Archive for April, 2011
Posted by William Byrnes on April 29, 2011
Today we re-examine the case in-depth, focusing on how the IRS utilizes the step transaction doctrine to deny taxpayers valuation discounts. The case is yet another example of how important the dating of transactions is when you’re looking to secure a valuation discount. A single date on a document can mean the difference between a substantial valuation discount on a gift and the expense of fighting the IRS through the court system. Read this complete analysis of the impact at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).
For previous coverage of valuation discounts in Advisor’s Journal, see IRS Rebuffed by Federal Court of Appeals in Valuation Discount Case (CC 11-21), Vigorous Debate over Qualified Appraisal Standard for Valuation of Donated Policies (CC 10-92) & Valuation Discounts: Only for a Bona Fide Business (CC 10-60).
For in-depth analysis of gift tax valuation discounts, see Advisor’s Main Library: A—Family Limited Partnerships and Estate & Gift Tax Valuation Discounting.
Posted in Estate Tax, Taxation | Tagged: Business, Discounting, Facebook, Foursquare, Internal Revenue Service, IRS, tax, valuation | Leave a Comment »
Posted by William Byrnes on April 28, 2011
In the midst of the tax filing season, the Internal Revenue Service released the 2011 version of its discussion of many of the more common “frivolous” tax arguments made by individuals and groups that oppose compliance with federal tax laws.
The Service suggested that “anyone who contemplates arguing on legal grounds against paying their fair share of taxes should first read their 84-page document, The Truth About Frivolous Tax Arguments.” At AdvisorFYI, we are not contemplating any particular legal grounds for not paying a “fair share of taxes”, whatever that may be, but rather are interested in presenting some of the frivolous positions argued and how the Government generally responds. We’ve presented a few select ones below.
The 2011 IRS document explains many of the common “frivolous” arguments made in recent years and it presents a legal position that attempts to refute these claims. The IRS claims, the document “will help taxpayers avoid wasting their time and money with frivolous arguments and incurring penalties.”
Congress in 2006 increased the amount of the penalty for frivolous tax returns from $500 to $5,000. The increased penalty amount applies when a person submits a tax return or other specified submission, and any portion of the submission is based on a position the IRS identifies as frivolous.
Here are some of positions we found to be commonly marketed to the public, and how the IRS responds to the positions: Read the analysis at AdvisorFYI
Posted in Taxation | Tagged: Internal Revenue Service, IRS tax forms, law, Offer in compromise, tax, TurboTax, United States, United States Congress | Leave a Comment »
Posted by William Byrnes on April 27, 2011
A growing number of consumers are opting for pre-packaged, low-cost portfolio managers. Portfolio-to-go companies can, at least nominally, provide many of the same services as full-service brokerage firms, since the companies are registered as either investment advisors or broker-dealers. And minimal overhead and services allow them to offer those services without the “high” price tag at brick-and-mortar institutions.
Portfolios-to-go have exploded in popularity recently, bringing in over $3 billion in assets over the past three years. Read this two-page article by linking to AdvisorOne – a National Underwriters Summit Business open-access original content wealth management news portal.
Posted in Wealth Management | Tagged: Brokerage firm, Brokerages, Business, Financial services, Investing, Investment Services, TD Ameritrade, U.S. Securities and Exchange Commission | Leave a Comment »
Posted by William Byrnes on April 14, 2011
From the experts of National Underwriters …. The Portability of the Spousal Credit webinar is an exclusive session covering the opportunities presented by the deceased spouse unused exclusion amount (DSUEA). This no-cost webinar will cover the intricacies of the DSUEA and ensure that you know everything you need to help your clients take full advantage of this tax break. Time will allotted for questions.
No-Cost registration at: https://www1.gotomeeting.com/register/851507536
Posted in Uncategorized | Leave a Comment »
Posted by William Byrnes on April 13, 2011
The Federal Reserve may consider downsizing its original plan to purchase $600 billion in Treasury bonds over fear that inflation could be driven to dangerous levels by the revitalized economy. Quantitative easing—the purchase of Treasuries by the central bank—is intended to raise the price of Treasuries, which should lower long-term interest rates and provide banks with cash to lend to their customers. The expectation is that lower long-term rates will encourage home refis and boost corporate investments and expansion, which, it is hoped, will created new jobs. Read this complete analysis of the impact at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).
