“Nightmares on Insurance Street”
Presented by:
The self proclaimed “FAIA Dream Team”
David Thompson, CPCU, AAI
aka “Dream Team 2”
Jay Williams, CIC, AAI
aka “Dream Team 1”
1
Housekeeping
• Class times
– 1:30 p.m. to 4:30 p.m.
• Break
– One break – 13 minutes
• DFS rules
– Phones, newspapers, etc
2
Unauthorized Entity Issues
 Verify with the DFS:
– www.myfloridacfo.com
– 1-800-342-2762 / 1-877-MY-FL-CFO
3
The Important Stuff
The Dream Team Dilemma
 Is our greatest asset…
– Our intelligence
– Our fantastic teaching ability
– Our amazing good looks
– Or….
– Our humility!
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Our Web Site
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Stump the Nerds
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BAP Temporary Substitutes
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BAP Temporary Substitutes
 BAP works just like a PAP
 All the same coverages follow over to a
temporary substitute
 Symbol used isn’t a factor
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BAP Temporary Substitutes





Symbol 1
Symbol 2
Symbol 7
Symbol 8
Symbol 9
Any Auto
Owned Autos
Specifically Described Autos
Hired Autos
Non-owned autos
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From the Policy (Liability)
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Regardless of symbol,
liability coverage for
temporary substitutes is
provided in the form.
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From the Policy (Physical Damage)
 SECTION III – PHYSICAL DAMAGE
COVERAGE
 A. Coverage
 1. We will pay for "loss" to a covered "auto"
or its equipment…
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Temporary Substitute
 Problem:
– Liability coverage automatically provided
– Physical damage coverage not provided
 Solution?
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Symbol 8
 Always add it to every BAP
 Is there a limit per vehicle?
 Solution for:
– Temporary substitutes
– “Regular” business rentals for traveling
employees
 Also add CA 20 54 – Employee Hired
Autos
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Temporary Substitutes
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Coverage B - Homeowners
 Short version:
– 10% of Coverage A
– Covers structures worldwide
– The 10% is part of Coverage A, and is not
additional insurance
22
Coverage B - Homeowners
 What is an “Other Structure”?
– Set apart by clear space
– On “residence premises”
– Limit is 10% of Coverage A
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Coverage B - Homeowners
 Important definition:
 "Residence premises" means:

a.
The one family dwelling where you reside;

b.
The two, three or four family dwelling where you
reside in at least one of the family units; or

c.
That part of any other building where you
reside;
 and which is shown as the "residence premises" in the
Declarations.
 "Residence premises" also includes other structures and
grounds at that location.
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Coverage B - Homeowners
 Important exclusions:
 We do not cover:

a.
Land, including land on which the other structures are
located;

b.
Other structures rented or held for rental to any person
not a tenant of the dwelling, unless used solely as a
private garage;

