Speech by SEC Commissioner:
Remarks at the New America Alliance Conference
Commissioner Roel C. Campos
U.S. Securities and Exchange Commission
Santa Ana Pueblo, New Mexico
August 11, 2006
Good afternoon. I'd like to thank Regina Montoya, Martin Cabrera, Jorge Castro, and Federico Muņoz for inviting me to join you in this wonderful initiative. Before diving into my remarks, it is necessary for me to make the disclaimer required of all Commission speakers that the comments I make here today are my own and do not represent the views of the Commission, the other Commissioners, or the staff.
As the first Latino Commissioner of the United States Securities and Exchange Commission and a former businessman, I have long been a strong supporter of and believer in New America Alliance's mission of empowering Latino business leaders through economic advancement and enhanced access to capital in all forms. In fact, one of my key initiatives during my tenure as an SEC Commissioner has been to push for enhanced diversity, not just at the SEC, but also in the corporate and securities industries. However, while we have witnessed some of the most fundamental reforms to the securities industry since possibly the inception of the SEC and the creation of federal securities laws in the 1930s, the issue of inadequate minority representation in our corporate boardrooms and in the financial services industry remains as frustrating a problem as ever. In my remarks today, I will discuss this ongoing problem as well as some recent SEC topics that are current and relevant to the pension fund industry. But, first, a "Wall Street" joke, if you will...
A hypothetical conversation between a Wall Street Stockbroker and God:
Stockbroker: What is a million years like to you?
God: Like one second.
Stockbroker: What is a million dollars like to you?
God: Like one penny.
Stockbroker: Can I have a penny?
God: Just a second ...
II. The Important Role of Pension Plan Investors
The critical importance of pension and retirement plans in today's financial marketplace is self-explanatory one need only look at the sheer size of assets that are managed by our public and private pension and retirement plans. In the U.S. alone, Americans' retirement assets reached a record $14.5 trillion in 2005 a 7% increase over 2004. Retirement assets now account for more than 1/3 of all U.S. household financial assets.
For many working Americans, their retirement assets will be their single largest financial asset. Assets held in employer-sponsored retirement plans represented 65% of total U.S. retirement assets in 2005. Investors held $3.7 trillion in defined contribution plans, accounting for 39% of employer-sponsored plan assets. Another $1.9 trillion was held in private employer-sponsored defined benefit plans in 2005, accounting for 21% of employer-sponsored plan assets. In addition, investors held $2.7 trillion in state and local government defined benefit plans and $1.1 trillion in federal pension plans. If you step back and look at these staggering numbers, it is self-evident why pension and retirement plans are such important investors in the U.S. they make up the largest category of institutional investors and are some of our most influential shareholder activists.
A. Pension and Retirement Plans as Forces for Positive Change
Pension and retirement plans often have been the force behind positive social, economic, and policy changes. Because of their "power in numbers," managers and trustees of these plans have had a particularly important role in shaping the structure and policies of the business world. Many state-level bodies manage huge amounts of state and local government retirement funds. Another important shareholder activist is the Teachers Insurance and Annuity Association-College Retirement Equity Fund also known at TIAA-CREF which manages more than $370 billion of this country's teacher retirement assets. Moreover, there are many private-sector, multi-employer funds that are managed by labor unions and employer groups who also are extremely influential shareholder voices. The opinion of institutional investors like pension and retirement plans have profoundly influenced the corporate governance structure of some of the largest businesses in the world and have also been major players in campaigns that challenged corporate policies on labor, the environment, and diversity.
The pension and retirement industry also has been an important voice in the SEC's regulatory process. This industry has commented and advised on every major rulemaking and regulatory action undertaken by the SEC in recent history. Hearing from this particular industry is very valuable for the SEC's work because the pension and retirement industry is not just any ordinary institutional investor community. As the keepers and safeguarders of trillions of retirement dollars, these plans speak with a dual voice they are not only some of the largest and most sophisticated investors, they also represent and speak for millions of individual investors who invest solely or primarily through their retirement plans.