For previous coverage of quantitative easing in Advisor’s Journal, see Fed to Purchase $600 Billion in Treasuries in Move to Stimulate Economy (CC 10-94).
Posted in Wealth Management | Tagged: Central bank, Economic, Federal Reserve System, FederalReserve, Government, Quantitative easing, United States Department of the Treasury, United States Treasury security | Leave a Comment »
Posted by William Byrnes on April 12, 2011
Now more than ever, clients and potential clients are concerned about how they’re going to continue to enjoy the lifestyle they’ve grown accustomed to pre-retirement. Most clients are still looking for the same basic retirement advice from their advisors—advice on how to define and meet their retirement goals.
Following the recent financial crisis, your affluent clients are more likely to gravitate to conservative investment strategies that will preserve their hard-earned principle. But many of them are not clear on the risks of that strategy—they aren’t aware of the opportunities they’re missing.
You can help them reach the retirement they want and find the level of risk appropriate to their long-term goals. Here’s a breakdown of their values and priorities and how you can appeal to them. Read this complete analysis of the impact at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).
For previous coverage of high net worth investors in Advisor’s Journal, see High Net Worth Clients: How to Find Them, How to Service Them (CC 10-07).
For in-depth analysis of investment planning for affluent clients, see Advisor’s Main Library: Investment Planning.
Posted in Wealth Management | Tagged: Business, Certified Financial Planner, Financial adviser, Financial services, Investing, Investment Advisor, Retirement, United States | Leave a Comment »
Posted by William Byrnes on April 11, 2011
The Obama administration’s 2012 budget includes an attack on corporate owned life insurance that could further erode its tax advantages and put a ding in carriers’ balance sheets. Washington’s repeated assaults on corporate-owned life insurance seem to be motivated by its view of corporate owned life insurance as simply a tax arbitrage opportunity for big corporations, ignoring its importance for smaller businesses that rely on a few key people to keep them afloat. Read this complete analysis of the impact at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).
For in-depth analysis of corporate-owned life insurance, see Advisor’s Main Library: D—Deductibility Of Business Insurance Premiums, E—Premiums As Taxable Income To The Insured & F—Taxability Of Corporate Owned Life Insurance Proceeds At Death.
Posted in Insurance, Tax Policy | Tagged: Agents and Marketers, Business, Corporate-owned life insurance, Financial services, insurance, life insurance, United States, Washington | 1 Comment »
Posted by William Byrnes on April 10, 2011
Why is this Topic Important to Wealth Managers? This topic discusses the Recovery Act spending and its effects on the national economy. It provides wealth managers with indicators and information to help clients better understand the use of government (taxpayer) funds and their allocation as a result of the financial crisis and ensuing financial recovery.
The American Recovery and Reinvestment Act of 2009, enacted February 2009, was designed to put Americans back to work and combat the largest downturn in the economy since the Great Depression. Through the Recovery Act, Congress allocated funds in three ways. The single largest part of the Act —more than one-third of it, or $288 billion— was tax cuts. Ninety-five percent of taxpayers have seen taxes go down as a result of the Act. 
The second-largest part or $244 billion — just under a third — was direct relief to state governments and individuals. This funding helped state governments avoid laying off teachers, firefighters and police officers and prevented states’ budget gaps from growing wider. On an individual level, the Act ensured those hardest hit by the recession received extended unemployment insurance, health coverage, and food assistance.
The remaining third or $275 billion of the Recovery Act financed the largest investment in roads since the creation of the Interstate Highway system; construction projects at military bases, ports, bridges and tunnels; overdue Superfund cleanups; clean energy projects; improvements in outdated rural water systems; upgrades to overburdened mass transit and rail systems; and much more.
The $787 billion (in total) economic Recovery plan included provisions, in sum, designed to (1) create and save jobs, (2) spur economic activity and invest in long-term economic growth, and (3) foster unprecedented levels of accountability and transparency in government spending.