c.
Other structures from which any "business" is
conducted; or

d.
Other structures used to store "business" property.
However, we do cover a structure that contains "business" property
solely owned by an "insured" or a tenant of the dwelling provided that
"business" property does not include gaseous or liquid fuel, other than
fuel in a permanently installed fuel tank of a vehicle or craft parked or
stored in the structure.
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Coverage B - Homeowners
 Endorsements:
– HO 04 40 Structures Rented to Others
 Used as a private residence
 Extends liability and med pay
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Coverage B - Homeowners
 Endorsements:
– HO 04 42 Permitted Incidental
Occupancies
 Limit applies separately from Coverage
B
 Contents that are described are now
covered under Coverage C
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Coverage B - Homeowners
 Endorsements:
– HO 04 48 Other Structures – Increased
Limits
 Increases the Coverage B limit
 Applies only to the structure described
in the endorsement
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Coverage B - Homeowners
 Endorsements:
– H0 04 91:
 Extends coverage to other structures
not located on the “residence premises”
 Cannot be used for a dwelling, rental,
business, or business property storage
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Coverage B - Homeowners
 Endorsements:
– H0 04 92:
 Similar to HO 04 91 but allows for
location schedule/amount of coverage
 Cannot be used for a dwelling, rental,
business, or business property storage
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Coverage B – Swimming Pools
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Coverage A or B?
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Coverage A or B?
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Coverage A or B?
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Coverage A or B?
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Coverage B - Homeowners
 Flood Insurance Issues:
– Coverage for detached garages only
– 10% of coverage limit (not an additional
amount)
– Separate policy needed for other
structures
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Coverage B - Homeowners
 Questions?
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Kid’s Cars
 Best advice:
– Title car to kid
– Put on kid’s PAP
– That way, parents can’t be sued
– Saves everyone money
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“It’s party
time!”
“The insurance went
up HOW much?”
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QUESTION
Who is This?
Kid’s Cars
 No matter how you slice the banana, it’s going to
cost you a ton to insure kids.
Before we go any
further, how will
 To quote a student:
this affect our
insurance in 16
– “When my customers complain
years?
about the cost to insure kids
I tell them they should
have considered that in
the heat of passion
16 years earlier.”
43
Kid’s Cars – The Cost
 Pre-kid, two cars, high limits:
–$750
 Kid turns 16:
–$1,250
 Kid gets boring car:
–$1,850
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Situation
 Parents:
– Assets to protect
– PAP with high limits and umbrella
 Kid:
– Excited to drive
– Cool car
– Low limits
 Tragedy: Kid hits car, serious injuries
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Avenues To Mom/Dad’s
Wallet
 1. Car registered to Mom/Dad
 2. Child under age (Statutory, state specific)
 3. Vicarious … “On a mission”
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Avenues To Mom/Dad’s
Wallet
 1. Car registered to Mom/Dad
If your name is here…
You’re gonna get sued!
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2. Child Under Age -Statutory
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FS 322.09
(1)(a) The application of any person under
the age of 18 years for a driver's license
must be signed and verified before a
person authorized to administer oaths by
the father, mother, or guardian….
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(2) Any negligence or willful misconduct
of a minor under the age of 18 years when
driving a motor vehicle upon a highway
shall be imputed to the person who has
signed the application of such minor for a
permit or license, which person shall be
jointly and severally liable with such
minor for any damages caused by such
negligence or willful misconduct.
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What About Age 18 & Older?
Car in Child’s Sole Name
 Situation:
– Child is age 22, in college. Rents apartment.
– Mom/Dad support child.
Would YOU sue?
– Mom/Dad claim child on taxes
– Child has bedroom at house, stays there from
time to time
– Child has no assets; parents have money
– Child has wreck, kills someone. Would you try
to chase Mom & Dad for the money?
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3. Vicarious – “On a Mission”
 Analogy:
– Producer uses his car to visit clients.
Agency sued. “Respondeat superior.”
 Situation:
– Dad gives kid list of eight places to go;
post office, grocery store, Sonny’s, etc
– Child has wreck. Parent’s sued: “Child on
a mission for parents.”
 Or, changing tire
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Discussion Based on ISO Forms
Main focus today is on liability
coverage.
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Kid’s Cars – The Options
 1. No car
– Good risk management
 2. Car in parents’ name, driven by kid
– Generally the least expensive way; no coverage
gaps
 3. Car in kid’s name
– Disaster waiting to happen
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1. Kid’s Cars – No Car
 List the kid as a driver for rating and
underwriting reasons
– QUESTION: How does listing the kid as a
driver affect coverage?
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1. Kid’s Cars – No Car
 List the kid as a driver for rating and
underwriting reasons
– QUESTION: How does listing the kid as a
driver affect coverage?
 As long as the kid is a resident family
member, he/she has all policy coverages
 Separate policy needed once the kid is no
longer a resident
 What is “resident?”
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2. Car in Parents’ Name




