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Filed on October 12, 2009, published the first business day after.

Inside Washington

  • WASHINGTON (10/13/09)--Interested credit unions are reminded to sign up for the Credit Union National Association's (CUNA) audio conference call Oct. 20 at 2 p.m. EDT on portions of the Credit Card Accountability, Responsibility and Disclosure Act that will take effect Feb. 22. The call will cover parts of the act addressing minimum payment warnings on credit card statements, interest rate increase prohibitions, and portions of the act that require co-signors for cardholders under age 21. The call will be led by CUNA Senior Assistant General Counsel Jeff Bloch and feature Federal Reserve representative Benjamin Olson, PSCU Financial Services' Steve Salzer, CUNA assistant general counsel and senior compliance counsel Michael McLain and University of Wisconsin CU Chief Credit Officer Mike Long ...

  • WASHINGTON (10/13/09)--Divisions over foreclosure mitigation--particularly between liberal Democrats and the Obama administration--are widening. On Friday, the Treasury issued a statement saying it had met its goal to modify 500,000 loans before a Nov. 1 deadline. On Monday, the Congressional Oversight Panel released a report indicating Treasury needs to re-examine the Home Affordable Modification Program because it deals with the housing crisis as it was six months earlier instead of the current situation (CongressDailyPM Oct. 9). The panel found that the program works only for certain mortgages, and does not help those struggling with job loss. Sen. Jack Reed (D-R.I.) has introduced legislation to fund grants for states to create mandatory mediation programs between lenders and borrowers; require lenders to evaluate if a borrower is eligible for a modification before; and give $7 billion to states to offer homeowners' grants. House Financial Services Chairman Barney Frank (D-Mass.) also has said he would attach legislation to allow bankruptcy judges to cram down the terms of a mortgage onto the House's regulatory reform measure. The Credit Union National Association has said that allowing bankruptcy judges to change the terms of a mortgage would lead to borrowers' gaming of the system. A dissatisfied borrower could stop payments on a home and possibly be able to keep it ...



Fryzel details 'intense' start to NCUA career

WASHINGTON (10/13/09)—Financial failures, market crashes, and the overall economic impact on individual credit unions and the corporate credit union system punctuated what was a "very intense" beginning to his tenure as National Credit Union Administration (NCUA) chairman, and the board had to make many tough decisions during that time, current NCUA board member Michael Fryzel told News Now.

"We faced many problems," but once those problems were laid out for credit unions "the industry was able to pull together" and handle those problems from within, without the need for direct government assistance, Fryzel added.

Working to ensure the viability of the corporate credit union system and, in turn, of individual credit unions was the greatest accomplishment of his tenure, Fryzel said. However, Fryzel added, he regrets not having a long enough tenure to adequately address some internal NCUA issues and make certain improvements to the NCUA staff.

Having both a former chairman and former board member turned chairman on the NCUA board--as is now the case--is an unprecedented event. Fryzel said that the combination of himself, NCUA Chairman Deborah Matz, and board member Gigi Hyland gives credit unions the "most knowledgeable and credit-union-familiar board that has ever been in charge of the NCUA."

Fryzel expressed his confidence in Matz's ability to "move forward with what needs to be done" and keep the agency moving in the "right direction" while continuing to address the needs of natural person and corporate credit unions.

The NCUA continues its work toward the creation of its own consumer protection agency, and while Fryzel said that he cannot comment on how that agency would interact with the Obama administration's proposed Consumer Financial Protection Agency (CFPA), the NCUA plans to have its own safeguards in place so that it can "make the argument for credit unions."

An NCUA's consumer protection agency should not create "significant additional costs" for credit unions, he said, adding that he did not think that the CFPA, if approved, would create additional burdens for credit unions.

Of member business loans, Fryzel said that there is a "niche" for some credit unions to offer business loans to their members, and does not oppose lifting the member business loan cap as long as credit unions make them "carefully and with the full understanding of how difficult those loans can be." The NCUA should also be allowed to "put in place the necessary rules that will ensure the safety and soundness of the funds of the credit unions that are making those loans," Fryzel added.

The NCUA's recent town hall meetings, which took place in 3 sites nationwide, have given the board "excellent" feedback, and the board is reviewing comments as it develops its new rules for corporate credit unions, which are expected to become permanent in early 2010.

