text: unaccountable, unchecked Director not only departs from settled historical practice, but also poses a far greater risk of arbitrary decisionmaking and abuse of power, and a far greater threat to individual liberty, than does a multi-member independent agency." See 2016 WL 5898801, at *4. The court also noted the "enormous power" the Director holds "over American businesses, American consumers, and the overall U.S. economy," as he "unilaterally enforces 19 federal consumer protection statutes, covering everything from home finance to student loans to credit cards to banking practices." See id. at *2. PHH argued for the shut-down of the CFPB as well as the invalidation of the Dodd-Frank Act. The court, however, opted for a narrower remedy and decided to sever the unconstitutional for-cause provision from the statute which would allow the President to remove the Director at will. With this approach, the CFPB could continue its day-to-day operations. The court then addressed PHH's challenge to the CFPB's $109 million penalty. First, PHH argued that the CFPB incorrectly interpreted Section 8 of the Real Estate Settlement Procedures Act ("RESPA") to bar captive reinsurance arrangements involving mortgage companies. The court agreed with PHH, finding that Section 8 of RESPA allows captive reinsurance arrangements as long as the amount paid by the mortgage insurer for the reinsurance does not exceed the reasonable market value. Second, PHH argued that the CFPB denied it due process by retroactively applying its interpretation of the statute against PHH. The court agreed with PHH on this point as well, finding that captive reinsurance arrangements were lawful prior to the CFPB's recent interpretation of Regulation X. Applying "fundamental anti-retroactivity principles [as] Rule of Law 101," the court held that The Dodd-Frank Wall Street Reform and Consumer Protection Act was enacted as a measure to promote financial stability and protection for consumers through increased regulation of nearly every aspect of the consumer finance industry. In the years since its enactment, the Dodd-Frank Act has led to significant industry reforms and the promulgation of numerous new laws and regulations. In an effort to stay apprised of these significant industry changes, Burr & Forman's Dodd-Frank Newsletter will serve as a periodic update of recent case law, news, and developments related to the Dodd-Frank Act. ---- RECENT CASES ---- CFPB Involvement in Litigation PHH Corp. v. Consumer Financial Protection Bureau, -- F.3d ---, 2016 WL 5898801 (D.C. Cir. Oct. 11, 2016). In a landmark decision, the U.S. Court of Appeals for the D.C. Circuit recently held that the CFPB's single-director structure violates Article II of the U.S. Constitution, which provides that the President alone has the authority to "take Care that the Laws be faithfully executed." With this ruling the court reversed a $109 million penalty the CFPB imposed on PHH. The court first addressed the CFPB's structure. In the Dodd-Frank Act, Congress established the CFPB, an independent agency headed not by a multi-member commission but a single Director who is removable only for cause. As such, the court said that this Director holds more unilateral authority than any single commissioner or board member than any other independent agency in the U.S. Government, and "[t]he CFPB's concentration of enormous executive power in a single, October 2016 RESPA Cole v. JPMorgan Chase Bank, N.A., No. 2:15-cv- 2634, 2016 WL 4491731 (S.D. Ohio Aug. 25, 2016). Plaintiff Andrew Cole filed suit against JPMorgan Chase Bank, N.A. ("Chase") alleging violations of RESPA, 12 U.S.C. § 2605. The court dismissed Plaintiff's complaint because Plaintiff lacked standing to assert claims that should have been brought before he filed Chapter 13 bankruptcy. The court allowed Plaintiff to amend his complaint to assert claims accruing after the date of his bankruptcy filing. Chase moved to dismiss Plaintiff's amended complaint. Plaintiff's RESPA claim was based on the allegation that Chase maintained a website in violation of 12 C.F.R. § 1024.35(c) and that Chase failed to respond properly to Plaintiff's qualified written request ("QWR"). With respect to Chase's website, Plaintiff argued that all of Chase's websites did not include the designated address to which borrowers should send QWRs. In response, Chase asserted that it provided the designated address in a letter sent to Plaintiff and on at least one of its websites. The court looked to the plain language of 12 C.F.R. § 1024.35(c), which provides that "[a] servicer that designates an address for receipt of notices of error must post the designated address on any Web site maintained by the servicer if the Web site lists any contact address for the servicer." See 12 C.F.R. § 1024.35(c). Because the regulations require servicers to include the designated address on "any" website, the court held that Plaintiff stated a claim for relief by alleging that Chase failed to include the designated address on certain websites. Turning to Plaintiff's claim that Chase did not respond properly to his QWRs, the court first addressed Chase's argument that Plaintiff's letters were not QWRs and, therefore, Chase had no duty to respond under RESPA. Chase argued that pursuant to 12 U.S.C. § 2605(e)(1)(A), RESPA imposed a duty to respond to a QWR that concerns loan servicing. In support of this argument, Chase 2 DODD-FRANK NEWS the CFPB violated PHH's due process rights by retroactively applying its changed interpretation of Regulation X and imposing a $109 million penalty. See 2016 WL 5898801, at *35. Finally, the court held that RESPA's three-year statute of limitations applies to CFPB enforcement actions, including administrative actions to enforce Section 8. With this holding, the court rejected the CFPB's argument that the Dodd-Frank Act as a whole does not impose any statute of limitations on CFPB enforcement actions brought in an administrative proceeding. Accordingly, the court vacated the $109 million penalty and remanded the case for further proceedings. Robins v. Spokeo, Inc., No. 11-56843 (9th Cir. July 11, 2016). In May 2016, the U.S. Supreme Court held that alleging a "bare procedural violation" of the Fair Credit Reporting Act ("FCRA") is insufficient to establish Article III standing. The Court remanded the case to the Ninth Circuit to determine whether Robins' alleged claims were sufficient to meet the concreteness standard. The CFPB filed an amicus brief urging the Ninth Circuit to find that Robins alleged dissemination of an inaccurate consumer report is a concrete injury under Article III. In support of its argument, the CFPB said that intangible injuries can be concrete. Additionally, the CFPB argued that by enacting the FCRA, Congress identified the dissemination of an inaccurate consumer report as an intangible injury and the court should rely on Congress' judgment as "instructive and important." The CFPB analogized the intangible harm protected by the FCRA to the intangible harm protected under a defamation claim. Both the FCRA and defamation, according to the CFPB, created a cause of action to prevented risk of future harm and did not require a showing of actual damages. As such, traditional principals of defamation law supported a conclusion that dissemination of an inaccurate consumer report was concrete and could therefore satisfy Article III's requirements. QWR and Plaintiff sufficiently alleged a violation of RESPA. Accordingly, the court denied Chase's motion to dismiss. Joussett v. Bank of America, N.A., No. 15-6318, 2016 WL 5848845 (E.D. Pa. Oct. 6, 2016). Plaintiff Jayme Joussett filed suit against Bank of America, N.A., Roundpoint Loan Servicing Corp., and Newlands Asset Holding Trust, alleging violations of §§ 1024.36, 1024.38, 1024.40 and 1024.41 of Regulation X of RESPA. Defendants moved to dismiss Plaintiff's complaint. Section 1024.36(d) requires a servicer to respond to a borrower's request for information within thirty days. Specifically, the servicer must respond by providing the borrower with the requested information, or by conducting a reasonable search for the requested information and by informing the borrower in writing that the requested information is not available. See 12 C.F.R. § 1024.36(d). The requirements set forth in § 1024.36(d) apply to qualified written requests, but the court found that, pursuant to the CFPB's regulations, which are broader than the language of RESPA, such requests are not limited to information relating to the servicing of the loan. However, the court found that Plaintiff failed to allege sufficiently that: (1) the defendant is a loan servicer; (2) the plaintiff sent the defendant a valid request under § 1024.36; (3) the defendant failed adequately to respond within the statutory period; and (4) the plaintiff is entitled to actual or statutory damages. Rather than sending requests for information, Plaintiff sent requests for a loan modification. Accordingly, the court declined to find that Plaintiff stated a claim under § 1024.36(d). Turning to Plaintiff's claim that defendants violated §§ 1024.38 and 1024.40, the court acknowledged that § 1024.38 requires servicers to maintain certain pro-borrower policies and procedures. In turn, § 1024.40 requires servicers to be reasonably accessible to borrowers. The court easily dismissed these claims finding that pursuant to its rulemaking authority granted by the Dodd-Frank Act, the CFPB did not create a private right of action under § 1024.38. relied on Martini v. JPMorgan Chase Bank, N.A., No. 15-1423, 2015 WL 8479633, at *5 (6th Cir. Dec. 10, 2015) and Medrano v. Flagstar Bank, FSB, 704 F.3d 661, 667 (9th Cir. 2012), which held that the subject letters were not QWRs because they did not address loan servicing. The court pointed out that the letters at issue in Martini and Medrano were sent before the effective date of Regulation X and Plaintiff's claims arose under § 2605(k), which were part of the Dodd-Frank amendments to RESPA and went into effect on January 10, 2014. Applying the new regulatory guidelines to Plaintiff's claims, the court noted that 12 C.F.R. § 1024.35(a) defines a QWR as "a qualified written request that asserts an error relating to the servicing of a mortgage is a notice of error for the purposes of this section, and a servicer must comply with the requirements applicable to a notice of error with respect to such qualified written request," and a "notice of error" encompasses a written notice from the borrower that, among other things, "asserts the error the borrower believes has occurred with respect to the borrower's mortgage loan." See 12 C.F.R. § 1024.35(a). The court also looked to the CFPB's Official Interpretation of the rule, which cautions servicers not to rely on the borrower's description of a submission when determining whether a request constitutes a QWR and provides that a "[QWR] is just one form that written notice of error or information request may take. Thus, the error resolution and information request requirements in §§ 1024.35 and 1024.36 apply as set forth in those sections irrespective of whether the servicer received a qualified written request." See Consumer Financial Protection Bureau, Mortg. Servicing Regulation X Final Rule – Interpretations, available at http://files. consumerfinance.gov/f/201301_cfpb_final-rule_ servicing-respa-interpretations.pdf. Further, Regulation X defines the "scope of error" to include errors that address the failure to provide accurate information to a borrower regarding loss mitigation. See 12 C.F.R. § 1024.35(b)(7). Under the new regulatory scheme implemented under the Dodd-Frank Act, the court found that Plaintiff's letters, which addressed errors in the evaluation of his loss mitigation application, constituted a 3 DODD-FRANK NEWS The court first addressed Santander's motions for summary judgment. With respect to liability under the TCPA, the parties agreed that any potential liability turned on whether Santander obtained the plaintiffs' consent to call the cell numbers at issue. Levins claimed that Santander called her cell phone numbers, one of which was provided on her credit application. Finding the undisputed facts showed Santander obtained consent to call, the court easily granted Santander's motion for summary judgment as it related to the cell number provided on Levins' credit application. With respect to one of the remaining cell numbers, Levins pointed to Santander's activity notes and argued there was an "utter lack of clarity" on the issue of consent. Drawing all reasonable inferences in favor of Levins, the court determined that a question of fact