List kid as driver – underwriting & rating
Least expensive choice
No coverage gaps
Kid’s wreck = parents’ problem
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3. Car in Kid’s Name
 Huge potential problem
 What limits do parents often want to carry
on the kid’s car?
 Why?
–Cost
–“My neighbor said…”
–“An attorney said…”
–“A guy in the bar told me…”
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Car in Kid’s Name -- Dangers
 Exclusion in parents’ policy voids coverage
for claims resulting from use of the kid’s car
– Liability
– Med-pay
– Physical damage
 UM and PIP
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The Exclusion
3. Any vehicle, other than "your covered auto", which
is:
a. Owned by any "family member"; or
b. Furnished or available for the regular use of any
"family member".
However, this Exclusion (B.3.) does not apply
to you while you are maintaining or "occupying"
any vehicle which is:
a. Owned by a "family member"; or
b. Furnished or available for the regular use of a
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"family member".
Examples – Under Mom/Dad’s
PAP
Mom/Dad Get Sued
 Kid driving kid’s car
 Sibling driving kid’s car
 Friend driving kid’s car
 Mom/Dad driving kid’s car
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Examples – Under Kid’s PAP
Mom/Dad Get Sued
 Kid driving kid’s car
 Sibling driving kid’s car
 Friend driving kid’s car
 Mom/Dad driving kid’s car
 Limits? $$$$
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Car in Kid’s Name
 QUESTION: If this option is selected what
recommendation is there to the parents?
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Kid’s Cars – Bottom Line
 If the car and policy are in the kid’s name,
assume the parents’ policy is worthless.
 Parents depend on kid’s limits if they are
sued.
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Other Coverages
 Med-pay
– Same exclusions
 PIP
– If car in kid’s name, kid gets his/her PIP
 UM
– Save the debate…clone limits and stack it
 Physical damage:
– Kid’s policy covers kid’s car
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Other Thoughts…
 The moral issue of low limits for the kid
 Future wage garnishments
 How would Mom/Dad feel if THEY were hit
and hurt bad by a kid with 10/20/10?
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Kid’s Cars
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Drive Other Car (DOC) Coverage
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Drive Other Car (DOC) Coverage
 Recent change…only liability coverage
available under DOC
 Huge new gap created
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Drive Other Car (DOC) Coverage
 Coverages Provided:
– Liability
– Med Pay
– Uninsured Motorist
– Physical Damage
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Drive Other Car (DOC) Coverage
 Coverage NOT Provided:
– Personal Injury Protection
 Broadened PIP for Named Individuals
 A MUST in FL and other no-fault states
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Drive Other Car (DOC) Coverage
 Who is an Insured:
– Med Pay and Uninsured Motorist
 Named insured and family
– Liability and Physical Damage
 Named insured and resident spouse
– Gaps for family members other than the
spouse
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Drive Other Car (DOC) Coverage
 Comparison to Personal Auto Policy
– Who is an insured
– Endorsements available
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Drive Other Car (DOC) Coverage
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NFIP: RCBAP vs. CPP
 Residential Condominium Building
Association Policy
 Commercial Property Policy
 Both policies cover building items the same
way
 Typically, coverages match
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NFIP: RCBAP vs. CPP
 RCBAP – Property covered
– The whole dang building!
 Foundations
 Paint, carpet, tile, cabinets, etc
 Additions and alterations made at the
sole expense of the unit owner
 Compared to CPP
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NFIP: RCBAP vs. CPP
 RCBAP – Unit owners make significant
improvements/additions
– Is RCBAP now under-insured?
– Is there now a potential coinsurance
problem?
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NFIP: RCBAP vs. CPP
 Replacement cost for flood is greater than
replacement cost for property…always!
 So…
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NFIP: RCBAP vs. CPP
 Your answer is:
– A. The RCBAP always has more
coverage than the CPP
– B. The RCBAP and CPP are always
equal
– C. The CPP always has more coverage
than the RCBAP
– D. Not enough information to answer
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Condos – How We Can Help
 I need:
– Copy of RCBAP dec page
– Copy of appraisal
 Must include foundation and all building
items
– Letter from lender with client name and
loan number
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NFIP
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Employees As Insureds –
Business Auto Policy – CA 99 33
 Employees are “an insured” under BAP
using any auto
 Employee is covered under BAP using
his/her own auto for business
 BAP is primary in all instances
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Employees As Insureds –
Business Auto Policy – CA 99 33
 Who is an Insured in the BAC
– Person or entity named
– Permissive users
– Exceptions/Exclusions
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Employees As Insureds –
Business Auto Policy – CA 99 33
 Coverage Provided by Endorsement:
– Liability
– Physical Damage
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Employees As Insureds –
Business Auto Policy – CA 99 33
 Uses:
– Employees driving autos owned by them
 Primary/excess issues
 PAP/BAP analysis
– Traveling employees – rental cars
 Liability
 Physical Damage
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Employees As Insureds –
Business Auto Policy – CA 99 33
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Uninsured Motorists (UM) on
Motorcycles
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Uninsured Motorists (UM) on
Motorcycles
 Cost for UM on cycles is very expensive
 Remember, the PAP excludes UM on
vehicles with less than four wheels
 UM must be purchased on a cycle policy for
coverage to apply
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UM on Motorcycles
 FS 627.727 (1)
 No motor vehicle liability insurance policy
which provides bodily injury liability
coverage shall be delivered or issued for
delivery in this state with respect to any
specifically insured or identified motor
vehicle registered
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The Statute - 627.727
 (1) No motor vehicle liability insurance
policy which…
– PAP
– BAP
– Motorhome policy
– Motorcycle policy
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The Policy
 INSURING AGREEMENT
 A. We will pay compensatory damages
which an "insured" is legally entitled to
recover from the owner or operator of an
"uninsured motor vehicle" because of "bodily
injury":
 1. Sustained by an "insured"; and
 2. Caused by an accident.
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Compensatory Damages
What are
“compensatory
damages?”
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Compensatory Damages
 Summary:
– Whatever the court awards!
 Medical bills
 Lost wages
 Loss of limbs
 Loss of enjoyment of life
 Pain & suffering
– UM Covers a lot more than medical bills!
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Will PIP, med-pay,
or health insurance
cover these?
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Stacked vs. Non-Stacked
Stacked
 Dollar difference
– More cars equals
more money
 Also, a coverage
difference
Non-stacked
 Dollar difference
– Same dollars,
regardless of
number of cars
 Coverage difference
– Excludes some
claims that stacked
covers.
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Stacked Exclusions









