Escheatment Update for AP

Accounts Payable Operations 2009 March 11-13, 2009 San Antonio, TX

By Dan Mayer Associate Director of Advisory Services Abandoned Property Services, LLC dmayer@apsescheat.net

Presentation Objectives
Refresh the escheatment compliance basics Suggest practices for minimizing liability Consider hot issues in audits, legislation and pending lawsuits

Basic Unclaimed Property Terminology

Basic Terminology
Holder The business or any other entity which holds inactive property that belongs to another and is deemed to be presumptively abandoned under state law. (In some case law, the debtor.) In A/P, this is the entity that is the payer of the check. Owner The person or entity to whom the property belongs. (Sometimes this is the creditor.) In the A/P realm, this is the check payee. Escheat In the UP industry, this means delivering or remitting property to the applicable state. Last Activity Date The date of last owner-generated activity. In A/P, the last activity date is the check date. This date is used to determine dormancy and correspondingly, when property is due for reporting and remitting to states. Dormancy Period The period of time property remains inactive before it is presumed abandoned by state law. Dormancy periods differ by property type and state. In A/P, most uncashed checks have a 3 or 5 year dormancy period.
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What is Unclaimed Property?

Unclaimed Property Basics: What is Unclaimed Property?

Definition: Any intangible personal property that is held, issued or owing in the ordinary course of business and has remained unclaimed by the apparent owner for a specified period of time after it became payable or distributable is presumed abandoned. Accounting errors are NOT unclaimed property. The most common unclaimed property:
1. A/P uncashed vendor checks 2. Payroll uncashed wage and expense checks 3. A/R unused customer/client credits, refunds 4. Equity uncashed dividend checks and underlying shares, certificates returned from the post office 5. Insurance-claims payments, refunds 6. Mineral Interests uncashed checks 7. Bonds uncashed interest checks and bond equity 8. Bank Accounts and CDs idle account proceeds (savings and checking accounts, official checks, timed deposits, etc.) 9. Third Party Administrator records 10. Suspense Accounts
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Do unclaimed property laws apply to my business?

1. Does every business have to comply with state unclaimed property laws? 2. Does it matter if our company doesnt do business or isnt registered in the state?

Business Nexus Not Required!

Answers: Yes, most businesses have to comply with state unclaimed property laws. No, it doesnt matter for unclaimed property purposes whether or not your company is registered to do business in a state. Business Nexus is NOT a consideration in determining whether property is due or the state to which it is to be reported. Texas v. New Jersey (USSC-1965): 3 rules Last known address of the payee/creditor controls When no address, the state of incorporation of the holder
controls When the state does not have a law pertaining to the property, the state of incorporation of the holder controls
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When Does a Business Comply?

What

is a dormancy period? is an as of or end date? are the reporting deadlines?

What

When

Examples of Dormancy Periods and End Dates for non-financial corporations

State Credit Balances (MS09)/A-R 3 years 3 years 5 years 3 years Vendor Checks (CK 13) 3 years 3 years 5 years 3 years Payroll Checks (MS 01) 1 year 1 year 5 years 3 years 3 years (8A) 1 year 2 years 1 year Annual Reporting Deadline 11/01 03/31 03/01 11/1 02/15 (1H) 03/10 (2G, 8A) 11/01 4/15 11/01 As of / End Date 06/30 12/31 12/31 6/30 12/31 6/30 12/31 6/30

California Connecticut Delaware Massachusetts New York Ohio Pennsylvania Texas

3 years (1H*) 3 years (2G) 5 years (1G) 3 years 5 years 3 years 3 years** 5 years 3 years

1H is the NY Code for Consumer Credit Balance **May be exempt under certain circumstances.
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Example - Facts

Yurco Industries (a business that is not a life insurance company) issued a check for $100 in payment to Yursupplier on Feb. 15, 2006. It appears from Yurcos records that Yursupplier has not cashed the check issued on Feb. 15, 2006. Yurcustomers address in Yurcos records is in California (where CK13 vendor checks have a 3-year dormancy period).
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Is this check reportable to California on the Fall 2009 reporting deadline?