The Recovery Act was intended to provide a short-term jump start to the economy, but many of the projects funded by Recovery money, especially infrastructure improvements, are expected to benefit economic growth for many years. Thus, the Recovery Act’s longer-term economic investment goals include:
- Initiating a process to computerize health records to reduce medical errors and save on health-care costs
- Investing in the domestic renewable energy industry
- Weatherizing 75 percent of federal buildings and more than one million homes
- Increasing college affordability for seven million students by funding a shortfall in Pell Grants, raising the maximum grant level by $500, and providing a higher education tax cut to nearly four million students
- Cutting taxes for 129 million working households by providing an $800 “Making Work Pay” tax credit
- Expanding the Child Tax Credit 
Has the Recovery Act worked? Read the analysis at AdvisorFYI
Posted in Tax Policy | Tagged: American Recovery and Reinvestment Act of 2009, Economic, economic growth, Great Depression, Investment, Pell Grant, Private sector, United States | Leave a Comment »
Posted by William Byrnes on April 9, 2011
Is hedge fund investment without capital gains or estate taxation possible for your high net worth clients? Yes, through the medium of private placement life insurance (“PPLI”). Read this complete analysis of the impact at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).
For previous coverage of topics relevant to estate planning for high net worth clients in Advisor’s Journal, see High Net Worth Clients: How to Find Them, How to Service Them (CC 10-07).
For in-depth analysis of state tax laws that are favorable for PPLI purposes, see Advisor’s Main Library: Estate Planning and the State Premium Tax.
Posted in Insurance, Retirement Planning, Taxation, Wealth Management | Tagged: Business, estate planning, Funds, Hedge fund, Inheritance tax, Investing, Net worth, Private placement life insurance | Leave a Comment »
Posted by William Byrnes on April 8, 2011
Why is this Topic Important to Wealth Managers? This topic discusses a relatively new form of retirement investment offered by companies to their employees. The topic presents information about target date funds, what they are, who may use them and how they work. The defined contribution retirement market is a prime location for wealth managers to earn fees and commissions. Thus, staying informed about new market updates is provided to give managers an edge when exploring retirement benefits.
The Government Accountability Office recently published a report stating that financial security of millions of Americans in their retirement years will substantially depend on their savings in 401(k) and other defined contribution (DC) plans. The GAO notes, to help ensure adequate financial resources for retirement, participants in DC plans should make adequate contributions during their working years and invest contributions in a way that will facilitate adequate investment returns over time.
To that end, the Pension Protection Act of 2006 (PPA) included various provisions designed to encourage greater retirement savings among workers eligible to participate in 401(k) plans, such as provisions that facilitate plan sponsors’ adoption of automatic enrollment policies. 
Under such policies, eligible workers are automatically enrolled unless they explicitly decide to opt out of participation. Because an automatic enrollment program must also include a default investment—a vehicle in which contributions will be invested absent a specific choice by the plan participant—the act also directed the Department of Labor to assist employers in selecting default investments that best serve the retirement needs of workers who do not direct their own investments. Since that time, target date funds (TDF)—that is, investment funds that invest in a mix of assets, and shift from higher-risk to lower-risk investments as a participant approaches their “target” retirement date—have emerged as by far the most popular default investment.
TDFs are designed to provide an age appropriate asset allocation for plan participants over time. However, target date funds vary considerably in asset structures and in other ways, largely as a result of the different objectives and investment philosophies of fund managers. In the years approaching the retirement date, for example, some TDFs have a relatively low equity allocation—35 percent or less—so that plan participants will be insulated from excessive losses near retirement. Other TDFs have an equity allocation of 60 percent or more in the belief that relatively high equity returns will help ensure that retirees do not deplete savings in old age.
TDFs also vary considerably in other respects, such as in the use of alternative assets and complex investment techniques. In addition, allocations are based in part on assumptions about plan participant actions—such as contribution rates and how plan participants will manage 401(k) assets upon retirement—which may differ from the actions of many participants. These investment differences and differences between assumed and actual participant behavior may have significant implications for the retirement security of plan participants invested in TDFs.