remained as to whether Levins provided consent. Turning to Levins' motion for class certification, the court noted that Fed. R. Civ. P. 23 required Levins to show (1) numerosity; (2) commonality; (3) typicality; and (4) adequacy of representation, as well as show "that the question of law or fact common to class members predominate over any questions affecting only individual members, and that a class action is superior to other available methods for fairly and efficiently adjudicating the controversy" pursuant to Fed. R. Civ. P. 23(b)(3). Levins sought to certify a class of all individuals who were called on a cell number that was not provided at origination, was not provided orally or in writing before Santander's first call as reflected in Santander's records, and was not verified before being called as reflected in Santander's records. Levins' proposed subclass consisted of those individuals whose cell number was captured through calls made to Santander's IVR system by its identification as such in Santander's records. According to Levins, the class could be determined by analyzing Santander's records. Finding that Levins could not have her cake and eat it too, the court first addressed the ascertainability and numerosity requirements, pointing out that Levins based her motion for class certification on Santander's activity notes, which were the very 4 DODD-FRANK NEWS Finally, the court addressed Plaintiff's claim that defendants violated § 1024.41 of Regulation X. Section 1024.41 requires a servicer to first determine whether a loss mitigation application is complete. If the application is received at least forty-five days before a foreclosure sale, then the servicer must acknowledge receipt within five days and inform the borrower whether the application is complete or advise them which documents are still needed. If the application is received at least thirty-seven days before a foreclosure sale, the servicer must evaluate the loss mitigation application within thirty days and notify the borrower. This provision also requires servicers to use reasonable diligence in obtaining documents required to evaluate loss mitigation applications. Section 1024.41 also prevents a servicer from moving for foreclosure judgment or conducting a sale if foreclosure proceedings have commenced but an application becomes complete within thirty-seven days before the sale. The court found that Plaintiff failed to allege that he submitted a timely loss mitigation application and, therefore, the requirements set forth in § 1024.41 were not triggered. As a result, the court dismissed Plaintiff's § 1024.41 claim. TCPA Class Actions Espejo v. Santander Consumer USA Inc., No. 11 C 8987, 2016 WL 6037625 (N.D. Ill. Oct. 14, 2016) and Levins v. Santander Consumer USA Inc., No. 12 C 9431, 2016 WL 6037 (N.D. Ill. Oct. 14, 2016). In the consolidated cases Espejo v. Santander Consumer USA Inc., No. 11 C 8987, 2016 WL 6037625 (N.D. Ill. Oct. 14, 2016) and Levins v. Santander Consumer USA Inc., No. 12 C 9431, 2016 WL 6037 (N.D. Ill. Oct. 14, 2016), the U.S. District Court for the Northern District of Illinois denied Plaintiff Faye Levins' motion to certify a class pursuant Fed. R. Civ. P. 23(b)(3), finding that Levins failed to meet the prerequisites for class certification. While the court denied Levins' motion for class certification, it granted in part and denied in part Santander Consumer USA Inc.'s ("Santander") motion for summary judgment on Levins' Telephone Consumer Protection Act ("TCPA") claims. records she challenged as having an "utter lack of clarity" in her response to Santander's motion for summary judgment. Because Levins challenged the "content, clarity, accuracy, and completeness" of the records upon which her class certification was based, the court found that Levins' proposed class definition was unascertainable. Similarly, Levins could not identify a group of any individuals who met her class definition and attempted to rely on Santander's activity notes to determine class members. Levins argued that her proposed class was "fail-safe" because it was defined so that whether the person qualifies as a member depends on whether the person has a valid claim. The court, however, adopted Santander's argument that the class definition was improper because a class member would win or, by virtue of losing, be defined out of the class and not bound by the judgment. Because a determination of the class would also constitute a determination of liability, the court held that Levins' proposed class was impermissible. The court then turned to the question of commonality, which requires a question of law or fact common to the class pursuant to Fed. R. Civ. P. 23(a)(2). Levins presented three proposed questions of law or fact common to the class. The court accepted Levins' first proposed question – whether Santander's dialing system falls within the definition of an ATDS – and found that it had the potential for class treatment. Levins' second proposed question asked only whether the class members suffered a violation of the same provision of law and was therefore an insufficient, "superficial" common question. The court said, however, that this "bottom-line liability question" did not raise jurisdictional concerns under Spokeo, Inc. v. Robins, 136 S. Ct. 1540, 1548 (2016). The court concurred with cases which held that allegations of nuisance and invasion of privacy in TCPA actions were sufficient to state a concrete injury under Article III. While the alleged TCPA injury satisfied Article III, it did not satisfy the requirements of Rule 23. Finally, the court dismissed Levins' third proposed question which asked whether Santander lacked consent to place the calls at issue. The third DODD-FRANK NEWS question, like Levins' proposed class, relied on an analysis of Santander's activity notes and records which rendered the class unascertainable. Further, this question would have already been resolved once the class was determined and, as a result, would no longer be a common question that united the class. Significantly, this question also raised individualized consent issues that would predominate in the litigation, and the court looked to other decisions wherein courts denied class certification of TCPA claims. To bolster this conclusion Santander produced evidence of its policies, which supported a finding that a significant percentage of the class members provided consent to be called. Because Levins' third question involved an analysis of Santander's activity notes to determine whether Santander obtained consent to call, it would inevitably raise factual disputes as illustrated by Levins' response in opposition to Santander's motion for summary judgment. The court then analyzed the typicality and adequacy requirements and found that Levins would likely have a defense unique to her, rendering her an inadequate representative of the class. The court again pointed to Santander's activity notes and Levins' argument on summary judgment where she asserted they contained "many inconsistencies" which, in turn, prevented the court from determining whether she provided consent to be called. In fact, the court determined that Levins could not be a member of her proposed class to the extent it consisted only of those individuals who never provided consent to be called, because her activity notes suggested that she provided consent at some point during the loan servicing. Accordingly, the court determined that Levins failed to meet the adequacy and typicality requirements. The court also held that Levins failed to meet the superiority requirement, citing the significant administrative burden involved with establishing the class which would require Santander to review several million sets of activity notes to determine, among other things, whether the number called was a cell number, whether the number was provided at origination, whether the loan was 5 subject to an enforceable arbitration agreement, and whether the TCPA claim had been litigated or released. Additionally, the court acknowledged that the TCPA's statutory damages provision is a built-in incentive for plaintiffs to bring individual actions, which weighed against a finding of superiority. For all of these reasons, the court denied Levins' motion for class certification. Levins illustrates the significant hurdles plaintiffs seeking to certify TCPA class actions face. Nonetheless, the Levins decision is significant in today's environment given the CFPB's push to encourage consumer class actions. At the same time, Levins follows the general trend of district courts to follow the pre-Spokeo TCPA standing cases which hold that the TCPA creates a cognizable right and, therefore, any violation of that right is a "concrete injury in fact." Whistleblower Protection Kuhns v. Ledgeri, --- F. Supp. 3d ---, 2016 WL 4705160 (S.D.N.Y. Aug. 24, 2016). Plaintiff John Kuhns filed suit against his former employer and executives alleging violations of the Dodd-Frank Act's whistleblower protection provision. Defendants moved to dismiss Plaintiff's complaint. The whistleblower protection provision of the Dodd-Frank Act provides that "no employer may discharge, demote, suspend, threaten, harass, directly or indirectly, or in any other manner discriminate against a whistleblower in the terms or conditions of employment because of any lawful act done by the whistleblower" related to providing information to the Securities and Exchange Commission or making disclosures that are required or protected under the SarbanesOxley Act of 2002. Dodd-Frank's whistleblower provision cross-references Sarbanes-Oxley, which prohibits retaliation when a person reports to "a person with supervisory authority over the employee (or such other person working for the employer who has the authority to investigate, discover, or terminate misconduct)." See 18 U.S.C. 1514A(a)(1)(C). Defendants argued that Plaintiff 6 DODD-FRANK NEWS did not report to a more senior member of the company with supervisory authority over the employee and, therefore, failed to state a claim under the Dodd-Frank Act. The court dismissed this argument finding that pursuant to the plain language of the statute, Plaintiff could report to "such other person working for the employer who has the authority to investigate, discover, or terminate misconduct." Defendants further argued that Plaintiff failed to allege that he reasonably believed that the conduct constituted securities fraud because he did not identify the violation of law he believed defendant committed and needed to have "definitively and specifically" alerted management that a violation of § 1514A occurred. The court, however, noted that the Second Circuit has held that "relief pursuant to § 1514A turns on the reasonableness of the employee's belief that the conduct violated one of the enumerated provisions." See 2016 WL 4705160, at *4 (quoting Nielsen v. AECOM Tech. Corp., 762 F.3d 214,221 (2d Cir. 2014)). The court found that Plaintiff alleged sufficiently an objective basis for belief that a violation occurred and that orally providing the information pursuant to § 1514A was sufficient. As a result, the court held that Plaintiff stated a claim under the whistleblower provision of the Dodd-Frank Act. ---- IN THE NEWS ---- Amendments to the Federal Mortgage Disclosure Requirements under the Truth in Lending Act (Regulation Z) On July 29, 2016, the CFPB issued a proposed rule to amend various disclosure requirements under Regulation Z. The "Know Before You Owe" mortgage disclosure rule took effect on October 3, 2015, and these amendments seek to provide greater clarity and certainty. The proposed changes affect tolerances for the total number of payments, housing assistance lending, cooperatives, and privacy and sharing of rule amends the prompt crediting and periodic statement requirements under TILA's servicing requirements. To read this final rule, visit: www. consumerfinance.gov/documents /813/20160804_cfpb_Final_Rule_Amendments_ to_the_2013_Mortgage_Rules.pdf Proposed Amendments to TILA (Regulation Z) and CLA (Regulation M) On August 4, 2016, the CFPB issued proposed rules that would amend TILA (Regulation Z) and CLA (Regulation M). The proposed rules would require the dollar threshold for exempt consumer credit transactions be adjusted annually by the annual percentage increase in the CPI-W, as required by the Dodd-Frank Act. To read more, visit: www.federalregister. gov/articles/2016/08/04/2016-18062/ truth-in-lending-regulation-z, and https://www.federalregister.gov/ articles/2016/08/04/2016-18059/consumerleasing-regulation-m. Federal Agency Issues Guidance on Uniform Residential