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Answer to Example Question

Calculation: CA Fall 09 End Date = 6/30/2009 LAD or Issue Date = 2/15/2006
Dormancy Time = 3 years, 4 months, 13 days CA Dormancy (CK13) = 3 years Answer: This check would be eligible for reporting to CA on the Fall 2009 deadline for businesses that are not life insurance companies.
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Compliance and Best Practices

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The Basic Compliance Obligations*

1. 2. 3. 4. Records Review Due Diligence/Owner Contact Reporting and Remitting Record Retention

*All of the above must be done within the time frames and/or in the formats/modes required by the various applicable state laws.
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RECORDS REVIEW (aka Procedural Due Diligence)

As a part of a businesses unclaimed property procedures, the appropriate accounts and ledgers must be reviewed and data collected. ITEMS TO REVIEW: Vendor Items uncashed vendor checks Payroll Items Credit Memos / Balances 3rd Party Benefit Checks
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RECORDS REVIEW/PROCEDURAL DUE DILIGENCE: VENDOR CHECKS

Three Questions: Is the owner really lost? owner-generated activity ongoing client or vendor relationship pertinent owner/payee address Indication of bad address? Is the property really unclaimed? Procedural Due Diligence Offsetting Entries? Is the property exempt from reporting?
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RECORDS REVIEW/PROCEDURAL DUE DILIGENCE: VENDOR CHECKS

Question 1: Is the owner/payee really lost?
Other addresses in vendor file Finding a new address:

Forwarding Address: Payroll Checks Internet Sources

Switchboard.com PeopleFind.com People.yahoo.com Anywho.com www.free-people-search-engines.com Credit Bureaus (TransUnion, Equifax, etc.) Heir Finders
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Outsource Services

RECORDS REVIEW/PROCEDURAL DUE DILIGENCE: VENDOR CHECKS

Question 2: Is the property really unclaimed? Re-issues without voiding original. Duplicate items on Vendor Master Duplicate payments. Wrong payee. Inter-company payments (payments between related party companies). Periodic/recurring vendor payments (utilities, landlords, etc.). Reconciliation error (i.e., Bank rec has checks with sequential numbers outstanding/bad check run). Large dollar checks with familiar payee names. Check represents payment for an invoice for which a credit was issued.
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RECORDS REVIEW/PROCEDURAL DUE DILIGENCE: VENDOR CHECKS

Question 3: Is the property exempt from reporting? No automatic de minimus property exemption Business to Business Exemption (tricky-generally, for MS09Credit Memos, ) AZ, IL, IN, IA, KS, MD, MA, NC, OH, TN, VA, WI (WY-only for merchandise credits from gift certificates) Floridas under $10 exemption for credit balances Gift Certificate / Card Exemption (tricky)
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RECORDS REVIEW/PROCEDURAL DUE DILIGENCE: PAYROLL ITEMS

Payroll - Follow-up on items outstanding once per year (internally) Review Listing of Eligible Escheatment
Are Employees active or retired? Are Employees on overseas assignment? Are Employees retired and receiving a pension?

Direct Deposit (monthly review / clear)

Third Party Checks (Benefits, etc.) Follow-up on items outstanding periodically (for items over 90 days old)
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Procedural Due Diligence Best Practices

1. Review / research outstanding checks/payments on a regular basis (60 90 days) for accounting errors, familiar payee names, or offsets. a. Set a materiality limit b. Reverse identified accounting errors, make appropriate offsets Review supplemental information that may lead to the address of an employee or former employee. Establish contact with the payee through correspondence and telephone calls and resolve outstanding checks. a. If appropriate, do electronic database searches for better addresses for items over the materiality limit and for those items with familiar payee names 4. Retain documentation of reversals resulting from research or contact. 5. Maintain written procedures for record review and make them a part of your companys policy or manual. 22

Statutory Due Diligence: Attempt to Contact the Payee/Owner

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Statutory Due Diligence (the 2nd Obligation)

The Due Diligence Requirement: A last attempt to contact the owner/payee prior to reporting and remitting unclaimed property Important Elements:

Method Letter Content Timing Form or Mode of Delivery Limitations/Exceptions Allowable Deductions
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Statutory Diligence (the 2nd Obligation)

1. Methods: a. Generally A letter to the owner at the last known address in the records of the holder b. Banks/Insurance Companies Delaware (Life Insurance) and New York (utilities, too) require publication in newspapers 2. Letter Content: a. Generally 1995 Uniform Act (Section 7e): i. Must state that the holder is in possession of the property subject to the unclaimed property law ii. b. Must state that the claim of the owner is not barred by the statute of limitations iii. That the value of the property is greater than $50.

