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Click Here to Begin

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The ARA Continuing Education Series

Ethics, ARA Code of

Conduct; and Debt

Collection Practices

American Recovery Association

Presented by

© 2019 All Rights Reserved

TABLE OF CONTENTS

APPENDIX

PAGE3

6

7

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9

18

26

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30

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34

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Instructions

Introduction

Pretest

Overview

Forward (Basic Review and Definitions)

ARA Code of Conduct

Ethics – A Little Test around Ethics

Summary

Personal Appearance

Closing Thoughts

A Glossary of Terms

15 U.S. Code Subchapter V – The law around Debt Collection Practices

This training course is intended to inform you of

• Key details and specific knowledge you need to know, or be aware of, as

you perform your job;

• The basic tasks and behaviors you will need to perform;

• Certain situations you should be prepared for when you are at work in

order to successfully complete your job.

INSTRUCTIONS

There are 4 main sections in each training course.

1.The FORWARD which provides introductory information about the topic in the training course.

2. We will start you off with a PRETEST. This test will not be graded but merely a taste of the kind of information we will share during this course. • There will be another test at the end of

the course that will be graded; So be sure to pay attention.

INSTRUCTIONS

There are 4 main sections in each training course.

3. The MAIN BODY of the course which provides the information and documentation on the material you will need to learn.

4. The APPENDIX which contains additional information to support the Main Body of the course. This could include definitions, policies, and other resources related to the topic.

• After you download the presentation, you might find it better to view the course in “Full Screen”, as you will be able to see everything much clearer.

• Once you get to the first page of the training course, you will begin the training and the presentation will start. You should both read the information on the screen as it appears AND listen to the audio of the information.

• The course material will move from screen to screen without any action by you. If you wish to review any previous material, you can move back to the screen you wish and continue with the training course.

• The content in the course booklet and the videos are identical. Having both written material and audio material will help to reinforce the information that is being presented in this course.

• You may wish to print out this course booklet so you can refer to the content when answering the review questions. When you take the final test, feel free to use the material in the course booklet as a reminder, especially if you are not sure of the answer.

INSTRUCTIONSContinued

INTRODUCTION

OBJECTIVES

The objective of this course, and the material it contains, is to provide you with important information you will need to do

your job well. Training helps to:

• Ensure that you have the technical and behavioral skills you need to perform your job to the best of your ability.

• Provide you with the knowledge, education and tools you need to work better, win promotions and fulfill your career potential.

• Give context to your job role so you understand how your daily efforts support the wider company mission.

• Expand your knowledge base and add new and different skills that allow you to work independently without supervision.

• Reduce the possibility of accidents, safety code violations, lawsuits and customer complaints.

EXPECTATIONS

This program has important information for you to learn and we expect you to do your best to

understand and appreciate what is being presented in this course; for your own safety, the safety of

everyone in your company and the customers we serve.

Legal Disclaimer The content in this training program is provided for educational and reference purposes only.

This content is provided to the American Recovery Association members and their employees as a courtesy to be used only for

information purposes. The content and the videos provided are not intended to be used as legal advice. This information shared

represents opinions based on readings, classes, published and verbal interpretations and standards in current use. You should always

consult with your attorney for official rulings and interpretations on specific issues.

7American Recovery Association

2019 © All Rights Reserved

Pretest

https://www.screencast.com/t/DcG9CgYA

OVERVIEW

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Merriam-Webster Dictionary defines ETHICS as:• A discipline dealing with what is Good or Bad, Moral Duty, or

Obligation, or

• A set of moral Principles as a system of moral values, or

• The principles of conduct governing an individual or group, or

• A guiding philosophy.

ETHICS FORWARD

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Socrates, would greet people by asking a question:

“Are you taking care of yourself?”

He saw ethics as being tied to choices and the consequences of those choices. He knew that having the ability to decide freely our actions if done badly could have devastating effects on ourselves as well as others.

To Socrates it meant becoming enlightened on proper behavior, best practices on treating others and yourself, doing what is right, fair and honest in all that you do including your life's work.

ETHICS FORWARD

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VALUES

In order to talk about ETHICS you have to define VALUES. In most cases one cannot operate properly without the other.

“VALUES” is the importance, worth, or usefulness of something. It is one’s judgment on what is important in life. Values come from within, some might say they come from your heart, and they tend to stay fairly stable throughout life. They are how you feel about things.

