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No Money Down Mortgages Stage a Comeback
Two credit unions, NASA Federal Credit Union and Navy Federal Credit Union, are offering members mortgages without requiring any down payment or mortgage insurance.
No money down mortgages were among the types of housing finance loans blamed for causing the housing finance crisis in 2007. Such mortgages would seem to run counter to the prevailing trend in housing finance regulation, which seeks to make sure participants in all parts of the lending process have a stake in the loan.
But executives from both credit unions defended offering the loans, maintaining that a mixture of underwriting standards and member relationships protected them from losses on the loans.
Bill White, vice president of residential lending at the 84,000-member $1.2 billion NASA Federal Credit Union, declined to say what percentage of the credit union's housing finance lending did not require a down payment. But he said that the volume in such loans was in the millions of dollars. The credit union booked $170 million in housing finance loans in 2012, White reported.
NASA FCU has confidence in the no money down loans because the credit union underwrites those more tightly than it does loans that are underwritten to the standard for the secondary market required by Fannie Mae and Freddie Mac, White explained.
Because no money down loans cannot be sold on the secondary market, the credit union's no down payment offerings are destined for its own portfolio.
The credit union, which has a nationwide field of membership based on SEGs, also limits the no down payment loans to real estate markets in the credit union's closest region, the Washington, D.C., suburbs, where NASA believes it best knows the market and where the credit union is confident housing prices have hit bottom.
"We focus on the ability to repay the loan as the standard independent of what might happen to the value of the underlying asset," White said, contrasting NASA's no money down loans to the sorts of no down payment lending that helped fuel the housing finance crisis. Those previous no money down loans offered by other financial institutions and mortgage brokers had been made on the assumption of rising real estate values, he explained, but NASA's program focused on ability to repay.
But if a member had the financial wherewithal to be able to easily repay the loan, why would they necessarily want a no money down mortgage?
White explained that some members were financially able to make mortgage payments but were not interested in tying down liquid assets in housing finance.
He also explained that the loans carried an interest rate premium and that members understood they would pay a slightly higher interest rate.
NASA ran the program past the NCUA for risk, and White said that after 36 months of offering the loans, there had been no problems with delinquency. "These loans work well for the credit union and our members," he said. The NCUA did not confirm that its staff reviewed the credit union's no money down program and has not reported how many credit unions around the country may offer similar programs. Aside from Navy Federal, White said he didn't know of any others.
The 4.2 million-member $52.4 billion Navy Federal Credit Union, by contrast, offers what it calls the Homebuyers Choice to all its members and doesn't underwrite the no money down loans differently than other mortgages, according to the housing finance executives with the nation's largest credit union.
"We underwrite all of our loans so our members can succeed with the loan," said Katie Miller, vice president for mortgage products, adding that the no money down loans are extremely popular with members who might not be able to come up the typical $20,000 down payment for a conventional mortgage from another lender.
The credit union also makes $2,500 available to members to help with closing costs and the loans allow up to 6% of the purchase price to come from the seller, according to the credit union's website.
Miller and Richard Morris, vice president of mortgage products and GSE relationships, put the loans in the context of the relationship Navy Federal has with its members, which is unlike the relationships other financial institution customers have with their financial institutions.
"We know and trust our members, and we believe they know and trust us," Morris explained. "It really is all about our members. They understand how the credit union seeks to help them and they want to help the credit union too."
Miller said the credit union had offered the no money down mortgages prior to 2008, but then put the program on a hiatus until February 2010 in order to re-examine and evaluate the loan portfolio. Subsequently they began to offer the loans again, she said, and reported the loans perform very well.


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This study is maintained and distributed by the National Addiction & HIV Data Archive Program (NAHDAP). NAHDAP is supported by the National Institute on Drug Abuse (NIDA), part of the National Institutes of Health (NIH).