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Sample Due Diligence Letter

Date Name, AP or AR Manager Company Street Address City, State Zip Dear AP or AR Manager: Our records indicate that your company may be the owner of funds or have an interest in funds represented by the items listed below. No transaction or other activity has occurred for a significant period of time. If you have an interest in the funds and wish to prevent the funds from being reported and remitted as unclaimed property to the State of ________, please indicate the disposition of the items listed below. After you complete the form, please fax it to us immediately at XXX-XXX-XXXX or mail it to us in the enclosed stamped, self-addressed envelope. Please reply by __________. Nature of Funds Check #XXXX Credit memo #XXX Date Issued XX/XX/XX XX/XX/XX Amont $XXXX $XXXX Description/Reference Invoice No. XXX-4 gross widgets

Disposition of Items (Check the blank next to one of the following.) ____ The above (s) / credit memo was cashed/or applied on ________. ____ Check (s) / credit memo was received but not cashed/applied. (If you still possess the check (s) / credit memo please return it/them along with this letter indicating if you are still entitled to these funds. ____ Check (s) / credit memo is no longer required. There are no outstanding invoices for this amount and the obligation has been satisfied. ____ This check (s) / credit memo was not received and our records indicate the amount is still due. Please issue another check. ____ Other: ____________________________________________________________________________________________ Name: ___________________________ Signature:___________________________________________________________ Address (if different from above)__________________________________________ SSN/Federal ID No. __________________________________ Date: ______________________________________________ Sincerely,

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3. Timing:

Statutory Due Diligence (the 2nd Obligation)

a. Generally Not more than 120 days nor less than 60 days prior to the reporting deadline. (1995 Uniform Act, Section 7(e)): AL, AR, DC, FL, GA, IL, IN, KS, KY, LA, ME, MT, NE, NV, NH, NJ, NM, NC, TN, UT, VT, WV, WI b. Within 180 to 365 days prior to filing report: CA c. Not required but recommended: DE*, TX, PA d. Required but no timing specified: IA*, MS, SD, WA *Please see state statute for more details. Time frames for due diligence may change as new legislation is adopted. 4. Form of Delivery: a. Generally No specification in the1995 Uniform Act, Section 7(e), but most states require first class mail. b. Notable exceptions: Iowa - Requires Banks and Financial Institutions only to send due diligence letters by certified mail. New Jersey For items that are greater than $50, the letter must be sent certified mail, return receipt requested. New York - First notice by first class mail within 90 days prior to reporting deadline; second notice by certified mail, return receipt for $1000+ Ohio - Certified mail requirement for items $1000 & greater
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Statutory Due Diligence (the 2nd Obligation)

5. Limitations/Exceptions: a. DUE DILIGENCE MINIMUMS - By Item Amount/Value (ex. Securities): $10 IL $25 - NE $50 AR, AZ, CA, CO, DC, FL, GA, HI, ID, IN, LA, ME, MI, MO, MT, NC, ND, NH, NJ, NM, NV, OH, OK, RI, SC, SD, TN, UT, VI, VT, WI, WV, WY $75 WA $100 - AK, KS, KY, MA, MD, MN, OR, VA No minimum AL, CT, IA, MS, NE, NY, PR b. No Statutory Letter Due Diligence RequirementDE, PA & TX c. Self-Addressed Stamped Envelope Requirement-OH d. Publication requirement 1. Delaware - Banks, courts, and life insurance 2. New York - Banking organizations, insurance companies, and utilities must publish in newspaper in city of residence of owner. Due Diligence mailing still required! 3. Puerto Rico has an advertising requirement.

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Statutory Due Diligence (the 2nd Obligation)

6. Allowable Deductions: CA Banks and financial organizations may impose a service charge for the notice in an amount not to exceed $2.00 on items over $50. DE Expense incurred for advertisement is deducted from remittance due IL May deduct first class mailing costs (postage, stationary, and envelopes IA May deduct cost of mailing from amount owed NV Charge of not more than $2.00 may be deducted from owners with over $50 and must be listed as line item on the report NY May deduct cost of certified mail and return receipt as a service charge. Also, may deduct costs of publication on a pro rata basis (using a specified formula.) OH Deductions are allowed up to $20.00 for certified mail OK May deduct only the cost of postage. PR May deduct expenses incurred in advertising
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Reporting and Remitting

