ 62 million for the years ended 2019 , 2018 and 2017 . cash used from continuing operations was higher in 2019 compared to 2018 , driven primarily by kudu 's deployments in asset management firms . cash used from continuing operations was lower in 2018 compared to 2017 , primarily due to $ 28 million of payments made in 2017 related to the departures of the company 's former chairman and ceo and former cfo . white mountains does not believe that these trends will have a meaningful impact on its future liquidity or its ability to meet its future cash requirements . the company and its intermediate holding companies had $ 603 million of net unrestricted cash , short-term investments and fixed maturity investments , $ 684 million of common equity securities and $ 202 million of private equity funds , hedge funds and ils funds as of december 31 , 2019 .


 Write a concise suspicious activity report of the following text delimited by triple backquotes. Return your response as a formal report which covers the key points highlighting the location,dates,entity names and account holder information in chronological order of the text.
     ```cash flows detailed information concerning white mountains 's cash flows during 2019 , 2018 and 2017 follows : cash flows from continuing operations for the years ended 2019 , 2018 and 2017 net cash flows used for continuing operations was $ 121 million , $ 31 million and $ 62 million for the years ended 2019 , 2018 and 2017 . cash used from continuing operations was higher in 2019 compared to 2018 , driven primarily by kudu 's deployments in asset management firms . cash used from continuing operations was lower in 2018 compared to 2017 , primarily due to $ 28 million of payments made in 2017 related to the departures of the company 's former chairman and ceo and former cfo . white mountains does not believe that these trends will have a meaningful impact on its future liquidity or its ability to meet its future cash requirements . the company and its intermediate holding companies had $ 603 million of net unrestricted cash , short-term investments and fixed maturity investments , $ 684 million of common equity securities and $ 202 million of private equity funds , hedge funds and ils funds as of december 31 , 2019 .
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 Suspicious Activity Report : during the fourth quarter of 2019 , white mountains updated its debt service model for the bam surplus notes to reflect ( i ) the cash payments of principal and interest on the bam surplus notes made in december 2019 and january 2020 , ( ii ) the amendments made to the terms of the bam surplus notes in january 2020 , including an extension of the variable interest rate period , and ( iii ) in light of the current interest rate environment , a more conservative forecast of future operating results for bam . this has resulted in slower modeled future payments on the bam surplus notes and , in turn , a $ 20 million increase to the time value of money discount on the bam surplus notes as reflected in adjusted book value per share as of december 31 , 2019 . 28 nsm reported pre-tax loss of $ 2 million , adjusted ebitda of $ 48 million , and commission and other revenues of $ 233 million in the year ended december 31 , 2019. for the period from may 11 , 2018 , the date white mountains acquired nsm , to december 31 , 2018 , nsm reported pre-tax loss of $ 5 million , adjusted ebitda of $ 18 million , and commission and other revenues of $ 102 million . results for the year ended december 31 , 2019 include the results , from the date of acquisition , of embrace , a nationwide provider of pet health insurance for dogs and cats , which nsm acquired on april 1 , 2019 , and kbk , a specialized mgu focused on the towing and transportation space , which nsm acquired on december 3 , 2018. on april 4 , 2019 , white mountains completed the kudu transaction . for the twelve months ended december 31 , 2019 , kudu deployed $ 203 million , including transaction costs , in seven asset management firms and has now deployed a total of $ 266 million , including transaction costs , in nine asset management firms with combined assets under management of over $ 33 billion , spanning a range of asset classes , including real estate , real assets , wealth management , hedge funds and alternative credit strategies . for the period from april 4 , 2019 , the date of the kudu transaction , through december 31 , 2019 , kudu reported total revenues of $ 21 million and pretax income of $ 11 million . white mountains 's pre-tax total return on invested assets was 20.4 % for 2019 , which included a $ 115 million pre-tax unrealized investment gain from the mediaalpha transaction . excluding the mediaalpha transaction , white mountains 's pre-tax total return on invested assets was 15.5 % for 2019 , compared to -1.7 % for 2018. investment returns for 2019 benefited from the decision to increase white mountains 's equity exposure during the equity rout at the end of 2018 , the strong rally in equity markets over the course of the year , and strong other long-term investments results . the strong other long-term investment results were driven primarily by a $ 65 million increase in the fair value of white mountains 's investment in mediaalpha resulting from increases in profitability metrics since the mediaalpha transaction . investment returns for 2018 were adversely impacted by the sharp decline in equity markets in the fourth quarter . white mountains 's portfolio of common equity securities and other long-term investments returned 36.9 % for 2019 , which included the $ 115 million pre-tax unrealized investment gain from the mediaalpha transaction . excluding the mediaalpha transaction , white mountains 's portfolio of common equity securities and other long-term investments returned 25.7 % for 2019 , compared to -3.6 % for 2018. white mountains 's fixed income portfolio returned 6.1 % for 2019 , compared to 1.2 % for 2018. overview—year ended december 31 , 2018 versus year ended december 31 , 2017 white mountains ended 2018 with book value per share of $ 896 and adjusted book value per share of $ 888 , a decrease of 3.7 % and 2.8 % for the year , including dividends . comprehensive loss attributable to common shareholders was $ 146 million in 2018 compared to comprehensive income attributable to common shareholders of $ 631 million in 2017. the results for 2018 were driven primarily by investment results , which were adversely impacted by the sharp decline in equity markets in the fourth quarter of 2018. the results for 2017 were driven primarily by the $ 557 million gain from the onebeacon transaction . including the estimated gain of $ 55 