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Cypen & Cypen
NEWSLETTER
for
January 10, 2019

Stephen H. Cypen, Esq., Editor

1. BALANCING OBJECTIVES IN PUBLIC EMPLOYEE POST-RETIREMENT EMPLOYMENT POLICIES: REASSESSING BARRIERS TO CONTINUED WORK:
Depending on applicable state law or the policies of a particular public retirement system, returning to work with a government agency after retirement can either be permissive or restrictive, and may further depend on the characteristics of individual employers and retirees. Much of the attitude of policymakers and the public toward such post-retirement employment stems from perceptions that public sector workers, either in general or in certain high-profile cases, have taken advantage of loopholes by being paid a pension benefit as a retiree while still drawing a salary. A common term for cases like these is “double dipping.” Concerns also have been expressed about “revolving door” agreements, wherein an employee approaching retirement may be promised a position post-retirement without first fulfilling an Internal Revenue Service (IRS) or retirement system required break in service. In some cases, the restrictions placed on reemployment apply not only to the direct agency from which an employee retired, but also potentially to other government agencies or government contractors within the state. While restrictions are rightfully enacted to address potential abuses, other approaches have attempted to balance the need for controls with a targeted policy of waiting periods, income limitations, exempted positions or other provisions that assist employers in meeting their workforce needs. This can be particularly helpful when highly skilled workers are needed in labor markets where particular skills may be in short supply, such as, but not limited to, in rural areas or inner cities. To get a better sense of the range of practice, the Center for State and Local Government Excellence (SLGE) and the National Association of State Retirement Administrators (NASRA) researched the post-retirement employment policies of eighty-three of the largest state pension plans in the United States— including those that cover state employees, public safety workers, teachers, and university faculty and staff. Where statewide plans included coverage for local government employees, such as under the public safety umbrella, or in a designated municipal retirement system, those plans were included in the analysis. Plans operated solely by an individual city or county were not considered. This report presents a review of related research in the field; describes findings from data collected on the post-retirement employment policies of large retirement systems across the United States; and provides case studies on three pension systems that have taken varying approaches to the re-employment question as it affects their stakeholders. The intent of this report is to provide additional resources for discussion among elected officials, pension plan administrators, labor unions, researchers, the media, the public, and any other interested party about the impacts that decisions around post-retirement employment can have on the ability of public employers to recruit, retain, and retire a talented and effective workforce, and about the approaches that have been and continue to be utilized around the country. This report was researched and written by Joshua Franzel, Ph.D., Gerald Young, and Rivka Liss-Levinson, Ph.D. of the Center for State and Local Government Excellence and Alex Brown and Keith Brainard of the National Association of State Retirement Administrators. The authors would like to thank Anne Phelan for copy editing this report and Rob Maguire Designs. SLGE gratefully acknowledges the support from the Alfred P. Sloan Foundation to undertake this research project. Access full report here. Center For State & Local Government Excellence, November 2018.
 