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Reporting and Remitting (the 3rd Obligation)

Important Considerations: Type of Report Report Format Negative Reporting Report Aggregate Limits Form of Remittance Report & Remittance Delivery Filing Extensions

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The Report 1. Type - Paper, Diskette, CD, Magnetic cartridge, tape or Internet a. Most states require electronic (diskette or CD) reporting if there are more than 25 items to report b. Note that some states that require electronic reporting also require that a hard copy of the report accompany the electronic report. c. Internet! Some states have on-line reporting. Examples: Massachusetts: https://abpweb.tre.state.ma.us/abp/frmLoginTaxId.aspx First time call: 617-367-0400 x471 or 1-800-647-2300 x 471 New York: First time call: 1-800-221-9311 or email NYSRPU@osc.state.ny.us to get username and password. Texas: https://txcpa.cpa.state.tx.us/unclpropholder/welcomeAction.do?actio n=Holder
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Reporting and Remitting (the 3rd Obligation)

Reporting and Remitting (the 3rd Obligation)

2. Format

NAUPA II Standard Reporting Format accepted by 44 states. See: www.wagers.net/NaupaSpec/NaupaRevisedStandard.pdf Standard relationship and property type codes listed as well. NY does not use the NAUPA II Format or property type codes. CA accepts the NAUPA II Format see: www.sco.ca.gov/col/ucp/holder/stdnaupa.pdf
3. Negative Reporting - Required by 30 states. Some states permit on-line. Example: Ohio - www.ohiobusinessgateway.ohio.gov negative reporting

4. Aggregate limits Most states have a limit under which the property does NOT have to be reported with name and address detail. Items are combined by property type and reported as an aggregate lump sum. $25, $50, & $100 are usual the limits. Most states do not permit aggregate reporting of dividends or mineral interests.

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Reporting and Remitting (the 3rd Obligation)

refunds) are usually by check written to the appropriate state official or agency. Example: TX-Texas Comptroller of Public Accounts Unclaimed Property Exception: Some states do not permit checks to be used for the remittance if the total amount is greater than a specified sum. Examples: 1. CA requires that if the sum (including interest penalty amounts) is greater than $20,000 it must be delivered by electronic funds transfer in the specific manner designated in CCP Section 1532. See www.sco.co.gov for details. 2. TX law requires holders who paid $100,000 or more during the previous state fiscal year to make subsequent payments by electronic fund transfer. The preferred method is through TEXNET for more information, see: http://www.window.state.tx.us/up/reporting.html
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The Remittance a. Form Cash (uncashed vendor, dividend and payroll checks, credits,

Reporting and Remitting (the 3rd Obligation)

5. The Remittance b. Form Certificate or Confirmation (stock, mutual funds, book entry shares, etc.) While some states want shares to be liquidated prior to remittance, most want certificated or book entry confirmation shares registered in the name of the appropriate state official or agency or nominee. 6. Report and Remittance Delivery a. Timing on or before the deadline specified. (Fall By Nov. 1st, Spring varies by state) b. Verifiable delivery is very important. 7. Filing Extensions a. Notification of state administrator b. Reason c. Estimated, timely payment required? (i.e. NJ, TX)
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Reporting Red Flags!

Tips - Preventing Reporting Red Flags by: Making sure your reports/cover sheets are completed and signed (and notarized if required) Making sure the report reflects the same dollar amount that is reflected by your remittance Filing negative reports if required (one exception) Requesting filing extensions at least 2 weeks prior to the filing deadline Using the state prescribed cover sheets and/or holder numbers when filing reports Filing all property types: securities and general ledgerrelated and filing them accurately (not disproportionately)
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Record Retention

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1. Retention Time Period

Record Retention (the 4th Obligation)

1995 Uniform Act (Section 21) a holder required to file a report must maintain the records containing the information required to be included in the report for 10 years after the report is filed. (Drafters notes indicate records are to be kept for 10 year from the date the property was first reportable.) TX Statutes Title 6, Section 74.103 - Holders must maintain records for 10 years after the property was reportable. 2. Records to Retain 1995 Uniform Act (Section 21) Silent on this issue. TX Statute is specific that records maintained must include: (1) the name, the social security number, if known, and the last known address of each person who, from the records of the holder of the property, appears to be the owner of the property; (2) a brief description of the property, including the identification number, if any; and (3) the balance of each account, if appropriate
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Record Retention (the 4th Obligation)

Practical Considerations: Audit Protection
Verification of reversals - accounting and data errors Evidence of reporting and timely reporting Evidence of due diligence including certified mailing if it was required. (Note: OH law specifically requires retention of proof of certified mailing, or proof of valid exemption of certified mailing, for at least 5 years from the report filing date or completion of a State compliance audit, whichever is earlier.)