Loan Application and Collection of Information about Ethnicity and Race in 2017 On September 23, 2016, the Bureau of Consumer Financial Protection published notice concerning the new Uniform Residential Loan Application under Regulation B. Additionally, this guidance explains the collection of expanded Home Mortgage Disclosure Act information about ethnicity and race that will begin on January 1, 2017. A creditor is generally prohibited from inquiring about ethnicity and race in connection with a credit application, but there is an exception for monitoring purposes, requiring creditors to request information as required by this guidance. To read more, visit: www.consumerfinance. gov/documents/1007/092016_ cfpb_ HMDAEthinicityRace.pdf information. This includes providing additional disclosures apart from the typical closing disclosures. To read more, visit: www.consumerfinance. gov/documents/ 769/20160728_cfpb_ Amendments_to_Federal_Mortgage_ Disclosure_Requirements_Under_TILA.pdf CFPB Issues Final Rule Interpreting the Interaction Between the FDCPA and Regulations X and Z On August 4, 2016, the CFPB issued a final rule to clarify the interaction between the FDCPA and the mortgage servicing rules in Regulations X and Z. Specifically, this final rule serves as an advisory opinion covering three situations. First, servicers do not violate the FDCPA when communicating about the mortgage with confirmed successors in interest in compliance with the mortgage servicing rules found in Regulation X and Z. Second, servicers do not violate the FDCPA when providing the written early intervention notice required by Regulation X to a borrower who has invoked the cease communication right under the FDCPA. Third, servicers do not violate the FDCPA when responding to borrower-initiated communications regarding loss mitigation after the borrower has invoked the cease communication right under the FDCPA. To read more, visit: www.consumerfinance. gov/documents/811/20160804_ cfpb_Bureau_ Interpretations_Safe_Harbors_from_ Liability_under_FDCPA.pdf CPFB Issues Final Rule Amending the 2013 Mortgage Rules under RESPA and TILA On August 4, 2016, the CFPB amended the mortgage servicing rules issued in 2013. Specifically, this final rule amends provisions regarding force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under RESPA's servicing requirements. Additionally, this final DODD-FRANK NEWS 7 8 DODD-FRANK NEWS CFPB Updates Military Lending Act Examination Procedures On September 30, 2016, the CFPB updated its Military Lending Act examination procedures to guide examiners through reviewing for compliance with the calculation of the Military Annual Percentage Rate, identification of covered borrowers, and mandatory loan disclosures. Specifically, any creditor lending to a servicemembers and their dependents must abide by the following requirements: (1) creditors cannot charge more than a 36 percent Military Annual Percentage Rate; (2) creditors cannot require a servicemember or covered dependents to submit to mandatory arbitration or to give up certain rights under state or federal law, such as the Servicemembers Civil Relief Act; and (3) creditors cannot require servicemembers or their covered dependents to create a voluntary military allotment in order to qualify for a loan. To read the updated procedures, visit: www. consumerfinance.gov/documents/1031/ 092016_cfpb_MLAExamManualUpdate.pdf CFPB's September Complaint Snapshot Focuses on Money Transfer Complaints The CFPB recently released its September Complaint Snapshot, which highlighted consumer complaints regarding money transfers. Specifically, many complaints related to the inability to access funds due to an unexplained hold, problems resolving errors, and complaints of fraud. To view this report, visit: http://files. consumerfinance.gov/f/documents/ 092016_ cfpb_MonthlyComplaintReportVol15.pdf CFPB Issues Final Rule Protecting Prepaid Accounts under the Electronic Fund Transfer Act and the Truth and Lending Act On October 5, 2016, the CFPB issued a final rule to create comprehensive consumer protections for prepaid debit cards, which come in the form of physical cards that can be bought in stores or digital cards found online. This final rule adds to the Electronic Fund Transfer Act additional requirements, such as free and easy access to account information and protections if a prepaid card is lost, stolen, or wrongfully charged. So long as the consumer promptly notifies his or her bank, the consumer's responsibility for unauthorized charges will be limited to $50. This rule also implements a new "Know Before You Owe" requirement. Consumers must be provided with standard, easy-to-understand, upfront information about prepaid accounts, as well as upfront disclosures about account fees. Prepaid card issuers must publicly post prepaid account agreements to permit consumers to compare competing prepaid cards. Finally, this new rule provides consumers using prepaid cards with strong protections, similar to those given to consumers using credit cards. Prepaid account issuers must provide monthly credit billing statements, give consumers 21 days to repay debt before being charged with a late fee, and may not assess fees in excess of 25 percent of the credit limit. To read the final rule, visit: www. consumerfinance.gov/documents/1063/ 20161005_cfpb_Final_Rule_Prepaid_ Accounts.pdf Project Catalyst Report: Promoting Consumer-Friendly Innovation The CFPB has published its first-ever Project Catalyst Innovation Highlights Report. This report highlights market developments that have the potential to benefit consumers, from new products to beneficial services. Innovations include expanding access to credit, supporting safe consumer financial records access, modernizing mortgage servicing platforms, and increasing options for student loan refinancing. To view this report, visit: www. consumerfinance.gov/documents/1331/ 102016_cfpb_Project_Catalyst_Report.pdf DODD-FRANK NEWS 2016 Annual Report of the CFPB Student Loan Ombudsman On October 17, 2016, the CFPB Student Loan Ombudsman, established by the Dodd-Frank Act, published a report analyzing complaints from the previous year submitted by consumers with student loans. The report features student loan complaint data, an overview of issues faced by borrowers, and specific issues addressed by the ombudsman, including rehabilitation and consolidation. To view this report, visit: www. consumerfinance.gov/documents/1229/ 102016_ cfpb_Transmittal_DFA_1035_Student_Loan_ Ombudsman_Report.pdf CFPB's October Complaint Snapshot Focuses on Prepaid Accounts The CFPB recently released its October Complaint Snapshot, which highlighted consumer complaints regarding prepaid accounts. According to the report, the three most common complaints involved managing, opening, or closing an account; unauthorized transactions; and fraud or scam. To view the full report, visit: www. consumerfinance.gov/documents/1365/ 102016_ cfpb_Monthly_Complaint_Report.pdf 9 12 DODD-FRANK NEWS - - ABOUT THE EDITORS - - David A. Elliott Partner, Litigation Ph: (205) 458-5324 n email@example.com About David: David serves as chair of the firm's Financial Services Litigation practice group, and has represented banks, finance companies and mortgage companies in all areas of statutory and common law litigation, as well as in asset based recovery actions. David also has extensive experience with enforcing arbitration agreements and with corresponding litigation before various arbitration associations. In 2016, BTI Consulting Group named David to its list of Client Service All-Stars. David was listed in the Best Lawyers in America for 2011-2016 in the field of Commercial Litigation nd for 2015 in Business Litigation and Banking & Finance Litigation. David was also recognized by Alabama Super Lawyers for 2011-2015 in Business Litigation. David is admitted to practice in Alabama, Florida, and South Carolina. Kristen Peters Watson Associate, Litigation Ph: (205) 458-5169 n email@example.com About Kristen: Kristen practices in the firm's Financial Services Litigation practice group. She received her J.D., magna cum laude, from the Cumberland School of Law at Samford University, where she served as the Writing Editor of the Cumberland Law Review. In addition, she was a Judge Abraham Caruthers Teaching Fellow and a Dean's Merit Scholar. Kristen received her B.A. from the University of Virginia. E. Jordan Teague Associate, Litigation Ph: (205) 458-5488 n firstname.lastname@example.com About Jordan: Jordan practices in the firm's Financial Services Litigation practice group. She received her J.D. from Vanderbilt University, where she was the Senior Technology Editor of the Vanderbilt Journal of Entertainment and Technology Law. Jordan received her B.A., magna cum laude, in Mathematics-Economics from Furman University. &KULVWLQD2OLYRV Associate, Litigation Ph: (407) 540-6632 n firstname.lastname@example.com About Christina: Christina practices in the Financial Services Litigation practice group. She received her J.D. from the University of Virginia School of Law, where she served on the editorial board of the Virginia Journal of International Law. Christina received her B.A., summa cum laude, in English and Political Science from Florida International University. No representation is made that the quality of services to be performed is greater than the quality of legal services performed by other lawyers. NICK AGNELLO Ft. Lauderdale (954) 414-6200 email@example.com ATLANTA 171 Seventeenth Street, NW Suite 1100 Atlanta, GA 30363 (404) 815-3000 BIRMINGHAM 420 North 20th Street Suite 3400, Wachovia Tower Birmingham, AL 35203 (205) 251-3000 FT. LAUDERDALE Las Olas Centre II 350 East Las Olas Boulevard Suite 1420 Ft. Lauderdale, FL 33301 (954) 414-6200 JACKSON 190 E Capitol Street Suite M-100 Jackson, MS 39201 (601) 355-3434 JACKSONVILLE Bank of America Tower 50 North Laura Street Suite 3000 Jacksonville, FL 32202 (904) 232-7200 MOBILE RSA Tower 11 North Water Street Suite 22200 Mobile, AL 36602 (251) 344-5151 MONTGOMERY 201 Monroe Street Suite 1950, RSA Tower Montgomery, AL 36104 (334) 241-7000 NASHVILLE Nashville City Center 511 Union Street Suite 2300 Nashville, TN 37219 (615) 724-3200 ORLANDO 200 S. 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Here's what we found...
Plan now and be prepared for our next winter storm
Is water enough or do you need something more?
Registered dietitian shares about the latest trend
The warmth gives us the opportunity to still enjoy the outdoors, but be aware of the risks of heat stroke and dehydration.
Adding spices to your meals may have health benefits
Have you ever heard the phrase "eat a rainbow a day?"
Don't join the one in four with this disease
The American Heart Association redefined high blood pressure and patients have had many questions.
Some of our neighbors are forced to choose between food, utilities or medical care.
James D. McDermott, MD, is Spartanburg Regional's newest sports medicine doctor
Some traditional holiday foods can be healthy and are considered "superfoods."
For some, traditions can be a reminder of loss and hosting visitors from out of town might be stressful.
Trying to eat healthier doesn't have to mean missing out on your holiday favorites.
Gibbs' international reputation for research is now beginning to attract the best and brightest researchers to the area.
Hospitalists work as 'primary care physicians' for patients in hospital
This seafood entree packs a lot of flavor
Annual Spartanburg Regional Foundation event pairs fun with charity
This delicious salad blends several sharp flavors – blueberries, pickled red onions and jalapeños, and the richness of a lemon raspberry vinaigrette.
As internal medicine physicians, sometimes known as internists, we are "gatekeepers."
If you're expecting to see creamy Italian rice in this dish, you'll be surprised.
Flavor collides with color in a fruit salad that packs in a lot of superfood nutrition
Many of us take for granted the role our kidneys play in our bodies.
Looking for a heart healthy but romantic dish? We've got you covered.
Serves: 20; Portion size, 1 ounce; Prep: 20 minutes; Cook time: 1 hour.
Serves: 8; Portion size: 3/4 cup; Prep: 10 minutes; Cook time: 20 minutes.
Diabetes is one condition where we constantly hear wrong information. Let's help set the record straight.
Serves: 5; Prep: 20 minutes; Cook time: 45 minutes.
Serves: 4; Portion Size: 8 ounces; Prep: 20 mins; Cook Time: 30 minutes
Meal: Lunch; Serves: 4; Prep: 10 minutes; Cook Time: 10 minutes.
Serves: 8; Portion Size: 1-1/2 cup; Prep: 20 minutes; Cook Time: 50 minutes.
Serves: 9; Portion Size: 1 cupcake.