2. MOST RETIREES SAY EMPLOYERS DID NOTHING TO HELP WITH RETIREMENT TRANSITION:
A survey of 2,043 retirees by the Transamerica Center for Retirement Studies (TCRS) shows two-thirds (66%) say their most recent employers did “nothing” to help pre-retirees transition into retirement, and 16% are “not sure” what their employers did. Among the 18% of retirees whose employers helped pre-retirees, the most frequently cited offerings are financial counseling about retirement (6%), seminars and education about transitioning into retirement (5%), the ability to reduce work hours and shift from full- to part-time (5%), and accommodating flexible work schedules and arrangements (5%). When looking back on their retirement preparations, almost three in four retirees (73%) agree they wish they would have saved more and on a consistent basis. About two-thirds (67%) say they did as much as they could to prepare for retirement, but almost as many (64%) wish they had been more knowledgeable about retirement saving and investing. Three in ten used a financial adviser before retiring to help them manage their retirement savings or investments. Many retirees also agree they waited too long to concern themselves with saving and investing for retirement (50%) and that debt interfered with their ability to save as much as they needed for a comfortable retirement (47%). The survey found 31% of retirees started saving before the age of 40, while 39% started saving in their forties or older. The median age retirees first started saving was 40. Three in ten indicate they did not save for retirement. For the majority of their working careers, 68% of retirees participated in some form of employer-sponsored retirement benefits, including 49% who participated in a 401(k) or similar plan and 37% who participated in a defined benefit (DB) plan. Thirty-two percent of retirees worked for employers that did not offer any retirement benefits. The majority of retirees (61%) say they saved for retirement outside of work. Fifty-four percent of retirees had a retirement strategy before they retired; however, only 10% had a written plan, while 44% had a plan but it was not written down. Forty-six percent did not have a retirement strategy. Fewer than half of retirees (46%) surveyed by the TCRS agree that they have built a large enough retirement nest egg, of whom only 16% “strongly agree.” Yet, 67% say they are confident that they will be able to maintain a comfortable lifestyle throughout retirement, with 18% being “very confident.” Since entering retirement, 42% of retirees indicate that their personal financial situation has “stayed the same,” while approximately one in three (36%) indicate it has “declined.” Only 20% of retirees say that their personal financial situation has “improved.” Since entering retirement, almost six in ten retirees (59%) spend less money each year, compared with when they were working. Thirty-one percent spend the same amount of money each year, and only 6% spend more money each year in retirement. Retirees cite diverse sources of income, but Social Security is the primary source of income for most retirees. The survey found nearly all retirees (96%) receive income from Social Security. Sixty-six percent of retirees indicate that Social Security will be their primary source of income over the course of their retirement. Twenty-one percent cite retirement accounts and personal savings, including a 401(k) or similar accounts, IRAs (10%) and other savings and investments (11%). One in 10 retirees cite a DB plan as their primary source of income. The survey confirms that retiring later is not the best retirement strategy, as it found more than half of retirees (56%) retired sooner than they had planned. Among those, more than half (54%) cite employment-related reasons, including job loss (24%), organizational changes at their place of employment (22%), unhappiness with their job (15%) or took a retirement incentive or buyout (11%). Forty-seven percent cite health or family-related reasons, including their own ill health (28%), family responsibilities (15%) or their spouse or partner retired. Only 11% of retirees retired sooner than planned because of financial ability, including they had saved enough and could afford to retire (10%) or they received a financial windfall (1%). Among the small proportion (9%) of retirees who retired later than planned, 75% cite financial-related reasons, including needing the income (54%), they hadn’t saved enough for retirement (27%), general anxieties about their financial situation (23%), Social Security less than expected (18%), needing health benefits (12%) or recovering from a major financial setback (8%). Sixty-four percent of retirees who retired later than planned cite healthy aging-related reasons, including enjoying their work (43%), staying active (42%), and keeping their brain alert (27%). Ten percent indicate that their employer requested that they stay longer, and 5% indicate their spouse or partner retired sooner than planned. TCRS’s survey report, “A Precarious Existence: How Today’s Retirees Are Financially Faring in Retirement,” includes many other findings about the retiree experience, as well as tips for pre-retirees and retirement policy recommendations. Rebecca Moore, Plansponsor, December 18, 2018.
 
3. LAWYER ACCUSES JUDGE OF ‘ROBE RAGE,’ TELLS OPPOSING COUNSEL TO ‘CERTIFY YOUR OWN STUPIDITY,’ ETHICS COMPLAINT SAYS:
A Chicago lawyer has been accused of belittling his opposing counsel during a deposition and then describing the judge’s reaction to his conduct as “robe rage.” Charles Andrew Cohn was accused in a Dec. 12 ethics complaint noted by the Legal Profession Blog. The complaint relies on a transcript of the November 2016 deposition and a court filing by Cohn. During the deposition, Cohn had instructed his client not to answer a question, spurring the opposing lawyer to note her disagreement. “Certify the question,” said the opposing lawyer, who is identified only as “K.H.” in the complaint. “OK,” Cohn replied. “Then certify your own stupidity.” “Counsel, I’m not going to sit here and take insults from you,” K.H. responded. “At this point in time,” Cohn replied, “a man who insults on a daily basis everybody he does business with has now been elected president of the United States. The standards have changed. I’ll say what I want.” Later in the deposition, Cohn interrupted K.H.’s question and said, “Don’t waste your breath.” After she continued, Cohn instructed his client not to answer. “Certify the question,” K.H. again said. Cohn replied: “Motions for sanctions; indicate that on the record. I’m going to get sanctions against your firm like you wouldn’t believe, bitch.” K.H. filed a motion to compel that sought to overrule Cohn’s objections to her questions. During a December 2016 hearing on the motion, Judge Franklin Valderrama of Cook County admonished Cohn for his deposition statements and allowed him to file a response to K.H.’s motion. In the court filing, Cohn said his statements were a response to K.H.’s “bullying and improper questions” as well as her “general angry tone.” Cohn also wrote that the judge had himself flown into a rage in the court hearing, describing the situation as a “robe rage incident.” The Illinois Attorney Registration and Disciplinary Commission filed the complaint. Cohn told the ABA Journalhe has certain feelings about the ethics complaint, but he prefers not to discuss them. “I have no comment of any kind at this time,” he said. “I think the safer move is not to say anything.” Debra Cassens Weiss, ABA Journal, December 20, 2018.
 