B. Pension Industry's Support of the Sarbanes-Oxley Act
The pension and retirement industry was one of the strongest supporters of the Sarbanes-Oxley Act. There was widespread support for the rigorous improvements to corporate governance, disclosure, and internal controls required by the Sarbanes-Oxley Act. In fact, I think it is fair to say that all of the major provisions of the Sarbanes-Oxley Act including the enhanced role of audit committees, certifications by executives on financial statements, the creation of the PCAOB, and independence on corporate boards have been embraced by investors. Moreover, every major principle of the Sarbanes-Oxley Act with one notable exception which I will discuss in a moment has been adopted or is converging through all jurisdictions.
The only real issue that has lingered with respect to the Sarbanes-Oxley Act is the internal control requirements of Section 404. A major issue of contention surrounding Section 404 has been the costs associated with compliance. We at the SEC have worked mightily to find a solution that will retain the tremendous investor protection benefits of Section 404, but also meaningfully reduce costs and implementation burdens. Thus, on May 17, 2006, the SEC announced a roadmap for improving the implementation of Section 404's internal control requirements. I am happy to report that over the past three months we already have accomplished many of our target goals. We recently issued a concept release as a prelude to forthcoming practical guidance for company management in assessing a company's internal controls for financial reporting. We are hopeful that such guidance will help improve the reliability of financial reporting and make Section 404 implementation more efficient and cost effective for investors. Moreover, this week we issued two releases that: (1) extended the compliance date for the auditor attestation portion of Section 404 compliance for foreign private issuers that are accelerated filers (but not large accelerated filers); (2) proposed to extend the compliance date for Section 404 compliance for all non-accelerated filers; and (3) proposed to give newly public companies a transition period to comply with the internal control requirements of Section 404.
Section 404 is a top priority for us this year, and we are determined to get it right. It is particularly important for the SEC to hear from the pension and retirement industry when dealing with a particularly controversial or costly regulatory initiative like Section 404. Therefore, we encourage your comments on this major ongoing regulatory initiative. Moreover, continuing support by the pension and retirement industry for the Sarbanes-Oxley Act will be critical to balance the counter-swing of the pendulum that will inevitably occur as corporate scandals recede from our country's collective memory. In this regard, I have been heartened to see major institutional pension investors such as CalPERS continue to strongly support the Sarbanes-Oxley Act, and publicly state their willingness, as shareholder-owners, to bear the associated costs.
III. Other Areas in Which Governance Strategies Have Led to Improvements
A. Majority Voting for Directors
As many have pointed out, the plurality voting system for directors has created a situation in which it is next-to-impossible for shareholders to remove a director from the board. Indeed, because the only choices for a shareholder with respect to director elections are to "vote for" a director or to "withhold" one's vote for a director, a director can still be elected even if the votes "withheld" exceed the votes "for" that candidate. In fact, a director could theoretically be elected with less than 1% of the vote for him.
Nevertheless, activist institutional investors have led the charge in improving the director election process. Some have availed themselves of the proxy process to require individual companies to adopt binding bylaw amendments or voluntary corporate governance policies requiring directors to receive a majority of the votes cast, not just a plurality. While the Commission itself is not responsible for the adoption of these policies, I should note that many companies have adopted them at the behest of shareholders, who have submitted proxy proposals in this regard. According to statistics from Neal, Gerber & Eisenberg, as of May 2006, at least 28% (a 12% increase from February 2006 just three months prior!) of the companies in the S&P 500 have adopted a majority vote policy, bylaw, and/or charter provision.
Of course, many companies have sought to exclude these proposals from their proxy materials, but if properly phrased, our Division of Corporation Finance has generally not allowed them to be excluded. Further, some companies are not waiting for shareholder pressure and are adopting majority voting requirements on their own. While these new policies still do not permit shareholders to affirmatively nominate a candidate for election to the board, they do allow shareholders to effectively vote off board members without having to engage in a full blown proxy contest. I view these as positive steps in favor of shareholder democracy.
B. Executive Compensation
As I'm sure many of you know, the SEC recently approved final rules that significantly updated and expanded executive compensation disclosure. Executive compensation has become a "hot-button" issue, with almost daily reports of massive salaries and perquisites for CEOs at companies whose stock price and financial condition have been average at best. I believe that a large part of the public outrage comes from two factors: (1) a disconnect between executive pay and company performance; and (2) the inability of investors to understand or do anything about this disconnect. While our new rules don't allow investors to have a direct say in the level of executive compensation, I'm hopeful that the new tabular and narrative disclosures will at least allow investors to have a clearer sense of total compensation, and, specifically, what executives are making. Further, I hope that this expanded disclosure will empower more shareholders, particularly the large pension funds and institutional investors, to challenge over-the-top executive compensation. Let me briefly mention some of the highlights of our new compensation disclosures, some of which are brand new requirements and others of which are improvements to the former disclosure requirements:
- First, the rules require disclosure of a "total" compensation figure, which includes the fair value of options and stock issued to executive officers.
