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Speeches & Testimony
Statement Of Martin J. Gruenberg, Chairman, Federal Deposit Insurance Corporation on Mitigating Systemic Risk Through Wall Street Reform before the Committee on Banking, Housing, and Urban Affairs of the U.S. Senate; 538 Dirksen Senate Office Building
July 11, 2013
Chairman Johnson, Ranking Member Crapo and members of the Committee, thank you for the opportunity to testify today on the Federal Deposit Insurance Corporation's (FDIC) actions to implement the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).
With the three-year anniversary of the Dodd-Frank Act approaching, the FDIC has made significant progress in implementing the new authorities granted by the Act, 1 particularly with regard to the authorities to address the issues presented by institutions that pose a risk to the financial system. We also have moved forward in our efforts to strengthen the Deposit Insurance Fund and to improve the resiliency of the capital framework for the banking industry.
My written testimony will address three key areas. First, I will provide a brief overview of the current state of the banking industry and the federal deposit insurance system. Second, I will provide an update on our progress in implementing the new authority provided to the FDIC to address the issues posed by systemically important financial institutions. Finally, I will discuss the Acts impact on our supervision of community banks.
Overview of the Banking Industry
The financial condition of the banking industry in the United States has experienced three consecutive years of gradual but steady improvement. Industry balance sheets have been strengthened and capital and liquidity ratios have been greatly improved.
Industry net income has now increased on a year-over-year basis for 15 consecutive quarters. FDIC-insured commercial banks and savings institutions reported aggregate net income of $40.3 billion in the first quarter of 2013, a $5.5 billion (15.8 percent) increase from the $34.8 billion in profits that the industry reported in the first quarter of 2012. Half of the 7,019 FDIC-insured institutions reporting financial results had year-over-year increases in their earnings. The proportion of banks that were unprofitable fell to 8.4 percent, down from 10.6 percent a year earlier.
Credit quality for the industry also has improved for 12 consecutive quarters. Delinquent loans and charge-offs have been steadily declining for over two years. Importantly, loan balances for the industry as a whole have now grown for six out of the last eight quarters. These positive trends have been broadly shared across the industry, among large institutions, mid-size institutions, and community banks.
The internal indicators for the FDIC also have been moving in a positive direction over this period. The number of banks on the FDIC's "Problem List" institutions that had our lowest supervisory CAMELS ratings of 4 or 5 peaked in March of 2011 at 888 institutions. By the end of last year, the number of problem banks stood at 651 institutions, dropping further to 612 institutions at the end of the first quarter 2013. In addition, the number of failed banks has been steadily declining. Bank failures peaked at 157 in 2010, followed by 92 in 2011, and 51 in 2012. To date in 2013, there have been 16 bank failures compared to 31 through the same period in 2012.
Despite these positive trends, the banking industry still faces a number of challenges. For example, although credit quality has been improving, delinquent loans and charge-offs remain at historically high levels. In addition, tighter net interest margins and relatively modest loan growth have created incentives for institutions to reach for yield in their loan and investment portfolios, heightening their vulnerability to interest rate risk and credit risk. Rising rates could heighten pressure on earnings at financial institutions that are not actively managing these risks. The federal banking agencies have reiterated their expectation that banks manage their interest rate risk in a prudent manner, and supervisors continue to actively monitor this risk.
Condition of the FDIC Deposit Insurance Fund
As the industry has recovered over the past three years, the Deposit Insurance Fund (DIF) also has moved into a stronger financial position.
Restoring the DIF
The Dodd-Frank Act raised the minimum reserve ratio for the DIF (the DIF balance as a percent of estimated insured deposits) from 1.15 percent to 1.35 percent, and required that the reserve ratio reach 1.35 percent by September 30, 2020. The FDIC is currently operating under a DIF Restoration Plan that is designed to meet this deadline, and the DIF reserve ratio is recovering at a pace that remains on track under the Plan. As of March 31, 2013, the DIF reserve ratio stood at 0.59 percent of estimated insured deposits, up from 0.44 percent at year-end 2012 and 0.22 percent at March 31 of last year. Most of the first quarter 2013 increase in the reserve ratio can be attributed to the expiration of temporary unlimited deposit insurance coverage for noninterest-bearing transaction accounts under the Act on December 31, 2012
The fund balance has grown for thirteen consecutive quarters and stood at $35.7 billion at March 31, 2013. This is in contrast to the negative $21 billion fund balance at its low point at the end of 2009. Assessment revenue and fewer anticipated bank failures have been the primary drivers of the growth in the DIF balance.
Prepaid Assessments
At the end of 2009, banks prepaid to the FDIC more than three years of estimated deposit insurance assessments, totaling $45.7 billion. The prepaid assessments were successful in ensuring that the DIF had adequate liquidity to handle a high volume of bank failures without having to borrow from the Treasury. In accordance with the regulation implementing the prepaid assessment, the FDIC refunded almost $6 billion in remaining unused balances of prepaid assessments to approximately 6,000 insured institutions at the end of June.
Improving Financial Stability and Mitigating Systemic Risk
Capital Requirements
On July 9, the FDIC Board acted on two important regulatory capital rulemakings. First, the FDIC issued an interim final rule that significantly revises and strengthens risk-based capital regulations through implementation of Basel III. This rule consolidates the proposals issued in the three separate notices of proposed rulemakings (NPRs) that the agencies issued last year and includes significant changes from the original proposals to address concerns raised by community banks. Second, the FDIC issued a joint interagency NPR to strengthen the leverage requirements for systemically important banking organizations.
Interim Final Rule on Basel III
The interim final rule on Basel III would strengthen both the quality and quantity of risk-based capital for all banks by placing greater emphasis on Tier 1 common equity capital. Tier 1 common equity capital is widely recognized as the most loss-absorbing form of capital. The interim final rule adopts with revisions the three notices of proposed rulemakings or NPRs that the banking agencies proposed last year. These are the Basel III NPR, the Basel III advanced approaches NPR, and the so-called Standardized Approach NPR. These changes will create a stronger, more resilient industry better able to withstand environments of economic stress in the future.
This interim final rule is identical in substance to the final rules issued by the Federal Reserve Board and the Office of the Comptroller of the Currency (OCC) and allows the FDIC to proceed with the implementation of these revised capital regulations in concert with our fellow regulators. Issuing the interim final rule also allows us to seek comment on the interactions between the revised risk-based capital regulations and the proposed strengthening of the leverage requirements for the largest and most systemically important banking organizations which is described in more detail below.
During the comment period on these proposals, we received a large number of comments, particularly from community banks, expressing concerns with some of the provisions of the NPRs. The interim final rule makes significant changes to aspects of the NPRs to address a number of these community bank comments. Specifically, unlike the NPR, the rule does not make any changes to the current risk-weighting approach for residential mortgages. It allows for an opt-out from the regulatory capital recognition of accumulated other comprehensive income, or AOCI, except for large banking organizations that are subject to the advanced approaches requirements. Further, the rule reflects that the Federal Reserve has adopted the grandfathering provisions of section 171 of the Dodd Frank Act for Trust Preferred Securities issued by smaller bank holding companies. Comments received on all these matters were extremely helpful to the agencies in reaching decisions on the proposals.
The interim final rule includes requirements for large banking organizations subject to the advanced approaches requirements that do not apply to community banks. For example, these advanced approach large institutions would be required to recognize AOCI in regulatory capital and also would face strengthened capital requirements for over-the-counter derivatives.
Consistent with the Basel III international agreement, the interim final rule includes a three percent supplementary leverage ratio that applies only to the 16 large banking organizations subject to the advanced approaches requirements. This supplementary leverage ratio is more stringent than the existing U.S. leverage ratio as it would include certain off-balance sheet exposures in its denominator. Given the extensive off-balance sheet activities of many advanced approaches organizations, the supplementary leverage ratio will play an important role. Finally, the rule maintains the existing U.S. leverage requirements for all insured banks, with the minimum leverage requirements continuing to set a floor for the leverage requirements of advanced approaches banking organizations.
Although the new requirements are higher and more stringent than the old requirements, the vast majority of banks meet the requirements of the interim final rule. Going forward, the rule would have the effect of preserving and maintaining the gains in capital strength the industry has achieved in recent years. As a result, banks should be better positioned to withstand periods of economic stress and serve as a source of credit to local communities.
While much contained in these rules does not apply to community banks, we want to be certain that community banks fully understand the changes in the capital rules that do apply to them. To that end, the FDIC is planning an extensive outreach program to assist community banks in understanding the interim final rule and the changes it makes to the existing capital requirements. We will provide technical assistance in a variety of forms, targeted specifically at community banks, including community bank guides on compliance with the rule, a video that will be available on the FDIC website, a series of regional outreach meetings, and subject matter experts at each of our regional offices whom banks can contact directly with questions.
Interagency NPR on the Supplementary Leverage Ratio
The FDIC joined the Federal Reserve and the OCC in issuing an NPR which would strengthen the supplementary leverage requirements encompassed in the interim final rule for certain large institutions and their insured banks. Using the NPRs proposed definitions of $700 billion in total consolidated assets or $10 trillion in assets under custody to identify large systemically significant firms, the new requirements would currently apply to eight U.S. bank holding companies and to their insured banks.