Read the analysis at AdvisorFYI
Posted in Retirement Planning | Tagged: 401(k), Government Accountability Office, Investment, Pension, Pension Protection Act of 2006, Retirement, Target date fund, United States Department of Labor | Leave a Comment »
Posted by William Byrnes on April 7, 2011
Why is this Topic Important to Wealth Managers? This topic discusses proposed legislation that would change defined contribution retirement reporting for plan sponsors. The new legislation would require additional information to be disclosed to consumers. Thus, wealth managers that are prepared with the most recent and relevant information with regards to retirement planning are better prepared to work with clients in defined contribution situations.
Senior members of the House Committee on Education and the Workforce, including U.S. House of Representatives Rush Holt (NJ) and Tom Petri (WI), recently introduced legislation which is designed to help ensure that Americans have saved enough for their full retirement.
The introducers of the bill note that many American workers have become increasingly responsible for saving for and managing their retirement investments through 401(k) plans. However, the contention is that many Americans are not saving enough, and they are unsure how quickly to draw down their savings in their retirement years.
To that end, the Lifetime Income Disclosure Act  would require 401(k) plan sponsors to inform participating workers of the projected monthly income they could expect at retirement based on their current account balance. The measure is patterned on the Social Security Administration’s annual statements, which are mailed annually to working Americans to inform them of estimated monthly benefits based on their current earnings. Congress mandated annual Social Security statements in 1989, and the government claims they have proven to be very useful to workers in preparing for retirement.
“We should do everything we can to help Americans save for retirement. Our bipartisan bill is a common sense approach to providing Americans with the tools and information they need to plan for a secure retirement future,” Rep. Holt said. The idea behind the legislation is that by providing similar information for 401(k) plans, the Lifetime Income Disclosure Act would give American workers a more complete snapshot of their projected income in retirement.
Specifically, under the legislation, defined contribution plans subject to ERISA – including 401(k) plans – would be required annually to inform participants of how the account balance would translate into a monthly income stream based on age at retirement and other factors. “As retirement plans shift increasingly toward a defined contribution basis, individuals have a greater responsibility to ensure that they are providing adequately for their retirement,” Rep. Petri said. “The information called for in the Lifetime Income Disclosure Act will serve as a scorecard showing savers their progress toward reaching this critical financial goal.”
To help ensure there is no material burden or potential liability on employers who voluntarily sponsor 401(k) plans, the legislation directs the Department of Labor to issue tables that employers may use in calculating an annuity equivalent, as well as a model disclosure. Employers and service providers using the model disclosure and following the prescribed assumptions and DOL rules would be insulated from liability.
“Half of American households will lack sufficient retirement income to maintain their pre-retirement standard of living, but many are unaware of their vulnerability. Our bill will empower Americans to determine whether they are on a path to a secure retirement,” said Senator Jeff Bingaman (D-NM). “This is the kind of common-sense, employer-friendly bill that deserves priority consideration.”
Such information in the hand of the consumer may lead to more retirement planning opportunities for wealth managers as the consumer seeks to “top up” for retirement. If enacted, this bill may lead to a big boost for such retirement savings as Individual Retirement Accounts, and for the corresponding asset management for institutions.
Senators Bingaman, Johnny Isakson (R-GA), and Herb Kohl (D-WI) previously introduced the legislation in the Senate, and Rep. Ron Kind (WI) and David Reichert (WA) are cosponsors of the bill.
Tomorrow’s blogticle will continue to discuss new and exciting planning aspects of 2011.
We invite your opinions and comments by posting them below, or by calling the Panel of Experts
Posted in Retirement Planning | Tagged: 401(k), Herb Kohl, Individual Retirement Account, Johnny Isakson, Pension, Tom Petri, United States, United States House Committee on Education and the Workforce | Leave a Comment »
Posted by William Byrnes on April 6, 2011
Taxpayers with assets hidden in offshore accounts will get a second chance to voluntarily declare their assets to the IRS in return for reduced penalties under the new Offshore Voluntary Disclosure Initiative (“OVDI”).
This newest offshore amnesty program offers a reduced, 25% penalty which will be calculated based on the highest aggregate amount in the taxpayer’s offshore account between 2003 and 2010. In addition to penalties, program participants will be required to pay eight years of back taxes plus interest, accuracy related penalties, and delinquency penalties. Read this complete analysis of the impact at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).