4. SOCIAL SECURITY SPOUSAL BENEFITS EXPLAINED:
When a spouse dies, the Social Security benefits may become available to the current or former marital partner, depending on certain circumstances. A Social Security spouse benefit is called a “spousal benefit" and is available to:

  • Current spouses
  • Widowed spouses
  • Ex-spouses 

Tip: Before applying for spousal benefits, you should understand how your spouse's benefit may be affected if you take your Social Security benefits early, and what happens upon the death of a spouse.

Eligibility for a Spousal Benefit
Current spouses and ex-spouses (if you were married for over 10 years and did not remarry prior to age 60) both have eligibility for the spousal benefit. You must be age 62 to file for or receive a spousal benefit. You are not eligible to receive a spousal benefit until your spouse files for their own benefit first. Different rules apply to ex-spouses. You can receive a spousal benefit based on an ex-spouse's record even if your ex-partner has not yet filed for his or her own benefits, but your ex must be age 62 or older.
 
Note: Taking a spousal benefit does not reduce or change the amount your current spouse, ex-spouse, or ex-spouse's current spouse may receive.
 
How Much You Get
As a spouse, you can claim a Social Security benefit based on your own earnings record, or you can collect a spousal benefit that will provide you 50 percent of the amount of your spouse’s Social Security benefit as calculated at their full retirement age (FRA). Check the Social Security website to determine your FRA, as it depends on your year of birth. You are automatically entitled to receive either a benefit based on your own earnings or a spousal benefit based on your spouse's or ex-spouse's earnings. Social Security calculates and pays the higher amount. If you were born on or before January 1, 1954, after you reach FRA, you can choose to receive only the spousal benefit by filing a restricted application. By doing this you delay receiving your own retirement benefits based on your earnings record, until a later date. For example, at age 70 you could switch from receiving a spousal benefit to receiving your own potentially higher benefit amount. Due to recent Social Security laws that went into effect Nov. 2, 2015, if you were born on or after Jan. 2, 1954, you will not be able to restrict your application and only receive spousal benefits. For anyone born on or after Jan. 2, 1954, when you file you will automatically be deemed to be filing for all benefits for which you are eligible.
 
How Early Retirement Affects Benefits
If you collect a spousal benefit and you begin collecting this benefit before you reach FRA, your benefit will be permanently reduced. If you collect any type of benefit before your FRA, and you continue to work and receive earned income, you may owe some of your Social Security benefits back. Once you reach FRA you can collect Social Security and earn any amount from working without being subject to any reduction in benefits or penalty. If your spouse takes Social Security early, and you take a spousal benefit early, you will be significantly reducing the benefits that may be paid out over your lifetime and will have permanently reduced the survivor benefit for which either of you is eligible. Married couples can get more in Social Security payments by coordinating how and when they should each begin collecting benefits. You can run these numbers yourself to see how it works by using an advanced Social Security calculator.
 
If You Become a Widow or Widower
If you become a widow or widower, you can collect a survivor’s benefit as early as age 60. Widows and widowers can restrict their application to file for either their own benefit or the widow/widower benefit, and then later switch to the other benefits amount. You might do this if your own benefit amount at age 70 would be larger than your widow benefit. You could claim the widow benefit for several years, and then at age 70 switch to your own benefit. Once you and your spouse start receiving Social Security benefits, upon the death of your spouse, you will continue to receive your benefit, or your spouse’s, but not both. In addition, a surviving spouse living in the same household is eligible to receive a one-time lump-sum payment of $255 upon the death of a spouse. When married couples choose to maximize the highest-earning spouse’s benefit by having that person delay collecting until age 70, it acts as a powerful form of life insurance. In many cases, it provides the equivalent of $50,000 to $250,000 of life insurance benefit. Overall, married couples, in particular, can optimize their Social Security benefits by working together and making decisions that maximize their spousal and survivor benefits. Too many couples overlook this strategy and end up getting less lifetime income. Dana, Anspach, The Balance, December 20, 2018.
 