As the NPR points out, maintenance of a strong base of capital at the largest, most systemically important institutions is particularly important because capital shortfalls at these institutions can contribute to systemic distress and can have material adverse economy effects. Analysis by the agencies suggests that a three percent minimum supplementary leverage ratio would not have appreciably mitigated the growth in leverage among these organizations in the years preceding the recent crisis. Higher capital standards for these institutions would place additional private capital at risk before calling upon the DIF and the Federal governments resolution mechanisms.
The NPR would require these insured banks to satisfy a six percent supplementary leverage ratio to be considered well capitalized for prompt corrective action (PCA) purposes. Based on current supervisory estimates of the off-balance sheet exposures of these banks, this would correspond to roughly an 8.6 percent U.S. leverage requirement. For the eight affected banks, this would currently represent $89 billion in additional capital for an insured bank to be considered well-capitalized.
Bank Holding Companies (BHCs) covered by the NPR would need to maintain supplementary leverage ratios of a three percent minimum plus a two percent buffer for a five percent requirement in order to avoid conservation buffer restrictions on capital distributions and executive compensation. This corresponds to roughly a 7.2 percent U.S. leverage ratio, which would currently require $63 billion in additional capital.
An important consideration in calibrating the proposal was the idea that the increase in stringency of the leverage requirements and the risk-based requirements should be balanced. Leverage capital requirements and risk-based capital requirements are complementary, with each type of requirement offsetting potential weaknesses of the other. Balancing the increase in stringency of the two types of capital requirement should make for a stronger and sounder capital base for the U.S. banking system.
Resolution of Systemically Important Financial Institutions
In addition to these capital proposals, the FDIC has made progress on policies and strategies to build a more effective resolution framework for large, complex financial institutions. One of the most important aspects of the Dodd-Frank Act is the establishment of new authorities for regulators to use in the event of the failure of a systemically important financial institution (SIFI).
Resolution Plans Living Wills
Under the framework of the Dodd-Frank Act, bankruptcy is the preferred option in the event of the failure of a SIFI. To make this objective achievable, Title I of the Dodd-Frank Act requires that all bank holding companies with total consolidated assets of $50 billion or more, and nonbank financial companies that the Financial Stability Oversight Council (FSOC) determines could pose a threat to the financial stability of the United States, prepare resolution plans, or living wills, to demonstrate how the company could be resolved in a rapid and orderly manner under the Bankruptcy Code in the event of the companys financial distress or failure. The living will process is an important new tool to enhance the resolvability of large financial institutions through the bankruptcy process.
The FDIC and the Federal Reserve Board issued a joint rule to implement Section 165(d) requirements for resolution plans (the 165(d) rule) in November 2011. The FDIC also issued a separate rule which requires all insured depository institutions (IDIs) with greater than $50 billion in assets to submit resolution plans to the FDIC for their orderly resolution through the FDICs traditional resolution powers under the Federal Deposit Insurance Act (FDI Act). The 165(d) rule and the IDI resolution plan rule are designed to work in tandem by covering the full range of business lines, legal entities and capital-structure combinations within a large financial firm.
The FDIC and the Federal Reserve review the 165(d) plans and may jointly find that a plan is not credible or would not facilitate an orderly resolution under the Bankruptcy Code. If a plan is found to be deficient and adequate revisions are not made, the FDIC and the Federal Reserve may jointly impose more stringent capital, leverage, or liquidity requirements, or restrictions on growth, activities, or operations of the company, including its subsidiaries. If compliance is not achieved within two years, the FDIC and the Federal Reserve, in consultation with the FSOC, can order the company to divest assets or operations to facilitate an orderly resolution under bankruptcy in the event of failure. A SIFIs plan for resolution under bankruptcy also will support the FDICs planning for the exercise of its Title II resolution powers by providing the FDIC with a better understanding of each SIFIs structure, complexity, and processes.
2013 Guidance on Living Wills
Eleven large, complex financial companies submitted initial 165(d) plans in 2012. Following the review of the initial resolution plans, the agencies developed Guidance for the firms to detail what information should be included in their 2013 resolution plan submissions. The agencies identified an initial set of significant obstacles to rapid and orderly resolution which covered companies are expected to address in the plans, including the actions or steps the company has taken or proposes to take to remediate or otherwise mitigate each obstacle and a timeline for any proposed actions. The agencies extended the filing date to October 1, 2013, to give the firms additional time to develop resolution plan submissions that address the instructions in the Guidance.
Resolution plans submitted in 2013 will be subject to informational completeness reviews and reviews for resolvability under the Bankruptcy Code. The agencies will be looking at how each resolution plan addresses a set of benchmarks outlined in the Guidance which pose the key impediments to an orderly resolution. The benchmarks are as follows:
As reflected in the Dodd-Frank Act and discussed above, the preferred option for resolution of a large failed financial firm is for the firm to file for bankruptcy just as any failed private company would. In certain circumstances, however, resolution under the Bankruptcy Code may result in serious adverse effects on financial stability in the United States. In such cases, the Orderly Liquidation Authority set out in Title II of the Dodd-Frank Act serves as the last resort alternative and could be invoked pursuant to the statutorily prescribed recommendation, determination and expedited judicial review process.
Orderly Liquidation Authority
Prior to the recent crisis, the FDICs receivership authorities were limited to federally insured banks and thrift institutions. The lack of authority to place the holding company or affiliates of an insured depository institution or any other non-bank financial company into an FDIC receivership to avoid systemic consequences severely constrained the ability to resolve a SIFI. Orderly Liquidation Authority provided under Title II of the Dodd-Frank Act gives the FDIC the powers necessary to resolve a failing systemic non-bank financial company in an orderly manner that imposes accountability on shareholders, creditors and management of the failed company while mitigating systemic risk and imposing no cost on taxpayers.
The FDIC has largely completed the core rulemakings necessary to carry out its systemic resolution responsibilities under Title II of the Dodd-Frank Act. For example, the FDIC approved a final rule implementing the Orderly Liquidation Authority that addressed, among other things, the priority of claims and the treatment of similarly situated creditors.
Under the Dodd-Frank Act, key findings and recommendations must be made before the Orderly Liquidation Authority can be considered as an option. These include a determination that the financial company is in default or danger of default, that failure of the financial company and its resolution under applicable Federal or State law, including bankruptcy, would have serious adverse effects on financial stability in the United States and that no viable private sector alternative is available to prevent the default of the financial company.
To implement its authority under Title II of the Dodd-Frank Act, the FDIC has developed a strategic approach to resolving a SIFI which is referred to as Single Point-of-Entry. In a Single Point-of-Entry resolution, the FDIC would be appointed as receiver of the top-tier parent holding company of the financial group following the companys failure and the completion of the recommendation, determination and expedited judicial review process set forth in Title II of the Act. Shareholders would be wiped out, unsecured debt holders would have their claims written down to reflect any losses that shareholders cannot cover, and culpable senior management would be replaced. Under the Act, officers and directors responsible for the failure cannot be retained.
During the resolution process, restructuring measures would be taken to address the problems that led to the companys failure. These could include shrinking businesses, breaking them into smaller entities, and/or liquidating certain assets or closing certain operations. The FDIC also would likely require the restructuring of the firm into one or more smaller non-systemic firms that could be resolved under bankruptcy.
The FDIC would organize a bridge financial company into which the FDIC would transfer assets from the receivership estate, including the failed holding companys investments in and loans to subsidiaries. Equity, subordinated debt, and senior unsecured debt of the failed company would likely remain in the receivership and be converted into claims. Losses would be apportioned to the claims of former equity holders and unsecured creditors according to their order of statutory priority. Remaining claims would be converted, in part, into equity that will serve to capitalize the new operations, or into new debt instruments. This newly formed bridge financial company would continue to operate the systemically important functions of the failed financial company, thereby minimizing disruptions to the financial system and the risk of spillover effects to counterparties.
The healthy subsidiaries of the financial company would remain open and operating, allowing them to continue business and avoid the disruption that would likely accompany their closings. Critical operations for the financial system would be maintained. However, creditors at the subsidiary level should not assume that they avoid risk of loss. For example, if the losses at the financial company are so large that the holding companys shareholders and creditors cannot absorb them, then the subsidiaries with the greatest losses would have to be placed into resolution, thus exposing those subsidiary creditors to loss.
The FDIC expects the well-capitalized bridge financial company and its subsidiaries to borrow in the private markets and from customary sources of liquidity. The new resolution authority under the Dodd- Frank Act provides a back-up source for liquidity support, the Orderly Liquidation Fund (OLF). If it is needed at all, the FDIC anticipates that this liquidity facility would only be required during the initial stage of the resolution process, until private funding sources can be arranged or accessed. The law expressly prohibits taxpayer losses from the use of Title II authority.
In our view, the Single Point-of-Entry strategy holds the best promise of achieving Title IIs goals of holding shareholders, creditors and management of the failed firm accountable for the companys losses and maintaining financial stability at no cost to taxpayers.
Statement of Policy
Informing capital markets, financial institutions, and the public on what to expect if the Orderly Liquidation Authority were to be invoked is an ongoing effort. While the FDIC has already been highly transparent in our planning efforts, we also are currently working on a Statement of Policy which would provide more clarity on the resolution process. We anticipate the release of a proposal for public comment before the end of the year.