While he expects credit unions and the nation in general to continue to see financial hardship in the near future, Fryzel said that credit unions remain the "premier source" of financial services in this country, and will continue to serve their members into the future.

Read the Oct. 19 issue of CUNA's Credit Union NewsWatch for more of Fryzel's views on credit union issues, including the future of alternative sources of capital.



Congress this week: Reg reform votes on calendar

WASHINGTON (10/13/09)--While the week for Congress began with the Columbus Day holiday, legislators on the House side will discuss H.R. 3606, the CARD Act Technical Corrections Act, when they reconvene today.

H.R. 3606, which was introduced by Rep. Peter Welch (D-Vt.) last week and has been supported by the Credit Union National Association, would clarify that the 21 day notification requirements of the CARD Act apply only to credit card accounts.

The week will continue with a pair of committee meetings set for Wednesday, and one of them will feature National Credit Union administration Chairman Deborah Matz representing the NCUA before Congress for the first time since her confirmation earlier this year. The hearing, which will focus on the state of the banking industry, will take place before the Senate financial institutions subcommittee and will also feature testimony from Federal Deposit Insurance Corporation Chairman Sheila Bair, Comptroller of the Currency John Dugan, and Federal Reserve Governor Daniel Tarullo, among others.

The House Financial Services Committee on Wednesday has also scheduled full committee markup sessions of H.R.3763, which would amend the Fair Credit Reporting Act to provide an exclusion from so-called "red flag" guidelines for certain businesses, and H.R. 3639, the "Expedited CARD Reform for Consumers Act of 2009."

H.R.3126, the "Consumer Financial Protection Agency Act of 2009"; will also be discussed during this markup session, which could extend into Thursday.

CUNA's Vice President of Legislative Affairs Ryan Donovan speculated that amendments addressing examination, enforcement, credit insurance, and preemption issues could come up during the discussion of H.R. 3126.



Sunday NY Times: Mica urges ‘don’t be fooled’ on interchange

WASHINGTON (10/13/09)--In an op-ed published in the Sunday edition of The New York Times, Credit Union National Association President/CEO Dan Mica urged legislators "not to be fooled" into passing "legislation that hurts one of the most important building blocks of our economy at a time when we can least afford it."

Responding to a recent Times story on interchange legislation, Mica said that "nearly all" credit unions are "concerned about the extremely harmful effects that interchange legislation would have on the services credit unions offer their members."

Eliminating or reducing interchange fee income could force credit unions "into the impossible decision" of raising member fees or ceasing participation in card programs, Mica added.

CUNA has fiercely opposed merchants proposals that would affect interchange fees, saying that interchange reflects a merchant's fair share of the costs of the convenient card system.



S&P commends NCUA addressing liquidity, capital

WASHINGTON (10/13/09)--Standard & Poor's (S&P) Ratings Service recognized a fundamental shift in the landscape for corporate credit unions when it downgraded six corporate credit unions in April, and withdrew the ratings on two others, S&P said in a press release Friday.

S&P said it believes that the National Credit Union Administration's (NCUA) efforts to preserve confidence in the credit union system have stemmed a liquidity crunch that could have been precipitated by significant outflows from the corporate system.

However, the release also highlights that the agency has not yet addressed some of the structural aspects of the system that are likely to evolve, and that could significantly alter the current framework. "Therefore, we believe that stand-alone evaluations of the corporate credit unions are in flux and will need to be re-evaluated in the context of the changing landscape," S&P said.

"Events of the past 18 months may shake members' faith in the cooperative nature of the system, which had been a major factor supporting the corporates' creditworthiness," S&P added. "Specifically, the burden of premium assessments on the members may appear too great when compared to the benefits of membership. Ultimately, we believe that the system will need capital to offset the increasingly likely losses stemming from mortgage-related structured securities."

"We believe that the NCUA has been proactive in addressing the needs of the system," S&P continued. "The NCUA's actions to assist corporate credit unions amidst a precarious environment include establishing the Temporary Corporate Credit Union Liquidity Guarantee Program, which guarantees participating corporates' debt, and establishing the Temporary Corporate Credit Union Stabilization Fund (TCCUSF) whose primary purpose is to absorb losses stemming from mortgage-backed securities investments in the corporate credit union system during a seven-year period. The TCCUSF is a $6 billion revolving facility provided by the Treasury.

