April In addition, we encounter valuation practices that present concerns in certain contexts, including:
|
|
- Allyson Booker
- 8 years ago
- Views:
Transcription
1 April 2011 We wanted t take the pprtunity prvided by the AICPA s recent release f the expsure draft Practice Aid t share with ur clients and friends sme bservatins and best practice suggestins n this tpic. We refer t the accmpanying article by Cgent Valuatin titled Cheap Stck Valuatin Allcatin Methds fr mre infrmatin n the AICPA Practice Aid and the significance f its release. Federal tax rules gverning deferred cmpensatin (Internal Revenue Cde Sectin 409A) have changed the landscape f private cmpany valuatin practices since The Sectin 409A regulatins impse a reasnableness requirement n the determinatin f the fair market value f the stck underlying emplyee stck ptins, with dire cnsequences fr ptins with strike prices belw the grant date fair market value. Because these regulatins ffer a presumptin f reasnableness if the stck value is based upn an independent appraisal that meets certain requirements (we refer t this presumptin as the independent valuatin safe harbr ), many private technlgy and bitechnlgy cmpanies nw rutinely btain third-party valuatins t supprt their ptin pricing decisins. Althugh many f the private cmpanies we wrk with nw rutinely btain independent valuatins f their stck, questins cntinue t arise. The AICPA Practice Aid will certainly draw renewed attentin t these issues, and perhaps bring greater clarity. Frm ur vantage pint, thugh, the Practice Aid release is just ne f several develpments related t private cmpany stck valuatin matters that merit attentin. These include: Increased IRS fcus n private cmpany valuatin matters, including in the cntext f nging 409A audits f larger public cmpanies that acquire private cmpanies, Public cmpanies increased reluctance t take n risk arising frm the valuatin practices f the private cmpanies they acquire, and Secndary sales f private cmpany stck at prices that vary frm a cmpany s 409A valuatin. We attach t this Alert sme Further Observatins n private cmpany valuatin matters in which we discuss these develpments in mre depth. In additin, we encunter valuatin practices that present cncerns in certain cntexts, including: Meaningful delays between the as f date f a third-party valuatin reprt and the issuance date f the same reprt t the cmpany, such that events ccurring after the as f date make the reprt s cnclusin bslete befre the cmpany can even use it, Obtaining a valuatin after the fact t supprt the pricing used fr already-granted ptins, where the valuatin btained reflects a grant date fair market value that is higher than the exercise price, Obtaining bard apprval f ptin grants prir t btaining the valuatin reprt n which the ptin pricing will be based, Cntinuing t rely n an independent valuatin fr 12 mnths (the maximum perid permitted under the safe harbr), withut cnsidering whether any material events made the valuatin bslete, and An absence f any prcess r back-up fr stck valuatins by early-stage cmpanies.
2 As we cntinue t watch these develpments, we wanted t ffer these best practice suggestins: Even early stage private cmpanies that d nt btain an independent valuatin shuld establish thughtful valuatin practices that include cnsideratin f the factrs identified in the Sectin 409A regulatins and shuld dcument the steps taken t determine the values used fr ptin pricing purpses. Such practices wuld ptimally include a mem t file that discusses the relevant factrs and circumstances that existed each time ptins are granted, as well as a bard recrd that reflects the bard f directr s cnsideratin f these same factrs and circumstances. The Sectin 409A regulatins ffer a secnd safe harbr fr early-stage private cmpanies that have access t a valuatin expert, such as a venture capitalist r smene else with at least five years apprpriate experience valuing cmpanies, prvided that the prcess is dcumented in a written reprt. Cmpanies nt btaining an independent valuatin shuld try t avail themselves f this safe harbr, when practicable. Private cmpanies that btain independent valuatins shuld recgnize that: Yu get what yu pay fr Saving a few thusand dllars nw might be imprtant, but it needs t be weighed against the truble that culd fllw if, a few years hence when the cmpany s stck value has risen cnsiderably, the auditrs, an acquirer r the IRS reject the valuatin, e.g., n the basis that the valuatin firm did nt use apprpriate methdlgy. Garbage in/garbage ut The valuatin firm needs t have all relevant infrmatin affecting the cmpany s stck value when they prepare their valuatin reprt. If in prximity t the valuatin reprt the cmpany has, fr example, received an acquisitin ffer r experienced significant secndary sales, we expect that n audit r in diligence it wuld be very helpful t see the valuatin reprt specifically reference these events, even if nly t dismiss them as nt influencing entity r stck value. Private cmpanies wrking with an appraisal firm shuld determine an apprpriate valuatin update cycle. While the independent appraisal safe harbr prvides that the appraisal may be relied upn fr as lng as 12 mnths, ur view is that the permitted reliance perid ends when an event ccurs that materially affects the valuatin. A bard f directrs shuld cnsider whether the business envirnment in which the cmpany perates requires either a mre frequent valuatin cycle r a less frequent ptin grant cycle. Valuatin firms will wrk with clients t help them determine whether an updated appraisal is apprpriate and many ffer a fixed annual rate that includes quarterly r semi-annual valuatin updates. Cmpanies whse circumstances are changing rapidly, in particular thse entering the registratin prcess r likely t receive acquisitin bids, shuld wrk with the valuatin firm t cmpress the time between delivery f the valuatin reprt and its as f date. Private cmpany valuatin matters are likely t see cntinued fcus and develpments ver the next few years. Fr cmpanies that have nt reviewed their valuatin practices recently, the issuance f the AICPA Practice Aid might serve as a useful wake-up call that nw wuld be a gd time t undertake such a review. Gundersn Dettmer s lawyers are available t assist in addressing questins yu may have regarding the issues discussed in this Alert. Please cntact the Gundersn Dettmer attrney with whm yu regularly wrk. Cntact infrmatin fr ur attrneys can be fund at LEGAL DISCLAIMER Gundersn Dettmer Stugh Villeneuve Franklin & Hachigian, LLP prvides these materials n its web pages fr infrmatin purpses nly and nt as legal advice. The Firm des nt intend t create an attrney-client relatinship with yu, and yu shuld nt assume such a relatinship r act n any material frm these pages withut seeking prfessinal cunsel.