In addition, the Federal Reserve, in consultation with the FDIC, is considering the merits of a regulatory requirement that the largest, most complex U.S. banking firms maintain a minimum amount of unsecured debt at the holding company level. Such a requirement would ensure that there are creditors at the holding company level to absorb losses at the failed firm. Questions surrounding a debt requirement are complex and include issues on the amount, seniority structure, and its relation to equity capital.
Cross-border Issues
Advance planning and cross border coordination for the resolution of globally active, systemically important financial institutions (G-SIFIs) will be critical to minimizing disruptions to global financial markets. Recognizing that G-SIFIs create complex international legal and operational concerns, the FDIC is actively reaching out to foreign host regulators to establish frameworks for effective cross-border cooperation and the basis for confidential information-sharing, among other initiatives.
As part of our bilateral efforts, the FDIC and the Bank of England, in conjunction with the prudential regulators in our respective jurisdictions, have been working to develop contingency plans for the failure of G-SIFIs that have operations in both the U.S. and the U.K. Of the 28 G-SIFIs designated by the Financial Stability Board (FSB) of the G-20 countries, four are headquartered in the U.K, and another eight are headquartered in the U.S. Moreover, approximately 70 percent of the reported foreign activities of the eight U.S. G-SIFIs emanates from the U.K. The magnitude of these financial relationships makes the U.S.-U.K. bilateral relationship by far the most significant with regard to the resolution of G-SIFIs. As a result, our two countries have a strong mutual interest in ensuring that, if such an institution should fail, it can be resolved at no cost to taxpayers and without placing the financial system at risk. The FDIC and U.K authorities released a joint paper on resolution strategies in December 2012, reflecting the close working relationship between the two authorities. This joint paper focuses on the application of top-down resolution strategies for a U.S. or a U.K. financial group in a cross-border context and addresses several common considerations to these resolution strategies.
In addition to the close working relationship with the U.K., the FDIC is coordinating with representatives from other European regulatory bodies to discuss issues of mutual interest including the resolution of European G-SIFIs. The FDIC and the European Commission (E.C.) have established a joint Working Group comprised of senior executives from the FDIC and the E.C. The Working Group convenes formally twice a year -- once in Washington, once in Brussels -- with on-going collaboration continuing in between the formal sessions. The first of these formal meetings took place in February 2013. Among the topics discussed at this meeting was the E.C.s proposed Recovery and Resolution Directive, which would establish a framework for dealing with failed and failing financial institutions. The overall authorities outlined in that document have a number of parallels to the SIFI resolution authorities provided here in the U.S. under the Dodd-Frank Act. The next meeting of the Working Group will take place in Brussels later this year.
The FDIC also is engaging with Switzerland, Germany, Japan, and Canada on a bilateral basis. Among other things, the FDIC has further developed its understanding of the Swiss resolution regime for G-SIFIs, including an in-depth examination of the two Swiss-based G-SIFIs with significant operations in the U.S. During the past year, we also have participated in several productive workshops with the Federal Financial Supervisory Authority (BaFin), the German resolution authority. The FDIC anticipates a principals-level meeting with Japan later this year.
To place these working relationships in perspective, the U.S., the U.K., the European Union, Switzerland and Japan account for the home jurisdictions of 27 of the 28 G-SIFIs designated by the Financial Stability Board (FSB) of the G-20 in November 2012. Progress in these cross-border relationships is thus critical to addressing the international dimension of SIFI resolutions.
The Volcker Rule
The Dodd-Frank Act requires the Securities and Exchange Commission (SEC), the Commodities Futures Trading Commission (CFTC), and the federal banking agencies to adopt regulations generally prohibiting proprietary trading and certain acquisitions of interest in hedge funds or private equity funds. The FDIC, jointly with the FRB, OCC, and SEC, published an NPR requesting public comment on a proposed regulation implementing the prohibition against proprietary trading. The CFTC separately approved the issuance of its NPR to implement the Volcker Rule, with a substantially identical proposed rule text.
The proposed rule also requires banking entities with significant covered trading activities to furnish periodic reports with quantitative measurements designed to help differentiate permitted market-making-related activities from prohibited proprietary trading. Under the proposed rule, these requirements contain important exclusions for banking organizations with trading assets and liabilities less than $1 billion, and reduced reporting requirements for organizations with trading assets and liabilities of less than $5 billion. These thresholds are designed to reduce the burden on smaller, less complex banking entities, which generally engage in limited market-making and other trading activities.
The agencies are evaluating a large body of comments on whether the proposed rule represents a balanced and effective approach or whether alternative approaches exist that would provide greater benefits or implement the statutory requirements with fewer costs. The FDIC is committed to developing a final rule that meets the objectives of the statute while preserving the ability of banking entities to perform important underwriting and market-making functions, including the ability to effectively carry out these functions in less-liquid markets. Most community banks do not engage in activities that would be impacted by the proposed rule.
The Dodd-Frank Act and Community Banks
While the Dodd-Frank Act has changed the regulatory framework for the financial services industry, many of the Acts reforms are geared toward larger institutions, as discussed above. At the same time, the Act included a number of provisions that impacted community banks. Of particular relevance to the FDIC, the Act made changes to the deposit insurance system that have specific consequences for community banks.
In the aftermath of the crisis, the Dodd-Frank Act made permanent the increase in the coverage limit to $250,000, a provision generally viewed by community banks as a helpful means to attract deposits.
The FDIC also implemented the Dodd-Frank Act requirement to redefine the base used for deposit insurance assessments as average consolidated total assets minus average tangible equity. As Congress intended, the change in the assessment base shifted some of the overall assessment burden from community banks to the largest institutions, which rely less on domestic deposits for their funding than do smaller institutions. The result was a sharing of the assessment burden that better reflects each group's share of industry assets. Aggregate premiums paid by institutions with less than $10 billion in assets declined by approximately one-third in the second quarter of 2011, primarily due to the assessment base change.
In the aftermath of the financial crisis and recession, as well as the enactment of the Dodd-Frank Act, many community banks had concerns about their continued viability in the U.S. financial system. Prompted by that concern, the FDIC initiated a comprehensive review of the U.S. community banking sector covering 27 years of data and released the FDIC Community Banking Study in December 2012.
Our research confirms the crucial role that community banks play in the U.S. financial system. As defined by the Study, community banks represented 95 percent of all U.S. banking organizations in 2011. These institutions accounted for just 14 percent of the U.S. banking assets, but held 46 percent of all the small loans to businesses and farms made by FDIC-insured institutions. While their share of total deposits has declined over time, community banks still hold the majority of bank deposits in rural and micropolitan counties. 2 The Study showed that in 629 U.S. counties (or almost one-fifth of all U.S. counties), the only banking offices operated by FDIC-insured institutions at year-end 2011 were those operated by community banks. Without community banks, many rural areas, small towns and urban neighborhoods would have little or no physical access to mainstream banking services.
The Study found that community banks that grew prudently and that maintained diversified portfolios or otherwise stuck to their core lending competencies funded by stable core deposits during the Study period exhibited relatively strong and stable performance over time. Institutions that departed from the traditional community bank business model generally underperformed over the long run. These institutions pursued higher-growth strategies frequently through commercial real estate or construction and development lending financed by volatile funding sources. This group encountered severe problems during real estate downturns and characterized the community banks that failed during the aftermath of the crisis.
As the primary federal regulator for the majority of smaller institutions (those with less than $1 billion in total assets), the FDIC is keenly aware of the challenges facing community banks. The FDIC has tailored its supervisory approach to consider the size, complexity, and risk profile of the institutions it oversees. For example, large institutions (those with $10 billion or more in total assets) are generally subject to continuous supervision (targeted reviews throughout the year), while smaller banks are examined periodically (every 12 to 18 months) based on their size and condition. Additionally, the frequency of our examinations of compliance with the Community Reinvestment Act can be extended for smaller, well-managed institutions. Moreover, in Financial Institution Letters issued to the industry to explain regulations and guidance, the FDIC includes a Statement of Applicability to institutions with less than $1 billion in total assets.
In addition to the changes in the Dodd-Frank Act affecting community banks, the FDIC also reviewed its examination, rulemaking, and guidance processes during 2012 as part of our broader review of community banking challenges, with a goal of identifying ways to make the supervisory process more efficient, consistent, and transparent, while maintaining safe and sound banking practices. Based on the review, the FDIC has implemented a number of enhancements to our supervisory and rulemaking processes. First, the FDIC has restructured the pre-exam process to better scope examinations, define expectations, and improve efficiency. Second, the FDIC is taking steps to improve communication with banks under our supervision through the use of web-based tools, regional meetings and outreach. Finally, the FDIC has instituted a number of outreach and technical assistance efforts, including increased direct communication between examinations, increased opportunities to attend training workshops and symposiums, and conference calls and training videos on complex topics of interest to community bankers. The FDIC plans to continue its review of examination and rulemaking processes, and continues to explore new initiatives to provide technical assistance to community banks.
Thank you for the opportunity to share with the Committee the work that the FDIC has been doing to address systemic risk in the aftermath of the financial crisis. I would be glad to respond to your questions. (Attachment)
1 A summary of the FDICs progress implementing the provisions of the Dodd-Frank Act is attached to this testimony.
2 The 3,238 U.S. counties in 2010 included 694 micropolitan counties centered on an urban core with populations between 10,000 and 50,000 people, and 1,376 rural counties with populations less than 10,000 people.
|Last Updated 7/10/2013