subset: commoncrawl


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BOY: I need someone to talk to ..
GiRL: I`m alwayz here for you.
BOY: I know.
GiRL: Whatz wrong?
BOY: I like her *s0o* much..
GiRL: Talk to her.
BOY: I don`t know.. she`ll never like me.
GiRL: Don`t say that. You`re amazing.
BOY: I just wanna tell her how I feel ..
GiRL: Then tell her.
BOY: She won`t like me.
GiRL: How do you know that?
BOY: I can just tell.
GiRL: Well, just tell her.
BOY: What should I say?
GiRL: Tell her how much you like her.
BOY: I tell her that daily.
GiRL: What youu mean?
BOY: I'm alwayz with her. I love her.
GiRL: I know how you feel. I have the same problem. But he`ll never like me.
BOY: Wait. Who do you like?
GiRL: Ooh, some boy..
BOY: Ooh, she won`t like me either.
GiRL: She does.
BOY: How do you know.. ?
GiRL: Because who wouldn`t like you?
BOY: You..
GiRL: You`re wrong. I love you.
BOY: I love you too.
GiRL: .. so are you going to talk to her?
BOY: I just did.
Got this as a forward. Somehow I feel that this conversation depicts the hesitation, self-doubt and love quite convincingly.


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2019/20 Masterpiece Series
Cape Symphony's Masterpiece Series features some of the greatest musical works ever written, plus new groundbreaking music that challenges and enthralls. Enjoy the high level of excellence Cape Symphony musicians produce.
When you subscribe to the Masterpiece Series, you get seated before the general public, keep your seats year after year, and save money!
The Masterpiece Series concerts also feature the Musically Speaking pre-concert talks, insightful and entertaining looks into the music you are about to hear. These free 30-minute talks begin one hour prior to each Masterpiece Series concert.
Visions: Mozart & Mahler
May 2 & 3 THIS CONCERT HAS BEEN CANCELED
Past Concerts
Beethoven on the Cape
September 21 & 22
Bach and Forth
November 2 & 3
Passport to Africa
January 25 & 26
Perfectly Paired
Rescheduled to April 10 & 11, 2021


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18 March, 2013
Crepes With Apple & Peach Compote
Helloo there
Happy Monday to you all and I hope that you guys had a fun and Safe St. Patrick's Day weekend, I know I did, Me and my Baby went to an Irish Dinner at my Baby's Brothers house and it was soo good and you know what It was my first time having Corn Beef. I had corn beef before but in a can and in most Filipino house hold they have corn beef and corn beef and hash in the can and its pretty popular to have it for breakfast, lunch or dinner but mostly for breakfast. I love Corn Beef its good and with cabbage its even better and with some roasted potatoes~it really simply was the bomb, or bomb.com lol, well anyways before all this goodness happened yesterday in the morning I made crepes with apples and peach compote and it was another spectacular breakfast at my house and quite delicious, easy to make and the filling for crepes are endless.
These Apples & Peach Compote are so easy and delicious, use them to make a topping for just plain vanilla Ice cream or for your morning Pancakes~Yummy~Make these for breakfast and give your hubby or your family a reason to wake up in the morning~Crepes and fruit are always a winner!!!
Ingredients Instructions