- Second, companies are required to have meaningful narrative disclosure about compensation practices in a new section entitled Compensation Discussion and Analysis (or CD&A, for short).
- Third, I think the new rules do a good job of capturing equity compensation in the form of restricted stock and options. We have a number of different tables designed to get at all aspects of equity compensation, including: (1) their fair value; (2) the number of shares of stock and options received; and (3) the value realized when options are exercised and restricted stock vests.
- Fourth, we are requiring much more extensive disclosure about post-employment compensation. Indeed, we have adopted two separate tables a pension benefits table and a deferred compensation table that will call for very specific disclosure in this regard. More than anything else, this new disclosure has the possibility of leading to as noted in a recent L.A. Times article "stunned-silence moments," "eye-popping" disclosures, and "holy cow" reactions.
C. Shareholder Advisory Vote on Executive Compensation
Now that I've mentioned a few of the more important items in the new executive compensation rules, let me briefly mention what is not in there, namely, a rule that would allow an advisory shareholder vote on certain aspects of executive compensation. I've previously discussed this, and I should point out that the United Kingdom and Australia already have an advisory vote requirement on the compensation report.
My point today, however, is that even though the SEC has not acted, you the investor can. Investors can use the proxy process (as they have with majority voting proposals) to force companies to include advisory vote proposals on executive compensation in their proxy materials. Indeed, this year, a number of companies determined not to fight the shareholders who submitted proposals calling for a policy whereby shareholders could vote on an advisory resolution to approve the Compensation Committee Report, and simply included them in their proxy materials. Further, during this proxy season, the SEC's Division of Corporation Finance required companies to include in their proxy materials various types of similar advisory vote proposals.
The bottom line is that today, investors armed with the increased knowledge of executive compensation as a result of our new rules can take matters into their own hands if they are unsatisfied with certain aspects of executive compensation.
D. Shareholder Access Is Being Accomplished.
Let me conclude this portion of my talk with some general thoughts on the topic of shareholder access which, in my mind, generally refers to the ability of shareholders to gain access to the directors of a company as a means of influencing important decisions. The SEC's most comprehensive foray into shareholder access was the late 2003 proposal which would have, under certain circumstances, required companies to include in their proxy materials shareholder nominees for election as director. As proposed, the rules would have created a mechanism for nominees of long-term shareholders with significant holdings to be included in company proxy materials where there were indications that shareholders need access to further an effective proxy process. I was in favor of the proposal then, and I think it is a shame that we never issued final rules on this topic.
That said, there is still reason to hope because I think institutional investors have become much smarter and more aggressive over the last few years, and have made their influence felt even without the finalization of our proposal. At the most basic level, large shareholders have been pressuring companies to adopt shareholder-friendly policies via letter writing campaigns and effective use of the media, as well as through more formal campaigns to withhold votes from directors and to place ballot initiatives on company proxy materials. There is at least anecdotal evidence that these tactics are working. I've mentioned a few of the more popular ballot initiatives majority voting for directors and advisory votes on executive compensation above.
IV. Alternative Investments
I'd like to move on to an area that has been the focus of much of the SEC's work over the past few years, and one that is very important to the pension and retirement industry today hedge funds and alternative investments. An increasing amount of pension money is being allocated to alternative investment vehicles such as hedge funds because of the allegedly greater returns produced by absolute returns. Between January 1997 and January 2005, pension-fund assets invested directly in hedge funds grew to $71 billion from $13 billion, according to Hennessee Group. As you well know, most hedge funds keep pension assets below the 25% ERISA limit so they are not declared a fiduciary with all of the associated legal obligations.
Congress recently approved a bill that would circumvent that threshold by permitting hedge funds to exclude assets of public-employee or foreign pension plans in the 25% ceiling. Proponents of the bill argued that pension funds are denied investment opportunities with quality hedge funds because the hedge funds must turn them away once the threshold is met. Opponents maintained that hedge fund strategies are inconsistent with the philosophy of pension funds that should look to steady, risk-adverse growth. In addition, those who believe hedge funds are not adequately regulated suggested that pensions could be threatened by loosening the 25% threshold. The answer may be somewhere in the middle and I am very interested in your thoughts.