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These investigators are studying additional mechanisms (other than insulin/IGF-1) for the metabolic decline with aging. Special efforts are focused on furthering the recent findings of the hypothalamus as regulator not only of food intake and whole body energy balance, but also of glucose metabolism and inflammation. Researchers are studying the central control of food intake (Schwartz, Chua)40,41, and inflammation (Cai)42 with aging, and have collaboratively developed tools to probe the hypothalamus in chronic, unstressed, awake rodents. Increased fat mass and changes in body fat distribution with aging also cause 43 glucose intolerance and systemic inflammation, presumably due to production of pro-inflammatory 'adipokines' from fat tissue. Several other investigators have developed tools to study these changes and the biology of adipose tissue and its role in inflammation (Barzilai, Hawkins, Pessin, Bastie)44-46, and cancer (Augenlicht)47.
Leonard Augenlicht, PhD
Nir Barzilai, MD
Claire Bastie, PhD
Dongsheng Cai, PhD
Streamson C. Chua, Jr., PhD
Meredith Hawkins, MD
Radhika Muzumdar, MD
Jeffrey Pessin, PhD
Gary J. Schwartz, PhD

subset: commoncrawl


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On February 12, 1809, two hundred years ago today, Charles Darwin was born. It's difficult to overstate the impact that his theory of evolution has had over the last 150 years.
The book by which he is best known, Origin of Species (or On the Origin of Species by Means of Natural Selection, or the Preservation of Favoured Races in the Struggle for Life), is available in our Harvard Classics and Fiction Collection (71 Vols.), which is currently on Pre-Pub. If you haven't yet pre-ordered this set, be sure to check it out. It's an incredible value—about $1.41 per volume!
In light of this important day and the impact Darwin has had on the relationship between science and the Christian faith, we put together a Creation and Science Product Guide, which features all of our titles on creation, evolution, and science.
In the product guide you'll find three collections and almost 30 individual titles:
- Hugh Ross / Reasons To Believe Collection (9 Vols.)
- Science & Theology Collection (9 Vols.)
- Day One Creation and Science Collection (10 Vols.)
The titles are written from a variety of perspectives and will help you grapple with the relationship between faith and science. So be sure to check it out and see which ones might be good additions to your library.
By the way, if you purchased the B. B. Warfield Collection (20 Vols.), you might want to read Warfield's article "Charles Darwin's Religious Life: A Sketch in Spiritual Biography" (The Works of Benjamin B. Warfield, Volume 9: Studies in Theology [Bellingham, WA: Logos, 2008], 541-81). It's a fascinating look into Darwin's spiritual journey.


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Good news for those whose heart ached after seeing the heartbreaking photos of the lonely, ginger seal all alone in the desolate, wintry countryside whom nobody wanted: Nafanya has a home. The rare, albino seal now resides in the Akvatoria dolphinarium in Russia, where he has quickly become the star attraction.
Yulia Frolova, head of the dolphinarium (why aren't there more dolphinariums in the US?), spoke to the Daily Mail about the seal's new life:
"She has a good appetite, and always seems in a happy mood. She is such an unusual seal with very beautiful bright blue eyes. When she arrived, she was tired after the long flight, but soon picked up her appetite. 'Nafanya is such a lovely animal and is certainly not afraid of people."
For those who are unable to travel all the way to Russia to see the seal, Nafanya has his own live webcam that you can watch during broadcasts between 7am and 1pm UK time. Hooray for happy endings!
Loneliest seal in the world, shunned by her colony for being ginger, is now the centre of attention at Russian zoo... and loving it [Daily Mail]


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If I don't use a web server in my infotainment system, will I miss out on some features of HTML5?A web server isn't strictly necessary, but there are two very good reasons for including one. First, it lets you export a user interface to devices outside the car, thereby allowing mobile phones or tablets to run apps that are hosted on the vehicle head unit. Second, it lets you export internal car resources, as a URL, to HMI software running in the head unit. For instance, the web server could provide the HMI with access to static vehicle-configuration data (through an xml file) or to a back-up camera (through a video stream).
Will using native code plug-ins compromise my ability to leverage HTML5?This is tricky, because a lot of things you want to do may require native code. So, yes, use native code, but do it judiciously. The more native code you use, the more it will limit the cross-platform capability of the HTML5 code that relies on it. The good news is that with HTML5 gaining so much functionality, plug-ins are needed far less than ever before.
|A sample climate control app from the
QNX CAR 2 platform, created with HTML5.
Would you consider HTML5 as an option for cluster instruments: speedometers, tachometers, etc.?At this point, I'd say no. HTML5 makes a lot of sense for in-vehicle infotainment, but it doesn't provide the response needed for a vehicle cluster and it won't ensure safety-critical certification. Plus, the instrument cluster isn't where you realize a lot of HTML5's value: downloadable apps, connectivity to mobile devices, and so on. If the cluster and the infotainment system eventually merge into one big screen, then it's more likely you could use HTML5 for both — but that's still a few years out.
What's a good way to get responsive display updates (10Hz update) into HTML5? Websockets?If you need to deliver high-speed updates to your head unit, Websockets is one way to go. Make sure, however, that you don't stall the rest of the JavaScript engine while your main thread is blocked on tasks. If you create another thread to monitor for changes, you can do it just as effectively (and probably with less work) with a JNEXT or NPAPI call into native code.