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At first light on July 6, 1685, the last battle ever fought on English soil was almost over. On one side of the watery pasture at Sedgemoor was the dashing thirty-six-year-old Duke of Monmouth, the charismatic son of Charles II, adored by the people. A reformer, a romantic, and a Protestant, he was fighting the army he had once commanded, in opposition to his uncle, King James II. Yet even before he launched his attack, Monmouth knew he would die.
How did he know that he would die? Because he was trapped and his surprise attack had failed, according to this UK Battlefields Resource Center post:
During the night, in a last desperate attempt to salvage something from his abortive rebellion, Monmouth launched a surprise night attack from the least expected direction, across the marshy wastes of Sedgemoor. But the rebels' bold strategy was discovered before they reached the royal camp and then, in the darkness, their cavalry failed to locate the ford giving access to the royal camp.
With the element of surprise lost any chance of victory had disappeared. The rebel horse soon fled the field and in open country without cavalry support Monmouth's infantry proved an easy target for the royal cavalry. The discipline, experience and firepower of the well equipped professional soldiers of the army of James II soon began to tell. As the morning light revealed the rebels' true plight of the rebels, Feversham launched a join cavalry and infantry attack. Monmouth's army was totally destroyed.
Monmouth, aka James Monmouth Scott, was Charles II's favorite bastard:
Born in the backstreets of Rotterdam in the year his grandfather Charles I was executed, Monmouth was the child of a turbulent age. His mother, the first of Charles II's famous liaisons, played courtesan to the band of raw and restless young royalists forced abroad by the changing political current. Conceived during a revolution and born into a republic, Monmouth, by the time he was twelve, was the sensation of the most licentious and libertine court in Europe. Adored by the king and drenched in honors, he became the greatest rake and reprobate of the age.
On his path to becoming "the last royal rebel," Monmouth consorted with a spectacular list of contemporaries: Louis XIV was his mentor, William of Orange his confidant, Nell Gwyn his friend, the future Duke of Marlborough his pupil, D'Artagnan his lieutenant, John Dryden his censor, and John Locke his comrade. Anna Keay expertly chronicles Monmouth's life and offers splendid insight into this crucial and dramatic period in English history.
It's interesting to note that another of Charles II's illegitimate sons fought for James II: Henry Fitzroy, the 1st Duke of Grafton. He was one of Charles's three sons with Barbara Palmer, the 1st Duchess of Cleveland. He would later support William of Orange in his invasion of England to depose James II, leaving his uncle's service with John Churchill. Churchill and Louis de Duras, 2nd Earl of Feversham also led the king's army against Monmouth's troops. Fitzroy was a Catholic; Monmouth an Anglican.
Monmouth's army was also commanded by Ford Grey, 1st Earl of Tankerville and Benjamin Hewling. Tankerville survived after the defeat:
Hewling was one of those executed in the Bloody Assizes condemned by Lord Chief Justice George Jeffreys, who had also presided over many of the Popish Plot trials. Just to show how tangled these webs of family, rebellion, and treachery were: Henry Fitzroy's guardian, Roger Palmer, Barbara's husband and a prominent Catholic (she had become Catholic too) was accused of involvement in the Popish Plot. He was imprisoned in the Tower of London but defended himself ably against Jeffreys and the Lord Chief Justice at the time, William Scroggs.
Monmouth was executed soon after his defeat, on July 15, 1685, despite offering to convert to Catholicism--at the same time, being refused Communion in the Church of England by the bishops of Bath and Wells (Thomas Ken, later a nonjuror) and Ely (Francis Turner, ditto) because he would acknowledge his sins. His execution, commuted from the usual penalty of being hanged, drawn, and quartered, was not merciful at all because Jack Ketch, the headsman, could not cut off the poor man's dead efficiently or expeditiously. According to Thomas Macaulay, Monmouth feared it would be so:
The hangman addressed himself to his office. But he had been disconcerted by what the Duke had said. The first blow inflicted only a slight wound. The Duke struggled, rose from the block, and looked reproachfully at the executioner. The head sank down once more. The stroke was repeated again and again; but still the neck was not severed, and the body continued to move. Yells of rage and horror rose from the crowd. Ketch flung down the axe with a curse. 'I cannot do it,' he said; `my heart fails me.' 'Take up the axe, man,' cried the sheriff. 'Fling him over the rails,' roared the mob. At length the axe was taken up. Two more blows extinguished the last remains of life; but a knife was used to separate the head from the shoulders. The crowd was wrought up to such an ecstasy of rage that the executioner was in danger of being torn in pieces, and was conveyed away under a strong guard.
Finally, you might recall that Raphael Sabatini wrote Captain Blood, an historical novel about a doctor, Peter Blood, who treats a Monmouth supporter wounded at the Battle of Sedgemoor and is transported to the West Indies as a slave during the Bloody Assizes. The novel was made into a movie in 1935 with Errol Flynn and Olivia de Havilland--Vernon Steele appears as James II and Leonard Mudie as Justice Jeffreys. TCM.com provides some scenes from the movie--at the beginning his servant tells Blood that he is thought to be a Papist by some because he is not fighting for Monmouth!


text:
Trust is a major brick in the foundation of interpersonal relationships, whether it is between parents and children, friends, or lovers.
It is just as easy to build trust as it is to break it down on a daily basis.
If your interpersonal relationships are plagued by that deadly element called "suspicion," then you might find success if you put effort toward trust-building.
Here are 7 steps to build trust
STEP 1) Envision Trust
Clarify exactly what you want. Get motivated with a clear picture of the value of building trust. Affirm what it will take to create trust. Start with the end in mind.
STEP 2) Listen Fully
Allow yourself to listen completely to others. Listening leads to understanding which causes trust. Use what you hear to adjust your trust-building activities. Keep opening yourself and listening.
STEP 3) Open Yourself
Discover what it takes for you to be open with others in your workplace. Build inner compassion for those you fear or dislike. Reveal more of yourself and model the openness you desire from others.
STEP 4) Appreciate Others
Learn how to appreciate others effectively such that you encourage desired behaviours and strengthen mutual trust. Notice the enormous impact of appreciation.
STEP 5) Be Reliable and Consistent
Upgrade your reliability and consistency to sustain high trust levels. Raise your awareness of your behaviours that threaten trust. Learn valuable techniques for reducing your own unintended breaking of trust.
STEP 6) Converse Frankly
Plan and carry out constructive conversations with key people with whom you are building trust. Build stronger foundations of trust. Mend past misunderstandings. Engage in building trust.
STEP 7) Notice the Difference
Become aware of the subtle and the obvious changes you have created throughout the course. Celebrate your success! Thank yourself. Be grateful for the challenges and the support you received. Commit to continuing to build trust.


text:
Peer reviewed
Direct link
Direct link
ERIC Number: EJ1036341
Record Type: Journal
Publication Date: 2014-Aug
Pages: 5
Abstractor: As Provided
Development and Implementation of a Two-Semester Introductory Organic-Bioorganic Chemistry Sequence: Conclusions from the First Six Years
Goess, Brian C.
Journal of Chemical Education, v91 n8 p1169-1173 Aug 2014
A two-semester second-year introductory organic chemistry sequence featuring one semester of accelerated organic chemistry followed by one semester of bioorganic chemistry is described. Assessment data collected over a six-year period reveal that such a course sequence can facilitate student mastery of fundamental organic chemistry in the first organic course, which is then reinforced during a second semester that is centered around the organic chemistry of biological molecules. Furthermore, student responses to the enhanced biological content of the bioorganic chemistry course have been almost universally positive, and selected data and student comments from course evaluations are presented. Finally, key sections of the revised Competency Areas on which the new Medical College Admissions Test will be based are analyzed, indicating that such a revised organic chemistry sequence will likely be particularly beneficial to students hoping to enter health-related fields.
Descriptors: Introductory Courses, Organic Chemistry, Curriculum Development, Sequential Approach, Scientific Concepts, Educational Methods, Biology, Molecular Structure, Student Attitudes, College Science, Undergraduate Students, Course Content, Medical Education, College Entrance Examinations
Division of Chemical Education, Inc and ACS Publications Division of the American Chemical Society. 1155 Sixteenth Street NW, Washington, DC 20036. Tel: 800-227-5558; Tel: 202-872-4600; e-mail: firstname.lastname@example.com; Web site: http://pubs.acs.org/jchemeduc
Publication Type: Journal Articles; Reports - Evaluative
Education Level: Higher Education; Postsecondary Education
Audience: N/A
Language: English
Sponsor: N/A
Authoring Institution: N/A


text:
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Raw Food Cookbook: 30 Fresh, Quick and Simple Recipes for Energy and Optimal Health: Natural Food
A raw food diet is simply becoming one of the most popular diets to choose from. It seems everyone wants to become healthier, detoxify their bodies or just lose weight and its becoming increasingly simple to do so. Starting a raw food diet could be the answer you're looking for.
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Hopefully this will be the guide you use to start the day right and get back on the road to healthy eating and healthy living.
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Customer Reviews
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Banjo & Kazooie stand at 9" and 6" inches tall respectively.