Monitoring the Future: A Continuing Study of American Youth (12th-Grade Survey), 2005 (ICPSR 4536)
Alternate Title: MTF 2005 (12th Grade)
Principal Investigator(s): Johnston, Lloyd D., University of Michigan. Institute for Social Research. Survey Research Center; Bachman, Jerald G., University of Michigan. Institute for Social Research. Survey Research Center; O'Malley, Patrick M., University of Michigan. Institute for Social Research. Survey Research Center; Schulenberg, John E., University of Michigan. Institute for Social Research. Survey Research Center
This survey of 12th-grade students is part of a series that explores changes in important values, behaviors, and lifestyle orientations of contemporary American youth. Students are randomly assigned to complete one of six questionnaires, each with a different subset of topical questions, but all containing a set of "core" questions on demographics and drug use. There are about 1,400 variables across the questionnaires. Drugs covered by this survey include tobacco, alcohol, marijuana, hashish, LSD, hallucinogens, amphetamines (stimulants), Ritalin (methylphenidate), Quaaludes (methaqualone), barbiturates (tranquilizers), cocaine, crack cocaine, GHB (gamma hydroxy butyrate), ecstasy, methamphetamine, and heroin. Other items include attitudes toward religion, changing roles for women, educational aspirations, self-esteem, exposure to drug education, and violence and crime (both in and out of school).
Access Notes
The public-use data files in this collection are available for access by the general public. Access does not require affiliation with an ICPSR member institution.
Study Description
Johnston, Lloyd D., Jerald G. Bachman, Patrick M. O'Malley, and John E. Schulenberg. Monitoring the Future: A Continuing Study of American Youth (12th-Grade Survey), 2005. ICPSR04536-v3. Ann Arbor, MI: Inter-university Consortium for Political and Social Research [distributor], 2007-07-18. https://doi.org/10.3886/ICPSR04536.v3
Persistent URL: https://doi.org/10.3886/ICPSR04536.v3
Export Citation:
- RIS (generic format for RefWorks, EndNote, etc.)
- EndNote XML (EndNote X4.0.1 or higher)
This study was funded by:
- United States Department of Health and Human Services. National Institutes of Health. National Institute on Drug Abuse (DA001411)
Scope of Study
Subject Terms: alcohol, attitudes, crime, drug education, drug use, families, gender roles, high school students, human behavior, lifestyles, religious attitudes, self esteem, social change, tobacco use, values, youths
Geographic Coverage: United States
- 2005
- 2005 (Spring)
Unit of Observation: individual
Universe: High school seniors in the contiguous United States.
For 2005, half of the questionnaire forms have a new version of the race question. Previously, the racial categories were Black and White. The new version includes Black, White, and Hispanic.
To protect the privacy of respondents, all variables that could be used to identify individuals have been collapsed or recoded in the public use files. These modifications should not affect analytic uses of the public use files.
Variables omitted from the Western region questionnaires are noted in each codebook.
A user guide is provided with the study documentation. It contains a year-to-year cross-time question index for the MTF 12th-grade surveys, which is sorted by subject area, item reference number, and questionnaire form.
MTF does not release detailed geography codes in its public use files because of the disclosure risk it would cause. The MTF sample is drawn to generate representative samples of the four Census Bureau regions of the country (Northeast, Midwest, South, and West), but it does not generate representative samples of smaller geographic areas such as states, counties, or cities. For additional information about data that is withheld from the public use files please contact MTF directly at firstname.lastname@example.com.
Sample: A multistage area probability sample design involving three selection stages: (1) geographic areas or primary sampling units (PSUs), (2) schools (or linked groups of schools) within PSUs, and (3) students within sampled schools. Of the 72 PSUs, 8 were selected with certainty, 10 were selected with a probability of .50, and the remainder were selected with a probability proportionate to the size of the senior class. In schools with more than 350 seniors, a random sample of seniors or classes was drawn. In schools with less than 350 seniors, all seniors were asked to participate. Each school was asked to participate for two years so that each year one-half of the sample would be replaced. Schools refusing participation were replaced with similar schools in terms of geographic location, size, and type of school (e.g., public, private/Catholic, private/non-Catholic). The total sample was divided into six subsamples consisting of an average of 2,300 respondents. Each subsample was administered a different form of the questionnaire, although all respondents answered the "core" drug and demographic questions. The participation rate among schools has been between 66 and 85 percent since the inception of the study.