3 DISCLAIMER UNDER IRS CIRCULAR 230 T ensure cmpliance with requirements impsed by the IRS, we infrm yu that any U.S. federal tax advice cntained in this cmmunicatin (including any attachments) is nt intended r written t be used, and cannt be used, fr the purpse f (i) aviding penalties under the Internal Revenue Cde r (ii) prmting, marketing r recmmending t anther party any transactin r matter addressed herein. Attrney Advertising: The enclsed materials have been prepared fr general infrmatinal purpses nly and are nt intended as legal advice. Our website may cntain attrney advertising as defined by laws f varius states.
4 April 2011 We wanted t share in greater detail sme bservatins we have related t the valuatin issues we discuss in ur Client Alert, Private Cmpany Stck Valuatin and Optin Pricing Matters. Our cmments n the tpics belw are merely that bservatins drawn frm ur practice and ur nging wrk with ver ne thusand private cmpanies: Increased IRS fcus n private cmpany valuatin matters. In the curse f its practice f nearly cntinual audits f large U.S. public crpratins, the IRS has issued multi-page infrmatin dcument requests that include Sectin 409A requests. These IDRs include requests fr detailed infrmatin relating t private cmpanies acquired by the public cmpany under audit, and we understand that in the curse f these audits the Service is lking clsely at the private target cmpany s valuatin practices. Cheap stck charges taken fr financial statement purpses at the time f an initial public ffering n the basis f after-the-fact (as ppsed t cntempraneus) valuatins is itself nthing new. Hwever, many clients express cncern abut the pssibility that the IRS might use a later-btained valuatin develped fr this nn-tax purpse t undermine the reasnableness f the valuatin used when the cmpany granted ptins s as t cnclude that the affected ptins are subject t and vilate Sectin 409A. In additin, the IRS has increased its audits f smaller cmpanies. We expect that recently-public cmpanies with relatively high valuatins wuld be a primary target f such audits. Secndary sales f private cmpany stck at prices that vary frm the cmpany s 409A valuatin. With high-valuatin private cmpanies seeing a dramatic increase in sales f their stck by existing stckhlders, including thrugh SecndMarket, SharesPst and in a variety f ther types f transactins, we currently have mre questins than answers abut the effect f such sales n 409A valuatins. This issue, which the AICPA Practice Aid may ultimately help clarify, bears clse attentin. T date, ur experience has generally been that limited secndary sales f a cmpany s stck, especially if the sales are t cmpany affiliates r t parties wh have access t little financial infrmatin abut the cmpany, have nt had much influence n the cmpany s 409A valuatin n the basis that sales under such circumstances are nt thught t be a gd indicatin f actual value. The valuatin analysis in this cntext, hwever, depends n the specific facts and circumstances, and cmpanies experiencing secndary sales will face increasing pressure t cnsider the need t update their 409A valuatin if they want t cntinue perating within the independent appraisal safe harbr. Clients shuld als nte that in sme circumstances insiders wh sell stck t the cmpany r t cmpany affiliates at a premium t the sale date fair market value f the stck can be deemed t have cmpensatin incme n sme r all f the sales prceeds abve fair market value. In certain fact-specific cntexts, the cmpany can als have withhlding bligatins n this incme, ntwithstanding that the cmpany may nt have been a direct party t the sale transactin. Cmpanies shuld seek advice n these matters early in the curse f the transactin. We nte this issue t highlight that successfully distinguishing the secndary sales values frm the cmpany s 409A valuatin can in sme circumstances result in transactins that feel capital in nature being re-characterized as cmpensatry transactins. Public cmpany acquirers exhibiting increasing reluctance t take n risk arising frm the valuatin practices f the private cmpanies they acquire. We nw see fewer acquisitins in which public cmpany acquirers assume private cmpany stck ptins and suspect that this change in deal structure relates in part t the acquirers reluctance t assume alng with the ptins themselves the tax and emplyee relatins risk that might accmpany the ptins if the histric stck values seem unreasnable.