I imagine that your views will vary based on your relationship with the hedge fund. At times, hedge funds and pension plans may be allies, pressing for corporate governance improvements. At other times, you may be on opposite sides because of your investment horizons or risk tolerance. This scenario mirrors that of the corporate shareholder role we discussed earlier, except that a hedge fund may have more heft in influencing corporate action based on the size of its typical investment. So, agreement with the hedge fund may produce welcome results while disagreement could mean your position loses. My point is that there is another player in the court of activism and pension funds will have to strategize carefully as to which team they choose to play on.
A. The SEC's Hedge Fund Rule
This past Monday, the Commission announced that it would not seek appeal of the Goldstein decision, thereby closing this particular chapter of hedge fund regulation. The Commission's decision not to appeal the decision was a tactical determination and not a statement on the merits of the rule. As the Chairman noted in his statement, "the Commission's Solicitor and General Counsel have concluded that, since the appellate court's decision was based on multiple grounds and was unanimous, further appeal would be futile and would simply delay and distract from our goal of advancing investor protection." While I might have seen value to an appeal with respect to fealty issues for the Agency in its rulemaking function, I agree with the final decision to forego an appeal.
However, the Commission already is faced with writing a new chapter on hedge fund regulation to quickly remedy some of the unintended consequences stemming from the breadth of the Court's opinion and its effect on the Commission's rulemaking. It may be as early as today that you will see some of the "clean up" measures that the Chairman spoke of at his Congressional testimony mid-July and in his statement earlier this week. First, the Chairman has tasked the staff with drafting an anti-fraud rule under the Investment Advisers Act that would have the effect of "looking through" a hedge fund to its investors. In addition, the staff has been tasked to consider whether the Commission should increase the minimum asset and income requirements for investors in hedge funds. I wonder, too, whether we should consider reforming the offering process for hedge funds, particularly the public solicitation component.
The bottom line is that the financial markets are at a crossroad with respect to hedge funds. The amount of money invested in hedge funds is large and growing and the impact of hedge funds on the markets is substantial, accounting for 30% of trading on US markets. Yet, the universe of information available regarding hedge funds and their attendant risk remains small albeit growing.
This is where your help is instrumental. We need to know your thoughts on hedge fund regulation. Is there a need for uniform regulation, along the lines of registration or notice filing? Should regulation focus on the hedge fund counterparties instead of the funds or advisers themselves? What information from a hedge fund or an adviser is critical to your comfort as an investor? I have been meeting with hedge funds of all types over the past few weeks to expand my understanding of this segment of the fund industry and to garner their thoughts on regulation. Now, I'd like to hear from the institutional investor so that I can further fill in the picture.
V. Latino Representation in the Pension Industry and Financial Service Sector
Let me conclude my remarks by touching upon a topic that is near and dear to all of us, and one of the many common ties that bring us to New Mexico today in such large numbers diversity and Latino representation in the financial services sector.
A. The Consumer/Population Power of Latinos
It is no secret that the future of America's success as a global economy and society will depend in significant measure upon the contributions of the American Latino community. The current aggregate purchasing power of Latinos is $768 billion a year, which is expected to grow to $1 trillion by 2010. According to a September 2005 U.S. Census Bureau press release, Latinos currently make up approximately 14% of the nation's total population, making us the largest race or ethnic minority in the country. And these numbers are exploding. By 2050, it is estimated that the Latino-American population will number approximately 102.6 million people and will represent nearly 1 out of every 4 people living in the U.S. Thus, Latinos in this country will be critical to all sides of the economic equation.
B. Lack of Capital and Human Investment in Minorities
So why is capital and human investment in the Latino community still lagging? Notwithstanding the incredible numbers I just listed above, minority representation in the financial and corporate sectors remains sub-optimal. While the number of people of color in the financial industry has increased over the last several years, the increase is, by many accounts, very small. A July 2006 study by the Government Accountability Office (GAO) found little increase in the diversity of financial services industry over an 11 year period from 1993 to 2004. Latinos are particularly hard hit in this respect. A study done for Hispanic MBA Magazine estimated that although Latinos account for 10% of the workforce, we number a mere 4.5% of all managers and less than 2% of all Fortune 1000 boards.