A. We do not provide Uninsured Motorists Coverage for "bodily injury" sustained by any
"insured":
1. If that "insured" or the legal representative settles the "bodily injury" claim and such
settlement prejudices our right to recover payment. However, this Exclusion (A.1.) does
not apply to a settlement made with the insurer of a vehicle described in Section 2. of the
definition of "uninsured motor vehicle".
2. While "occupying" "your covered auto" when it is being used as a public or livery
conveyance. This Exclusion (A.2.) does not apply to a share-the-expense car pool.
3. Using a vehicle without a reasonable belief that that "insured" is entitled to do so. This
Exclusion (A.3.) does not apply to a "family member" using your "covered auto" which is
owned by you.
4. With respect to damages for pain, suffering, mental anguish or inconvenience unless
the "bodily injury" consists in whole or in part of:
a. Significant and permanent loss of an important bodily function;
b. Permanent injury within a reasonable degree of medical probability, other than
scarring or disfigurement;
c. Significant and permanent scarring or disfigurement; or
d. Death.
102
Non-Stacked Exclusions
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Non-Stacked Exclusions













A. We do not provide Uninsured Motorists Coverage for "bodily injury" sustained:
1. By an "insured" while "occupying" any motor vehicle owned by that "insured" which is not insured for this coverage
under this policy. This includes a trailer of any type used with that vehicle.
2. By any "family member" while "occupying" any motor vehicle you own which is insured for this coverage on a
primary basis under any other policy.
B. We do not provide Uninsured Motorists Coverage for "bodily injury" sustained by any "insured":
1. If that "insured" or the legal representative settles the "bodily injury" claim and such settlement prejudices our right to
recover payment.
However, this Exclusion (B.1.) does not apply to a settlement made with the insurer of a vehicle described in Section 2.
of the definition of "uninsured motor vehicle".
2. While "occupying" "your covered auto" when it is being used as a public or livery conveyance. This Exclusion (B.2.)
does not apply to a share-the-expense car pool.
3. Using a vehicle without a reasonable belief that that "insured" is entitled to do so. This Exclusion (B.3.) does not
apply to a "family member" using "your covered auto" which is owned by you.
4. With respect to damages for pain, suffering, mental anguish or inconvenience unless the "bodily injury" consists in
whole or in part of:
a. Significant and permanent loss of an important bodily function;
b. Permanent injury within a reasonable degree of medical probability, other than scarring or disfigurement;
c. Significant and permanent scarring or disfigurement; or
d. Death.
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Non-Stacked Exclusions