5 In additin, ptins granted in the weeks preceding an acquisitin with strike prices at a discunt t the deal price receive a high level f scrutiny. The results f this scrutiny are unpredictable and are likely influenced by the parties risk prfiles. In sme deals, the parties have cncluded that ptins granted in the weeks prir t the transactin must be uppriced under existing IRS crrectins prcedures (if these prcedures are available in the specific circumstances). In ther cntexts, parties have btained a retractive independent valuatin cncluding that the actual fair market value was nt nly substantially less than the deal price but less even than the value the target cmpany used fr purpses f setting the exercise price! Further, and while we wuld nt suggest this is a trend, we have encuntered acquirers that, when faced with what they view as inadequate prcess supprting the exercise prices that apply t the target cmpany s ptins, are inclined t simply cncede that pre-acquisitin ptins vilate Sectin 409A (and require that they be reprted as such, a matter which the acquirer cntrls nce the deal clses) withut waiting fr that pint t be raised in an audit. Shuld this extremely cnservative apprach develp int a trend, it seems that Sectin 409A wuld have the effect f impsing a ptentially substantial premium n the cst f acquiring private cmpanies. Fr all f these reasns, it is in ur view well wrth it fr even an early-stage cmpany t develp and keep current n thughtful valuatin practices and t cntinue t pay attentin t further develpments n these issues. Gundersn Dettmer s lawyers are available t assist in addressing questins yu may have regarding the issues discussed in this Alert. Please cntact the Gundersn Dettmer attrney with whm yu regularly wrk. Cntact infrmatin fr ur attrneys can be fund at T ensure cmpliance with IRS requirements, any U.S. federal tax advice cntained in this cmmunicatin is nt intended r written t, and cannt, be used (i) by any taxpayer fr the purpse f aviding tax penalties under the Internal Revenue Cde, and (ii) fr prmting, marketing r recmmending t anther party any transactin r matter addressed herein. Attrney Advertising: The enclsed materials have been prepared fr general infrmatinal purpses nly and are nt intended as legal advice.
10 th May 2010. Dear Peter, Re: Audit Quality in Australia: A Strategic Review
10 th May 2010 Mr. Peter Levy Audit Quality Strategic Review Crpratins and Financial Services Divisin The Treasury Langtn Crescent PARKES ACT 2600 Dear Peter, Re: Audit Quality in Australia: A Strategic
More informationImproved ADP and ACP Safe Harbor Plan Designs
Imprtant Infrmatin Plan Administratin and Operatin April 2000* Imprved ADP and ACP Safe Harbr Plan Designs WHO'S AFFECTED This infrmatin applies t defined cntributin plans with a 401(k) feature r emplyer
More informationWe will record and prepare documents based off the information presented
Dear Client: We appreciate the pprtunity f wrking with yu regarding yur Payrll needs. T ensure a cmplete understanding between us, we are setting frth the pertinent infrmatin abut the services that we
More informationCell Phone & Data Access Policy Frequently Asked Questions
Cell Phne & Data Access Plicy Frequently Asked Questins 1. Wh is eligible fr a technlgy allwance? First and fremst, the technlgy allwance is fr the benefit f the University, rather than fr the cnvenience
More informationValuation Analysis: The Role of the Expert in Litigation
Valuatin Analysis: The Rle f the Expert in Litigatin In cmmercial litigatin the valuatin expert must balance varying methds and the use f judgment in delivering an ptimal result and then must be prepared
More informationIFRS Discussion Group
IFRS Discussin Grup Reprt n the Public Meeting February 26, 2014 The IFRS Discussin Grup is a discussin frum nly. The Grup s purpse is t assist the Accunting Standards Bard (AcSB) regarding issues arising
More informationCommunicating Deficiencies in Internal Control to Those Charged with Governance and Management
Internatinal Auditing and Assurance Standards Bard ISA 265 April 2009 Internatinal Standard n Auditing Cmmunicating Deficiencies in Internal Cntrl t Thse Charged with Gvernance and Management Internatinal
More informationSpecial Tax Notice Regarding 403(b) (TSA) Distributions
Special Tax Ntice Regarding 403(b) (TSA) Distributins P.O. Bx 7893 Madisn, WI 53707-7893 1-800-279-4030 Fax: (608) 237-2529 The IRS requires us t prvide yu with a cpy f the Explanatin f Direct Rllver,
More informationCorporations Q&A. Shareholders. 2006 Edward R. Alexander, Jr.
Crpratins Q&A. What is a crpratin and why frm ne? A crpratin is a business entity that is separate and distinct frm its wners. It can enter cntracts, sue and be sued withut invlving its wners (the sharehlders).