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HP Spectre x360 (2018) evaluation: Redesigned, redefined and highly effective
HP, nonetheless driving the wave of its profitable resurgence, is unstoppable. With the assistance of its model new shopper id and laptops such because the achingly slender Spectre 13, the corporate's high-end shopper gadgets now rank among the many extra fascinating laptops you should purchase, and it's maintaining that arduous work with the model new HP Spectre x360, a 2-in-1 laptop computer that hits all the fitting notes.
From its trendy-looking HP emblem on the lid to the Bang & Olufsen audio system above the keyboard and its luxurious touch-enabled 4K show, it is a laptop computer that's dressed to impress and, now that its innards have been up to date, it stands among the many highest relating to core elements as properly.
READ NEXT: Greatest laptop computer: The best Home windows, Apple and Chrome OS laptops you should purchase
HP Spectre x360 evaluation: What it is advisable know
As 2-in-1 ultraportable laptops go, HP's Spectre x360 sits on the tippy high of greatness. There's little standing in its approach; it's well-equipped with Intel's latest eighth-generation Kaby Lake R processors, with a selection of as much as 16GB of RAM and 1TB of storage. There's additionally the choice of a devoted GPU for gaming on the go.
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HP Spectre x360 evaluation: Worth and competitors
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Unsurprisingly, the Spectre x360 whizzes by means of on a regular basis duties. Within the Knowledgeable Evaluations benchmarks – which assessments picture and video modifying speeds and the way properly the laptop computer copes with multitasking – it scored 56, which is a marginal enchancment over final yr's mannequin however is a large 80% quicker than Dell's Core Y-equipped XPS 13 2-in-1.
Storage-wise, the 256GB and 512GB PCIe NVMe SSD configurations include 8GB of RAM, however should you improve to a 1TB PCIe NVMe SSD you'll have 16GB to mess around with. These Samsung PCIe SSDs are blisteringly quick, reaching 2,316MB/sec sequential learn and 1,095MB/sec sequential write speeds in response to the AS SSD benchmark.
Regardless of the shortage of a devoted graphics chip, this Spectre x360 is a well-equipped machine for gentle gaming on the go. At 1,920 x 1,080 – the built-in Intel UHD Graphics 620 chip isn't able to producing playable framerates at native 4K decision – the Spectre reached a median of 28 fps when taking part in Dust Showdown on the "Extremely Low" element preset. Knock the decision all the way down to 720p and the framerate jumps to 72 fps below the identical situations.
Alas, the x360's battery life holds this laptop computer again from attaining high marks. Portray a well-recognized image with the super-slim Spectre 13, HP's newest hybrid survived for less than 4hrs and 51minutes in our battery life benchmark. As some extent of comparability, the XPS 13 2-in-1 lasted three hours longer in the identical take a look at.
HP Spectre x360 evaluation: Design
The HP Spectre x360 is the very definition of a top-tier ultraportable. It's a 2-in-1 convertible laptop computer, which implies the display screen folds over moderately than detaches just like the Floor E book, and it's very beautiful to take a look at. Copper accents glint out from the x360's "Darkish Ash Silver" physique, which is constructed completely from aluminium. Weighing 1.29Kg, it's not the lightest of hybrids – due to the weighty touch-enabled 4K show – however solely measures 306 x 218 x 13.6mm.
On the fitting facet of the laptop computer you'll discover two USB Three.1 Gen 1 Sort-C ports, each of which can be utilized to switch knowledge and connect with an exterior monitor. On the left facet sits a solitary HDMI port with a multi-format SD card reader, common USB Sort-A Three.1 port, a headphone/mic combo jack and the illuminated energy button.
As for audio, that's delivered by the upward-firing Bang & Olufsen-branded speaker located above the keyboard, which could be fine-tuned to your liking by means of the Bang & Olufsen Audio Management desktop app. Sound high quality is respectable and when used as a pill, the audio system resonate successfully below the display screen.
HP Spectre x360 evaluation: Show
The Spectre x360's display screen is a 4K (Three,840 x 2,160) IPS unit with multitouch enter and stylus assist, with HP offering a low-profile bezel on both facet of the show, though the underside bezel is moderately chunky.
The panel itself has improved tremendously over final yr's mannequin. Color rendition is nice, with 97% sRGB gamut protection and the display screen is rather more color correct, with a median Delta E of two.14 (decrease is healthier). It's additionally tremendous shiny, and also you gained't have any hassle squinting on the display screen outside, with most brightness reaching 327cd/m2.
HP Spectre x360 evaluation: Keyboard, touchpad and stylus
The x360's glass-topped touchpad is bigger than most, offering a beneficiant quantity of house to your finger prospers. It's responsive and able to performing Home windows' lengthy listing of multi-touch gestures with none hiccups. The HP's backlit keyboard is equally a pleasure to make use of, too. Every key press feels weighty, with loads of clicky, constructive suggestions.
It's at all times good of HP to bundle a stylus within the field at no added price, particularly when Microsoft desires an additional fifty quid for one while you purchase the Floor Professional or Floor E book 2. This one works flawlessly and the laptop computer's palm rejection works successfully, too: disabling capacitive contact enter as quickly because the tip of the stylus will get round 1cm near the display screen. It has 102 strain ranges, a quoted battery lifetime of 18 months (with 2-Three hours of use a day), however just isn't angle delicate.
HP Spectre x360 evaluation: Verdict
HP's Spectre x360 cements the hybrid benchmark as soon as extra. Its design, regardless of being virtually two-years-old at this level, remains to be as breathtaking and efficiency is unbeatable, too. Throw in a bundled stylus and a pixel-perfect 4K show, and this 2-in-1 is basically unstoppable.
The Spectre's quick battery life does undermine its ultraportable credentials, nonetheless, and in that respect Dell's XPS 13 2-in-1 is the laptop computer you'll need should you're after one thing that's longer-lasting. However, regardless of these battery niggles, the Spectre x360 remains to be a well-priced do-it-all laptop computer that's at present unmatched in each different space.
|Core specs
|Quad-core 1.8GHz Intel Core i7-8550U
|Reminiscence slots (free)
|1 (zero)
|Max reminiscence
|306 x 218 x 13.6mm
|Realtek HD Audio (Three.5mm headset port)
|Pointing gadget
|Touchpad, touchscreen
|Display screen dimension
|Display screen decision
|Three,840 x 2,160
|Graphics adaptor
|Intel UHD Graphics 620
|Graphics outputs
|2x USB-C
|Graphics reminiscence
|Complete storage
|Optical drive kind
|Ports and enlargement
|USB ports
|2x USB-C, 1x USB3.1
|Reminiscence card reader
|Different ports


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The narrative composition arrangement is quite obvious and exceptionally readily comprehensible. When writing a personal essay, it's crucial to bear in mind that the primary persona is you. Narrative composition assignments are very flexible within the manner of writing. You can utilize narrative essay illustrations as a means to observe the numerous platforms, which is frequently used, in this kind of composition. Your narrative article warrants an inclusive version, which is truly a lot more than simply a check. Narrative composition, more than just about any other type of custom essay, should to be graphic. Composing an excellent dissertation will be uncomplicated.
–> the instructor or perhaps a fellow student can offer cases.
To summary, developing a narrative article is just storytelling. Nonfiction determined by real activities and may be story writing. Composing this kind of article students desire to triumph. There are a lot of kinds of story composing. Request beginners to complete their unique graphic organizers utilizing one type you've educated and employed. Students, utilize the work graph below to steer you in your own personal story writing. Making do with narrative essays illustrations especially, you might want expert article writing help. The essay specifies a particular viewpoint. Story composition is among the most interesting kinds of documents.
About 50 to 80 inquiries on each strategy.
Thus, don't wait to purchase essays on line. Oh, sure, additionally you will require a very good story essay topic. The solution is much simpler than you might have anticipated order essay. Poetry composed within the style of the story is called narrative verse. Story essays are told from a defined point of view, frequently the writer's, therefore there's feeling in addition to unique and frequently physical particulars furnished to find the audience included within the elements and sequence of the narrative. For anyone who is creating the concluding section, never forget to summarize everything and truly don't make an effort to r e -narrate the whole story. Some people believe a story composition is merely a free fluid narrative, but that's incorrect.
Utilize paper that is intelligent, and often produce your letter.
A story composition needs you to certainly be descriptive, and so you might have to pay attention to every individual detail within the paper. That's the cause why, this particular sort of essay is among the most interesting ones. An abstract painting, for instance, doesn't ordinarily feature identifiable things. The rest you may depart for the skilled custom essay writers of ProfEssays, we understand how to show points within your party favor. Successful story documents empower visitors to imagine all that's occurring, inside their own thoughts. You'll nevertheless require a thesis and primary suggestions to organize your narrative. Trivial experiences are fertile issues for distinctive stories.
While promises one and three are energetic, the second record is in the passive variety.
Subjects for good essays don't have any limitations. Consequently, you know that you have to examine your principal point within the dissertation assertion. The dissertation, the principal articles physique plus an ideal judgment, that is all you have to draft a pleasant story essay. A thesis statement is the greatest method of change your stage and after that start backing this up with relevant justifications. A superb dissertation declaration doesn't automatically must list each of the principal points, however. Here, you can surely explain the facts the audience may perhaps not know about your own topic. The intention of a narrative report may be to explain something. It's not necessary in any way presenting the subject in a superior and accurate phrase. In the very first part, it is wise to present some overall advice on your own subject and listing the points you're going to further grow within the body of your own composition.


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Brighten up your sock drawer with these British bird printed socks from Thought. Inspired by nature these breathable socks are made from a bamboo and organic cotton blend making them incredibly soft. With natural anti-bacterial and anti-fungal properties these socks ensure your feet – and the planet – stays healthy and happy.
Suitable for vegans, free from GMO and AZO dyes, GOTS certified, Oeko-tex 100 Standard, organic and sustainable.
Thought work closely with their factories in China to ensure products are made to the highest ethical standards. Today they still work with the first factories they did when the company was founded, and continue to create long term partnerships. Thought has a strict code of conduct policy their suppliers must follow, and ensure the conditions are always being met.
54% Bamboo viscose, 22% organic cotton, 22% recycled polyester, 2% elastane
Packaged in a biodegradable poly bag, manufactured in China.
The Thought Women's Raven Grey British Birds Bamboo Socks product ethics are indicated below. To learn more about these product ethics and to see related products, follow the links below.
There are currently no reviews to display for Thought Women's Raven Grey British Birds Bamboo Socks
There are currently no questions to display about Thought Women's Raven Grey British Birds Bamboo Socks.
Please see our Despatch & Delivery page for more information on delivery areas, services and charges.