A. We do not provide Uninsured Motorists Coverage for "bodily injury" sustained:
1. By an "insured" while "occupying" any motor vehicle owned by that "insured" which is not insured for this
coverage under this policy. This includes a trailer of any type used with that vehicle.
2. By any "family member" while "occupying" any motor vehicle you own which is insured for this coverage on a
primary basis under any other policy.
B. We do not provide Uninsured Motorists Coverage for "bodily injury" sustained by any "insured":
1. If that "insured" or the legal representative settles the "bodily injury" claim and such settlement prejudices our right to
recover payment.
However, this Exclusion (B.1.) does not apply to a settlement made with the insurer of a vehicle described in Section 2.
of the definition of "uninsured motor vehicle".
2. While "occupying" "your covered auto" when it is being used as a public or livery conveyance. This Exclusion (B.2.)
does not apply to a share-the-expense car pool.
3. Using a vehicle without a reasonable belief that that "insured" is entitled to do so. This Exclusion (B.3.) does not
apply to a "family member" using "your covered auto" which is owned by you.
4. With respect to damages for pain, suffering, mental anguish or inconvenience unless the "bodily injury" consists in
whole or in part of:
a. Significant and permanent loss of an important bodily function;
b. Permanent injury within a reasonable degree of medical probability, other than scarring or disfigurement;
c. Significant and permanent scarring or disfigurement; or
d. Death.
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So……
 This exclusion is in the non-stacked form,
It’s the “owned but not insured” exclusion.
but not in No
thecoverage
stacked
form:
with
non-stacked.
Coverage
does apply
with stacked.
– A. We do
not provide
Uninsured
Motorists
Coverage for "bodily injury" sustained:
– 1. By an "insured" while "occupying" any
motor vehicle owned by that "insured"
which is not insured for this coverage under
this policy…”
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Owned Motorcycle
Broward County Zip
Code
300/500 Non-Stacked PAP UM
$116 for six months
(Stacked $155)
$300K Cycle UM - $1451/year
(Liability $119)
Stacked PAP UM will respond
on the motorcycle. (300/500)
UM REJECTED!
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Alabama Car
One Car
UM Rejected!
Two Cars
250/500 Non-Stacked
Stacked PAP UM will respond
on the Alabama car. (500/1,000)
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109
UM On Motorcycles
110
PEO (Professional Employer
Organization) Tricks & Traps
 When a “client company” uses a PEO:
– No need for WC
– No need for CGL
– No need for any other policies
– PEO provides all coverages for client
company
– Great benefit for client company
111
PEO (Professional Employer
Organization) Tricks & Traps
 Co-employment Relationship:
– Primary employer (PEO)
 Pays employees
 Pays taxes
 Pays SUTA & FUTA
 Offers Benefits
112
PEO (Professional Employer
Organization) Tricks & Traps
 Co-employment Relationship:
– Worksite Employer
 Hires/fires
 Salary determination
 Supervises
 Offers benefits
113
PEO (Professional Employer
Organization) Tricks & Traps
 Co-employment Relationship:
– Contractual relationship
 Client Services Agreement (CSA)
 Defines the exact relationship and who
is responsible for what
114
PEO (Professional Employer
Organization) Tricks & Traps
 Gaps Created by the CSA:
– Newly hired employees
 Client (WSE) must notify the PEO
 New employee not covered until
received AND approved
– Uninsured sub-contractors
 CSA does not recognize these as
employees
 Client is “naked”
115
PEO (Professional Employer
Organization) Tricks & Traps
 Other PEO “tricks”:
– Can be “hidden” costs in the CSA
 Set up and change fees
 WC claim fees
 Garnishment fees
 Other administration fees
116
PEO (Professional Employer
Organization) Tricks & Traps
 Other PEO “tricks”:
– State Unemployment Tax (SUTA)
 Tax “cutoffs” not honored
 Rates increased without notice
– High administration fees
 Lead with WC – low pricing for high risk
 Increase admin to cover WC costs
 Rates for master health plan
117
manipulated
PEO (Professional Employer
Organization) Tricks & Traps
118
Fair Credit Reporting Act (FCRA)
119
Fair Credit Reporting Act (FCRA)
 FCRA was renamed FACTA
 When renamed, there was no longer any
impact on insurance agencies and the MVR
issue.
– Agents can now supply MVRs to
commercial customers
120
Fair Credit Reporting Act (FCRA)
 Key terms
– Consumer report
– Consumer reporting agency
– Permissible purpose
– Employment purposes
– Adverse action
– Insurance underwriting
121
Fair Credit Reporting Act (FCRA)
 Consumer report:

The term “consumer report” means any written, oral, or other
communication of any information by a consumer reporting agency
bearing on a consumer's credit worthiness, credit standing, credit
capacity, character, general reputation, personal characteristics,
or mode of living which is used or expected to be used or
collected in whole or in part for the purpose of serving as a factor
in establishing the consumer's eligibility for:
– (A) credit or insurance to be used primarily for personal,
family, or household purposes;
– (B) employment purposes; or
– (C) any other purpose authorized under section 604 [§ 1681b].
122
Fair Credit Reporting Act (FCRA)
 Consumer reporting agency:
– The term “consumer reporting agency” means any
person which, for monetary fees, dues, or on a
cooperative nonprofit basis, regularly engages in whole
or in part in the practice of assembling or evaluating
consumer credit information or other information on
consumers for the purpose of furnishing consumer
reports to third parties, and which uses any means or
facility of interstate commerce for the purpose of
preparing or furnishing consumer reports.
123
Fair Credit Reporting Act (FCRA)
 Permissible purpose:







In general. Subject to subsection (c), any consumer reporting agency may
furnish a consumer report under the following circumstances and no other:
(2) In accordance with the written instructions of the consumer to whom it
relates.
(3) To a person which it has reason to believe
(A) intends to use the information in connection with a credit transaction
involving the consumer on whom the information is to be furnished and
involving the extension of credit to, or review or collection of an account of the
consumer; or
(B) intends to use the information for employment purposes; or
(C) intends to use the information in connection with the underwriting of
insurance involving the consumer; or
124
Fair Credit Reporting Act (FCRA)
 Permissible purpose:
– Before an employer can get a consumer report
for employment purposes, they must notify the
individual in writing - in a document consisting
solely of this notice - that a report may be
used. They must also get the person's written
authorization before asking the provider for the
report.
125
Fair Credit Reporting Act (FCRA)
 Employments purposes:
– The term “employment purposes” when
used in connection with a consumer
report means a report used for the
purpose of evaluating a consumer for
employment, promotion, reassignment or
retention as an employee.
126
Fair Credit Reporting Act (FCRA)
 Adverse action:
– Step 1: Before you take the adverse
action, the employer must give the
individual a pre-adverse action disclosure
that includes a copy of the individual's
consumer report and a copy of "A
Summary of Your Rights Under the Fair
Credit Reporting Act."
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Fair Credit Reporting Act (FCRA)
 Adverse action:
 Step 2: After you've taken an adverse action, the employer must give
the individual notice that the action has been taken in an adverse
action notice. It must include:
– The name, address and phone number of the CRA that supplied
the report;
– A statement that the CRA who supplied the report did not make the
decision to take the adverse action and cannot give specific
reasons for it; and
– A notice of the individual's right to dispute the accuracy or
completeness of any information the agency furnished, and his or
her right to an additional free consumer report from the agency
directly upon request within 60 days.
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Don’t mess with
the feds!
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Fair Credit Reporting Act (FCRA)
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Business Income and Extra
Expense
 Coverage Options
– Monthly limit: 1/3, 1/4, 1/6
 Limits to 3, 4, or 6 months
– Maximum period of indemnity
 No time limit on recovery
– Agreed value
 Does not waive coinsurance
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Business Income and Extra
Expense
 Coverage Options
– Business Income WITH Extra Expense
– Business Income WITHOUT Extra
Expense
– Extra Expense Only
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Business Income and Extra
Expense
 Coverage Options
– Business Income WITH Extra Expense
– Business Income WITHOUT Extra
Expense
– Extra Expense Only
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Business Income and Extra
Expense
 Methods to Provide Coverage:
– Coinsurance method
 Business Income Worksheet needed
 Long, tedious form
 Even accountants don’t understand it!
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Business Income and Extra
Expense
 Methods to Provide Coverage:
– Waiving coinsurance:
 Maximum Period of Indemnity
–Pays for a specific period of time
–Ends when coverage runs out or $$
runs out…whichever comes FIRST
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Business Income and Extra
Expense
 Methods to Provide Coverage:
– Waiving coinsurance:
 Monthly Limit of Indemnity
–1/3, 1/4, or 1/6 of the limit per month
–Limited to the maximum amount per
MONTH
–Pays until the $$ runs out
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Business Income and Extra
Expense
 Methods to Provide Coverage:
– Waiving coinsurance:
 Agreed Value
–Worksheet needed
–Insured and company agree on
values
–Good for 1 year from the agreement
date
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BBQ Joints
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And The BBQ Winner Is…
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As We Conclude…
 E-mail me with questions
 Dthompson@faia.com
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