ETHICS are the outward showing of your values. Ethics demonstrate themselves in your day to day practices.

ETHICS FORWARD

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The 4 components of Ethics

1) Know what is right;

2) Do the right thing;

3) Manage competing rights; and

4) Know that everything counts(“Ethics 4 Everyone” by Eric Harvey and Scott Airitam).

ETHICS FORWARD

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The 4 components of Ethics#1 - Knowing What is Right.

• Guided by the laws of our government.

• The company’s “red” rules are those you never, ever break, like theft of money and material.

• The company’s “blue” rules are those that outline general guidelines to assure consistent behavior and process, but are discretionary.

• The shared values, as articulated in a well thought through mission or values statement, provides the sense of fairness, respect, and integrity we have all come to expect in a workplace.

• Match your words and your actions.

ETHICS FORWARD

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The 4 components of Ethics#2 - Doing What is Right.

• The 3 “R’s” of Ethics• Respect for the rights of each person you deal with.

• Responsibility to provide both speed and accuracy in delivering quality goods and services.

• Results of your actions where achieving the ends are just as important as the means.

• It is the little things that count. Ethics is everyone’s job.

ETHICS FORWARD

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The 4 components of Ethics#3 - Managing Competing “Rights”

Some choices between right and wrong are easy, but when the choice is between two “rights”, it gets more difficult.

Three basic options:1. Eliminate the conflict2. Decide which is more “right”3. Seek assistance.

“Shelving hard decisions is the least ethical course.”(Adrian Cadbury)

ETHICS FORWARD

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The 4 components of Ethics#4 - Everything counts.

“Big 4” factors leading to unethical behavior:1. Greed – the drive to acquire or possess more and more in one’s self-

interest at others expense.

2. Speed – the motivation to cut corners in response to the “warp” pace of business.

3. Laziness – taking the easy path and the one of least resistance.

4. Haziness – acting and reacting without thinking of the consequences.

ETHICS FORWARD

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Why is all this important to do?Why should leaders be a role model for ethics?

• It will mean less temptation for employees to compromise ethical standards.• Employees will be more willing to report misconduct.• It improves respect at all levels.• It encourages early detection of problem areas.• It protects the positive reputation of the organization.• It improves customer service.• It increases pride and professionalism.• It enhances your ability to attract and retain the highest quality employees.

It is the right thing to do!

ETHICS FORWARD

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ARA Code of ConductA Review

ARA Code of Conduct

PURSUANT TO ARTICLE III OF THE ASSOCIATION BY-LAWS.

• Maintain a high standard of business principles and avoid all conduct, which would bring reproach upon this Association, its members and the repossession industry.

• Abide by this Association’s Charter, By-Laws, this Code and other policies adopted by the Board of Directors.

• Comply with all federal, state, county and municipal laws relating to the ownership and operation of a repossession business.

• Never operate under a name, style, insignia, device or logo simulating that of any governmental or law enforcement agency or otherwise to imply affiliation with any branch of any governmental or law enforcement agency.

ARA Code of Conduct (continued)

• Ensure that owner, management, and all personnel are thoroughly familiar with the repossession laws of the member’s state, the ARA Charter, By-Laws, this Code and other policies of this Association and that they are complied with.

• Delegate tasks only to qualified personnel.


• Never discriminate or interfere with anyone on the basis of:• Race• Creed• Color• Sex• National Origin

• The selection of creditors whom he or she represents.

• The selection of staff, personnel or employees.

• Business dealings with consumers and the general public.

• Colleagues and competitors.

• Prospective members of this Association.

• Fellow members of the Association.


• Maintain a sufficiently strong financial position to reasonably assure continued business operation.

• Provide efficient, effective repossession service in the member’s trade or service area.

• Always protect the interest of the client and give prompt diligent attention to all assignments.

• Follow instructions given by clients, give prompt explanation in the event of inability to do so, and always seek clarification of or additional instructions in a doubtful situation.


• Never misrepresent qualifications, capacity, experience or abilities as a repossessor or credit adjuster.

• Always compete in a fair and honorable manner.

• Never publicly attack the reputation of a competitor.

• Never distort an evaluation of competitors or colleagues.

• Members should refrain from disclosing financial information except to correct, eliminate or avoid unethical or illegal practices.