"We believe that the NCUA has the mandate, the authority, and the capacity to continue to address the liquidity and capital needs of the credit union system, which is a major factor supporting our current ratings," S&P concluded.

The S&P release helps to underscore the importance of NCUA's review of the corporate system," Mary Dunn, senior vice president and deputy general counsel for the Credit Union National Association (CUNA), told News Now.

"While S&P notes that it downgraded six corporate credit unions and withdrew the ratings on two others earlier this year, it commends NCUA for acting to ‘preserve confidence' in the credit union system, including addressing problems within the corporates. At the same time, S&P notes that NCUA has not yet addressed structural issues and indicates the corporates will need more capital," Dunn said.

"No one that I am aware of is disagreeing with that," Dunn added. "NCUA is planning to address those structural issues, including capital standards, in the proposed corporate credit union rule that it is set to issue for comments in November. CUNA agrees with S&P that NCUA has the authority to address the liquidity and capital needs of the credit union system."



WOCCU: Not every nation ready for accounting changes

MADISON, Wis. (10/13/09)--Financial regulators and corporations worldwide are moving closer to accepting--even demanding--a uniform set of international accounting standards with which financial institutions in all countries must comply. However, not all countries, including the U.S., have yet required their institutions to rise to the global regulatory challenge, said the World Council of Credit Unions (WOCCU).

That inconsistency was revealed during an International Financial Reporting Standards (IFRS) webinar hosted Oct. 8 by WOCCU.

The 90-minute broadcast from WOCCU's Madison office included financial experts in the U.S., Canada and Macedonia. The latter two were connected remotely. Participants from 12 countries logged on for the discussion.

Demand for the topic emerged from WOCCU member countries, many of which are already in the process of transitioning to international standards, said Dave Grace, WOCCU vice president of association services. The complex demands of the process prompted WOCCU to address the topic in the webinar.

"More than 100 countries are actively moving towards international standards," Grace said. "We have a tremendous opportunity to learn from credit union systems already at the forefront of the transition. We don't want other credit unions and their regulators to have to make this journey on their own."

Participants heard from Holly Skaife, an associate professor of accounting at the University of Wisconsin-Madison, who serves on the Standards Advisory Council of the International Accounting Standards Board; Gary Rogers, vice president of financial policy for Credit Union Central of Canada (CUCC), a WOCCU member organization; and Eleonora Zgonjanin, CEO of FULM Savings House, WOCCU's member in Macedonia.

Institutions in each country have found themselves at different stages of the process, and all presenters shared their experiences.

"The U.S. is the largest country that has not yet embraced IFRS and still favors generally accepted accounting principles (GAAP)," said Skaife. For many U.S. regulators, GAAP's rules-based methodology is more stringent and demanding than IFRS standards, which are more principles-based and rely on faithfulness of the representation of financial data. The country's eventual migration to IFRS, while likely inevitable, still may be three to four years away, she explained.

In Canada, the process already is underway for most credit unions, which will be required to comply with IFRS standards in reporting their financial data for all fiscal years beginning Jan. 1, 2011, according to CUCC's Rogers. This will require more judgment and more disclosure by institutions, which will be facing less rules-based guidance, he added.

"This is far more than an accounting exercise," Rogers said. "Canadian credit unions are facing a creeping crisis of complexity, and our obligation is to provide credit unions with the right tools so that, together with their auditors, they are able to ready themselves for the change."

For Macedonia's single credit union, the process is already complete, said Zgonjanin. The credit union CEO emphasized the need for adequate time and resources. She suggested setting aside a minimum of 12 months for the transition process, including six months for development of the proper policies and procedures in order to keep the process on track.

"The transition to international accounting standards is not possible to complete manually, with fewer than three employees, in less than six months and without external assistance," Zgonjanin said.

To view the webinar, use the link.



Suze Orman: Switch cards to CUs

NEW YORK (10/13/09)--Consumers with credit cards might want to think about doing a balance transfer to a credit union, personal finance expert Suze Orman said on MSNBC's "Morning Joe" program Friday.

"Credit unions are being more responsible to their [members] than banks," Orman said.

During the show, Orman discussed the limited availability of credit plaguing consumers and said many large banks are raising their interest rates on customers who have consistently have paid their bills.