5. MILLENNIALS ARE “DELUSIONAL” ABOUT HOW RICH THEY’RE GOING TO BE:
By 45, most millennials think they’ll be living the good life. But the reality is likely to be much different. According to a recent survey by YCharts, an investment research platform, 65% of millennials ages 22-37 say they’ll reach seven-figure wealth by age 45 or sooner. That finding is backed by a survey released earlier this year from TD Ameritrade that found that more than half of millennials expect to be millionaires in their lifetimes, with more than four in ten saying it’ll happen by 50. As many a Gen Xer can attest to, this is unlikely to be the case -- at least if millennials’ current savings rates continue. Fully two-thirds of millennials have nothing saved for retirement, according to a report released this year by the National Institute for Retirement Studies -- and 95% are not properly saving for retirement. “Financial experts recommend that millennials set aside 15% or more of their salary for retirement, which is a much higher rule of thumb than recommendations for previous generations. But we find that millennials’ average retirement savings rate, including employers’ matching contributions, is 10% of their salary,” Jennifer Brown, NIRS manager of research, writes in the report. All this means it’s pretty unlikely that most millennials will be worth seven figures by the time they’re 45, experts say. “It’s probably not going to happen,” says Sean Brown, the CEO of YCharts. So why do so many think they’ll be rich? They may be “delusional” about “how much money they are able to save and how much they will be able to earn,” explains Agnes Kowalski, a wealth therapist -- who adds this can happen with people of all ages. But she explains that millennials in particular “have incredibly powerful new belief systems about not capping how much money can be earned” as “there are so many careers that were non-existent even 10 years ago” -- which may help explain why they think seven figures is possible. The FIRE movement (financial independence, retire early) isn’t helping matters either, says Bobbi Rebell, a certified financial planner and host the Financial Grownup podcast. Many of those doing it are millennials, so others who see that may think they can do it too. Another issue is that the millennials who are good at saving may not do an adequate job investing, says Brown -- which is what experts say can get you to seven figures quicker. A survey from Bankrate found that “millennials continue to lag behind their elders when it comes to investing in the stock market” with just one third of millennials owning stock, compared to roughly half of Gen Xer and boomers. Still, the fact that millennials think they might hit seven figures well before their 60s isn’t necessarily a bad thing, says Prudential’s Vice President of Strategic Initiatives Jim Mahaney. Indeed, he says the fact that they think they might hit a goal like that might actually encourage them to save even more. What’s more, you needn’t have seven figures socked away by 45 to be financially secure. Fidelity recommends that you save four times your annual salary by 45; that means that a person making $75,000 a year should have saved $300,000. By 65 they recommend 10 times your annual salary, or $750,000 in this case. As for how much total you’ll want to save before you quit working, Kimberly Foss, president and founder of Empyrion Wealth Management and a certified financial planner says to aim for roughly 25 times your desired annual retirement income in savings -- though this will vary depending on where you live. So in simple terms, if you want to live on $75,000 a year, you’ll want to have socked away nearly $1.9 million. She adds that you should also be able to live on about 4% of your retirement savings, withdrawn annually. So, if you have $1.9 million socked away, if you withdrew 4% of that a year, you’d get $75,000 to spend. Foss says that you can check on whether you’re on track with your savings by using tools like this Marketwatch calculator or this Vanguard calculator. Catey Hill, Market Watch, December 23, 2018.
 