• Confirm or acknowledge all assignments within twenty-four hours of receipt, whether received verbally, through a portal, or in writing.

• Reply to a client’s request for a report within twenty-four hours, confirming verbal reports (if any) within seven days.

• Provide the client with:

a) Detailed reports on a regular basis to keep client informed asto your findings on the account.

b) A full and complete report immediately upon repossession.


• Never mislead any third person into the mistaken belief that the member is the American Recovery Association, Inc., although each member is always entitled to an appropriate reference to membership in this Association, including discreet use of its logo on letterheads, business cards, advertising, etc.

• Quote in advance the estimated charges, costs and fees for his/her various services upon request of any client.

One of the easiest ways to apply ethics to things we do every day is ask some of these simple questions below.

1. Do I avoid conduct that would bring reproach on my company, my client, or my industry?

2. Did I call in sick, when I really wasn’t?3. Do I protect consumers personal property as if it were my own?4. Do I knowingly ignore or violate my company’s rules?5. Do I withhold information that others need?6. Do I fail to admit and correct a mistake I have made?7. Have I accepted an inappropriate gift or gratuity?8. Do I comply with all laws pertaining to repossessions?9. Do I engage in gossip or rumors?10. Do I take care of company equipment?11. Do I tolerate prohibited behavior because the person is a family member or friend?12. Have I misled a consumer as to the status of his debt amount?

ETHICS - A Little Test

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A Summary of Basic Ethical ApproachesFor Management

• Proper ethical behavior starts at the top.

• Don’t expect your employees to be fair, honest and ethical if you are not.

• Action always speaks louder than words

• Position does not excuse bad behavior

• Shady is a word you want used only in your backyard

• Image is everything

A Summary of Street Level Ethics

• Make decisions that reflect company goals.

• Tell management when unethical behaviors occur.

• Be a leader. Follow the rules and policies of your company.

• Don’t look for loopholes or provide unreasonable excuses.

Personal Appearance

How does personal appearance influence success?

• Probably the most important aspect of personal appearance is that it reveals how people feel about themselves. Self-confidence is crucial to success, and well-groomed people look confident even if they may not always feel it. Dressing for success is one of the first steps towards feeling and becoming successful.

• In the real world of repossessions’ a good personal appearance would be represented by being sure all aspects of your clothing including your shoes are clean, free of holes and represent a conservative look. Your hair and facial hair should represent the attitude of your company and your clients. We have to move around neighborhoods and presenting the proper professional image always helps.

Personal Appearance (Continued)

• Visual impact is at least as important as verbal impact. Your personal appearance is the first thing people see. As soon as you arrive on scene and exit the truck the consumer begins to decide how he is going to respond to you. People will very quickly make assumptions based on your personal appearance, including your facial expressions, the clothes you wear, how well-groomed you are and your body language.

• An example of a good general appearance could be made up of a collared shirt, clean and without wrinkles, Clean Blue Jeans without holes or designs, and work boots that are clean and all parts are intact.

• The way you look, the way you talk, The way you carry your body and head position as well as your clothing can make the difference between experiencing a consumer conflict or not.

Closing Thoughts

• The Board of Directors of ARA want you, the member, to know we are committed as a board and expect ALL of our members to work within a culture of compliance and impeccable ethics.

• To our clients, we want you to know we expect that everyone will adhere to the highest standards of compliance and ethics.

Closing Thoughts

(continued)

• Both sides of this industry have to buy in on working together.

• Both sides have to communicate HONESTLY with each other.

• Both sides have to protect each other.

• Both sides have to protect the consumer.

• Both sides have to be sure they could stand in front of the most important person in their life and say, “I have respected my industry and the people who work in it and I have treated everyone as I would like to be treated.”

APPENDIX

Please take time to familiarize yourself with the information on the

following pages.

It includes definitions and terms used in the repossession industry. This

appendix also contains the details of the laws pertaining to 15 U.S. Code

Subchapter 5; related to DEBT COLLECTION PRACTICES.

Your test may include questions that come from some of this material.

34

A GLOSSARY OF TERMSSpecific to the Repossession Industry

The following are some of the everyday terms used in the repossession industry. The

definitions are in layman terms, if you want proper definitions check the legal guides or wiki’s.

Debtor or ConsumerIs the person that is behind on the asset or the person that signed for the asset to begin with. Anyone

accountable will be considered the debtor.

