From The Surplus Line Association of Oregon

Transcription

1 July 2012 Editor, Larry Boyd Graphics and Layout, Carolee Lance SLAOR News: N Results year to date through May show premiums off 28.4 % for the year to date while the national trend shows a slight increase in rates overall. One could assume this indicates that the NRRA is shifting between 20% and 30% premiums away from Oregon to other home states. However, new and renewal policy count is off % and this should be a more reliable indication of NRRA impact. I m guessing that the combination of the two indices reflects a shifting policy count which sends 16% of policies to another Home State and the greater premium reduction reflects the fact that the multi state policies being shifted to another Home State bear greater average premiums than the overall Oregon average per policy. Year to date operations including investment income realized and unrealized show a year to date income of $10 k. Operations for the five months showed a loss of $2.3 k. ational News: Big Corporate Political Spenders Often Worst Market Performers: Study Despite a popular belief that spending on lobbyists and political gifts yield fat dividends for business, a study has found just the opposite that in general, higher corporate spending in Washington is linked to worse market performance. Researchers from Rice University in Texas and Long Island University in New York analyzed end of year stock value and return on assets of 943 companies in the S&P 1500 over eleven years and lined up those factors against spending on campaign donations, lobbyists and other political giving. The researchers looked at some $5 billion in spending from 1998 to 2008 in their study that will be published in the fall. Their findings showed that on average, the more a company shelled out for government affairs and political interests at the federal level, the worse it performed financially. If you look at most of the literature on business management and strategy, the implication is that these investments really pay off, Doug Schuler, study co author and professor of business and public policy at Rice, told Reuters. But we found a really persistent negative relationship between political activity and market performance, he said. The research also found that in terms of return on sales, higher political spending on average had either marginally negative, or statistically insignificant impacts. The only instance of benefit was over time in those industries researchers found substantially regulated, such as oil, telecommunications, insurance or utilities representing about 10% of the companies they considered. If you re regulated and for many years you keep repeatedly investing in (political activity), then you ll realize some return on your investments. Then, and only then, it makes financial sense, said Michael Hadani, co author of the study and assistant professor of management at Long Island University. The study also found little financial benefit in putting former federal or state officials, such as ambassadors or secretaries, on corporate boards of directors. Looking at 72 firms with politically tied directors in their sample, researchers again linked their presence to inferior market and accounting performance. The study, titled In Search of El Dorado: The Elusive Financial Returns on Corporate Political Investments is expected to be published in the Strategic Management Journal. Why do people who know the least know it the loudest? 1

2 N ational News (): Ex-Partner Sues Dewey, Says Law Firm Was Ponzi Scheme A former partner at Dewey & LeBoeuf has sued a group of the law firm s ex leaders for fraud, saying they ran the now bankrupt firm as a Ponzi scheme to benefit themselves. Henry Bunsow, an intellectual property lawyer in San Francisco, said in court papers that former Dewey Chairman Steven Davis and other one time members of top management sought to misrepresent the firm s financial performance and stability as they tried to recruit partners at other firms. Management was running a Ponzi scheme in order to enrich themselves and select members of Dewey, Bunsow said in the complaint, filed Tuesday in California Superior Court in San Francisco. The case is the first lawsuit to be made public by a former partner against Dewey or its former management in the wake of the firm s Chapter 11 bankruptcy filing last month. Formerly one of the largest U.S. law firms, the firm collapsed amid a high debt load and a raft of partner defections this year. Defendants in the lawsuit include Davis; Jeffrey Kessler, the former head of litigation; Joel Sanders, the former chief financial officer; Stephen DiCarmine, its former executive director; and James Woods, a one time executive committee member. Davis, through a spokeswoman, declined to comment, as did Ned Bassen, a lawyer for DiCarmine. Kessler, now a partner at Winston & Strawn, said in an that the allegations about him were outrageous, untrue and without the slightest bit of merit. It is sad that Mr. Bunsow, who received more of his compensation for 2011 than I did, would lash out with such false allegations against me, Kessler wrote. The other defendants or their representative did not respond to requests for comment. Ronald Souza, a lawyer for Bunsow, also did not respond to a request for