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Two-time defending Big South volleyball champion Liberty opens its 2013 season schedule on Friday against No. 23 Ohio State.
Complete Match Notes Liberty volleyball, two-time defending Big South champion, begins the 2013 campaign at the NIU Invitational in DeKalb, Ill., Friday and Saturday. The Lady Flames face No. 23 Ohio State in the season opener, Friday at 6 p.m. It will mark the first time Liberty has faced a Top 25 team in its volleyball season opener. On Saturday, Liberty meets host Northern Illinois of the MAC, a 21-win program from last season, before closing the weekend with a 6 p.m. match against Horizon League team Green Bay.
Liberty at a Glance Liberty went 25-8 last season, going 12-2 in conference play and winning the Big South regular season title for the sixth straight year. The Lady Flames made their sixth consecutive appearance in the conference final, downing Coastal Carolina to win its second Big South tournament title in a row and fourth in the last six seasons. The team has also posted six straight 20-win campaigns. The Lady Flames return five starters from last year's team, including Big South Player of the Year and Freshman of the Year Caroline Douglas, three-time all-conference setter Jade Craycraft and two-time All-Big South outside hitter Lillie Happel.
How to Follow the Lady Flames Live stats will be available for all of this weekend's matches. Live stats are courtesy of Northern Illinois' athletics media relations office. A live video stream for Liberty's match against NIU will be available, for a small fee, through Huskie All-Access. Fans can also follow the matches through periodic twitter updates from @libertyflames.
Quick Hits - Liberty opens the season against a Top 25 opponent for the first time (No. 23 Ohio State) - The Lady Flames have won 20 or more matches for six straight seasons. - 2012 marked Liberty's sixth straight conference regular-season title - Two-time defending champion Liberty is the preseason favorite in the Big South poll. - Caroline Douglas was named the 2013 Big South Preseason Player of the Year - Five starters, including three all-conference selections, return for the Lady Flames. - 10th-year head coach Shane Pinder is one win shy of 175 for his career. - The Lady Flames open campaign in DeKalb, Ill., for the second time ever (also 2003). - Liberty is 0-1 all-time against Ohio State, 0-2 vs NIU.
Who Else Can Say That? Liberty volleyball has posted six straight 20-win seasons, earned six straight conference regular-season titles and made six consecutive appearances in the conference final (2007-2012). The Lady Flames are the only volleyball team in NCAA Division I about which each of the following three statements is true. Liberty is: - one of four volleyball programs in NCAA Division I to have won or shared their conference or division regular-season championship in each of the last six years. - one of six volleyball programs in NCAA Division I to appear in its conference championship match in each of the last six seasons. - one of 21 volleyball programs in NCAA Division I to win 20 or more matches in each of the last six seasons.
175/700 Shane Pinder, in his 10th season as Liberty's head coach, has compiled a 174-121 career record and ranks fourth in the Big South in career coaching victories. Liberty's next victory will be Pinder's 175th career win and will also be the 700th victory in program history. The Lady Flames have averaged nearly 19 wins per season since the founding of the program in 1976.
Outstanding Outsides Liberty's starting outside hitters, Caroline Douglas and Lillie Happel, have been two of the top hitters in the Big South. Douglas led the league with 454 kills, hitting .281 as a redshirt freshman in 2012. She was named both Freshman of the Year and Player of the Year by the Big South and VaSID All-State, and was voted to the AVCA All-Region honorable mention team. Happel earned Big South All-Conference second-team mention as a junior last year, after making the first team in 2011. She is currently 54 kills away from becoming the 14th player in program history with 1,000 career kills.
Block Party The Lady Flames lost three-time all-conference middle blocker Loren Thomas to graduation. She totaled 477 career blocks, the second most in program history. Returning middle blocker, redshirt senior Kendle Rollins, is ranked eighth all-time at Liberty with 310 blocks. She is 15 blocks away from entering the all-time top 5.
Setting the Tone Senior Jade Craycraft, the 2012 Big South Tournament MVP, is a three-time all-conference setter. She was named to the Big South All-Conference first team in 2012, when she led the team with 1,152 assists and 11 double-doubles. Craycraft guided the Lady Flames to a program-record and conference-best .250 team hitting percentage last year. Craycraft enters the 2013 campaign sixth in program history with 3,305 career assists. A versatile player, she also has a triple-double (2010 at Winthrop) and a 10-block match (2011 at Radford) to her credt while at Liberty.
Dig In Junior libero Gabrielle Shipe finished fourth in the Big South with 510 digs last season, and was twice named the Big South Defensive Player of the Week. She reached double-figures in digs 25 times, including each of the final 13 matches of the season.
Scouting Ohio State No. 23 Ohio State enters the campaign with three returning starters from a team which went 23-11 in 2013 and posted a fourth-place finish in the Big Ten. The Buckeyes have won 20 or more matches and qualified for the NCAA Tournament in each of the last four seasons. Ohio State lost a pair of impact outside hitters to graduation, in two-time All-American Mari Hole and two-time all-region player Emily Danks. 2012 All-Big Ten honorable mention selection Kaitlyn Leary averaged 2.90 kills per set last season. Davionna DiSalvatore led the Buckeyes with 512 digs in 2012, while Anna Faul (0.98 bps) and Andrea Kacsits (0.82 bps) are the team's top two returning blockers. Sixth-year head coach Geoff Carlston is 105-68 at Ohio State, and is 298-132 in a 13-year career which included stops at Ohio (144-22) and Concordia-St. Paul (49-42). Carlston's 15th-ranked Ohio team downed Liberty, 3-0, on Sept. 2, 2006. Ohio State won its only previous meeting against the Lady Flames, 3-0, on Sept. 15, 2000, in Kalamazoo, Mich. Liberty is 0-7 all-time against teams currently in the Big Ten, including setbacks to Penn State and Minnesota in the last two NCAA tournaments. Scouting Northern Illinois Northern Illinois posted a 21-15 record last season, its third 20-win season in a row, while qualifying for the MAC championship match for the third straight campaign. NIU lost a pair of all-conference players, middle blocker Mary Kurisch and libero Amber Walker. Senior middle blocker Sarah Angelos returns as a two-time all-MAC player, while 2012 MAC All-Freshman team setter Alexis Gonzalez dished out 1,376 assists last year. MacKenzie Roddy averaged 3.33 kills and a team-leading 0.33 aces per set last year. 12th-year head coach Ray Gooden has posted a 205-151 record at the helm of Northern Illinois, and won MAC Coach of the Year honors in 2006, 2011 and 2012. The Lady Flames have faced Northern Illinois twice all-time, with the Huskies winning both meetings. NIU defeated Liberty, 3-1, on Aug. 29, 2003 in DeKalb, the Lady Flames' season opener, in which current Liberty assistant coach Jennifer (Belk) Vaden and Rebecca Rudnick both sent down 11 kills. On Sept. 10, 2010, the Huskies beat the Lady Flames, 3-0 in Elon, N.C. Current Liberty seniors Kendle Rollins (redshirt), Jade Craycraft, Lillie Happel and Becca Haraf all started as freshmen in that match.
Scouting Green Bay The Green Bay Phoenix, coming off of a 15-14 campaign in 2012, were predicted to finish sixth in the Horizon League this season. Green Bay will be looking to fill in for departed libero Brittany Groth, a 2012 AVCA All-America selection, and all-conference middle blocker Carmen Leitermann. Senior outside hitter Monica Anderson record 297 kills a year ago, while senior setter Leah Poel is back after leading the team with 1,089 assists in 2012. The Phoenix' top blocker, Katie Mroczenski, finished third in the Horizon League with 128 total blocks last season. Green Bay enters its first year under head coach Michaela Franklin, who replaces longtime head coach Debbie Kirch. Franklin spent the last four years as an assistant coach at Marquette, a team which appeared at the same opening-round NCAA Tournament site as Liberty in 2012, Minneapolis. Liberty and Green Bay will be meeting for the first time. The Lady Flames are 1-4 all-time against members of the Horizon League. Their lone win against a Horizon League opponent came on Sept. 7, 2007, a 3-1 win over Wright State.
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Jrpoulter's Weblog
Just another WordPress.com weblog
Tag Archives: Allen & Unwin
Trends – New bends in the path to publication. By J.R.Poulter
Some time last year, Erica Wagner, Publisher at Allen and Unwin, was reported as having said, in relation to graphic novels, that there was a lot to be gained by submitting a text already illustrated or mostly illustrated [Allen & Unwin publish purely commission only picture books]. Perhaps this may signal a change in direction that may even extend to those other illustrated tomes – picture books and picture book/graphic novel crossovers.
Some writers/illustrators I know have recently signed contracts for 'print ready' books. This is not self-publishing, nor submission to a print-on-demand house but submission to a traditional, royalty paying publisher of a book that is 'ready to go' in publishing terms.
What constitutes a 'print ready' book? It is a book that has been –
- professionally edited,
- proofread,
- designed to industry standards,
- professionally designed cover and,
- if illustrated, has all images appropriately set.
This is a great way to go for authors who are able to pay illustrators and book designers up front. Most authors are not able to do this. This then means all creators involved in a book project agreeing to royalty share and working between paid projects to collaborate on their book.
What have I gleaned about such 'print ready' deals? One company, smaller and reasonably new, offered a small advance and a good contract, by industry standards, with higher than regular royalty share for creators. An offer of help with promotion was also part of the deal. Another company, medium sized and established, offered no advance but better than average royalty shares for creators and help with promotion and marketing of the book.
How does this stack up against what is generally on offer now?
- Small and middle range publishers, in general, do not offer advances.
- Larger publishers offer advances depending on the book, depending on the author, and depending on the agent involved.
- Smaller and middle range publishers often [there are exceptions] expect the author to do it all in relation to promotion, even requiring the submission of a marketing plan.
- Larger publishers vary greatly as to how much promotion they will give a book.
- Generally, publishers will submit copies of their publishing output for major awards, such as the CBCA, and to a selection of leading review outlets.
What's the down side for author, illustrator, book designer, [often the illustrator], to go down the 'print ready' publishing path?
- It IS a lot of extra work for all creators involved to ensure the book is 'professional' standard even before it is submitted.
- There is no money upfront.
Are the rewards worth the effort?
- If you love collaborative work, it is a big plus.
- Creators have much more project control to create the book they have collaboratively envisaged.
- A quality product, 'print ready', is a major bargaining point for creators/agents. 'Print ready' saves the publisher heaps!
The first company mentioned does small print runs, sells out their print runs, reprints and even sells out reprints and so it seems to be gradually snowballing.
It is too early to know in the second instance. [I'll keep you posted!]
My feeling is that, if Erica Wagner was sensing a 'trend' and if these companies make a success of it, we will see more such deals. It's something to think about!
My own news –
To be launched end of June – "Toofs!" a collaboration between J.R. and Estelle A.Poulter and illustrators Monica Rondino and Andrea Pucci.