More informationFundingEdge. Guide to Business Cash Advance & Bank Statement Loan Programs
Guide t Business Cash Advance & Bank Statement Lan Prgrams Cash Advances: $2,500 - $1,000,000 Business Bank Statement Lans: $5,000 - $500,000 Canada Cash Advances: $5,000 - $500,000 (must have 9 mnths
More informationAnnuities and Senior Citizens
Illinis Insurance Facts Illinis Department f Insurance January 2010 Annuities and Senir Citizens Nte: This infrmatin was develped t prvide cnsumers with general infrmatin and guidance abut insurance cverages
More informationDodd-Frank Report on Seller Financing
Ddd-Frank Reprt n Seller Financing December 10, 2013 Published by Glbal Publishing Inc. 9799 Old St. Augustine Rd. Jacksnville, FL 32257 p. 904-262-0491 f. 904-262-1464 VIPServices@GlbalPublishinginc.cm
More informationNational Australia Bank Limited Group Disclosure & External Communications Policy
Natinal Australia Bank Limited Grup Disclsure & External Cmmunicatins Plicy Grup Disclsure & External Cmmunicatins Plicy Page 2 f 7 Grup Disclsure & External Cmmunicatins Plicy ( the Plicy ) 1. Overview
More informationInternal Audit Charter and operating standards
Internal Audit Charter and perating standards 2 1 verview This dcument sets ut the basis fr internal audit: (i) the Internal Audit charter, which establishes the framewrk fr Internal Audit; and (ii) hw
More informationPrivacy Breach and Complaint Protocol
Privacy Breach and Cmplaint Prtcl Effective: December 31, 2012 Apprved by: Le McKenna, CFO 1.0 General Privacy breaches and privacy cmplaints will be handled in accrdance with this prtcl. This prtcl is
More informationHearing Loss Regulations Vendor information pack
Hearing Lss Regulatins Vendr infrmatin pack Nvember 2010 Implementing the Accident Cmpensatin (Apprtining Entitlements fr Hearing Lss) Regulatins 2010 The Minister fr ACC, the Hn. Dr Nick Smith, has annunced
More informationMSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER
MSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER This Audit Cmmittee Charter has been amended as f July 17, 2015. The Audit Cmmittee shall review and reassess this Charter annually and recmmend
More informationWire Transfer Request
Wire Transfer Request Requirements and Instructins OFFICE OF DISBURSEMENTS Categry: Dcument Name: Payment Prcessing Wire Transfer Request - Requirements and Instructins Respnsible Department: Office f
More informationFINANCE SCRUTINY SUB-COMMITTEE
REPORT FOR: PERFORMANCE AND FINANCE SCRUTINY SUB-COMMITTEE Date f Meeting: 6 January 2015 Subject: Staff Survey and Sickness Absence Mnitring Results and Actin plans Respnsible Officer: Scrutiny Lead Member
More informationChange Management Process
Change Management Prcess B1.10 Change Management Prcess 1. Intrductin This plicy utlines [Yur Cmpany] s apprach t managing change within the rganisatin. All changes in strategy, activities and prcesses
More informationHOW TO SELECT A LIFE INSURANCE COMPANY
HOW TO SELECT A LIFE INSURANCE COMPANY There will prbably be hundreds f life insurance cmpanies t chse frm when yu decide t purchase a life insurance plicy. Hw d yu decide which ne? Mst cmpanies are quite
More informationChris Chiron, Interim Senior Director, Employee & Management Relations Jessica Moore, Senior Director, Classification & Compensation
TO: FROM: HR Officers & Human Resurces Representatives Chris Chirn, Interim Senir Directr, Emplyee & Management Relatins Jessica Mre, Senir Directr, Classificatin & Cmpensatin DATE: May 26, 2015 RE: Annual
More informationLOUISIANA TECH UNIVERSITY Division of Student Financial Aid Post Office Box 7925 Ruston, LA 71272
LOUISIANA TECH UNIVERSITY Divisin f Student Financial Aid Pst Office Bx 7925 Rustn, LA 71272 Dear Financial Aid Applicant, Accrding t yur 2011-2012 Student Aid Reprt (SAR), yu did nt include any parental
More informationMarch 2016 Group A Payment Issues: Missing Information-Loss Calculation letters ( MILC ) - deficiency resolutions: Outstanding appeals:
The fllwing tpics were discussed in the March 24, 2016 meeting with law firms representing VCF claimants. Grup A Payment Issues: We cntinue t fcus n paying Grup A claims in full and are meeting the schedule
More information7 October 2011. Re: Themed Inspection into Third Party Personal Injury Claims. Dear
7 Octber 2011 Re: Themed Inspectin int Third Party Persnal Injury Claims Dear During 2011 the Central Bank f Ireland ( Central Bank ) undertk a themed inspectin prject in relatin t the prcessing f third
More informationMalpractice and Maladministration Policy
TR340 Malpractice and Maladministratin Plicy This plicy aims t: Define malpractice and maladministratin in the cntext f CIM/CAM studying members, Accredited study centres (ASCs), examinatin centres, invigilatrs
More informationHeythrop College Disciplinary Procedure for Support Staff
Heythrp Cllege Disciplinary Prcedure fr Supprt Staff Intrductin 1. This prcedural dcument des nt apply t thse academic-related staff wh are mentined in the Cllege s Ordinance, namely the Librarian and
More informationData Protection Act Data security breach management
Data Prtectin Act Data security breach management The seventh data prtectin principle requires that rganisatins prcessing persnal data take apprpriate measures against unauthrised r unlawful prcessing
More informationFinancial Planning Agreement
Financial Planning Agreement This Financial Planning Agreement, the ( Agreement ), dated as f, 20, is by and between Vulcan Investments LLC, 2100 SuthBridge Pkwy, Suite 650 Birmingham, AL. 35209, an investment
More informationPhi Kappa Sigma International Fraternity Insurance Billing Methodology
Phi Kappa Sigma Internatinal Fraternity Insurance Billing Methdlgy The Phi Kappa Sigma Internatinal Fraternity Executive Bard implres each chapter t thrughly review the attached methdlgy and plan nw t
More informationAustralian Institute of Psychology. Human Research Ethics Committee. Terms of Reference
Australian Institute f Psychlgy Human Research Ethics Cmmittee Terms f Reference What is research? Accrding t the Natinal Statement research... is widely understd t include at least investigatin undertaken
More informationWhat Does Specialty Own Occupation Really Mean?