comment. Bunsow is now with law firm Bunsow De Mory Smith Allison in San Francisco. The lawsuit was first reported by The American Lawyer. Bunsow joined Dewey in January 2011 from Howrey, a law firm that filed for bankruptcy later that year. In his complaint, he said Dewey s management lured him to join the firm with a promise of $5 million a year in guaranteed compensation. But he said Davis and others knew they would be unable to keep that promised guarantee in view of the huge debt of guaranteed income then owed to prior partners. Bunsow said that in conversations before joining Dewey, Dewey s management assured him about the firm s financial condition, with Davis stating he expected its profits per partner to hit $2million for But he said the defendants misrepresented Dewey s financial picture. Bunsow said Dewey s management conspired to deprive partners of their capital investments in the firm and instead selectively distributed those investments to themselves and others. He said he suffered $7.55 million in damages as a result of losing capital he invested in the firm and not being paid owed compensation and other benefits. Davis has been the focus of an investigation by Manhattan District Attorney Cyrus Vance into his oversight of Dewey. He has denied wrongdoing. A Dewey bankruptcy lawyer, Albert Togut, said at a May 29 hearing in U.S. Bankruptcy Court in Manhattan that the firm was fully cooperating with the New York probe. Several Dewey partners have retained lawyers in anticipation of being sued by the firm s bankruptcy estate and to consider bringing their own claims against Dewey and its principals. On Wednesday, the firm reached a deal with lenders on a budget to fund the bankruptcy through July. Dewey lawyer Togut said at a bankruptcy hearing that the primary task now for the parties was to seek a settlement under which hundreds of former partners would pay Dewey varying amounts for creditor paybacks. Bunsow s case is Bunsow v. Davis, Superior Court of the State of California, County of San Francisco, No CHC The bankruptcy case is In re Dewey & LeBoeuf LLP, U.S. Bankruptcy Court, Southern District of New York, No If someone comes up to you and tells you that they're an obsessive compulsive liar, how do you know they're telling the truth? 2

3 N ational News (): Last Loans Used to Buy AIG, Bear Stearns Assets Repaid: Fed Reserve The Federal Reserve Bank of New York said on Thursday the last of its loans made to acquire risky assets from AIG and Bear Stearns during the financial crisis have been paid off with interest. The Fed bank acquired the assets in the portfolio known as Maiden Lane III in the 2008 government rescue of U.S. insurer American International Group Inc. It acquired the Maiden Lane I assets from Bear Stearns around the time of its takeover. The original loans totaled just over $53 billion. The New York Fed will continue to sell assets remaining in the Maiden Lane I and III portfolios as market conditions warrant and if the sales represent good value for the public, it said, adding there is no fixed time frame for the sales. Proceeds from Maiden Lane I sales will be used to retire a loan from JPMorgan Chase & Co., after which the Fed bank logs the profits. Proceeds from Maiden Lane III sales will be used to repay AIG s equity contribution, after which the New York Fed will receive two thirds of residual profits. As of June 6, the outstanding principal and interest due to AIG was about $5.6 billion. We are extremely encouraged by the continued progress our partners at the Federal Reserve and U.S. Treasury have made to profitably reduce the U.S. government s investments in AIG, AIG Chief Executive Bob Benmosche said in a statement. The repayment of the Maiden Lane III loan in particular is the latest unexpected twist in the AIG saga, which began with a last minute rescue in Sept Part of the ultimate rescue package was the Nov creation of Maiden Lane III, a facility that eased some of AIG s obligations by buying collateralized debt obligations from the company s counterparties. The Fed put up $24.3 billion and AIG put in another $5 billion. In exchange for being bought out at 100 cents on the dollar, the counterparties agreed to terminate credit default swaps with AIG s Financial Products unit. Many people criticized it as a back door bailout of the banks with which AIG did business, but the deal was also seen as crucial to buying the company more time for a planned fire sale of its assets. That fire sale never came to pass, though. Starting in late 2009, AIG embarked on a different course, shedding some assets while strengthening others. AIG will profit on the rest of the MLIII sales because of the way the deal was originally structured. After all the loans from both parties are repaid, the Fed and AIG split any proceeds, with the company getting one third of the money. With the Maiden Lane facilities resolved, the balance of AIG s obligation to the government is the U.S. Treasury s 61% stake in the company. Allegedly from hospital charts: The patient refused autopsy. The patient has no previous history of suicides. Patient has left white blood cells at another hospital. She has no rigors or shaking chills, but her husband states she was very hot in bed last night. Patient has chest pain if she lies on her left side for over a year. 3