per share for the mediaalpha transaction , december 31 , 2018 book value per share would have been $ 951 and adjusted book value per share would have been $ 943. had the mediaalpha transaction closed on december 31 , 2018 , white mountains 's book value per share would have increased 2.2 % and adjusted book value per share would have increased 3.2 % in 2018 , including dividends . during 2018 , white mountains repurchased and retired 592,458 of its common shares for $ 519 million at an average share price of $ 877. the average share price paid was approximately 98 % and 99 % , respectively , of white mountains 's december 31 , 2018 book value per share and adjusted book value per share . the average share price paid was approximately 92 % and 93 % , respectively , of white mountains 's december 31 , 2018 book value per share including the estimated gain of $ 55 per share from the mediaalpha transaction and adjusted book value per share including the estimated gain from the mediaalpha transaction . story_separator_special_tag bam 's claims paying resources increased to $ 871 million as of december 31 , 2018 from $ 708 million as of december 31 , 2017. the increase was driven primarily by the $ 100 million reinsurance agreement with fidus re , $ 54 million of msc collected and a $ 52 million increase in the invested assets of the hg re collateral trusts , partially offset by bam 's 2018 statutory net loss of $ 35 million . 37 hg global/bam balance sheets the following table presents amounts from hg global , which includes hg re and its other wholly-owned subsidiaries , and bam that are contained within white mountains 's consolidated balance sheet as of december 31 , 2019 and 2018 : replace_table_token_18_th ( 1 ) under gaap , the bam surplus notes are classified as debt by the issuer . under u.s. statutory accounting , they are classified as policyholders ' surplus . ( 2 ) under gaap , interest accrues daily on the bam surplus notes . under u.s. statutory accounting , interest is not accrued on the bam surplus notes until it has been approved for payment by insurance regulators . ( 3 ) hg global preferred dividends payable to white mountains 's subsidiaries is eliminated in white mountains 's consolidated financial statements . for segment reporting , the hg global preferred dividends payable to white mountains 's subsidiaries included within the hg global/bam segment are eliminated against the offsetting receivable included within the other operations segment , and therefore are added back to white mountains 's common shareholders ' equity within the hg global/bam segment . 38 replace_table_token_19_th ( 1 ) under gaap , the bam surplus notes are classified as debt by the issuer . under u.s. statutory accounting , they are classified as policyholders ' surplus . ( 2 ) under gaap , interest accrues daily on the bam surplus notes . under u.s. statutory accounting , interest is not accrued on the bam surplus notes until it has been approved for payment by insurance regulators . ( 3 ) hg global preferred dividends payable to white mountains 's subsidiaries is eliminated in white mountains 's consolidated financial statements . for segment reporting , the hg global preferred dividends payable to white mountains 's subsidiaries included within the hg global/bam segment are eliminated against the offsetting receivable included within the other operations segment , and therefore are added back to white mountains 's common shareholders ' equity within the hg global/bam segment . 39 nsm the following table presents the components of gaap net loss and adjusted ebitda included in white mountains 's nsm segment for the year ended december 31 , 2019 and the for the period of may 11 , 2018 to december 31 , 2018 : replace_table_token_20_th ( 1 ) see “ non-gaap financial measures ” on page 58 . 40 nsm results—year ended december 31 , 2019 versus the period from may 11 , 2018 to december 31 , 2018 for the year ended december 31 , 2019 , nsm reported gaap pre-tax loss of $ 2 million , adjusted ebitda of $ 48 million , and commission and other revenues of $ 233 million . for the period from may 11 , 2018 , the date white mountains acquired nsm , to december 31 , 2018 , nsm reported pre-tax loss of $ 5 million , adjusted ebitda of $ 18 million , and commission and other revenues of $ 102 million . nsm 's pre-tax loss included interest expense of $ 17 million and amortization of other intangible assets of $ 19 million in 2019 , compared to $ 8 million and $ 8 million , respectively , for the period from may 11 , 2018 to december 31 , 2018. broker commission expenses and general and administrative expenses were $ 65 million and $ 132 million for 2019 , compared to $ 28 million and $ 59 million , respectively , for the period from may 11 , 2018 to december 31 , 2018. nsm 's general and administrative expenses for 2019 included a $ 2 million impairment of intangible assets related to fresh insurance . nsm business trends the following is a discussion of the trends in nsm 's business including periods prior to white mountains 's ownership of nsm . white mountains believes this is useful in understanding the newly acquired business . nsm 's business consists of a number of active programs that are broadly categorized into six market verticals . the following table presents the controlled premium and commission and other revenues by vertical for the years ended december 31 , 2019 , 2018 and 2017 : replace_table_token_21_th ( 1 ) controlled premium are total premiums placed by nsm during the period . ( 2 ) controlled premium and commission and other revenue includes results prior to white mountains 's ownership of nsm . year ended december 31 , 2019 versus year ended december 31 , 2018 specialty transportation : nsm 's specialty transportation controlled premium and commission and other revenues increased significantly in 2019 , compared to 2018 , driven primarily by the acquisition of kbk in the fourth quarter of 2018 and an increase in contingent commissions and fees in 2019. kbk contributed $ 160 million of controlled premium and $ 32 million of commission and other revenues in 2019. real estate : nsm 's real estate controlled premium increased 16 % in 2019 , compared to 2018 , driven primarily by organic growth in both rate and units . the organic growth was driven by rate increases in the champ program , which offers insurance coverage for wind-exposed coastal condominium associations , combined with significant unit growth in nsm 's excess and surplus habitational program . nsm 's real estate commission and other revenues increased 15 % in 2019 , compared to 2018 , driven primarily by the increase in controlled premium , increases in rate and an