6. MONEY MANAGERS TURN TO JOB CUTS TO STEADY SHIP:
Faced with the weight of fee pressures and industry consolidation, many money managers are quietly cutting staff, either in a pre-emptive attempt to buckle down against headwinds and shift their business focus or more urgent cuts out of necessity, sources said. "Every single firm is taking a look at costs and strategy," said Michael Fitzgerald, a Boston-based managing director within the asset management practice at RSR Partners, an executive search and leadership consulting firm. "Some firms are doing it from a position of strength where they know the business is changing and (are) looking at how (to) get ahead of this and structure (themselves). The other firms are doing it out of necessity, whether from pressure on flows, AUM or increased volatility that may have exposed managers living on the effects of market appreciation. They've had to make decisions that are maybe a little more drastic," Mr. Fitzgerald continued. When job cuts are occurring, they are "much more tactical or strategic, even surgical, where (managers) are merging certain distribution channels and investment teams as well as (sales) teams," he added later. In 2018, several managers put dozens, in some cases hundreds, of jobs on the chopping block. In August, J.P. Morgan Asset Management said it was laying off about 100 people, representative of 1% to 2% of staff in the J.P. Morgan Chase & Co. division. The cuts came despite the fact the asset management unit reported $1.8 billion in revenue in the second quarter, up 2% year-over-year. Assets under management in the unit were $2.028 trillion as of June 30, an 8% increase from the year prior, according to J.P. Morgan Chase's quarterly earnings statement. JPMAM managed $2.077 trillion as of Sept. 30. Standard Life Aberdeen PLC, Edinburgh, is in the midst of cutting around 800 jobs across its global business over a three-year integration period related to the merger of Standard Life PLC and Aberdeen Asset Management PLC. The company confirmed the planned job losses in May 2017, just months before the deal closed that August. Meanwhile, Zurich-based GAM Holding AG announced this month a restructuring plan that will include the elimination of approximately 10% of its more than 900-person staff during 2019. The cuts include previously announced efforts in November to consolidate investment teams across its fixed-income and equities business, a news release said. GAM faces job cuts as its overall AUM dropped 4.8% to 139.1 billion Swiss francs ($140.3 billion) over the two-month period ended Nov. 30, the money manager said in a Dec. 13 news release, following a period of upheaval at the firm where Tim Haywood, investment director business unit head for the unconstrained/absolute-return bond strategy, was suspended following an investigation, resulting in the liquidation of bond funds. For asset managers weighing cuts, such decisions primarily are being driven by two factors, said Alan Johnson, managing director of compensation consulting firm Johnson Associates Inc., New York. "One, is the continual, gradual erosion of fee levels, which reduces revenue," as investor clients move to passive strategies from active, Mr. Johnson said. Additionally, managers might put jobs on the line in response to declining firmwide or product assets, he said. Johnson Associates published a report in November that predicted there will be asset manager layoffs or downsizings coming in the first quarter of 2019. The moves may come with firms' "recognition of business dynamics and productivity increases/automation," the report said. Mr. Johnson believes the positions that would be affected the most by cuts are operations, sales and general management roles. "I think, by and large, the investment side will be protected even though they are more expensive per person … with automation and technology, you don't necessarily need as many people as you needed five or so years ago. I think most of the impact of technology is probably going to fall on operations staff," Mr. Johnson said. Firms likely will aim to make these adjustments as quietly as possible, he added. "I think everyone wants to be as quiet as can be. It will be layoffs (and) not filling positions as they open up … a combination of both," Mr. Johnson said. Johnson Associates' November compensation report also suggested firms will be eyeing costs associated with their locations. The impact of cost-of-living differences is expected to increase for financial services firms, including money managers, the report said. In fact, "financial services' overconcentration in select cities will diminish," the report predicted. The industry will see "more aggressive strategies to minimize costly locations." As such, money managers are determining: "how many people do we need, and where do we need them?" Mr. Johnson said in a telephone interview. AllianceBernstein (AB) LP (AB) announced that it was moving its headquarters to downtown Nashville from New York and expects to complete all phases of the move by 2024. In October, the $550 billion money manager reported to the New York State Department of Labor it would be laying off 35 of 244 employees in its White Plains, N.Y., offices throughout 2019, citing the relocation to Nashville, a public notice on the department's website showed. An AB spokeswoman declined to comment on the layoffs beyond the notice. While one recruiter shared that she has not seen widespread layoffs at money managers, "there have been a number of organizations that have come up and are doing this. And some are doing it discreetly," said Debra "Deb" Brown, a senior member of the investment management practice at Russell Reynolds Associates Inc., New York. Generally speaking, however, she said the the asset management industry has been resilient despite headwinds that could drag on costs for firms. Still, "There is some cutting going on in underperforming active strategies," Ms. Brown said, later adding: "Where you've got a dependence on active strategies, yes, (money managers) are prudent on how they can improve the economics." Ms. Brown also noted that cuts aren't always indicative of "an overall contraction of the firm," but a reallocation of resources. In June, it surfaced that Swiss bank UBS Group AG was eliminating at least 100 positions in its asset management unit as it shifted its focus to key areas such as growth in China, as well as passive and sustainable investing, sources told Bloomberg at the time. A UBS spokeswoman declined this month to comment on the matter, but an October company presentation for investors shows the company has pegged five strategic areas for growth: wholesale and platform services, investment solutions, sustainable and impact investing, China and indexed products, including exchange-traded funds. UBS Asset Management's total invested assets have grown to 810 billion Swiss francs ($1.065 trillion) as of June 30 from 656 billion Swiss francs at the end of 2016, the investor presentation showed. Separately, AXA Investment Managers completed around 200 job cuts in the second half of this year under an internal restructuring, a company spokeswoman confirmed in an email. The cuts, which were initially announced in June, affected roughly 160 positions in France, with the remainder in the U.K. Savings from the job cuts will go toward AXA's plan to invest around €100 million ($114 million) by 2020 in focus areas, which include alternatives, multiasset and fixed-income specialty investment strategies; ESG integration across investment teams; digital and advanced data analytics capabilities; and quantitative and data science skills. Katie Vande Water, a Boston-based partner in the financial services practice of executive search firm DHR International Inc., said money managers resorting to layoffs are often doing so to consolidate products -- in the process, leaving an investment team or distribution professionals without a place at the firm -- or to weed out staff whose performance has been lackluster. Danielle Walker, Pensions & Investments, December 24, 2018.
 