Creditor A person or entity to whom money is owed by another person or entity.

IntentA resolve to perform an act for a specific purpose; a resolution to use a particular means to a specific end.

LitigationThe process of taking legal action; the process of suing someone, or of trying someone for a criminal act.

Straw PurchaseIs when someone used their own credit to buy an asset for another person. Someone that may buy the car for

themselves in the beginning but later transfers the collateral to an unknown buyer.

AssetThe unit that is used for collateral in each case.

ReplevinIs a court order allowing the repossession agent to pick up the asset with a court order, usually escorted by

the police department. If the debtor does not comply with a replevin or court order, the case can be turned into

a criminal case usually citing the debtor in contempt. It is a legal action.

SkipAn asset that cannot be located by means of the original documentation during purchase. It could also be if a

finance company calls a debtor and the debtor purposely hides the unit. Skip tracing will need to be

completed to find the asset. Skip tracing is an industry term used to describe the process of locating a

debtor that can't be found at their place of residence or usual hangouts. The act of skip tracing is most often

used by bail bondsmen, bounty hunters, repossession agents, private investigators, debt collectors, and even

journalists

Fraud CaseIs a case where the unit cannot be located and the person originally defrauded the finance company

knowingly when purchasing the asset. Possibly using a fake social security, possibly using false information,

buying the unit with intent to not pay for it. or basically any fraudulent means.

Charge-offIs when collateral has not been paid in several months and the account is getting ready for charge-off.

Sometimes banks will increase the pay amount to have an agent be more aggressive in finding a unit that is

close to charge-off. 35

A GLOSSARY OF TERMS (continued)

RORegistered owner of the asset

Voluntary RepossessionThis is when the RO calls the bank to surrender the asset. When the debtor is cooperative in returning the unit

he or she can no longer pay.

Break OrderThis usually comes with a replevin order. It gives the Sheriff the right to open a garage or storage facility to

collect the asset.

Arrest of AssetThis term deals with boats that have been seized - usually by the marshal’s office or other federal agency. It

usually means that the bank and the repossession agency will either lose the asset completely or must wait a

long time to retrieve the asset.

Agent or Field AgentA trained Recovery Professional.

CompWhen a skip trace agent runs a comprehensive report on someone in an effort to locate the unit.

Brought CurrentWhen a debtor brings the loan current and the bank accepts the late payment.

AuctionMost assets that are repossessed will go to an auction or liquidation sale. By law, aircraft must be sold

through auction sale, like that of a house.

• The American Recovery Association www.repo.org

• TalentValue; a division of Business Value, Inc.

• The Workforce Builder; a division of Business Value, Inc.

https://businessvaluesolutions.net36

RESOURCES

http://www.repo.org/

https://businessvaluesolutions.net/

15 U.S. Code Subchapter VDEBT COLLECTION PRACTICES

15 U.S. Code Subchapter V DEBT COLLECTION PRACTICES

• Most sections of the U.S. Code 15 are covered in other modules such as the FDCPA, Skip Tracing, UDAAP and others.

• We want you to be aware that this code is where most laws have emanated from and want to highlight some of them here.


In the code there are eight primary definitions spelled out in Chapter 1692:

• Bureau, means Consumer Financial Protection Bureau .

• Communication, means conveying of information regarding a debt to any person.

• Consumer, means any natural person obligated or allegedly obligated to pay any debt.

• Creditor, means any person who offers or extends credit creating a debt.

• Debt, any obligation of a consumer to pay money which the money, property, insurance, or service were for personal, family, or household purposes.

• Debt Collector, who is included: any person who uses any instrumentality of interstate commerce or the mails in any business the principal purpose of which is the collection of any debts, or who regularly collects or attempts to collect, directly or indirectly, debts owed or due or asserted to be owed or due another.


• Debt Collector, who is included: any person who uses any instrumentality of interstate commerce or the mails in any business the principal purpose of which is the collection of any debts, or who regularly collects or attempts to collect, directly or indirectly, debts owed or due or asserted to be owed or due another.

• Debt Collector, who is included: A creditor who, in the process of collecting his own debts, uses any name other than his own which would indicate that a third person is collecting or attempting to collect such debts.

• For the purpose of section 1692f(6) of this title, such term also includes any person who uses any instrumentality of interstate commerce or the mails in any business the principal purpose of which is the enforcement of security interests.