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Firefox allows JavaScript code to install search engine plugins to the search box using OpenSearch.
When JavaScript code attempts to install a search plugin, Firefox presents an alert asking the user for permission to install the plugin.
This method is not widely supported. The preferred method of exposing OpenSearch is to use search plugin autodiscovery.
Installing OpenSearch plugins
To install an OpenSearch plugin, use the
window.external.AddSearchProvider() DOM method. The syntax for this method is:
Where engineURL is the absolute URL to the XML file for the search engine plugin.


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I love perusing Instagram and discovering people's artwork, crafts and small businesses! When I was pregnant with Brielle, I came across the "Solly Baby Wrap" as some of my Instagram mom friends were using it and saying how much they loved it! Myla was never a big fan of being in a carrier, but we had previous experience with a structured Ergo carrier which we used on trips (like on our Maui vacation during the Pipiwai Trail HERE)! This Solly Baby Wrap looked intriguing because it is a wrap style carrier that can be used immediately with newborns and babies of any size.
The story behind Solly Baby is wonderful too as Elle Rowley designed the wrap after she had her second child Solomon (hence the name "Solly") in 2011. Elle was an advocate of babywearing but was unhappy with the carriers that she had used, so she decided to experiment with different fabrics and create her own! Fast forward years later and Solly Baby is immensely popular and successful- Elle and her husband Jared now have three children and closely oversee the production of their wraps while supporting American factories, fabric mills, dye houses and printers. It's incredible how Elle saw a need for this product, designed it herself, and is now sharing her work with families all over the world!
The colours and prints of the Solly Baby Wrap are absolutely gorgeous, and every season they come out with new colours. I heard nothing but high praise for this carrier and hoped that our second baby would love being in it! I decided to go with their popular "Natural & Grey Stripe" and was thrilled when it came in the mail!
Isn't the packaging gorgeous? I love the embossed polka dots and writing, and it's wonderful that the colour of the wrap is visible through the box!
You can tell that Elle and her team have put a lot of thought and detail into the packaging so that their product makes a bold first impression! Look at this adorable cut-out heart that appears when you open the box!
What a cute little reminder that the Solly Baby Wrap is made in the USA!
During the weeks leading up to my due date, Ryan and I practiced how to wrap the Solly by watching their very helpful video tutorials HERE! In these videos, Elle teaches you how to do the "Newborn Carry" and the "Classic Carry", and even how to nurse in your wrap! Ryan and I got the hang of it in no time and were excited to put our sweet little babe in our wrap…
We ended up using our Solly Baby Wrap pretty much EVERY SINGLE DAY when Brie was a newborn up till three months old! They recommend going from womb to wrap as the Solly provides a womb-like environment after giving birth that makes babies feel safe, secure and comfortable. The wonderful thing is that you can get a custom fit every time you wear the wrap (they do recommend taking extra care of keeping the air passage ways clear when wearing babies under 7 lbs though). Brie absolutely loved being close to us and of course we loved being able to cuddle her so closely as well! She had difficulty napping in her bassinet back then so it was easier for us to just strap her to us in the wrap so she could fall asleep peacefully.
Becoming a mother of two children was a big adjustment, and I tried my best to give my care and attention to both my toddler and my newborn. I knew this transition would be a sensitive time for Myla since she was used to being the only child and getting all the attention. Thankfully, putting Brie in the wrap allowed me to still play with Myla, prep our meals and be hands free to do activities whenever needed. I was even able to crochet and blog while Brie was asleep in the Solly as well! I did not have the luxury of being able to lie in bed with a newborn asleep on my chest as I did with Myla! I've read testimonies from mothers with multiple children who all agree that the Solly has been instrumental in helping them bond with their newborns while also allowing them to keep up with their other children!
I've loved babywearing as it helps you bond with your baby! Babywearing is said to calm fussy babies, especially those with reflux or gas and reduce crying. From personal experience, Brie has loved being in the Solly Baby Wrap, and staring down at her adorable face and seeing her smile up at us is priceless!
Solly Baby Wraps are designed for the first year of a child's life or up to 25 lbs, but most wearers get the most use out of their wraps during the first six months. Once they get heavier, moving to a more structured carrier would probably be better and more comfortable for the wearer as they provide more support. Solly Baby Wraps are made of Lenzing Modal which is a soft sustainable knit made from Austrian beechwood trees and manufactured in Los Angeles. The material is very lightweight and breathable!
The Solly Baby Wrap is also very portable as it folds into itself and tucks away nicely into a little pouch that can be found on one end of the wrap. It does not take up too much space in my purse, and it's wonderful being able to have it ready to go whenever we might need it!
Dads can wear the wraps too! Here is a photo below showing a family excursion to the Science Centre. Ryan strapped Brie to himself in the carrier and was able to play with Myla while Brie had a wonderful nap!
***IMPORTANT NOTE: When using the Classic Carry, the baby's legs and bum should create an "M position" achieved by the baby's knees being bent and above the hip bone (knees are higher than bum). Baby Brie is in the correct position in the photo below but not in the above photos! I did not pull the fabric under her thighs enough during this photoshoot, so her legs are dangling- her hips should be spread open and her legs should be in a "frog position"! You can read more about correct positioning HERE!
We used this opportunity to take an outdoor family photo before Brie fell asleep in the wrap! We are still trying to take monthly family photos so we can document the growth of our two little ones! Here is Brie at 5 months old
❤ She has grown so much and is a very happy, content, and sweet baby girl!
Here is a selection of some of the wraps currently available! It comes in "Mint", "Swiss Dot" (I am swooning over that beautiful blush pink), Oh Joy! and the Solly Dolly, which is made for your toddlers to carry their stuffies and dolls- how cute is that? Check out their full selection HERE!
You know how much I adore this wrap, and now you can win one for yourself or a loved one too! Please see how to enter by using the Rafflecopter widget below! This GIVEAWAY is open to US residents only and closes on Sunday, June 14th at midnight MST. To read more about the Solly Baby Wrap, check out their website HERE and stay connected with them through their Instagram, Facebook and Twitter! We love our wrap and highly recommend it!


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Baggabond Cotton Canvas Messenger Bag BGCM0002
Rs. 899.00
Rs. 2,399.00
This gently distressed canvas barrack backpack from Baggabond lends a road-trip-ready vibe .With one large compartment to carry all your travel needs this sturdy cotton canvas backpack comes with a drawstring closure alongwith 1 zipped and 2 slip pockets on the inside. This sturdy backpack also sports an adjustable straps made of web cotton and a zipped pocket on the back for all your essentials.
Color - Coffee
Material - Cotton Canvas
Wash Care - Machine Wash and Do not Bleach
|LENGTH (inch)
|Width (inch)
|Depth (inch)