Weight: Each of the seven parts contains a weight variable, V5. They were originally varied by school but were modified to protect respondent confidentiality. Users should use the weight variable for all analyses, the results of which will differ slightly from published data tables that used original data.
Mode of Data Collection: self-enumerated questionnaire
Response Rates: The overall student response rate for 2005 was 82 percent.
Extent of Processing: ICPSR data undergo a confidentiality review and are altered when necessary to limit the risk of disclosure. ICPSR also routinely creates ready-to-go data files along with setups in the major statistical software formats as well as standard codebooks to accompany the data. In addition to these procedures, ICPSR performed the following processing steps for this data collection:
- Standardized missing values.
- Created online analysis version with question text.
- Performed recodes and/or calculated derived variables.
- Checked for undocumented or out-of-range codes.
Original ICPSR Release: 2006-10-31
- 2007-07-18 The Core Codebook was updated to include an index of core drug variables sorted by substance category and form number. It will serve as a table of contents in the frequencies section of the codebook. Also the Base Year Question Index: 1976-2005 was updated to include a few missing question numbers previously omitted.
- 2007-05-17 The principal investigator supplied new data to correct one variable (V108) for Part 1: Core Data and to correct five variables (V1108, V1243, V1824, V1825, and V1826) for Part 2: Form 1 Data. Also updated the SAS setup and SAS supplemental syntax files for all seven parts to remove duplicate values embedded in the value labels.
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LGBT Community Eyes Obamacare
Equal access to Obamacare for all Americans – including lesbians, gays, bisexuals and transgenders.
It's a tall order, but ensuring it happens is now part of the mission at the U.S. Health and Human Services Office for Civil Rights. The agency is a nearly $40 million operation that historically has investigated discrimination charges against hospitals and other providers in cases that typically involved the disabled or minorities.
By year's end, if not before, the OCR will detail just how it plans to go about doing its new job of helping LGBT Americans gain equal access to the benefits outlined in the Patient Protection and Affordable Care Act.
Once it does, one of the more important battles in the fight for LGBT rights in the United States will have been won, at least on paper.
"Significantly, this is the first time that sex discrimination in health care is prohibited by a national civil rights law," HHS noted in its budget paperwork in early April.
PPACA is unequivocal on this point, promising health care regardless of race, color, national origin, disability, age or gender.
"Health is an LGBT equality issue," said Kellan Baker, associate director for LGBT research and communications at the Center for American Progress. "If we don't have our health, we don't have anything. I would say that the ACA and the changes at HHS are some of the most significant opportunities for LGBT equality that we have seen in a long time."
Hashing out just how to make it all work will be top of mind for the OCR in coming months. There will be a series of "listening sessions" before the final rules are crafted.
Equal rights are of keen interest to many Americans, but among those "listening" most intently are those in the LGBT community. Employers, insurers and the benefits community at large are paying close attention, too.
As advocates will point out, 51% of small business offer coverage to same-sex partners of employees, and more than 60% of Fortune 500 companies do the same. The PPACA promotes the expansion of these practices and authorizes the coming insurance exchanges to offer coverage that includes same-sex couples and their children.
The health system's problems can be especially pronounced in the LGBT community, advocates say, and discrimination that's based on real or perceived sexual orientation or gender identity is commonplace.
Access to health care services, including preventive care such as cancer screenings, are a huge part of the problem.
According to a 2011 report from the Center for American Progress, gay men and lesbians experience elevated rates of certain cancers, including breast cancer, melanoma, and non-Hodgkin's lymphoma, because of the difficulty they have in accessing health care. Also, lesbian and bisexual women are at greater risk than heterosexual women for chronic diseases linked to smoking and obesity.
The Center for American Progress is a left-leaning group, leaving it open to attack by skeptics. But its statistics about the health of the LGBT community are viewed as reliable as anyone else's, albeit incomplete.