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By David Joel Miller, MS, Licensed Therapist & Licensed Counselor.
Bipolar or Borderline Personality Disorder?
People with Borderline Personality Disorder (BPD) experience intense emotional pain and lots of loss in their life. They never feel the faint breeze or the warmth of the sun in the springtime. For the Borderline the world is a place of hurricanes and scorching heat. Life is one horrific storm. They experience terrible loss. BPD may result in interrupted education, ruined or unstable relationships and frequent job loss.
BPD can look like Bipolar Disorder but while the Bipolar person may have months of depression and long periods of elevated mood or irritability the BPD person has all those mood changes in a single day.
Borderline Personality Disorder (BPD) is an often overlooked and misunderstood mental health issues that get placed under the heading Personality Disorders. BPD is coded on Axis II and viewed as long-standing and difficult to treat. Personality disorders often co-occur with other mental health challenges such as depression and Bipolar disorder. Because of the notion that a personality disorder is difficult, if not impossible to treat, there is a reluctance to give clients this diagnosis.
Untreated BPD is viewed as a "pervasive" or inflexible pattern in life and includes four characteristics, unstable relationships, fuzzy self-image, impulsivity and lots of negative emotions. The DSM lists 9 "criteria" or symptoms the client might have but only requires 5 of those nine symptoms to make the diagnosis. In practice, this means a lot of judgment calls.
Most people with Borderline Personality Disorder have some but not all of the "criteria" for the disorder. Gunderson suggests in his book that there are three distinct Levels of Borderline Personality Disorder based on the nature of your relationships with others.
Children experience some mood instability as a normal part of growing up. We expect some BPD characteristic that will go away as they mature. As a result, children are almost never given a personality disorder diagnosis. When the BPD picture seems to be developing, the child may be described as having "Borderline traits." Those with untreated BPD generally do not get better with age, the pain they experience grows.
BPD begins in early adulthood and those "characteristics" or "traits" need to occur in multiple situations. This disorder, when treated, generally fades as the person gets older. Women make up 75% of those who get BPD diagnosis and frequently had a diagnosis of Bipolar Disorder prior to being diagnosed with BPD. This disorder is probably underdiagnosed in men because men act out, break laws and get caught abusing substances more often than women. These other problems get diagnosed first and become the focus of treatment.
Treatment for Borderline Personality Disorder is effective in reducing symptoms. Ten years after treatment half of those diagnosed with BPD no longer have enough symptoms to receive the diagnosis though they may continue to have some Borderline "traits."
There appear to be a number of Causes of Borderline Personality Disorder. Some of the symptoms of BPD are adaptive behaviors that may have worked to protect you and get your needs met when you were younger but as you grow up these behaviors no longer work.
Abandonment is a key issue for those with BPD. They need someone in their life and can't stand being alone but fear being rejected and abandoned. They are constantly on the lookout for signs of potential abandonment. As a result, they may appear needy and drive people away. Their impulsive behavior creates exactly what they most fear.
Someone with BPD is very sensitive to their environment. When things do not go well in relationships they blame themselves and may "take it out" on themselves. Self-mutilating, cutting, burning, and suicide attempts are common.
Because of their terrible need for a supportive relationship BPD individuals tend to jump into very close intimate relationships without getting to know the other person. As a result, they over-trust people who should not be trusted and expect more from partners than another person can provide. Once disappointed they become furiously angry. They are often demanding in relationships and need lots of time with their partner. They may have violent emotional reactions when their partner attempts to leave for work, school or errands.
Sudden changes in their opinions of others are common. When let down by those in their life they respond with lots of anger, sarcasm, and bitterness which only drives others farther away.
Many individuals with BPD report they don't know who they are other than by adopting the values of those around them. They may have sudden changes or difficulty identifying values, goals or career plans. They often self-sabotage. It is not uncommon for someone with BPD to quit school just before finals or leave a job just as they were about to get a raise or promotion.
Living with Borderline Personality Disorder is a horrific challenge for those with this condition and it challenges those who would like to be in a relationship with the person with a Borderline condition. While treatment is never easy it can be effective and result in creating a happy, fulfilled and connected life.
Other posts on Borderline Personality Disorder include:
What is Borderline Personality Disorder?
What causes Borderline Personality Disorder?
Levels or types of Borderline Personality Disorder
Treatment for Borderline Personality Disorder
Staying connected with David Joel Miller
Three David Joel Miller Books are available now!
Bumps on the Road of Life. Whether you struggle with anxiety, depression, low motivation, or addiction, you can recover. Bumps on the Road of Life is the story of how people get off track and how to get your life out of the ditch.
Casino Robbery is a novel about a man with PTSD who must cope with his symptoms to solve a mystery and create a new life.
Sasquatch. Wandering through a hole in time, they encounter Sasquatch. Can they survive? The guests had come to Meditation Mountain to find themselves. Trapped in the Menhirs during a sudden desert storm, two guests move through a porthole in time and encounter long extinct monsters. They want to get back to their own time, but the Sasquatch intends to kill them.
For these and my upcoming books; please visit my Author Page – David Joel Miller
Books are now available on Amazon, Kobo, iBooks, Barnes & Noble, and many other online stores.
Want the latest blog posts as they publish? Subscribe to this blog.
Want the latest on news from recoveryland, the field of counseling, my writing projects, speaking and teaching? Please sign up for my newsletter at – Newsletter. I promise not to share your email or to send you spam, and you can unsubscribe at any time.
For more about David Joel Miller and my work in the areas of mental health, substance abuse, and Co-occurring disorders see my Facebook author's page, davidjoelmillerwriter. If you are in the Fresno California area, information about my private practice is at counselorfresno.com.


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Men's Timberland 6 Inch Premium Classic Boots On Sale !!!
Men's Timberland 6 Inch Premium Classic Boots - 10061 WHE | Finish Line Information
FinishLine.com Features & Description
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The reduced weight and exclusive anti-fatigue technology help absorb shock so your feet won't feel like you've been standing all day, even if you have. Premium leather offers abrasion resistance and comfort, while waterproof construction keeps whatever is on the outside out. The toe box and forefoot is lined with moisture-wicking, breathable fabric so your feet remain dry. The rubber lug outsole provides superior traction, and rustproof hardware offers durability.
Sealed to keep water out and comfort in, these waterproof leather boots are sure to keep your feet happy. The climate control lining wicks away moisture while the durable lug rubber outsole can stand up to all types of terrain. These boots aren't all about function though, they also have a classic signature style that you'll reach for again and again.
- UPPER: Waterproof nubuck and leather
- MIDSOLE: Climate control lining
- OUTSOLE: Lug rubber
- Original Boot. New Guts. Lighter than ever! The Timberland 6 inch Premium Boot is the boot that got things started for Timberland nearly forty years ago. Now updated with exclusive anti-fatigue technology helps absorb shock.