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AUDITS
Preparing for An Audit Working with the State Considerations Penalty Review

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Preparing for An Audit

Preliminary Questions 1. Who is performing the audit? (State or contract/third party auditors?) 2. Which states are involved? 3. What is the scope of the audit? (Number of years covered in the audit.) 4. What audit procedures will be used? (What procedures will be used when records are incomplete or nonexistent?) 5. What are the auditors schedules and site requirements? 6. Will the state(s) or their agent sign a confidentiality agreement? 7. Have you considered obtaining legal counsel and outside expertise to address audit issues?
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Preparing for An Audit

Internal Review Prior to Audit Document internal controls Review chart of accounts Consider all company policies and procedures related to unclaimed property compliance and reporting Review previously filed unclaimed property reports Compile supporting documentation, including due diligence records Review voided and outstanding check lists Obtain non-ERISA benefit plan information and evaluate potential liability Involve legal counsel in the internal review and in correspondence with the auditors
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Preparing for An Audit

Data to Provide to Auditors Organization Chart Chart of Accounts Merger and Acquisition history Unclaimed Property Reports in previous years Bank Account Related Info (Reconciliations, Statements and Outstanding, Voided and Stopped Check Lists) General Ledger Trial Balance Documentation (including A/P, Payroll and Write-off Account Detail)

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Working with the State

Audit Considerations Consider Documentation Availability Timeframe Available Research Depth (to determine disposition of specific items) System Conversions/Upgrades may impact historical data available Understand Write-Off History for A/P and Payroll Accounts Review Chart of Accounts and Trial Balance
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Working with the State: Penalty and Interest Assessments

Is the penalty accurate? Consider time frame/scope of the penalty (CA corporate fiscal year controls) Does state law permit compounding? Recalculate penalty to determine accuracy Was the penalty assessed in error or is it unenforceable? Is there a statute of limitations on penalty assessment? Was the property that is the subject of the penalty filed during an amnesty period? Are there circumstances that may permit the state to set aside the penalty ? Can the state waive penalties and interest? (If so, what are the parameters for waiver?)
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Latest Developments

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Latest Developments: Audit Issues

Received Not Invoiced/Unmatched receivers Assuming excess merchandise shipped over order and not invoiced. Extrapolations Unreasonable basis Extended Audit Periods Eroding the holders will Audit Costs Indiana now requires holders to pay the costs of third party audits

Latest Developments: Legislation/ Dormancy Period Changes

Delaware SB 334 Effective Date: 7/1/2008 - Reduced the securities-related dormancy periods from 5 years to 3 years (except SC20 Credit Balances which remain at 5 years). Hawaii - HB 2559 Effective date: 7/1/2009 - the HI legislature adopted the 1995 Uniform Unclaimed Property Act to replace the current Hawaii unclaimed property law. This legislation impacts reporting for the October 31st, 2009 deadline. As of or cut-off date for that year will be June 30th for all entities except life insurance which will have a December 31st cut-off date AND an October 31st reporting deadline. The report aggregate limit will be $50. New Hampshire HB 1533 Effective date: Approx. 8/3/2008 - Various changes to the NH Abandoned Property law. Significant provisions in the bill include: 1) All reports with 20 or more items must be reported in an electronic format prescribed by the administrator; 2) Securities dormancy periods (including underlying shares) were reduced to 3 years from 5 years; and 3) Requires the unclaimed property administrator to precede a sale of securities with a mailing to the owner. Virgin Islands: Bill 27-0169 Effective Date: 7/12/08 Repeals the unclaimed property law and replaced it with a new one. Generally, the new law has 5, 3 and 1 year dormancy periods (i.e., gift certificates, customer credits in retail and insurance payments = 3 years; utility deposits and refunds, payroll and property held by a court or government = 1 year, securities, savings accounts and checking accounts = 5 years). The new law has a due diligence minimum and aggregate limit of $50. The reporting deadline is November 1st for all entities except life insurance which has a May 1st reporting deadline.