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Deep Sea O2 Snorkel Mask: What Makes It Stand Out?
Did you know that snorkel masks can trap carbon dioxide in? As a consequence, breathing this in can cause a headache, poor concentration, and discomfort. For this reason, when snorkeling, you should use only snorkel masks that do not only keep water out but carbon dioxide as well.
There are other important factors to consider in a snorkeling mask. One of them is the fit and comfort to ensure that it stays wrapped around your face while swimming. The strap should also be elastic so that it will be easy to adjust and not pull your hair. Another important factor is the breathing mechanism and seal, which both keep saltwater out and prevent you from gagging from it.
One awesome product that has these features is the Deep Sea O2 Snorkel Mask. What else does it have to offer?
Deep Sea O2 Snorkel Mask: A Detailed Look
The Deep Sea O2 Snorkel Mask stands out because of its notable features and advantages. It has one minor drawback, but it is something that is easily compensated by its indispensable advantages.
Is this the snorkel mask that best matches your needs and preferences? Let's see!
Key Features
There are many reasons to love the Deep Sea O2 Snorkel Mask. Among them are the following:
- Comfort
When you are snorkeling, one important thing to keep in mind is comfort. This is to keep your mind and body at ease so that you will appreciate the underwater view more.
The Deep Sea O2 Snorkel Mask has an overall comfortable built. Its full-face design is more manageable and allows normal breathing compared to the traditional separate mask and snorkel sets. Its full-face design lets you breathe through the nose and mouth.
The materials used to make this mask are soft and fit around the face comfortably. When it comes to the Deep Sea O2 Snorkel Mask, comfort also means that it prevents you to swallow saltwater or gag on the snorkel tube. The straps are elastic and don't pull the user's hair as well.
The Deep Sea O2 Snorkel Mask comes in one size only. It can fit anyone because it has adjustable soft straps. Moreover, it has an air-filled seal that keeps it well-fitted and prevents water from getting inside. The clip that secures its size is easy to wear and take off too.
- Patented Breathing System
One best feature of the Deep Sea O2 Snorkel Mask is its patented breathing system, which allows healthy air circulation. This system makes it possible for you to inhale oxygen and keep the carbon dioxide out. In fact, this mask is one of the few that have the lowest carbon dioxide intake system. The breathing mechanism also reduces fogging to keep the view crystal clear.
The breathing mechanism is made with a soft nose that is easy to press so that you can conveniently equalize the pressure you feel in your head when you dive deeper than five feet. Compared with other snorkel masks, this one allows you to dive down so that you can see a sea creature up close.
- Panoramic View
The Deep Sea O2 Snorkel Mask is a full-face mask. It covers the entire face and provides a 180-degree viewing angle. Additionally, you can capture the mesmerizing view of the ocean with the integrated action camera mount. The high-definition panoramic display allows you to watch realistic recorded views or taken photos.
- Design
The Deep Sea O2 Snorkel Mask comes in four colors to choose from: deep black, salt white, sea blue, and tang yellow. While comfort and fit always come first, this brand offers their mask in variorus beautiful colors as a bonus feature.
- Low carbon dioxide intake
- Camera mount
- Wide viewing angle
- Comfortable, secure fit
- For kids and adults
- Can be used for diving
- Easy to equalize
- Anti-fog mechanism
- Easy to use
- Quite expensive
Summary of the Features
The Deep Sea O2 Snorkel Mask is a full-face snorkel mask made with innovative breathing mechanism that allows the lowest amount of carbon dioxide intake. This feature also prevents the viewing visor from fogging, hence keeping the panoramic view clear.
This mask can also be used for diving, and its soft nose makes equalizing easy. It secures a comfortable fit, and it is easy to wear and take off too, thanks to its soft straps. The added camera mount feature allows you to capture beautiful underwater images.
Comparison with Other Snorkel Mask
The Deep Sea O2 Snorkel Mask seems like the perfect snorkel mask that is safe for everyone's use. However, given its price, some users might want a cheaper one but with good features too. A good alternative is the WSTOO Snorkel Mask.
Similar to the Deep Sea O2 Snorkel Mask, the one from WSTOO also features a panoramic view, an anti-fog and anti-leak design, and a removable camera mount. It is also a one-size-fits-all mask too, which means that it can be used by both adults and children. It comes in various colors to match personal preference.
Even though the WSTOO Snorkel Mask is quite cheaper than the Deep Sea O2 Snorkel Mask, the latter has more valuable features. It has anti-CO2 breathing mechanism that makes it safer than most snorkel masks today.
Moreover, unlike the WSTOO Snorkel Mask that doesn't allow strenuous swimming and diving, the Deep Sea O2 Snorkel Mask can be used for diving deeper than five feet.
Final Say
Snorkeling is a fun activity, and to have the best experience in the ocean, a snorkel mask is a must-have gear. This should not be just an ordinary snorkel set though, but a really good one. Among the hundreds of snorkel sets available today, the Deep Sea O2 Snorkel Mask stands out.
There are many notable features to love about this Deep Sea O2 Snorkel Mask. One of them is its patented breathing system, which improves oxygen circulation and retains minimal carbon dioxide inhalation. Hence, it is safer on health and keeps the view clear because of its anti-fogging feature. It has a full-face coverage, giving the wearer a panoramic view for better sight.
Compared to most snorkel sets, the Deep Sea O2 Snorkel Mask can be used for diving deeper than the surface. Everything that you look for in a snorkel set, this snorkeling mask already has it. For kids and adult use, as well as for surface snorkeling or diving, the Deep Sea O2 Snorkel Mask has got it all covered.


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To obtain a money transmitter license, every state requires a surety bond. Depending on your state, this license may be called money remitter, money services business, check casher, or sales of check license. In Florida, it is referred to as a Florida Money Transmitter Bond.
A surety bond is made to protect the public. In basic terms, it guarantees your business will adhere to all laws and requirements in your industry. In the event your business conducts unlawful acts, a consumer of your services may file a claim on the bond.
Nearly any company that offers payment services requires a money transmitter bond. Due to a history of fraudulence and inaccurate money transmissions, state agencies now require this bond to protect consumers. While this bond does not protect the business owner, it offers proof that your business handles clients' money responsibly.
The cost of the bond, the "premium," depends largely on the bond amount and the applicant's financial status. The state requiring the bond determines the amount. At Surety 1, we will find you the lowest quote for your bond, starting at only 1.5% of the bond amount.
In order to get your money transmitter's business license, you'll need a bond. This bond guarantees the money transmitter will abide by the laws and regulations stated in Chapter 560 of the Florida Statutes along with other Florida state laws.
The applicant should verify the bond amount with the obligee before applying for the bond to ensure the bond amount is correct.
The bond amount is must be equal to 2% of the total amount of finances handled by the business the previous fiscal year. For a new business, however, the bond amount must be 2% of the projected money handled.
The exact bond amount should be verified with the Office of Financial Regulation before applying for the bond in order to guarantee the amount is correct.
These are additional details about the licensing process that you should be aware of. (Only the bond is handled at Surety1, but this information will help you get your license.)
The state-issued application packet must be completed for a license. Fees for a license include a $40 filing fee, $375 application fee + $30 for every additional location. The licensing fees are required by the obligee, not the surety company.
The license application requires several supporting documents:
The license application can be filled out using an electronic system referred to as NMLS. Businesses that are not conducting multi-state businesses, or those that do not want to use the electronic application system, can also have access to other application forms.
Money transmitters in Florida must also register as a money services business (MSB) with the Federal Crimes Enforcement Network (FinCEN). The registration process must be completed by the Bank Secretary Act (BSA) e-filing system.
Learn more at the Florida Office of Financial Regulation.
Surety1 has been providing surety bonds in Florida, and all fifty states since 2003. The company maintains an A+ rating by the better business bureau and offers and easy to navigate online application. Simply complete the online application and one of our agents will be in touch with you within one business day with either a quote or a request for additional information.


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Most of the training posts that I write about are ones that I have performed myself and then are passed onto you guys. I know what you are thinking, I am a nice guy giving you all these different painful, agonizing, sweat dripping workouts but hey, you can thank me another time ;), you have work to do! This specific workout is all about squats and lunges and nothing else, but with just two exercises it makes it one of my toughest workouts yet that I have put myself through...
The Workout
This workout is all about volume and with volume comes a lot of reps and funny faces being pulled (you know the ones I am talking about). You will perform 10 sets of squats along with 10 sets of walking lunges with a bar resting on the back of your neck and shoulders. This is considered as a superset and the rate at which you are working is what makes this even more intense than how it already sounds. Here's why...
The Tempo
The tempo is really important in both exercises for this workout to be effective so in order to feel the full effects you have to stick with it and push through the pain barriers that are going to arise after each set. If you train your legs often and are used to training them heavy with fewer repetitions then this is going to be a pleasant wake up into the world of volume training as the feeling is slightly different.
Heavy Weights Vs Volume Training
When you are lifting heavy in the squat rack it is taxing for the body and not just in a physical way. Let's say for example you are doing a maximum of five reps per set but pushing yourself to the limits with every one you perform. However, it is also draining on your mental side and your central nervous system. Volume training on the other hand is focusing on repetitions and using a lighter weight to generate more of a pump in the area you are targeting.
The Setup
In this workout you are going to perform 10 sets, 15 reps in each set of squats at 80% of your body weight. (I weigh 80 kgs so I was squatting 60 kg on the bar.) The tempo with these squats is going to be one up and one down with no rest at the top. As soon as you finish one rep it is straight back into the squat firing out the next rep. Locking of the knees is a no go area so it really is a bouncing (but controlled) squat movement that WILL burn! Once you have completed your 15 reps here, rack the bar and go straight into your walking lunges. For this I used a ready made up 30 kg bar and performed 15 reps each way, totaling 30 altogether before resting.
Session Complete
You are free to go, so to speak once you have finished your 10 sets of both exercises which might leave you feeling a little worse for wear. Make sure you have got your bottle of water with electrolytes in to replenish the loss salts you will lose through sweat. I always like to mix up some BCAA's within my drink to maximise performance and keep my muscles contracting as well as possible.


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Address musculoskeletal complaints with the help of an osteopath, who may draw on modalities such as massage, Bowen therapy or acupuncture
Customer Reviews
What You'll Get
The Deal
During an initial osteopathic spinal consultation lasting between ten minutes and half an hour, customers can talk through any niggling issues or recurring bodily strains. The practitioner will then conduct a physical examination, and decide on the best treatment choice for each individual case. A one-hour treatment will then take the form of a osteopathic treatment including spinal assessment, cranial osteopathy, Bowen session or acupuncture. A discount will also be available on three additional sessions of Bowen therapy.
The Merchant
Specialists in soothing creaking joints, team members at Croydon Osteopathic Practice are also practitioners of the Bowen technique, focusing on muscles and connective tissues. With homely surrounds and a varied list of treatments up for grabs, the team also offers personalised orthotics, physiotherapy and individually tailored massages.
The Fine Print
Expires 120 days after purchase (Excl. 18, 21 Apr; 5 May). The merchant reserves the right to refuse the treatment if customer is ineligible.
Purchase: Limit 1 per person. May buy 5 additional as gifts.
Booking: Required by phone 0208 6882088, 07986041152. 48-hour cancellation policy. No email booking acceptable.
Restrictions: Valid Mon-Fri 9am-5pm. Must be 18 or older. New customers only.