She also noted the case of a Bank of America customer who experienced an increase in interest rates on her credit card balance despite paying all of her bills on time.

The woman contacted Bank of America about the rate hike, but the bank refused to help her. She then posted a video on YouTube proclaiming that she would no longer make her payments. Bank of America eventually contacted her to mitigate the interest rate (News Now Sept. 25).

To view the video, use the link.



CEOs at two troubled CUs replaced

LAS VEGAS (10/13/09)--The CEOs at two credit unions in Las Vegas have been replaced, according to local media reports.

Andy Baumann, former National Credit Union Administration (NCUA) supervisor, has been named as interim CEO for WestStar CU. The institution is known as the "Gaming Employees' Credit Union" and has $174 million in assets (The Las Vegas Review-Journal Oct. 10).

Baumann replaces Dan Paulson, former Nevada Credit Union League chairman. WestStar lost $3.5 million in the first half of its year. Its net worth is 10%, which is considered well-capitalized by NCUA standards.

Paul Simons, CEO of Rantoul, Ill.-based Credit Union 1, will serve as CEO at Cumorah CU, which serves members of The Church of Jesus Christ of Latter-day Saints. The credit union has $157 million in assets. Simons replaces Tony Mook, who resigned Oct. 5.

Cumorah's financial reports indicate the credit union lost $7.3 million during the first half of 2009. Its net worth is 3.4%, which is below NCUA's threshold to be considered a well-capitalized institution.



CU marketer pens 'Motherhood is the New MBA'

SEATTLE (10/13/09)--A credit union marketing officer in Seattle is on a nationwide tour, promoting her new book about management, "MOTHERHOOD IS THE NEW MBA: Using Your Parenting Skills to be a Better Boss."

Shari Storm is vice president and chief marketing officer at Seattle-based Verity CU, where she has worked more than 10 years. She has a master's in business administration.

She launched her book, published by St. Martin's Press, on Sept. 29 to some very good press, according to the Washington Credit Union League.

"So far it's been featured in Body and Soul, Hybrid Mom and Coscto Connection Magazines, as well as Warner Bros.' MomLogic website and Business Week online," said David Bennett, director of public relations at the league. The book also was featured on Martha Stewart's radio show Thursday and in the Metro News in New York.

In the book, Storm offers advice to the working mom on how to be a better boss and relates management to motherhood. Each chapter takes a basic parenting rule and demonstrates how that advice can translate to successful management at the office. For example:

  • Speak Their Language: Study what types of communication work best with your co-workers and engage them on those terms.

  • Never Underestimate the Power of "Kiss It, Make It Better": If your employee needs your support, don't put it off and don't be afraid. If employees are worth keeping, they are worth going to bat for. That is your responsibility as their boss.

  • Hold the Line on Tantrums: Watch out for signs of your staff looking overworked or bored, and if someone does let loose, take that person aside and address the situation.

  • Be the Good Mom: Do not be afraid to be caring, nurturing, friendly and casual with your employees. You can be a good person to them without trying to be their best friend.

Storm's October and November tour will take to her Olympia, Wash.; Madison, Wis.; Cleveland, Ohio; and Brooklyn, N.Y. For more information, use the resource link.



Subprime Blogger suggests going to CUs

MADISON, Wis. (10/13/09)--Consumers who are seeking personal loans should check out credit unions, said Subprime Blogger in a Sunday post.

"If you currently use a credit union, you know there are a few benefits over a national or regional bank," the blog said. "You also want these benefits during the loan process."

Obtaining a bad personal loan can "lead to a very high interest rate," said the blog.

Even if a consumer has bad credit, "there are many ... credit unions out there that are more than willing to help you get a personal loan," the blog added.



Alco FCU employee hurt while foiling robbery

WELLSVILLE, N.Y. (10/13/09)--A credit union employee was hurt while foiling an attempted robbery in Wellsville, N.Y.

The robbery took place at Alco CU on Oct. 7. The employee was injured after struggling with the would-be robber, who was carrying a pellet handgun. The gun broke in half, and the employee was cut. She was treated with stitches at a local hospital and released (Olean Times Herald Oct. 9).

A suspect--Michael R. Lamb, 21--was apprehended by police and charged with attempted robbery, second-degree assault and third-degree aggravated unlicensed operation of a motor vehicle. A 17-year-old female who was a passenger in Lamb's vehicle also was arrested and charged with attempted robbery.