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Latest Developments: Legislation/Various Changes

Tennessee - HB 3793 Effective Date: 5/16/2008 - Safeguards the working papers and identity of holders involved in unclaimed property audits. Makes such paper confidential and not public records unless certain circumstances exist. Wisconsin: AB 617 Effective Date: 3/21/2008 The fiscal year is defined to be from July 1st to June 30th for the purposes of the report information cut-off and penalty assessment.
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Latest Developments: Gift Cards and Certificates

Over 30 states have statutes that restrict gift card and certificates. Some prohibit dormancy fees and expiration dates. The statutes vary dramatically from each other. Some do not apply to prepaid phone cards, pay cards, or other open system cards that can be used with multiple stores Simon Lawsuits federal preemption for certain cards not subject to state restrictions Newest legislation: Nebraska exempts from the NE unclaimed property law, gift cards or certificates that have no expiration date or dormancy fees. If have such then law applies with a 3 year dormancy period. Does not apply to prepaid cards.

Latest Developments: Gift Cards and Certificates (2)

Options: 1. Incorporate a gift card issuing company in a state where gift cards are exempt from escheatment. May need a consultant to make it is done correctly. 2. Remove expiration dates and dormancy fees from gift cards. 3. Retain name and address of purchasers of gift cards and certificates. 4. Consider transactional rules. 5. Consider privacy issues.

Latest Developments: Third Party Disbursements

A Third Party Administrator (TPA) is a specialized service provider that may manage all or parts of specific functions within a company. Transfer Agent Securities/Dividend Payroll & Vendor Payments HR Benefit / 401K Paying Agent

Latest Developments: Third Party Disbursements

Who is Liable for Escheat? What functions were outsourced? Issuer/Company may still be liable Best Practices If TPA is required under contract to do the escheatment: Make sure contract permits audit of escheat activities Add a clause to contract that the TPA must provide proof of compliance with state escheat laws (i.e., copies of due diligence letters, reports and remittances) Add a clause to the contract that requires the TPA to indemnify your company if the TPA fails to comply or inadequately complies and your company is assessed penalties and/or interest

Latest Developments: Rebates

Third party rebate processors Whose obligation is it? Ongoing litigation Fitzgerald v. Young America Current status Rebate creation/construction Problem provisions Current Audit Ramifications

Latest Developments: Pending Lawsuits

1. Massachusetts B2B Exemption - Outstanding credit balances to a vendor or commercial customer from a vendor resulting from a transaction occurring in the normal and ordinary course of business shall be exempt from the provisions of this chapter. M.G.L. ch. 200A, 5. Massachusetts reverses its application of this statute, resulting in lawsuits: Biogen v. Cahill Stride Rite v. Cahill

Latest Developments: Pending Lawsuits

2. California Release of Liability No Bar to Suit CA Court of Appeals overturned the summary judgment granted by the lower court stating that Hewlett Packard is not immune from suit when it transferred the plaintiffs abandoned property to the state of California under the California unclaimed property law. Vondjidis v. Hewlett Packard, 85 Cal. Rptr. 3d 806 (6th App. Dist., Nov. 25, 2008) 3. Holder challenges Delaware in assessing interest and for enforcement of terms of a voluntary disclosure agreement. Computer Associates, Inc. v. Cordrey, et. al. (Filed 10/22/08). 4. California Violates Due Process and Must Make More Effort to Contact Owners - In a California US District Court, the initial rulings caused California to change how unclaimed property reports must be filed. Main case pending. Taylor v. Westly, 488 F.3d 1197, 1201-02 (9th Cir. 2007).

Resources
1. 2. 3. National Association of Unclaimed Property Administrators (NAUPA) www.unclaimed.org NAUPA II Standard Reporting Format: www.wagers.net/NaupaSpec/NaupaRevisedStandard.pdf 1995 Uniform Unclaimed Property Act Reporting Specifications: http://www.law.upenn.edu/library/ulc/fnact99/1990s/uupa95. txt National Association of State Treasurers (NAST) www.nast.net Unclaimed Property Professionals Organization (UPPO) www.uppo.org Annual Conference March 10 13, 2009 Hyatt Regency Jacksonville, FL
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4. 5.

Your Presenter Today:

Dan Mayer 770-437-0506 dmayer@apsescheat.net

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