What Des Specialty Own Occupatin Really Mean? Plicy definitins are cnfusing, nt nly t cnsumers but als t many f the insurance prfessinals wh sell them. Belw we will try t prvide an understandable explanatin
More information2015 MSBO ANNUAL CONFERENCE. Miller, Canfield, Paddock & Stone, P.L.C. Random IRS Audits: What Do They Look For?
2015 MSBO ANNUAL CONFERENCE Presenter: Jeffrey McHugh Miller, Canfield, Paddck & Stne, P.L.C. Randm IRS Audits: What D They Lk Fr? Intrductin: The IRS has added new auditrs in the tax-exempt bnd enfrcement
More informationPersonal Data Security Breach Management Policy
Persnal Data Security Breach Management Plicy 1.0 Purpse The Data Prtectin Acts 1988 and 2003 impse bligatins n data cntrllers in Western Care Assciatin t prcess persnal data entrusted t them in a manner
More informationCMS Eligibility Requirements Checklist for MSSP ACO Participation
ATTACHMENT 1 CMS Eligibility Requirements Checklist fr MSSP ACO Participatin 1. General Eligibility Requirements ACO participants wrk tgether t manage and crdinate care fr Medicare fee-fr-service beneficiaries.
More informationDampier Bunbury Pipeline (DBP)
Limited ABN 59 001 777 591 AFSL 232497 April 2011 (Update) Cst f Debt Summary Paper Dampier Bunbury Pipeline (DBP) IMPORTANT NOTE Nte 1 This dcument has been prepared by AMP Capital Investrs Limited (AMP
More informationE.ON UK plc v Gilesports Limited : Section 1(3) of the Landlord and Tenant Act 1988 BRIEFING. Introduction
E.ON UK plc v Gilesprts Limited : Sectin 1(3) f the Landlrd and Tenant Act 1988 BRIEFING Intrductin A tenant applicatin fr cnsent t assign a lease can smetimes prve a fractius affair and can strain relatins
More informationUNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES
UNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES REFERENCES AND RELATED POLICIES A. UC PPSM 2 -Definitin f Terms B. UC PPSM 12 -Nndiscriminatin in Emplyment C. UC PPSM 14 -Affirmative
More information- Upfront fee of $ + GST - Ongoing fee commencing immediately after plan implementation of $20.00 + GST per fortnight.
Cntract f engagement This cntract f engagement is between FSB 4 Financial Limited (the adviser) and (the client). Purpse This cntract establishes the relatinship between the adviser and the client relating
More informationChicago Department of Finance. Tax Audit Process
Chicag Department f Finance Tax Audit Prcess Audit Overview There are varius ways a business gets selected fr audit. The mst cmmn are referrals frm anther divisin f the Department f Finance, referral frm
More informationGroup Term Life Insurance: Table I Straddle Testing and Imputed Income for Dependent Life Insurance
An American Benefits Cnsulting White Paper American Benefits Cnsulting, LLC 99 Park Ave, 25 th Flr New Yrk, NY 10016 212 716-3400 http://www.abcsys.cm Grup Term Life Insurance: Table I Straddle Testing
More informationBill Payment Agreement & Disclosures
Bill Payment Agreement & Disclsures Welcme t Online Banking Bill Payment Service. Use f the Bill Payment Service indicates acceptance f terms and cnditins set frth in the Online Banking Agreement & Disclsures
More informationINSTRUCTIONS ON HOW TO IMPORT (Attach) DOCUMENTS TO TRANSACTIONS IN THE EMPLOYEE REIMBURSEMENT SYSTEM
INSTRUCTIONS ON HOW TO IMPORT (Attach) DOCUMENTS TO TRANSACTIONS IN THE EMPLOYEE REIMBURSEMENT SYSTEM In the Emplyee Reimbursement System, users with verifier and apprver/prxy access rights have the ability
More informationPatient Participation Report
Patient Participatin Reprt In 2011, Westngrve Partnership decided t establish a PPG (Patient Participatin Grup) that wuld allw us t engage with ur patients, receive feedback frm them and ensure that they
More informationThe Family Cost Share system is designed so families with the ability to pay will share in the cost of services.
Paying fr Early Childhd Interventin Services What is ECI? Texas Early Childhd Interventin (ECI) prgrams serve families with children birth t 36 mnths with develpmental delays r disabilities. ECI prvides
More informationWatlington and Chalgrove GP Practice - Patient Satisfaction Survey 2011
Watlingtn and Chalgrve GP - Patient Satisfactin Survey 2011 Backgrund During ne week in Nvember last year patients attending either the Chalgrve r the Watlingtn surgeries were asked t cmplete a survey
More informationThinking Different About Alternative Financing Options
Thinking Different Abut Alternative Financing Optins Christpher Mills Senir Business Develpment Officer Federal Natinal Cmmercial Credit This whitepaper will make yu think differently abut alternative
More informationEqual Pay Audit 2014 Summary
Equal Pay Audit 2014 Summary Abut the dcument The fllwing summary is an abridged versin f Ofcm s equal pay audit 2014. In the full versin f the reprt we set ut ur key findings, cmment n any issues arising
More informationPresentation: The Demise of SAS 70 - What s Next?