Alco CU has $15.6 million in assets.



CU System briefs

  • SPRING, Texas (10/13/09)--A former intern at Investex CU's Spring, Texas, branch was sentenced Friday to more than 13 years in prison for helping shotgun-wielding men rob the credit union twice within three months last year. Dorcell Devon Johnson, 19, pleaded guilty to aggravated bank robbery and aiding the brandishing of a firearm during a robbery. In November 2008, the credit union was robbed of $202,250. In August of 2008, robbers took $126,750 during a heist in which they pretended to take Johnson hostage. Police became suspicious when he appeared unafraid on surveillance tapes of the earlier robbery. Co-defendants Dominique Sherrard Ervin, 20, and Carl Edward Preston Jr., 19, both of Houston, also pleaded guilty. Preston was sentenced to about 13 years in prison while Ervin was sentenced to 16 1/2 years (Houston Chronicle) ...

  • YAKIMA, Wash. (10/13/09)--The Washington Credit Union League has named Paula Slaye chairman of the Washington Credit Union Foundation. Slaye is chief financial officer of Catholic CU in Yakima. Slaye has served on the foundation's board of trustees for the past seven years in several positions, including treasurer, grants committee chairman and vice chairman (Yakima Herald Republic Oct. 12) ...

  • St. Louis (10/13/09)-- More than a dozen Missouri credit union representatives met with State Rep. Jake Zimmerman (D-83) at St. Louis Community CU Oct. 7, according to the Missouri Credit Union Association (The Missouri difference Oct. 9). He discussed matters that affect credit unions and their members, and highlighted the primary advantage credit unions have over other financial institutions. "Credit unions benefit from serving their members," Zimmerman said. "When you can actually deliver credit union members into a legislative office, that's when you get the point across--with human beings." When St. Louis Community CU President Patrick Adams asked why Zimmerman supports credit unions, Zimmerman responded that credit unions look out for the little guy, just like he does. Pictured are, from left, Adams, Zimmerman, and Mike O'Brien, St. Louis Community CU senior vice president and chief marketing officer. (Photo provided by the Missouri Credit Union Association) ...



Market News

Market News

MADISON, Wis. (10/13/09)

  • Consumer spending now constitutes 71% of gross domestic product (GDP), according to the latest statistics from the Bureau of Economic Analysis. That percentage is slightly above the year-ago level and substantially higher than the long-term average of about 65%, analysts said. GDP includes personal spending on cars, clothes, food and other items. "It's somewhat ironic: We keep referring to the less prominent role for consumer spending in this economy," said John Lonski, Moody's chief economist. "Yet, in the second quarter '09, it rose to a post-World War II record high." During a recession, the consumption component of the economy typically rises, said economist Jim Hamilton of the University of California-San Diego. Most economists expect the consumption share to gradually shrink as the economy emerges from the downturn, analysts said. "I fully expect the consumer share to drop. But it'll take five to 10 years to happen," said Nariman Behravesh, chief economist at IHS Global Insight (USA Today Oct. 12) ...

  • With record reserves filling their coffers, central banks worldwide are increasingly eschewing dollars in favor of euros and yen, putting more pressure on the dollar after its biggest rout in nearly two decades, analysts said. In the third quarter, policymakers increased foreign currency holdings by $413 billion--the most since 2003, according to data compiled by Bloomberg. About 63% of the nations that reported their currency breakdowns put new cash into euros and yen in April, May and June--the highest percentage in any quarter with more than an $80 billion increase, according to the most recent data from Barclays Capital. "Global central banks are getting more serious about diversification, whereas in the past they used to just talk about it," said Steven Englander, Barclay's chief U.S. currency strategist. "It looks like they are really backing away from the dollar" (Bloomberg.com Oct. 12) ...

  • Federal debt and rising unemployment continue to be concerns, even though the recession has all but ended, according to a National Association for Business Economics (NABE) survey of economists released Monday. More than 80% of the economists surveyed said the economic recovery has begun. Real gross domestic product is expected to increase at a 2.9% pace in the second half of this year and at a 3% rate next year--up from its 2.7% forecast in May, NABE said. However, NABE added that the recovery will be more moderate than in previous post-recession periods. "The good news is that this deep and long recession appears to be over, and with improving credit markets, the U.S. economy can return next year without worry about inflation," said NABE President-elect Lynn Reaser (The Wall Street Journal Oct. 12) ...