The problem with LGBT health statistics in general is that, while there are more than 9 million Americans who identify as LGBT, federal and state governments have not routinely collected data on people's sexual orientation or gender identity.
That started to change in January of this year, when the federal government began to collect sexual orientation on its most important health assessment tool, the National Health Interview Survey. But there's a long way to go before enough of this data is collected, and doing so won't be easy.
Based on the numbers that are available, the National Academy of Sciences, in a report released in 2011, agreed that gay and transgender people often face "barriers to equitable health care" and receive substandard care when they seek it.
"Fearing discrimination and prejudice," it said, "many lesbian, gay, bisexual and transgender people refrain from disclosing their sexual orientation or gender identity to researchers and health care providers."
In part, that's because as states finalize the details of benefit plans and packages expected to be sold on the coming insurance exchanges, or marketplaces, the question is just how much variation might be seen between plans.
One big variable already identified clearly: While many of those with HIV live in the nearly 30 states that have either already opted for Medicaid expansion under PPACA or are in the process of doing so, there are many more who live in states still sitting on the sidelines.
And then there's the concern shared by all – whether the exchanges will be up and running in October.
"That's not a long time from now and we're talking about millions of people who will need help figuring out how to enroll themselves and their families. It's a real complicated challenge," Baker said.
It's a sentiment that helps explains another concern running through Baker's head:
"We really are looking forward to seeing some strong implementation of Section 1557 of the law."
This article was originally posted at BenefitsPro.com, a sister site of Credit Union Times.


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UEFA European Football Championship safety an INTERPOL priority
To assist local police authorities in making the 2012 UEFA European Football Championship in Ukraine and Poland as safe as possible for the players, officials and thousands of expected spectators, two INTERPOL Major Events Support Teams (IMESTs) have been deployed to the two host countries to help detect potential threats of terrorism, hooliganism and serious crime and to facilitate the real-time exchange of key police information to secure their borders.
Composed of experienced specialized police officers and highly trained operational assistants, the two IMEST teams were put in place ahead of the opening of the event (8 June – 1 July), to help make critical data accessible to key security officials in the two host countries.
The IMEST teams will help local police forces secure the four-week event by facilitating access to INTERPOL's secure network which permits the exchange of vital police data such as fingerprints, images, stolen identity documents and wanted person profiles with all 190 INTERPOL member countries, allowing police in the field to quickly identify potential criminals.
"The 2012 UEFA European Football Championship is not exclusively a Ukrainian and Polish event. From a security standpoint, it is an international event, with all the security risks that entails," commented Michael O'Connell, Director of Operational Police Support at INTERPOL's General Secretariat headquarters in Lyon, France.
"The safety of thousands of fans over the next four weeks is INTERPOL's current top priority, which is why the INTERPOL IMEST teams will be there throughout the event to provide operational support to national law enforcement authorities, along with the INTERPOL National Central Bureaus in Warsaw and Kiev," O'Connell added.
With thousands of visitors travelling to Poland and Ukraine during the tournament, ensuring security is the top priority for local law enforcement, as terrorists and other international criminals might try to use falsified, stolen or lost passports to conceal their identities and enter the country to engage in criminal activities.
To counter this threat, IMEST staff in Kiev and Warsaw will be able to process and check thousands of identity profiles with instant, direct access to INTERPOL's Stolen and Lost Travel Documents (SLTD) database, which contains information on more than 32 million travel documents reported as lost or stolen by 163 countries and enables immigration and border control officers to ascertain the validity of a suspect travel document in seconds.
To date, some 70 IMESTs have provided support to countries across the world. INTERPOL is also preparing to deploy an IMEST to London to boost security at the London 2012 Olympic and Paralympic Games.
Interview: Lieutenant Colonel Rafal Lysakowski - Head of NCB Warsaw
Interview: Major General Vasyl Nevolia
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In a Dilbert cartoon published on August 13, 2011 in the Sun-Sentinel, the nerdy engineer was offered one million dollars a year to work at a hedge fund. All Dilbert had to do was pretend he created an algorithm that makes winning trades. The hedge fund manager assured Dilbert that he would do the insider trading. Unfortunately, in real life, there have been investment advisors with business models that aren't much different.