Presentatin: The Demise f SAS 70 - What s Next? September 15, 2011 1 Presenters: Jeffrey Ziplw - Partner BlumShapir Jennifer Gerasimv Senir Manager Delitte. SAS 70 Backgrund and Overview Purpse f a SAS
More informationFinancial Accountability Handbook
Financial Accuntability Handbk >> Vlume 5 Reprting Systems Infrmatin Sheet 5.2 Preparatin f Financial Statements Intrductin The Financial Accuntability Act 2009 (the Act) and the Financial and Perfrmance
More informationRQ10.06 AACo Share Trading Policy
Australian Agricultural Cmpany Limited ACN 010 892 270 RQ10.06 AAC Share Trading Plicy Versin 5 This plicy was apprved by the Bard f Australian Agricultural Cmpany Limited n 15 December 2010. This plicy
More informationDisplayNote Technologies Limited Data Protection Policy July 2014
DisplayNte Technlgies Limited Data Prtectin Plicy July 2014 1. Intrductin This dcument sets ut the bligatins f DisplayNte Technlgies Limited ( the Cmpany ) with regard t data prtectin and the rights f
More informationARE YOU INTERESTED IN THE PRIOR LEARNING ASSESSMENT (PLA) PROGRAM?
ARE YOU INTERESTED IN THE PRIOR LEARNING ASSESSMENT (PLA) PROGRAM? City University f Seattle recgnizes that learning ccurs in many different ways and under varied circumstances. As a result, the University
More informationCredit Work Group Recommendation
Credit Wrk Grup Recmmendatin T: Credit Wrk Grup Frm: Mike Bixby (305) 829-5549 mbixby@inf1team.cm Paul Wills (770) 740-7353 Paul.Wills@equifax.cm Date: Octber 7, 2004 Re: FACT Act Implicatins and Recmmendatins
More information7/25/14 FAIRFAX COUNTY PUBLIC SCHOOLS SUPPORT EMPLOYEE PERFORMANCE ASSESSMENT HANDBOOK
7/25/14 FAIRFAX COUNTY PUBLIC SCHOOLS SUPPORT EMPLOYEE PERFORMANCE ASSESSMENT HANDBOOK A Resurce Fr Supprt Emplyees Cpyright 2014, Fairfax Cunty Public Schls http://www.fcps.edu/hr/epd/evaluatins/supprt.shtml
More informationFORM ADV (Paper Version) UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT FORM BY EXEMPT REPORTING ADVISERS
APPENDIX A FORM ADV (Paper Versin) UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT FORM BY EXEMPT REPORTING ADVISERS Frm ADV: General Instructins Read these instructins carefully befre
More informationTHIRD PARTY PROCUREMENT PROCEDURES
ADDENDUM #1 THIRD PARTY PROCUREMENT PROCEDURES NORTH CENTRAL TEXAS COUNCIL OF GOVERNMENTS TRANSPORTATION DEPARTMENT JUNE 2011 OVERVIEW These prcedures establish standards and guidelines fr the Nrth Central
More informationFINANCIAL OPTIONS. 2. For non-insured patients, payment is due on the day of service.
FINANCIAL OPTIONS 1. Fr thse patients wh carry dental insurance, all c-payments are due n date f service. We will file yur claim as a service t yu, and will d ur very best t maximize yur benefits. We accept
More informationFINANCIAL SERVICES FLASH REPORT
FINANCIAL SERVICES FLASH REPORT Draft Regulatry Cmpliance Management Guideline Released by the Office f the Superintendent f Financial Institutins May 5, 2014 On April 30, 2014, the Office f the Superintendent
More informationAudit Committee Charter
Audit Cmmittee Charter Membership The Audit Cmmittee (the "Cmmittee") f the Bard f Directrs (the "Bard") f Philip Mrris Internatinal Inc. (the "Cmpany") shall cnsist f at least three directrs all f whm
More informationONGOING FEEDBACK AND PERFORMANCE MANAGEMENT. A. Principles and Benefits of Ongoing Feedback
ONGOING FEEDBACK AND PERFORMANCE MANAGEMENT A. Principles and Benefits f Onging Feedback While it may seem like an added respnsibility t managers already "full plate," managers that prvide nging feedback
More informationData Protection Policy & Procedure
Data Prtectin Plicy & Prcedure Page 1 Prcnnect Marketing Data Prtectin Plicy V1.2 Data prtectin plicy Cntext and verview Key details Plicy prepared by: Adam Haycck Apprved by bard / management n: 01/01/2015
More informationB Bard Video Games - Cnflict F interest
St Andrews Christian Cllege BOARD CONFLICT OF INTEREST POLICY April 2011 St Andrews Christian Cllege 2 Bard Cnflict f Interest Plicy Plicy Dcument Infrmatin Plicy Name Bard Cnflict f Interest Plicy Authr/Supervisr
More informationThe Preparation of Expert Reports to be Used in a Civil Lawsuit: A Guideline for the Expert Witness
The Preparatin f Expert Reprts t be Used in a Civil Lawsuit: A Guideline fr the Expert Witness by Nigel Kent Clark Wilsn LLP tel. 604.643.3135 npk@cwilsn.cm with revisins made in 2011 by Raman Jhal Clark
More informationFAQs about Registration & Licensing in Dubai
FAQs abut Registratin & Licensing in Dubai Trade Names 1. Is it required t register a trade name in rder t apply fr an initial apprval? N, a trade name may be bked fr ne year renewable perid, against payment
More informationTo discuss Chapter 13 bankruptcy questions with our bankruptcy attorney, please call us or fill out a Free Evaluation form on our website.