Corporate citizens and the financial sector play a critical role in supporting the American economy both as market participants, capital distributors, and employers. Their roles as major policy drivers not only influence our economy, but our domestic and social policy agendas as well. So long as we remain marginalized in corporate and financial America, we will be unable to access one of the largest "voices" in this country and will be underrepresented in American policy. As the saying goes, "money talks," and nowhere does this voice register more loudly than in our Fortune 1000 boardrooms, the investment banks, and in the ever-growing pension industry.
C. The Business Case for Diversity
Responsibility falls upon our corporate and banking citizens to hire, promote, and enter into business relationships with the Latino community. Doing so not only makes good social sense, it makes good business sense since more and more of our businesses and our human talent will come from the Latino community over time. Failure to adequately access this resource will result in a competitive disadvantage for companies who are facing a huge wave of baby boomer retirements, fierce competition for the best employees, and an increasingly complex and technical business environment. According to the U.S. Census Bureau, approximately 2.7 million Latinos hold college degrees and 714,000 hold advanced degrees and these numbers will only continue to grow.
As a Commissioner, I have been fortunate to have had a significant role in recruiting, supporting, and promoting talented Latino candidates for some of the most senior policy positions at the agency. In the corporate world, we also have seen outstanding examples of Latino executives personally pushing for greater diversity both within their ranks and in their outside communities. Jim Padilla, as Chief Operating Officer of Ford, spearheaded a Multicultural Alliance in 2003 which contributed to Ford naming its first Latina Kimberly Casiano to its board of directors, and making the recruitment and retention of minorities at Ford a priority. Commerce Secretary Carlos Gutierrez also championed for diversity when he was CEO of Kellogg Corporation by prohibiting executives from speaking at student functions, attending recruiting programs, or offering scholarship money to schools that skimped on affirmative action.
Companies have been saying for years that it makes good business sense to diversify both their human and investment capital, but change continues at a snail's pace. These difficulties are only exacerbated by other factors that inhibit the free flow of capital to and amongst Latino businesses: imperfect investor information about opportunities and business models in the Latino market, weak professional and social networks between Latino businesses and the financial markets, and extremely low Latino representation in the financial industry.
D. Greater Allocation to Minorities
The message that diversity is "good for business" does, however, seem to be getting put into action, albeit slowly. In this regard, I thank the pension and retirement industry because it is once again at the forefront of this very important cultural and social shift. Major pension and retirement plans, together with some of our most forward-thinking corporate and private equity citizens, have significantly improved the minority landscape by making it clear to the world that a commitment to diversity e.g., having minorities on investment teams, engaging minority professionals, and utilizing minority service providers is a factor in their investment decisions. While I am aware that this is happening all over the U.S., I mention just a few notable examples:
Public Pension Plans. The Teacher's Retirement System of Illinois has in place two impressive programs to increase minority representation in the financial community. First, the Minority Business Enterprise Brokerage program specifically seeks to enhance the use of minority broker-dealers by imposing minority trading goals of 15% of all equity commissions and 10% of total par traded for fixed income for fiscal year 2007. Second, the Emerging Manager Program seeks to engage smaller investment managers many of which are minority-owned or minority-controlled firms who show promise. Similarly, CalSTRS and CalPERS recently entered into a joint effort to build a first-of-its-kind database of emerging managers and financial service providers which would capture a wide universe of untapped talent in the investment industry. This initiative will broaden diversity investment opportunities for public and private pension funds by expanding the diversity of ideas and people in these pension funds' investment portfolios and hammering home the message to all that diversity is a competitive advantage in business and investment.
Private Equity. Some of the greatest advances in diversifying the financial sector have come from our private equity partners. For example, Palladium Equity Partners has a $520 million dollar fund that seeks to find and invest in promising businesses that focus on the U.S. Spanish-speaking market. As recently reported in the New York Times, this Palladium is taking "advantage of its partners' Latin American heritage and community ties to spot deals that other Wall Street investors may not see." Similarly, other influential firms like Nogales Investors, RC Fontis Partners, and Hispania Capital Partners have raised hundreds of millions of dollars specifically to invest in firms owned by or serving the Latino community.