For previous coverage of offshore issues in Advisor’s Journal, see IRS Planning New Voluntary Disclosure Program for Offshore Assets (CC 10-118), Offshore’s Limited Shelf Life (CC 10-47) & IRS Proposed FATCA Guidance Expands Offshore Compliance Initiatives (CC 10-52)
Posted in Compliance, Tax Policy | Tagged: Douglas Shulman, Internal Revenue Service, IRS, Offshore bank, Switzerland, tax, UBS, United States | Leave a Comment »
Posted by William Byrnes on April 5, 2011
Why is this Topic Important to Wealth Managers? This topic discusses the evaluation report of the financial crisis issued by a Congressionally appointed body. The report presents discussion of events and causes leading up to the ordeal, as well as indications and factors which presented its forthcoming. The discussion is aimed to allow wealth managers to intelligently discuss some causes of the financial crisis with clients and colleagues.
There was a new report issued earlier this year by the Financial Crisis Inquiry Commission, which was created to “examine the causes of the current financial and economic crisis in the United States.”  In this report, the Commission presents to the President, the Congress, and the general public the results of its examination and its conclusions as to the causes of the crisis.
The Commission was established as part of the Fraud Enforcement and Recovery Act passed by Congress and signed by the President in May 2009.  The independent panel was selected by Congress and composed of private citizens with experience in areas such as housing, economics, insurance, market regulation, banking, and consumer protection.
The report is intended to provide a historical accounting of what brought our financial system and economy to a precipice and to help policy makers and the public better understand how this calamity came to be.
Below are some of the findings issued in the report: Read the analysis at AdvisorFYI
Posted in Compliance | Tagged: Finance, Financial crisis, Financial Crisis Inquiry Commission, Government, Policy, United States, United States Congress, Wall Street | Leave a Comment »
Posted by William Byrnes on April 4, 2011
Last month, we discussed the obvious relevance of pricing competitiveness to overall life insurance product suitability. This month, we discuss the stability of pricing representations which is also a factor of suitability. After all, pricing that appears competitive at the time of sale/purchase but which cannot be maintained can be worse than a less-competitive product with more stable pricing representations.
For instance, while premiums are often considered the price/cost of a life insurance policy, the premium is not the price/cost of a life insurance policy (unless contractually guaranteed like in term life insurance or guaranteed universal life insurance) any more than the $2,000 contributed to an Individual Retirement Account (IRA) is the cost of the IRA. In both cases, the cost is the sum of what is deducted from the premium/contribution. Read this complete analysis of the impact at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).
For previous coverage of suitability in Advisor’s Journal, see Life Insurance Product Suitability (CC 10-90), Financial Strength and Claims-Paying Ability (CC 10-115) & Cost Competitiveness of Life Insurance (CC 11-11).
Posted in Insurance | Tagged: Business, Financial services, insurance, Insurance policy, life insurance, Pricing, term life insurance, United States | Leave a Comment »
Posted by William Byrnes on April 3, 2011
Why is this Topic Important to Wealth Managers? This topic discusses the new regulatory agency that will have an effect on most life insurance companies doing business in New York. Because the new regulatory agency will oversee insurance and banking, it is likely that changes in the insurance compliance law are just around the corner. After the financial crisis of 2008, it appears New York is taking action to prevent future disruptions in the market. Wealth managers should be aware of the new agency as changes to insurance regulation and compliance are sure to result from the creation of this organization.
New York State is in the process of creating a new Department of Financial Regulation (DFR) which is designed to harnesses the regulatory powers and expertise of the Banking and Insurance Departments, as well as the Consumer Protection Board, by combining the functions of each, to make the State’s oversight of financial services responsive to the 21st century needs of the industry and its consumers.
This new State agency, created pursuant to legislation submitted as part of the 2011-2012 State Executive Budget, consolidates the functions, operations and staff of the Banking and Insurance Departments, along with related segments of the Consumer Protection Board, into a single State agency.
Consolidation of these agencies and activities within a single agency platform is intended to afford the State the ability to unify the State’s regulation of financial services and to more rapidly and capably respond to changing market practices and consumer preferences, thereby ensuring the industry’s continued integrity while shielding consumers from abuses.