Intrductin This Ebk fcuses n Chapter 13 bankruptcy, hw it wrks, and hw it helps yu eliminate debt and keep yur assets (such as yur hme). We hpe yu find this infrmatin t be helpful. T discuss Chapter 13
More informationThe Ohio Board of Regents Credit When It s Due process identifies students who
Credit When It s Due/ Reverse Transfer FAQ fr students Ohi is participating in a natinal grant initiative, Credit When It s Due, designed t implement reverse-transfer, which is a prcess t award assciate
More informationAll Harvard University schools, tubs, local units, Affiliate Institutions, Allied Institutions and University-wide Initiatives.
HARVARD UNIVERSITY FINANCIAL POLICY INDEPENDENT CONTRACTOR CLASSIFICATION Plicy Title: Independent Cntractr Respnsible Office: ERP and UFS Effective Date: Octber 4, 2000 Revisin Date: May 12, 2009 Plicy
More informationConvenience Fees BEST PRACTICES FOR MERCHANT USE OF CONVENIENCE FEES:
Cnvenience Fees This publicatin includes Card Acceptance Guide language n Best Practices fr Merchant Use f Cnvenience Fees in additin t addressing specific differences by card brand and special circumstances
More informationKey Steps for Organizations in Responding to Privacy Breaches
Key Steps fr Organizatins in Respnding t Privacy Breaches Purpse The purpse f this dcument is t prvide guidance t private sectr rganizatins, bth small and large, when a privacy breach ccurs. Organizatins
More informationPrivacy Policy. The Central Equity Group understands how highly people value the protection of their privacy.
Privacy Plicy The Central Equity Grup understands hw highly peple value the prtectin f their privacy. Fr that reasn, the Central Equity Grup takes particular care in dealing with any persnal and sensitive
More informationAccess EEC s Web Applications... 2 View Messages from EEC... 3 Sign In as a Returning User... 3
EEC Single Sign In (SSI) Applicatin The EEC Single Sign In (SSI) Single Sign In (SSI) is the secure, nline applicatin that cntrls access t all f the Department f Early Educatin and Care (EEC) web applicatins.
More informationBetter Practice Guide Financial Considerations for Government use of Cloud Computing
Better Practice Guide Financial Cnsideratins fr Gvernment use f Clud Cmputing Nvember 2011 Intrductin Many Australian Gvernment agencies are in the prcess f cnsidering the adptin f clud-based slutins.
More informationRecent IRS Developments and Avoiding Form 990 Red Flags Brian Todd, CPA, Partner
Recent IRS Develpments and Aviding Frm 990 Red Flags Brian Tdd, CPA, Partner Agenda Recent IRS Activity Cllege and University Cmpliance Reprt IRS Annual Reprt and Wrkplan Observed IRS Examinatin Activity
More informationBriefing 4 Inquests and the disclosure of information to the coroner
briefing February 2013 The Francis Reprt Briefing 4 Inquests and the disclsure f infrmatin t the crner Key chapters Key recmmendatins 2, 11, 14, 22 274, 45, 273, 282, 283, 17 There is a requirement nt
More informationA Guide to Understanding and Claiming the Disability Tax Credit:
A Guide t Understanding and Claiming the Disability Tax Credit: The Gvernment f Canada ffers a variety f tax benefits t peple with disabilities. These benefits are prvided under the assumptin that peple
More informationOUR DISCIPLINARY POLICY
OUR DISCIPLINARY POLICY WHO is this plicy fr? Channel 4 emplyees wh ve passed their prbatinary perid Channel 4 managers This plicy des nt frm part f any emplyee s cntract f emplyment and we may amend it
More informationSelect Auditing Considerations for the 2014 Audit Cycle
Select Auditing Cnsideratins fr the 2014 Audit Cycle This Alert is intended t remind member firms f certain auditing cnsideratins that may be relevant fr the 2014 audit cycle. The Alert identifies and
More informationUnderstanding Federal Direct Consolidation Loans. 2012 Spring MASFAA Conference
Understanding Federal Direct Cnslidatin Lans 2012 Spring MASFAA Cnference UNDERSTANDING FEDERAL DIRECT & SPECIAL CONSOLIDATION LOANS Amy M. Mser, Reginal Directr Nelnet Educatin Lan Services 2 Nelnet Educatin
More informationMerchant Processes and Procedures
Merchant Prcesses and Prcedures Table f Cntents EXHIBIT C 1. MERCHANT INTRODUCTION TO T-CHEK 3 1.1 Wh is T-Chek Systems? 3 1.2 Hw t Cntact T-Chek Systems 3 1.3 Hw t Recgnize T-Chek Frms f Payment 3 1.3.1
More informationInternet and E-Mail Policy User s Guide
Internet and E-Mail Plicy User s Guide Versin 2.2 supprting partnership in mental health Internet and E-Mail Plicy User s Guide Ver. 2.2-1/5 Intrductin Health and Scial Care requires a great deal f cmmunicatin
More informationExecutive Summary. ERISA allows for the Delegation of Fiduciary Responsibility to independent investment professionals. www.theadvisorlab.com.