4 N ational News (): NAPSLO Legislative Update (as of June 1, 2012) states have taken action to implement the NRRA: 33 states have either implemented home state approach or have no current plans to participate in tax sharing arrangements, representing 73% of nationwide premium. 15 states and Puerto Rico are working toward tax sharing through two inconsistent tax sharing approaches. Following the withdrawals of Nebraska, Connecticut, Mississippi, Alaska and Hawaii, the Nonadmitted Insurance Multi State Agreement (NIMA) includes Florida, Louisiana, Nevada, Utah, Wyoming, South Dakota and Puerto Rico. The Surplus Lines Insurance Multi State Compliance Compact (SLIMPACT) includes Alabama, Indiana, Tennessee, Kentucky, Kansas, New Mexico, North Dakota, Vermont and Rhode Island. In total, the current NIMA and SLIMPACT states represent just 23% of nationwide premium. [Nevada has subsequently dropped out of NIMA - ed.] Two states and the District of Columbia have not yet taken action to implement the NRRA through either legislation or interim regulation representing just 4% of nationwide premium. The updated tax sharing map is available from the NRRA Resources Compliance link of the NAPSLO Website. 2. On May 22nd, NIMA Inc. announced the adoption of the Kentucky premium allocation methodology by the seven states and Puerto Rico who are members of NIMA. The adopted allocation methodology, which is based on a proposal initially created by the Kentucky Department of Insurance and referred to as the "Kentucky Compromise, excludes the majority of casualty surplus lines premium from multi state allocation. Instead, the home state continues to collect most surplus lines tax for casualty insurance unless a casualty policy is rated on a state or location specific basis. Notices were sent to all NAPSLO members on May 25th and June 12th alerting them of NIMA s actions and continued plans for the July 1, 2012 effective date. [Where is the uniformity? we now have at least three classification tables of coverage to use in reporting: none, Kentucky, suggested by NIMA, state based (as Oregon does); three responses for reporting allocations: no allocation, NIMA, SLIM PACT. ed.] 3. NAPSLO has posted updated bulletins regarding filing surplus lines taxes from the Mississippi, Alaska, Connecticut, Louisiana, South Dakota and Utah insurance departments on the NRRA Resources link on the NAPSLO website. The bulletins track the guidance offered by the states, who were or are part of NIMA, in preparation for the July 1 start of operations of the Surplus Lines Clearinghouse. The bulletins and other important NAPSLO updates can be found at 4. NAPSLO continues to contact certain states in hopes of reform in states currently taxing at the other state s rates on multi state risks. Georgia and Oklahoma have issued revised guidance in 2012 to tax 100% of the gross premium at their own tax rate when they are the home state of the insured. 5. NAPSLO, in coalition with several other trades, has reached out to the NAIC regarding concerns with the nationwide uniform implementation of the insurer eligibility standards of the NRRA. At present, the NAIC has reported plans to address this issue at its Surplus Lines Task Force. NAPSLO continues to update the NRRA Resources link on the NAPSLO website to provide a user friendly interface to NRRA compliance information and ongoing NRRA updates. Check out their legislative updates and E News releases for informative updates on the NRRA s implementation and helpful information. Should you have questions or need any additional information, contact the NAPSLO office at (816) Should bankruptcy lawyers expect to be paid? 4

5 The Marketplace Commercial Insurance Prices Continue to Rise: Towers Watson Commercial insurance prices in aggregate increased by nearly five% during the first quarter of 2012, the fifth consecutive quarter that prices rose. In addition, commercial insurers loss ratios stabilized for most insurance lines and improved in lines with the largest price increases, according to the most recent Commercial Lines Insurance Pricing Survey (CLIPS) by global professional services company Towers Watson. The survey compared prices charged on policies underwritten during the first quarter of 2012 to those charged for the same coverage during the same quarter in CLIPS data revealed that the largest price increases were once again in workers compensation and commercial property. Workers compensation prices increased for the fifth consecutive quarter, after flat pricing in all of 2010, while commercial property prices rose for the fourth consecutive quarter. We are seeing a continuing trend of price level increases in the commercial insurance marketplace, said Thomas Hettinger, property/casualty sales and practice leader for the Americas at Towers Watson. This quarter, the industry reached a significant threshold an aggregate price increase of nearly five% the largest quarterly increase we ve seen since Price increases were observed across all account sizes for standard commercial lines, with the most significant increases observed in mid market accounts. Specialty lines lagged, with much more modest increases of less than 2%. Historical loss cost information reported by participating carriers points to a deterioration of less than 1% in