In addition to enhancing and refining the State’s regulatory oversight of the industry, the consolidation will provide the State with the opportunity to reduce overall spending with the use of shared services.
The Superintendent of the Department of Financial Regulation will be appointed by the Governor, with the consent of the Senate. The Department’s main offices will be located in Albany and New York City.
The Department’s main responsibilities will be carried out through two major programs: regulation and consumer protection. Read the analysis at AdvisorFYI
Posted in Compliance, Insurance | Tagged: Consumer protection, Financial services, Government agency, insurance, New York, New York State, Regulation, United States | Leave a Comment »
Posted by William Byrnes on April 2, 2011
Life Partners Holdings, Inc. investors have filed a class-action lawsuit against the Waco Texas based life settlement provider, alleging that its directors and officers violated securities laws. The lawsuit comes a month after an announcement was made that the publically-traded company is the subject of an SEC investigation into the life expectancies the company uses to value the life insurance policies it sells to its customers. Life Partners is accused of misleading its customers—investors in life insurance policy—about the life expectancies of insureds on the policies it sells, with insureds outliving the life settlement company’s life expectancy estimates 90% of the time. Read this complete analysis of the impact at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).
For previous coverage of life settlements in Advisor’s Journal, see Life Settlement Provider Accused of Falsifying Life Span Reports (CC 11-23), Life Settlements Funds Performance Fees under Scrutiny (CC 10-116) & Should the Basis of a Life Contract be Adjusted by Mortality Charges? Rev. Rul. 2009-13 Says Yes in Context of Life Settlements; Certain Amounts over Adjusted Basis Treated as Capital Gains (CC 09-19).
For in-depth analysis of life settlements, see Advisor’s Main Library: A—Life Settlements—Introduction.
Posted in Insurance | Tagged: Investor, Life expectancy, life insurance, Life settlement, Public company, Texas, Viatical settlement, Waco Texas | Leave a Comment »
Posted by William Byrnes on April 1, 2011
Why is this Topic Important to Wealth Managers? This topic discusses the potential consequences of not playing by the rules; it is important to constantly keep in mind the balance between providing the most efficient and effective services to clients and crossing the line into illegal territory. Clients may not realize the harsh penalties associated with offshore activity, and although when performed by expert planners under the proper circumstances, that some offshore transactions may be legal and beneficial, it is the job of informed wealth managers to keep clients abreast of information that is useful in making long-term financial decisions.
Four bankers at an international bank incorporated and with its headquarters in Zurich, Switzerland, with offices worldwide, including New York City and Miami, were indicted by a federal grand jury in the Eastern District of Virginia and charged with conspiring with other Swiss bankers to defraud the United States, the Justice Department and the Internal Revenue Service (IRS) announced Wednesday.
According to the indictment, the international bank’s managers and bankers engaged in illegal cross-border banking that was designed to assist U.S. customers evade their income taxes by opening and maintaining secret bank accounts at the bank and other Swiss banks. As of the fall of 2008, the international bank maintained thousands of secret accounts for customers in the United States with as much as $3 billion in total assets under management in those accounts.
The Justice Department announced the scheme dates back to 1953 and involved two generations of U.S. tax evaders including U.S. customers who inherited secret accounts at the international bank.
The indictment asserts that four foreign individuals, members of senior management, bankers and others assisted U.S. taxpayers in evading their U.S. taxes through the use of secret bank accounts in Switzerland.
According to the indictment, the defendants and their co-conspirators solicited U.S. customers to open secret accounts because Swiss bank secrecy would permit them to conceal from the IRS their ownership of accounts at the bank and other Swiss banks. It is further alleged that they provided unlicensed and unregistered banking services and investment advice to customers in the United States in person while on travel to here, including at the international bank’s representative office in New York City and by mailings, e-mail and telephone calls to and from the United States.
Read the analysis at AdvisorFYI
Posted in Compliance, Money Laundering | Tagged: Banking in Switzerland, Internal Revenue Service, New York City, Switzerland, UBS, United States, United States Department of Justice, Zurich | 2 Comments »