Page 2 ERISA allws fr the Delegatin f Fiduciary Respnsibility t independent investment prfessinals. Executive Summary Many wners/executives f businesses that spnsr 401(k) plans dn t have the faintest idea
More informationClient Memorandum. Under the SEC's final rules, the Section 16 reporting rules have been amended as follows:
Client Memrandum RE: SEC Adpts New Sectin 16 Reprting Rules August 28, 2002 The recently enacted Sarbanes-Oxley Act (the "S-O Act") amended and restated Sectin 16(a) f the Securities Exchange Act f 1934
More informationDraft for consultation
Draft fr cnsultatin Draft Cde f Practice n discipline and grievance May 2008 Further infrmatin is available frm www.acas.rg.uk CONSULTATION ON REVISED ACAS CODE OF PRACTICE ON DISCIPLINE AND GRIEVANCE
More informationAHI. Foreign Pre-Approval Inspections (PAIs) Points to Consider
AHI Freign Pre-Apprval Inspectins (PAIs) Pints t Cnsider The fllwing suggestins are intended t prvide spnsr guidance fr timeliness and predictability f freign PAIs. The FDA Center fr Veterinary Medicine
More informationNational Australia Bank Limited Group Securities Trading Policy
Natinal Australia Bank Limited Grup Securities Trading Plicy Table f Cntents Grup Securities Trading Plicy... 1 Grup Securities Trading Plicy... 3 1. Overview... 3 2. Plicy Statements... 3 3. Special Cnsideratins...
More informationFiscal Operation of Service Centers
Oregn University System Fiscal Plicy Manual Fiscal Operatin f Service Centers Sectin: Accunting and Financial Reprting Number: 05.713 Title: Fiscal Operatin f Service Centers Index POLICY.100 POLICY STATEMENT.110
More informationEstablishing a Paralegal Law Firm Points for Consideration
Establishing a Paralegal Law Firm Pints fr Cnsideratin 1. Backgrund Paralegal law firms are a relatively new phenmenn: but a ppular ne. At the end f the 1990s there were very few indeed. Hwever as realisatin
More informationWHAT YOU NEED TO KNOW ABOUT. Protecting your Privacy
WHAT YOU NEED TO KNOW ABOUT Prtecting yur Privacy YOUR PRIVACY IS OUR PRIORITY Credit unins have a histry f respecting the privacy f ur members and custmers. Yur Bard f Directrs has adpted the Credit Unin
More informationFINAL DECISION. Mr A Complaint about: Complaint by: the firm Complaint reference: Date of final decision: November 2008. summary of complaint
FINAL DECISION Cmplaint by: Mr A Cmplaint abut: the firm Cmplaint reference: Date f final decisin: Nvember 2008 summary f cmplaint This final decisin is issued by me, Tny Brman, an mbudsman with the Financial
More informationPurpose Statement. Objectives
Apprved by Academic Affairs Cuncil, June 24, 2014 Faculty Handbk Part VI: Other Plicies and Prcedures Sectin R. Intellectual Prperty Classified Emplyee Handbk Part VI: Other Plicies and Prcedures Sectin
More informationBRILL s Editorial Manager (EM) Manual for Authors Table of Contents
BRILL s Editrial Manager (EM) Manual fr Authrs Table f Cntents Intrductin... 2 1. Getting Started: Creating an Accunt... 2 2. Lgging int EM... 3 3. Changing Yur Access Cdes and Cntact Infrmatin... 3 3.1
More information[Preliminary] Staff Publication
[Preliminary] Staff Publicatin Addressing Disclsures in the Audit f Financial Statements 1. This [preliminary] 1 dcument highlights matters that may be f relevance fr auditrs when addressing disclsures
More informationFixed vs. Variable Interest Rates
Fixed vs. Variable Interest Rates Understanding the Advantages and Disadvantages f Each Rate Type When shpping fr financial prducts, there are a lt f factrs t cnsider. Much has changed in the financial
More informationThe Advisor Lab, LLC www.theadvisorlab.com Bay Point Financial, LLC www. bayptfin.com. www. bayptfin.com www.theadvisorlab.com.
The Advisr Lab, LLC www.theadvisrlab.cm Bay Pint Financial, LLC www. bayptfin.cm Page 2 Histry The clsing f the Studebaker autmbile plant in Suth Bend, Indiana, is generally regarded as the pivtal event
More informationMunicipal Advisor Registration
FACT SHEET Municipal Advisr Registratin SEC Open Meeting Sept. 18, 2013 The Securities and Exchange Cmmissin tday will cnsider whether t adpt a rule that wuld establish a permanent registratin regime fr
More informationBuying An Existing Business
Buying An Existing Business (Last Revised January, 2005) The fllwing is intended fr general infrmatin nly, regarding sme f the issues relating t purchasing a business in Saskatchewan. We advise yu t seek
More informationKey Solar Lease Considerations for Landowners Tiffany Dowell Lashmet, Texas A&M Agrilife Extension. To which estate does the sun belong?
Key Slar Lease Cnsideratins fr Landwners Tiffany Dwell Lashmet, Texas A&M Agrilife Extensin In the last few mnths, I have heard frm several Texas landwners wh have been cntacted by slar cmpanies seeking
More informationFrequently Asked Questions about the Faith A. Fields Nursing Scholarship Loan
ARKANSAS STATE BOARD OF NURSING 1123 S. University Avenue, Suite 800, University Twer Building, Little Rck, AR 72204 Phne: (501) 686-2700 Fax: (501) 686-2714 www.arsbn.rg Frequently Asked Questins abut
More information