loss ratios for accident year 2012 data compared with 2011, a more favorable indication than the estimated 3% deterioration between 2010 and Towers Watson said data from the lines with the largest price increases workers compensation, commercial property and general/products liability indicate improving loss ratios. We are likely to see improving loss ratios in the near future if this level of price increases and loss trends continues, said Hettinger. This would be welcome news for the insurance industry, which has been dealing with low asset returns and significant catastrophe activity for the last few years. CLIPS data are based on both new and renewal business figures obtained directly from carriers underwriting the business. Data were contributed by forty participating insurers representing approximately 20% of the U.S. commercial insurance market. The Washington Post recently had a contest wherein participants were asked to tell the younger generation how much harder they had it "in the old days". Winners, runners up, and honorable mentions are listed below. Second Runner Up: In my day, we couldn't afford shoes, so we went barefoot. In winter, we had to wrap our feet with barbed wire for traction. First Runner Up: In my day, we didn't have MTV or in line skates, or any of that stuff. No, it was 45 s and regular old metal wheeled roller skates, and the 45 s always skipped, so to get them to play right you'd weigh the needle down with something like quarters, which we never had because our allowances were way too small, so we'd use our skate keys instead and end up forgetting they were taped to the record player arm so that we couldn't adjust our skates, which didn't really matter because those crummy metal wheels would kill you if you hit a pebble anyway, and in those days roads had real pebbles on them, not like today. And the winner: In my day, we didn't have rocks. We had to go down to the creek and wash our clothes by beating them with our heads. Honorable Mentions: In my day, we didn't have fancy health food restaurants. Every day we ate lots of easily recognizable animal parts, along with potatoes. In my day, we didn't have hand held calculators. We had to do addition on our fingers. To subtract, we had to have some fingers amputated. In my day, we didn't get that disembodied, slightly ticked off voice saying 'Doors closing.' We got on the train, the doors closed, and if your hand was sticking out, it scraped along the tunnel all the way to the next station and it was a bloody stump at the end. But the base fare was only a dollar. 5

6 The Marketplace (): P/C Industry Should Not Expect Traditional Hard Market Soon: Hartwig Although insurance rates have been drifting upward in recent months, the property/casualty industry is unlikely to see a return to the traditional hard market this year or next, an insurance expert told reinsurance actuaries at the Casualty Actuarial Society s Seminar on Reinsurance. Robert Hartwig, president and economist of the Insurance Information Institute, noted that four criteria have to be present for a truly hard market, one in which rates climb sharply in excess of 10% to 15% or more: First, the industry must endure a sustained period of large underwriting losses. Only when underwriting losses are large and sustained do insurers turn disciplined, Hartwig said. Second, the industry suffers a material decline in industry surplus or capacity. When surplus falls, rates rise as customers compete for access to the surplus. But industry surplus remains high, Hartwig said, hitting a record $565 billion as of first quarter 2011 and falling off only slightly during 2011, despite all the catastrophic losses. Third, the reinsurance market must be tight, meaning reinsurance costs are rising and there is a shortage of reinsurance capital. Reinsurance rates have risen, especially in markets where the mega catastrophes occurred. And in the United States, reinsurance prices for catastrophe business are modestly higher, Hartwig said, about 8%. But the current increases pale in comparison to increases seen after other bad years for catastrophe, he observed. After Hurricane Andrew, the 1993 catastrophe market suffered tremendous dislocation, Hartwig said, with rates rising 68%. After Hurricane Katrina, rates rose 76%. More important, the current environment contradicts this notion that somehow big catastrophe losses are somehow [by themselves] going to affect prices here, he said. That notion is incorrect. Finally, the industry must show renewed underwriting and pricing discipline. There are some signs this is beginning to happen, Hartwig said. Rates are creeping up in commercial lines, after having fallen steadily for several years. Commercial insurance rates rose 4.4% in the first quarter, which was the third consecutive quarter of higher rates, according to the Council of Insurance Agents and Brokers. That followed thirty consecutive quarters of declining rates. Of all lines, workers compensation rates are rising fastest, up 7.4% in first quarter. But that s in part because results have deteriorated so much in that line. Workers compensation insurance combined ratios were 110.6, and over the past three years, vs. 99.5, and on commercial lines overall. Workers compensation results are as bad as they were a decade ago, he said, the last time the industry experienced a hard market. ** Adult Truths *** I think part of a best friend's job should be to immediately clear your computer history if you die. Nothing worse than that moment during an argument when you realize you're wrong. 3. I totally take back all those times I didn't want to nap when I was younger. 6