Investment advisors should not need a code of ethics to help them distinguish between right and wrong. Nevertheless, the Code of Ethics Rule, found in Rule 204A-1, helps to ensure that IARs do the right thing. It provides oversight that can ferret out wrongdoing. All SEC-registered investment advisors must adopt and enforce a code of ethics. Some states have also implemented a code of ethics requirement.
The consequences for violating the Code of Ethics Rule are severe. On March 9, 2009, the SEC filed a fraud action against Locke Capital Management. Among other allegations in the SEC's complaint, the RIA was accused of not having a code of ethics. The Commission further alleged that the firm's principal made numerous misrepresentations. The advisor lied about the firm's performance for years, and about the number of clients the firm had. Even if this RIA had implemented a code of ethics, it does not appear that the advisor would have been deterred from this type of misconduct. You can read more about this case at:
Nevertheless, a code of ethics can serve important purposes at advisory firms. The fact that an RIA owes a fiduciary duty is an abstract concept. A code of ethics brings specificity to concepts that might otherwise be abstract.
Rule 204A-1 of the Investment Advisers Act
Access persons should pay particular attention to the Code of Ethics Rule. An access person is a supervised individual who has access to nonpublic information pertaining to clients' purchases or sales of securities and makes securities recommendations to clients. The definition also includes supervised persons who have access to non-public information about the portfolio holdings of affiliated mutual funds. Just about every IAR of an advisory firm will meet the definition of access person.
Pursuant to Rule 204A-1, each SEC-registered RIA must adopt a code of ethics that does the following:
- Sets forth a standard of business conduct required of all employees that, at a minimum, reinforces the RIA's fiduciary obligations and requires compliance with the federal securities laws
- Requires an RIA's access persons to report their personal securities transactions and holdings on an initial and ongoing basis
- Requires an RIA's access persons to obtain the advisor's approval before investing in an Initial Public Offering (IPO) or private placement
- Requires an advisor to maintain and enforce the code of ethics, including reviewing the personal trading reports to identify improper trades or patterns of trading and promptly reporting any violations
- Requires an RIA to provide a copy of the code of ethics to all employees and to obtain each employee's written acknowledgment of receipt
A code of ethics must require all supervised persons to promptly report violations to the CCO or other appropriate personnel, as long as the CCO gets a copy. RIAs may permit reports to be submitted anonymously. It is recommended that whistleblowers be afforded protection from retaliation. They might also be protected from retaliation by the SEC's new rule relating to whistleblowers, which we will examine in Whistleblowers.
Doing the Bare Minimum is not Enough
An RIA's code of ethics should go well beyond the minimum requirements stipulated by Rule 204A. An RIA may elect to implement a code of ethics that requires:
- prior written approval before access persons can implement any personal securities transaction, commonly referred to as a pre-clearance of these trades;
- maintenance of lists of issuers of securities that the RIA is analyzing or recommending for client transactions, and prohibitions on any trading (personal or for clients) in securities of those issuers;
- maintenance of restricted lists of issuers about which the RIA has inside information, and prohibitions on any trading (personal or for clients) in securities of those issuers;
- blackout periods for personal trades;
- training and communication to remind employees that investment opportunities must be offered first to clients before acting upon them, and implementing procedures to enforce this principle;
- prohibitions or restrictions on short-swing trading and market timing;
- requirements to provide the CCO with duplicate trade confirmations and account statements;
- requirements to trade only through certain brokers, or limitations on the number of brokerage accounts permitted; and
- procedures for assigning new securities analysis responsibilities to employees whose personal holdings do not present apparent conflicts of interest.
Although RIAs are not required to implement these requirements, there must be strict compliance with them after they are adopted.