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The mission of the Stalking Resource Center is to enhance the ability of professionals, organizations, and systems to effectively respond to stalking.
Welcome to our Information Clearinghouse. It provides a wide range of useful information for practitioners. Materials include: research on stalking, practitioner-specific educational tools, mutlidisiciplinary curricula, model protocols and more. If you are looking for state and/or federal stalking legislation, please visit stalking laws.
Our Information Clearinghouse Index is searchable by any of the categories provided (jurisdiction, focus, type, format). However, we suggest that you search broadly first, starting with one category, and narrow down your search if it yields an overwhelming number of matches.
The Stalking Resource Center does not claim authorship of the materials contained in the Information Clearinghouse, unless so specified. For permission to use materials in any way other than that expressly permitted by law, please contact the author/producer.
2011© National Center for Victims of Crime. All Rights Reserved.
P.O. Box 101207, Arlington, VA 22210
p.202-467-8700 | f.202-467-8701 | [email protected]
Return to the National Center


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Michele Bachmann might actually be the worst human being in the world.
Bachmann is locked in a tight race for reelection, judging by both her poll numbers and the increasingly desperate emails her campaign keeps sending me (BILL CLINTON ATTACKS! was yesterday's). So, in her bid to be moderate, she's decided that sure, life begins at conception, but women who are getting IVF treatments can go ahead and keep getting IVF treatments the regular way, but rape victims get no such exception. If you're raped and you get pregnant, sorry, but that violent insemination is precious, and you must give birth to it. Thank goodness Minnesota has Michele Bachmann to bravely stand as a defender of all penis-induced pregnancies.
Twin Cities area rapper and writer Dessa had some harsh but graceful words for Bachmann, not that the Congresswoman will pay her any attention.
But then, some painfully brilliant real talk:
Don't you hate it when the truth feels like a punch in the stomach?
-Erin Ryan


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I am really intrigued by the latest creation from the Department of Health and Human Services (HHS). Last week, HHS announced a contract to set up a group of experts to identify and attempt to fix any "undesirable" and "potentially harmful unintended consequences" that result from the stimulus legislation's EHR incentives. According to the announcement, which was posted on the Federal Business Opportunities website: "Historical experience, as well as mounting evidence of unexpected problems, demands that we consider potential downsides."
My curiosity is piqued! What are the unexpected consequences the government anticipates, and why is HHS so concerned? Awaiting the report from the panel of experts, I started thinking—and it didn't take me long to create a list of my own.
My top three unintended consequences are the following: (If you'd like to suggest other potential unanticipated consequences—positive or negative—please submit a comment at the bottom of this page.)
- There will be more EHR failures than successes, particularly among high-performance specialists.
- "Certification" will stifle innovation.
- Productivity and physician-focused EHRs will lead the market among high-performance physicians.
More EHR Failures:
After an initial peak in implementations, long-term EHR adoption will slow—particularly among high-performance specialists—and the current failure rate will escalate. Many factors will contribute to this: (1) Some physicians will rush into EHR purchases without conducting proper due diligence. (2) Products that were overly complex and did not work in busy specialists' practices in the past will surely not succeed now, particularly since these same products must now be used in an even more structured and demanding way. (3) Sorely needed implementation and training will be provided by inexperienced and rushed implementation teams, further reducing the likelihood of success with providers, many of whom are less technologically savvy than the early adopters. (4) Where there was never a convincing economic justification in the past, the addition of data-collection requirements will further lessen the economic feasibility of traditional, point-and-click EHRs. (5) Physicians will try to transfer data entry tasks to scribes and other lower-cost employees (assuming that the regulations allow CPOE to be done by other than the ordering provider), but this strategy will not make economic sense, either, since the additional costs will outweigh the government incentives. The result? The high failure rate will leave physicians "holding the bag" after investing large sums of money, failing to earn the anticipated incentives, and owning a system that doesn't meet their needs.
"Certification" will stifle innovation:
Innovation will suffer, as it did in the past when many EHR vendors devoted all their development resources to complying with the long list of CCHIT-certification requirements. Forcing all vendors seeking certification to meet the same criteria will surely sap the drive for innovation. As vendors burn through precious development resources to meet evolving government standards instead of improving their core product, they will fail to respond to the interests of their customers, i.e., the physicians. Sales and marketing will drive physicians' choices, rather than the EHR products themselves. Large companies, which have the largest sales organizations and marketing budgets, will be successful in the short term. Smaller vendors who follow the herd instead of their entrepreneurial and innovative instincts will be driven out of the market.
Productivity and physician-focused EHRs will lead the market:
The good news is that innovation will triumph in the end. Alternative solutions—like the hybrid EMR—will prevail as high-performance physicians find success with products that focus on their needs and enhance their productivity. It will take 4 to 5 years for physicians who have experienced government-program EHR failures to reapproach the market after amortizing their losses. These physicians will seek products that focus on clinical-workflow efficiency and physician productivity. The long-term winners in the EHR market will be those vendors who resist the temptation to chase the "windfall" stemming from the stimulus legislation, and instead focus on improving their products to deliver these benefits.
Please share your thoughts on other possible unintended consequences by submitting a comment below.


text: Summer get-togethers are all the more glam when you invite this darling 2 piece bikini along for the fun. Because Sun, sand and glam is all a fashionista like you needs for a good time! The features for this two-piece swimsuit includes a strapless bandeau top with a large bow accent and back tie closure, chevron pattern throughout, and finished with a matching high waist bottoms. Style: swimsuit-twopiece-ami-hwbowchevwht This item is FINAL SALE and is not eligible for return or exchanges.


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The winter days can be long, cold and dreary, but we've got something to engage your mind – great books. Nothing beats cozying up by the fire or under a blanket with a good book to pass a chilly winter's day. Whether it's romance, adventure, poetry or drama, there's something for everyone in the land of books. Based on what Blue Mountain Facebook Friends say they're reading these days, here are just a few suggestions to get you into the reading spirit!
MAKING ROUNDS WITH OSCAR: THE EXTRAORDINARY GIFT OF AN ORDINARY CAT by David Dosa – published in 2010.
Oscar, a therapy cat born in 2005, became known for his uncanny ability to predict death in a Rhode Island Nursing and Rehabilitation facility. Called everything from an "amazing cat" to a "harbinger of death", Oscar has predicted approximately 50 deaths by curling up to certain terminal patients just before their expiration. The "early warning system" brings both a heads-up and comfort to the families of the patients, and a curiosity about his abilities to the world.
THE HELP by Kathryn Stockett – published in 2009.
Recent college-graduate Eugenia Skeeter Phelan is anxious to become a writer, and is encouraged to write about things that disturb her. A social activist in the making, she collects the stories of the black women on whom the country club sets both relies and mistrusts. Aibileen (a maid) and Minny (Aibileen's best friend) provide Skeeter with their scathing and shocking stories, bringing pride and optimism to the black community, while giving Skeeter the bravery to conquer her personal limitations and accomplish her goals.
THE SHACK by William P. Young – published in 2007.
Mackenzie "Mack" Allen Philips' youngest daughter, Missy, is abducted while on an Oregon family vacation. An abandoned shack is the only thing that provides any clues, and the evidence says that she may have been brutally murdered. Four years later, Mack receives a suspicious note (supposedly from God) that invites him back to that shack for a weekend. The revelation that he gets will astound and transform him, and possibly you, the Reader.
THE HEART MENDER: A STORY OF SECOND CHANCES by Andy Andrews – published in 2010.
While digging up a withering wax myrtle tree beside his waterfront home on the Gulf coast, author Andy Andrews unearths a rusted metal container filled with Nazi artifacts and begins an intriguing investigation that unlocks an unspoken past that took place in his backyard… literally. Set in a period simmering with anger and suspicion The Heart Mender offers the very real chronicle of a small town preparing itself for the worst the world has to offer.
WHAT SOUTHERN WOMEN KNOW (THAT EVERY WOMAN SHOULD): Timeless Secrets to Get Everything you Want in Love, Life, and Work by Ronda Rich – published in 2000.
Rich explains the mystique of Southern women and why they always get what they want. She also shows women how to achieve the same kind of personal and professional success by retaining their femininity and respect for tradition, choosing their battles carefully, and being courteous and positive.
"Reading her book is like watching a hilarious episode of the sitcom Designing Women."-The Tennessean (Nashville)"
EAT, PRAY, LOVE by Elizabeth Gilbert – published in 2006.
32-year-old Elizabeth Gilbert had a successful life, but is unhappy in her marriage. An affair followed by a divorce leads her on an introspective journey to Italy, India and Bali to "eat", "pray" and "love" her way back into a centered, happy life.
What books are you recommending to friends these days?