7 The Marketplace (): How Predictive Modeling Has Revolutionized Insurance The use of predictive modeling has forever changed the way insurance policies are priced. The revolutionary tool allows insurers to design ever more sophisticated models that tap ever more detailed data sets to refine precisely how much each customer should be charged. Casualty actuaries got an overview of how far the revolution has come and how it will continue to change insurance pricing at the session The Revolution and Evolution of Predictive Modeling presented at the Casualty Actuarial Society Spring Meeting, in Phoenix recently. Claudine Modlin, a senior consultant at Towers Watson, laid out how far predictive analytics has advanced insurance pricing in the past decade. Steven Armstrong, a fellow of the Casualty Actuarial Society, laid out a variety of ways those same tools and skills could improve insurance operations beyond the pricing function. At the end of the 20th century, Modlin said, insurers were still bound to mainframe computers and highly aggregated data sets. Rating plans were less sophisticated and it was easy for a company to understand its competitors plans. And the rating plans were finalized based on the collective judgment of underwriters and actuaries, with little datadriven guidance in how and where to deviate from the expected costs. Today, insurers use a variety of predictive analytic tools to hunt through gigabytes of data to find variables sometimes non intuitive ones that hold clues to a customer s riskiness and purchasing behavior. Generalized linear models (GLMs) have become the global industry standard for pricing segmentation. This is due in large part to the multivariate framework, the multiplicative nature of rating plans, and the high degree of transparency in the results. As an industry, we have really learned a lot, Modlin said. We have advanced our toolkit. The use of insurance credit scores was one of the great new loss predictors over the last two decades and the ongoing search for the next great loss predictor has increasingly become the norm. As insurers follow the information revolution, they are improving the quality and accessibility of their internal data, investigating third party data sources, and investing more computing power to harness the information. This has led some companies to investigate thousands of predictors including such things as what other policies an insured has, whether they pay their bills on time, and various characteristics of the area in which the risk is located. Interpreting a large list of related variables requires more refined methods. Modelers employ a variety of techniques to cull the list of potential predictors. The process of variable reduction involves a lot of business judgment but is frequently supplemented with data mining techniques such as principle components analysis or classification and regression trees. Within the GLM exercise, modelers use a blend of statistical diagnostics, practical tests and our business acumen to select predictive factors, Modlin said. Companies looking to refine their GLMs further pay significant attention to identifying interaction variables and to mining GLM residuals in order to improve the pricing of certain high dimension variables (e.g., territory and vehicle groups). And in auto insurance, the revolution is moving even further, as insurers start to use telematics gathering information about a customer s driving behavior from a device attached to the vehicle. Information will flow in, virtually moment by moment, Modlin said. Do you slam on the brakes? Do you peel around corners? If talk is cheap, why is my phone bill so high? 7

8 The Marketplace (): As much of the industry has refined its approach to estimating loss costs, the use of science to understand customer demand lags behind. GLMs are a suitable technique for this as well. The challenge here is to capture customer attributes as well as price related information (e.g., quote offered at new business or price change offered at renewal) that will provide useful insights into customer elasticity. The next evolutionary stage for pricing sophistication is for companies to learn to integrate their cost estimates with knowledge of customer behavior. This can involve scenario testing possible rate changes and measuring the effect on key performance indicators, taking the effect of customer behavior into account. Scenario testing in its ultimate form involves price optimization techniques that systematically integrate cost and demand in order to indicate an optimal set of prices that meets or exceeds corporate objectives for profitable growth while staying within company constraints. But use of predictive models doesn t have to end with ratemaking, said Armstrong in his presentation. The models can help other aspects of the insurance organization. And as they do, actuaries can follow them, helping explain how the models work and what potential they contain. You have