7. NETFLIX PHISHING SCAM: DON’T TAKE THE BAIT:
Phishing is when someone uses fake emails or texts to get you to share valuable personal information – like account numbers, Social Security numbers, or your login IDs and passwords. Scammers use your information to steal your money, your identity, or both. They also use phishing emails to get access to your computer or network. If you click on a link, they can install ransomware or other programs that can lock you out of your data. Scammers often use familiar company names or pretend to be someone you know. Here’s a real world example featuring Netflix. Police in Ohio shared a screenshot of a phishing email designed to steal personal information. The email claims the user’s account is on hold because Netflix is “having some trouble with your current billing information” and invites the user to click on a link to update their payment method. Before you click on a link or share any of your sensitive information:

  • Check it out. If you have concerns about the email, contact the company directly. But look up their phone number or website yourself. That way, you’ll know you’re getting the real company and not about to call a scammer or follow a link that will download malware.
  • Take a closer look. While some phishing emails look completely legit, bad grammar and spelling can tip you off to phishing. Other clues: Your name is missing, or you don’t even have an account with the company. In the Netflix example, the scammer used the British spelling of “Center” (Centre) and used the greeting, “Hi Dear.” Listing only an international phone number for a U.S.-based company is also suspicious.
  • Report phishing emails. Forward them to spam@uce.gov (an address used by the FTC) and to reportphishing@apwg.org (an address used by the Anti-Phishing Working Group, which includes ISPs, security vendors, financial institutions, and law enforcement agencies). You can also report phishing to the FTC at ftc.gov/complaint. Also, let the company or person that was impersonated know about the phishing scheme. For Netflix, forward the message to phishing@netflix.com

Colleen Tressler, Consumer Education Specialist, Federal Trade Commission, December 26, 2018.

8. DID YOU KNOW BENJAMIN FRANKLIN SAID THIS?:
“Better slip with foot than tongue.”  

9. OXYMORONS:
 How come abbreviated is such a long word?

10. INSPIRATIONAL QUOTES:
The battles that count aren't the ones for gold medals. The struggles within yourself--the invisible battles inside all of us--that's where it's at. – Jesse Owens
 
11. TODAY IN HISTORY:
On this day in 1776, "Common Sense" Pamphlet by Thomas Paine, published advocating American independence.
 
12. REMEMBER, YOU CAN NEVER OUTLIVE YOUR DEFINED RETIREMENT BENEFIT.

 

 

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Items in this Newsletter may be excerpts or summaries of original or secondary source material, and may have been reorganized for clarity and brevity. This Newsletter is general in nature and is not intended to provide specific legal or other advice.


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