1692 (b) Acquisition of location information

Any DEBT COLECTOR communicating with any person other than the consumer shall:

• Identify himself, state that he is confirming or correcting location information concerning the consumer, and, only if expressly requested, identify his employer.

• Not state that such consumer owes any debt.• Not communicate with any such person more than once unless requested to

do so by such person or unless the debt collector reasonably believes that the earlier response of such person is erroneous or incomplete.

• Not use any language or symbol on an envelope that indicates the contents are from a debt collector or in the business of debt collecting.

• Not communicate with any person once it is known that the consumer is represented by an attorney and the name and the address of the attorney are readily attainable, or the attorney fails to respond within a reasonable time.


1692 (d) Harassment or Abuse

• Debt collector may not engage in any conduct the natural consequence of which is to harass, oppress, or abuse any person in connection with the collection of a debt.

• Use or threat of use of violence or other criminal means to harm the physical person, reputation, or property of any person.

• Use obscene or profane language or language the natural consequence of which is to abuse the hearer or reader.

• Cause a telephone to ring or engaging any person in telephone conversation repeatedly or continuously with intent to annoy, abuse, or harass any person at the called number.

• Except as provided in section 1692b of this title, the placement of telephone calls without meaningful disclosure of the caller’s identity.


1692 (e) False or Misleading Representations

• Debt collector may not use any false, deceptive, or misleading representation or means in connection with the collection of any debt.

• False Misrepresentations include: that the debt collector is vouched for, bonded, or affiliated with any state or the United States including the use of a badge, or uniform. The character, amount, or legal status of a debt. Falsely state the service the debt collector is rendering or the compensation lawfully received for the collection of the debt.

• The false representation or implication that any individual is an attorney or that any communication is from an attorney.

• The representation or implication that nonpayment of any debt will result in the arrest or imprisonment of any person or the seizure, garnishment, attachment, or sale of any property or wages of any person unless such action is lawful and the debt collector or creditor intends to take such action.

15 U.S. Code Subchapter V - DEBT COLLECTION PRACTICES

1692 (f) Unfair Practices

• A debt collector may not use unfair or unconscionable means to collect or attempt to collect any debt.

• Accept from any person of a check or other payment instrument postdated by more than five days unless such person is notified in writing of the debt collector’s intent to deposit such check or instrument not more than ten nor less than three business days prior to such deposit.

• The solicitation by a debt collector of any postdated check or other postdated payment instrument for the purpose of threatening or instituting criminal prosecution.

• Causing charges to be made to any person. Such charges include, but are not limited to, collect telephone calls and telegram fees.


1692 (g) Validation of Debts

• To avoid complications be sure any initial communication with a consumer includes:

• The amount of the debt.

• The name of the creditor to whom the debt is owed.

• A statement that unless the consumer, within thirty days after receipt of the notice, disputes the validity of the debt, or any portion thereof, the debt will be assumed to be valid by the debt collector.

• A statement that if the consumer notifies the debt collector in writing within the thirty-day period that the debt, or any portion thereof, is disputed, the debt collector will obtain verification of the debt or a copy of a judgment against the consumer and mail it to them and provide them with the name of the original creditor if different from the current creditor.


1692 (g) Validation of Debts

• A communication in the form of a formal pleading in a civil action shall not be treated as an initial communication for purposes of subsection (a).

• The sending or delivery of any form or notice which does not relate to the collection of a debt and is expressly required by title 26, title V of Gramm-Leach-Bliley Act [15 U.S.C. 6801 et seq.], or any provision of Federal or State law relating to notice of data security breach or privacy, or any regulation prescribed under any such provision of law, shall not be treated as an initial communication in connection with debt collection for purposes of this section.


1692 (h) Multiple Debts

• If any consumer owes multiple debts and makes any single payment to any debt collector with respect to such debts, such debt collector may not apply such payment to any debt which is disputed by the consumer and, where applicable, shall apply such payment in accordance with the consumer’s directions.


1692 (i) Venue

In the case of an action to enforce an interest in real property securing the consumer’s obligation, bring such action only in a judicial district or similar legal entity in which such real property is located; or

(2) in the case of an action not described in paragraph (1), bring such action only in the judicial district or similar legal entity.

a) in which such consumer signed the contract sued upon; or

b) in which such consumer resides at the commencement of the action.