this pricing tool kit, he said. I want you to think beyond pricing and help solve business problems. For example, predictive models could likely help underwriters work more efficiently. Right now, underwriting tends to follow rules with limited flexibility. For auto insurance, for example, young drivers receiving good student discounts have to regularly turn in copies of their grades. Predictive modeling could show, perhaps, that some types of students don t need to perpetually update, while others would. Models could also help underwriters in other lines, Armstrong said helping determine which workers compensation risks should be tapped for a premium audit. Predictive modeling could also help marketing by researching what mix of social media grows the customer base or what brand attributes drive new business. The concept isn t new to marketers, but the actuarial skill set can enhance understanding of the work. And claims departments swim in a vast, vast pool of data, Armstrong said, that only awaits discovery claims diaries, records on attorney involvement, and information on service providers and adjusters. Predictive models could answer questions such as: If a damaged auto gets to the body shop a day sooner, will it affect claim severity? What sorts of claims are driving costs higher? What sorts of claims should be reported to the special investigations unit for potential fraud? Can one pick out potential fraudsters during the underwriting process? The models could also assist sales departments (What s the best spot to start a new agency?), human resources (How long is a new employee likely to remain with the company?) or expense management (What underwriting reports are cost effective?). The list of areas where actuaries could help insurers quantify and understand their operations seems limitless, Armstrong said. Wherever there is data, there is opportunity, Armstrong said. Who is more foolish, the fool, or the fool who follows him? 8

9 The Marketplace (): P/C Insurers Profits Rose to $10.1B in Q1 Private U.S. property/casualty insurers net income after taxes rose to $10.1 billion in first quarter 2012 from $7.8 billion in first quarter 2011, with insurers overall profitability as measured by their annualized rate of return on average policyholders surplus climbing to 7.2% from 5.6%. Driving the increases in insurers net income and overall rate of return, net losses on underwriting receded to $0.2 billion in first quarter 2012 from $4.5 billion in first quarter The combined ratio a key measure of losses and other underwriting expenses per dollar of premium improved to 99% in first quarter 2012 from 103.3% in first quarter 2011, according to ISO, a Verisk Analytics company (Nasdaq:VRSK), and the Property Casualty Insurers Association of America (PCI). The improvement in underwriting results is primarily attributable to a drop in net losses and loss adjustment expenses (LLAE) from catastrophes. ISO estimates that insurers net LLAE from catastrophes fell to $3.4 billion in first quarter 2012 from $6.6 billion in first quarter Those amounts exclude LLAE that emerged after insurers closed their books for each period but do include late emerging LLAE from events in prior periods. Partially offsetting the improvement in underwriting results, net investment gains the sum of net investment income and realized capital gains (or losses) on investments dropped $1.2 billion to $12.3 billion in first quarter 2012 from $13.6 billion in first quarter Also limiting the improvement in insurers overall results, insurers miscellaneous other income receded to $0.4 billion in first quarter 2012 from $0.5 billion in first quarter 2011, and insurers federal and foreign income taxes rose to $2.3 billion from $1.8 billion. Subject: Life's laws Law of the Bath When the body is fully immersed in water, the telephone rings. Law of Close Encounters The probability of meeting someone you know increases dramatically when you are with someone you don't want to be seen with. Law of the Result When you try to prove to someone that a machine won't work, it will. Law of Biomechanics The severity of the itch is inversely proportional to the reach. Law of the Theatre & Football At any event, the people whose seats are furthest from the aisle, always arrive last. They are the ones who will leave their seats several times to go for food, beer, or the toilet and who leave early before the end of the performance or the game is over. The folks in the aisle seats come early, never move once, have long gangly legs or big bellies and stay to the bitter end of the performance. The aisle people also are very surly folk. Please share this NewsLetter with your staff Thanks Editor s note: The SLAOR NewsLetter is compiled from press releases and news articles published in industry publications such as Advisen FPN, The Insurance Journal and Business Insurance among others. The opinions expressed in this newsletter are those of the Editor and do not reflect an official position of The Surplus Line Association of Oregon unless so noted The Surplus Line Association of Oregon NewsLetter is published monthly by SLAOR, 7360 SW Hunziker Street, Suite 105, Portland, OR Phone: , Fax: Previous issues of this newsletter are available on the SLAOR website at: Inquiries can be directed to: slaor@slaor.org 9