Corporate America: Ethnic-specific business investments also have drawn the attention of major corporate players such as Goldman Sachs and Microsoft. They now attract $2 billion from institutions that are eager to accomplish what some call a "double bottom line" good double-digit returns as well as the social benefits of supporting minority-owned businesses. Moreover, some of our most powerful corporate citizens are now using their influence, money, and clout to force change even among the unwilling. As an attorney, I applaud Wal-Mart's groundbreaking initiative to increase the racial and gender diversity of its outside counsels. In 2005, Wal-Mart implemented a policy of ending or limiting its law firm relationships with law firms who failed to demonstrate a meaningful interest in the importance of diversity. While such policies have been adopted by several Blue Chip companies such as General Motors and Boeing, Wal-Mart actively enforced this policy by changing 40 of the relationship partners at its top 100 law firms from non-diverse to diverse attorneys, and dropping two law firms who failed to adequately incorporate diversity.
E. Latinos in the Retirement Space
For the vast majority of Americans much if not all of their investments will be held through pension and retirement accounts. What this means for the Latino-owned investment advisory, asset management, and brokerage firms is an enormous pool of potential clients that will need sound advice, trustworthy management, and valuable assistance. What this means for the large Wall Street firms and pension funds is the opportunity to reform their management and executive ranks to better mirror the growing diversity of their clients. In short, this is a golden opportunity to promote Latinos who will generate business from, manage, and successfully interface with a pool of clients and service providers that will increasingly be made up of Latinos and Latino-owned entities.
Nevertheless, competition is fierce in this industry. So I'd like to close with some thoughts for improving Latino and minority presence in the growing retirement and pension fund industry:
- Access decision-making channels. One critical way to give Latinos greater access to investment channels is by supporting and promoting Latino leaders into decision making positions in the corporate board room, pension trust boards, and on Wall Street. We face a major hurdle in this respect given the not-surprising finding by the GAO that gaining employees' "buy-in" to diversity programs remains a challenge. However, we have seen improvements made by those Latinos who have managed to surmount obstacles and put themselves in positions where they can change the dominant culture.
- Support minority-controlled firms. In September 2004, I issued the "Campos Capital Challenge" to all the major investment firms and urged them to fund at least 5 companies that operate in minority communities. Unfortunately, despite this challenge, lack of capital for expansion remains a major difficulty for minority-controlled firms today. This lack of capital directly and negatively limits a firm's ability to secure contracts or agreements with major institutional and retail investors. Thus, I urge those of you in decision making positions at private and mutual funds, pension funds, and investment banks to strongly consider minority-controlled firms when making your investment decisions.
- Seize new business opportunities. One thing that I have learned during my tenure as a SEC Commissioner is that: (1) regulation itself often provides new windows of business opportunity for minorities to gain access to a particular sector; and (2) unless acted upon quickly, those windows of opportunity will be seized by the status quo industry players who have an incredible ability to quickly adapt and profit from any changes. For example, the Sarbanes-Oxley Act with its rigorous board independence requirements provided historic opportunities to incorporate greater diversity on corporate boards. Regulatory changes occur constantly and frequently, and each regulatory change brings with it the need for corollary changes within the industry. It is to your benefit and advantage to stay on top of and adapt to these developments as soon as they arise.
- Keep knowledge/training levels at the highest and act with the utmost integrity. As advisers, consultants, broker-dealers, and service providers to institutions and individuals who manage retirement assets, you hold a critical and fragile trust in your hands. The stakes have never been so great I'm sure that you all have been closely following the scandal unfolding around the San Diego City's Retirement System. A long-awaited audit released just this past Tuesday blamed San Diego's pension fund debacle on mismanagement and illegal financial manipulations by city pension board officials in pursuit of short-term solutions for a pension fund deficit of almost $2 billion. While I am sure that this type of mismanagement is the exception not the norm for the pension industry, it is a sobering reminder to us all. The assets in this industry are extraordinarily precious, and the consequences for abusing this trust can be severe not only professionally, but also financially and criminally. Therefore, how you handle this trust is critical. If you mismanage this trust, you will lose business credibility and will be accountable to not only your client, but to the criminal and regulatory agencies who are charged with protecting your clients. However, if you manage and honor this trust well, I assure you that you will be amply rewarded with repeat business arrangements, numerous referrals, a positive business reputation, and a strong track record.
Thank you. I appreciate your time and attention.