1692 (j) Deceptive Forms

• It is unlawful to design, compile, and furnish any form knowing that such form would be used to create the false belief in a consumer that a person other than the creditor of such consumer is participating in the collection of or in an attempt to collect a debt such consumer allegedly owes such creditor, when in fact such person is not so participating.

(b) Any person who violates this section shall be liable to the same extent and in the same manner as a debt collector is liable under section 1692k of this title for failure to comply with a provision of this subchapter.


1692 (k) Civil Liability

• Any debt collector who fails to comply with any provision of this subchapter with respect to any person is liable to such person in an amount equal to the sum of—

• (1) any actual damage sustained by such person as a result of such failure.

• In the case of any action by an individual, such additional damages as the court may allow, but not exceeding $1,000; or in the case of a class action such amount for each named plaintiff as could be recovered under subparagraph (A), and (ii) such amount as the court may allow for all other class members, without regard to a minimum individual recovery, not to exceed the lesser of $500,000 or 1 per centum of the net worth of the debt collector.

15 U.S. Code Subchapter V -DEBT COLLECTION PRACTICES

1692 (l) Administrative Enforcement

• The Federal Trade Commission shall be authorized to enforce compliance with this subchapter, except to the extent that enforcement of the requirements imposed under this subchapter is specifically committed to another Government agency under any of paragraphs (1) through (5) of subsection (b), subject to subtitle B of the Consumer Financial Protection Act of 2010 [12 U.S.C. 5511 et seq.].

• The other ACTS that may give enforcement rights to other agencies are:

• The Federal Deposit Insurance Act

• The Federal Reserve Act


1692 (l) Administrative Enforcement

• The Federal Credit Union Act

• Packers and Stockyard Act

• Consumer Financial Protection Act

• International Banking Act


1692 (m) Reports to Congress

• Not later than one year after the effective date of this subchapter and at one-year intervals thereafter, the Bureau shall make reports to the Congress concerning the administration of its functions under this subchapter, including such recommendations as the Bureau deems necessary or appropriate. In addition, each report of the Bureau shall include its assessment of the extent to which compliance with this subchapter is being achieved and a summary of the enforcement actions taken by the Bureau under section 1692l of this title.


1692 (n) Relation to State Laws

• Not later than one year after the effective date of this subchapter and at one-year intervals thereafter, the Bureau shall make reports to the Congress concerning the administration of its functions under this subchapter, including such recommendations as the Bureau deems necessary or appropriate. In addition, each report of the Bureau shall include its assessment of the extent to which compliance with this subchapter is being achieved and a summary of the enforcement actions taken by the Bureau under section 1692l of this title.


1692 (o) Exemption for state regulation

• The Bureau shall by regulation exempt from the requirements of this subchapter any class of debt collection practices within any State if the Bureau determines that under the law of that State that class of debt collection practices is subject to requirements substantially similar to those imposed by this subchapter, and that there is adequate provision for enforcement.


1692 (p) Exception for Certain Bad Check Enforcement Programs

• Subject to paragraph (2), a private entity shall be excluded from the definition of a debt collector, pursuant to the exception provided in section 1692a(6) of this title, with respect to the operation by the entity of a program described in paragraph (2)(A) under a contract described in paragraph (2)(B).

• A check issued to pay an obligation arising from a transaction that was illegal in the jurisdiction of the State or district attorney at the time the check was made, drawn, or delivered.

Legal Disclaimer

57

THE CONTENT PROVIDED IN THIS TRAINING PROGRAM IS FOR EDUCATIONAL AND REFERENCE PURPOSES ONLY.

THIS CONTENT IS PROVIDED TO THE AMERICAN RECOVERY ASSOCIATION MEMBERS AND THEIR EMPLOYEES AS A COURTESY TO BE USED FOR INFORMATION PURPOSES ONLY.

THE INFORMATION IS BASED ON READINGS, CLASSES, PUBLISHED AND VERBAL INTERPRETATIONS AND STANDARDS IN CURRENT USE.

THE CONTENT AND THE AUDIO PROVIDED ARE NOT INTENDED TO BE USED AS LEGAL ADVICE. YOU SHOULD ALWAYS CONSULT WITH YOUR ATTORNEY FOR OFFICIAL RULINGS AND INTERPRETATIONS ON SPECIFIC ISSUES.

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