News of the Competition

MADISON, Wis. (10/13/09)

  • After marking up mortgage collection contracts by $11 billion in the second quarter, the four largest U.S. banks by assets may be forced to take writedowns of $55 billion on the contracts, analysts said. Bank of America Corp., Citigroup Inc., JPMorgan Chase & Co. and Wells Fargo & Co. wrote up the value of the contracts--known as mortgage-servicing rights or MSRs--by 26% in the quarter as mortgage rates rose about 0.45 of a percentage point. Wells Fargo experienced net gains on the contract that added more than $1 billion to its record earnings in the quarter. JPMorgan added $1 billion to its first-quarter profit, analysts said (Bloomberg.com Oct. 12) ...



FIs working to cut down on data duplication

NEW YORK (10/13/09)--The amount of data stored by databases is growing at a rate of 25% yearly, and some financial institutions have deployed technology to eliminate data duplication, according to BankTechnology News.

Storing a massive amount of data can strain information technology (IT) architectures (Sept. 1). Simply updating a member's address can prompt a system to resave the entire member file even though nothing else has changed, the newspaper said.

Virginia CU, Richmond, Va., has implemented a NetApp solution to cut down on data duplication.

"We've seen an 80% savings on backup copies, 78% in Virtual Desktop Infrastructure, and we're routinely achieving 25% on home directories and group shares, 35% in our live documentation environment, and 50% savings in our scratch volumes," Rich Barlow, senior systems architect, told the newspaper.

Because deduplication cuts on data protection capital and operation expenses, it should be on "every chief information officer's project short list," according to a report from Milford, Mass.-based The Enterprise Strategy Group, an industry analyst firm.

Aside from freeing storage, reducing data duplication also yields "green" benefits, the report said. About 70% of business executives measure the success of corporate green initiatives by tracking energy cost reductions.

If IT staffs can align with green business priorities, cutting power consumption via deduplication "is a great start," said Lauren Whitehouse, senior analyst, in the report.



CUNA Mutual introduces ID theft insurance for CU staff

MADISON, Wis. (10/13/09)--CUNA Mutual Group is introducing an optional Identity Theft insurance program for credit union directors, officers and employees as part of its new Management and Professional Liability Insurance (MPL) policy.

Identity theft is a complex and ever-changing crime, said John Wallace, CUNA Mutual Credit Union Protection product executive. "The unlawful use of personal identifying information drains resources from businesses, government agencies and consumers alike," he said. "It can take considerable effort to repair identity theft-related damages, including time and expenses."

There are nearly nine million identity theft victims in the U.S. annually who invest 55 to 130 hours and $1,200 to $1,500 out-of-pocket to resolve the issue, according to the Federal Trade Commission. This process can span months or years. About 47% of identity theft victims needed a year or more to restore their identity, said an Identity Theft Resource Center study.

When an insured individual's personal identification information is compromised and used unlawfully, CUNA Mutual's Identity Theft insurance will cover fees related to:

  • Notarized affidavits attesting to the fraud;
  • Time away from work;
  • Certified mail to law enforcement agencies, credit agencies and financial institutions;
  • Application fees associated with reapplying for loans; and
  • Child care and/or elder care.

Insured individuals also will receive Identity Theft Restoration and Consultation services from a licensed investigator during the entire resolution process. CUNA Mutual is partnering exclusively with Kroll Fraud Solutions, a division of Kroll, a risk consulting company, to provide the services to policyholders. Kroll Fraud Solutions serves more than 10,000 businesses and millions of individual consumers in the areas of data breach and identity theft discovery, investigation and restoration.

Identity theft insurance is optional as part of MPL coverage for credit unions renewing their current policies on or after Jan. 1 in most states. MPL is a new policy designed to protect credit unions and the personal assets of their directors, officers, volunteers and employees from a growing number of litigation exposures related to operating a credit union.

MPL is part of CUNA Mutual's Credit Union Protection insurance and risk management portfolio designed exclusively for credit unions to manage their financial, operational and personal risk exposures. The program includes:

  • Bond;
  • Plastic Card;
  • Management and Professional Liability;
  • Property and Business Liability;
  • Business Auto;
  • Workers Compensation; and
  • Additional policies.



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