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THE SPORTS DOCTOR- Cubs contaminated: Fear and self-loathing in Chicago
Last week when Chicago Cubs' manager Lou Piniella announced his intent to retire at the end of this season, my first thought wasn't "The job had better go to Ryne Sandberg," or "Please don't let it be Tony La Russa," but rather, "Save yourself, Lou." As a Cubs fan, it is my wont to always think of next year and pray it will be better than this one, but I'm not doing that. This year I'm just trying not to walk away.
Last Saturday, a column about Sweet Lou's retirement appeared in the Chicago Sun-Times. It referenced Whitey Hertzog, Hall of Fame MLB manager. Hertzog coached the Rangers, the Angels, the Royals and the Cardinals– in Kansas City he won three straight AL Western division titles from 1976 to 1978 and in St. Louis he won the 1982 World Series and the'85 and '87 NL Pennant. When he retired from coaching in 1990 after 36 years in the MLB, everyone was shocked, but baseball had become a bitter pill Hertzog could no longer swallow.
Chris De Luca, who wrote the column for the Sun-Times, didn't come out and say Piniella's impetus for retiring is the same as was Hertzog's, but one only need read Hertzog's farewell to get the picture.
"I just can't get the guys to play," Hertzog said. "I was bewildered a little bit. I just can't believe that we can have players that as a team are playing as bad as they have.... I've never been through a situation like this. The effort is there... but sometimes I don't know if their minds are there."
Amen to that, brother.
There's a bit of dispute over who coined the phrase "every country has the government it deserves," but most attribute it to 18th century French diplomat and philosopher Joseph Marie de Maistre (I shudder to think all France did to deserve Robespierre). You can go ahead and ascribe "every ball club gets the players it deserves" to me.
From the bat boy to Chairman Tom Ricketts, with only a few exceptions (mostly in the minor league department), the Chicago Cubs organization is in serious trouble. Most fans are happy to blame the Cubs' woes on general manager Jim Hendry and the person who decided to replace the organ with taped music when introducing batters, but the epic misery that calls Wrigley Field home is a new and insidious poison.
The Cubs are, and for the most part have always been, terrible, and even when they win, they lose (see 1998, 2003, 2007, 2008). The team has always fallen back on the same excuses: bad luck, no money, a goat, etc., but this year is different, and no curse is to blame.
It's not the pathetic averages, though there are plenty; it's not the errors, although there are plenty of those, too. It's not the temper tantrums, the horrible pitching, or the terrible-looking swings. But these are mere symptoms of an ugly truth: the Cubs hate themselves.
It's no joke. Just two years ago the Cubs were repeat NLC champions, owned by the Tribune Company, boasted their first no-hitter in 36 years and had amassed a truly promising infield. In 2009, the Cubs saw new ownership, a gutted infield, a hostile outfield and no championship. This year the Cubs are well under .500, their best pitcher is a step away from a sanitarium, and the team's worst performers aren't the new guys, but the players who won the division title just two years ago.
It may seem indulgent to write about the Cubs when there is so much else that warrants attention (the NFL's backpeddling on helmet safety and whether ACC athletes were ever improperly compensated) but it isn't. When GM Jim Hendry (whom the Ricketts are keeping, by the way) dismantled the 2008 team, and the Ricketts made it known they valued ego more than performance, they broke players' spirits and left a shell of a beloved and storied franchise.
Piniella is retiring because, like Hertzog, he can't get his guys to play, but it isn't their minds that aren't in it; it's their hearts. I hope Lou can salvage what's left of his.
Juanita Giles lives in Keysville where she makes videos and updates her Sports Doctor site.


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text: Sian Ka'an is a biosphere reserve in the town of Tulum, Quintana Roo, Mexico. It became a UNESCO UNESCOs verdensarvliste in 1987. Part of the reserve is on land and part is in the Caribbean Sea, including a section of coral reef. The reserve offers protection for the endangered species in the Riviera Maya and provides environmental education to the local communities to assist and train the residents working with ecotourism.


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Thank you Esther Sasson! Esther lives in Israel and shared pictures of two beautiful Hanukka parties that she created. Esther plans parties and dessert buffets in Israel. She also creates beautiful flower arrangements such as the menorah centerpiece below. You can contact Esther at email@example.com.
"Hi Marlene,
These pictures were taken in Israel at a Hanuka party that I made for my husband's students and their wives.
In the first pictures I made an olive themed party. I set out all different types of marinated olives. For the centerpiece of the main table I made a menorah out of glass squares built on top of a long glass sheet. The cups are filled with olive oil and can actually be lit with floating wicks. Under the menorah I put a small jug of olive oil pouring into a square of olives.
On the buffet tables I just put pretty, purple, brown, and green artificial flower arrangements, that I made, with pretty olive trifles.
The blue party pictures were a party that I made for the Syrian women of Israel. I just took mirrored trays and set them with all different types of desserts. The menorah centerpiece in the middle was built out of long goblets filled with blue marbles. On top of the goblets I put small cups of blue water with tea lights in them. On the table itself I put all kinds of blue Hanuka knick knacks like marbles, candles, coins, and dreidels.
That's basically what I did in a nut shell. If you have any more questions, I'd be happy to answer.
Good luck, Esther"
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- An Easy and Elegant Hanukkah Table by Yvette Kassin (thejewishhostess.com)
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The Look Here! Project sought to develop a community of expertise in the creation, management, and use of digitised library, museum, and archive collections for learning, teaching, and research in the creative arts.
The project was led by the Visual Arts Data Service at the University for the Creative Arts in collaboration with nine partners from the Arts University College at Bournemouth, Bradford College, Norwich University College of the Arts, Royal School of Needlework, University College Falmouth, University for the Creative Arts, University of Brighton, University of the Arts London, and University of Southampton.
Funded as part of the JISC e-Content Programme, the project sought to develop skills and strategies to support digitisation in the partner institutions and the wider arts education sector. The project is running from October 2009 to February 2011.
You can browse the outputs of the project in the left hand menu. We are continuing to add further digital collections on a regular basis, for further details see collections.


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27 Million... That is the number of victims of human trafficking worldwide. Let that number sink in....27 million and we are in the 21st century. Its a sad but very true fact and it is happening here in the USA and all over the globe. Women are being sold into sex slavery every day. We need to do something to help!
There are many great organizations dedicated to stopping this horrendous crime. One of these organizations is the A21 Campaign headed by Christine Caine. On October 21st the A21 Campaign is asking everyone to wear a key necklace to promote Key2Free, a way to show awareness and help end human trafficking.
Please watch the following video for more information:


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A tweet sent out on Texas Agriculture Commissioner Sid Miller's Twitter account referred to Democratic presidential candidate Hillary Clinton as a sexually explicit, derogatory term for women.
NBC 5 political reporter Julie Fine reached out to Miller, who said the tweet was a retweet sent by a staffer that was later removed after someone realized what it said.
"Someone from my campaign retweeted it without reading it closely enough, and did not catch the derogatory term. Right when we found out we took it down," Miller told NBC 5.
The latest news from around North Texas.
The tweet referenced a Pennsylvania Auto Alliance poll showing Republican candidate Donald Trump receiving support from 44 percent of voters and Clinton, refered to as "c---" in the tweet, earning 43 percent support. "Go Trump Go!" the tweet said.
Miller later tweeted an apology for anyone who saw the tweet and added that he found the term "vulgar and offensive."
Gov. Greg Abbott, a fellow Republican, released a statement in response to Miller's tweet: "The language is reprehensible and is an embarrassment. No true Texas gentleman would ever talk this way."
On his Twitter page Miller describes himself not only as the 12th Agriculture Commissioner of Texas, but also as a "deplorable" -- a description Clinton made when describing some of Trump's supporters.
Miller, of Stephenville, has been the state's agriculture commissioner since 2014.
NBC 5's Julie Fine contributed to this report.