Purpose of the Code of Ethics Rule
One goal of the Code of Ethics Rule and personal securities transactions reporting requirements is to ensure that RIAs comply with their fiduciary duty to keep clients' security holdings and financial circumstances confidential. Each RIA's code of ethics must maintain and enforce procedures to prevent the misuse of material nonpublic information about the adviser's securities recommendations, client securities holdings, and transactions.
Reporting personal securities transactions prevents misuse of confidential information. An RIA's code of ethics must also require the review of such reports in order to identify improper trades or patterns of trading by access persons.
The purpose of the Code of Ethics Rule and restrictions on personal trading is to prevent misconduct such as:
- potential misuse of nonpublic information;
- inappropriate allocation of investment opportunities like IPOs;
- failure to report new accounts; and
- front-running.
Front running occurs when an RIA takes advantage of advance knowledge of pending transactions involving the firm's clients.
Who is an Access Person?
Rule 204A-1 under the Investment Advisers Act is better known as the Code of Ethics Rule. The rule focuses on access persons who, not surprisingly, have access to confidential information that might be exploited for personal gain. Rule 204A-1(e)(1) defines access persons to include any supervised person who:
- has access to nonpublic information regarding a client's securities transactions or holdings;
- is involved in making securities recommendations to clients; or
- has access to nonpublic securities recommendations.
An access person might also be someone who has access to nonpublic information regarding the securities holdings of affiliated mutual funds.
If providing investment advice is an RIA's primary business, an access person includes any director, officer, or partner of the RIA. The definition of access person also includes any employee with access to that kind of information. All of these individuals are subject to the Code of Ethics Rule, because they are in a position to take advantage of nonpublic information about clients' securities holdings and transactions.
An RIA's access persons may go far beyond high-level employees. According to the SEC's adopting release, administrative, technical, and clerical personnel may be viewed as access persons if their duties give them access to nonpublic information. In some circumstances, a summer intern may fall within the definition of access person and could be subject to the reporting requirements imposed by the Code of Ethics Rule. In some firms, all employees are treated as access persons.
Holdings Reports
A firm's CCO can uncover potential misconduct by reviewing each access person's holdings reports. Holdings reports provide a trail for investigating an access person's misuse of non-public information, and contains a complete listing of the access person's securities holdings (see Figure 9-1).
Initial/Annual Holdings Reports
The annual holdings report must be submitted at least once during each twelve-month period and thereafter on a date selected by the RIA. The information must be current as of a date no more than 45 days prior to the date the report was submitted.
For new access persons, initial holdings reports must be submitted no later than ten days after the individual becomes an access person. The report must be current no more than 45 days prior to the individual becoming an access person. These holdings reports must be submitted to a designated person, usually the CCO.
At a minimum, each holdings report must contain the following:
- The title and type of security, and as applicable the exchange ticker symbol or CUSIP number, number of shares, and principal amount of each reportable security in which the access person has any direct or indirect beneficial ownership
- The name of any broker, dealer, or bank with which the access person maintains an account in which any securities are held for the access person's direct or indirect benefit
- The date the access person submits the report.
*Used with permission from National Compliance Services, Inc.
Quarterly Transaction Reports
The code of ethics must require quarterly reports of certain personal securities transactions by access persons, which are due no later than thirty days after the close of the calendar quarter. An RIA may excuse access persons from submitting transaction reports that would duplicate information contained in trade confirmations or account statements, so long as the advisor has received them no later than thirty days after the close of the calendar quarter in which the transaction takes place (see Figure 9-2).
Even though an RIA is filing quarterly transaction reports, it must still file an annual holdings report. The annual holdings report provides examiners with a snapshot of access persons' holdings. Examiners cannot be expected to compile them from the quarterly transaction reports.
At a minimum, each transaction report (both quarterly and annual) must contain the following information about each transaction involving a reportable security in which the access person had, or because of the transaction acquired, any direct or indirect beneficial ownership:
- The date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and principal amount of each reportable security involved
- The nature of the transaction and whether it is a purchase, sale, or any other type of acquisition or disposition
- The price of the security at which the transaction was effected
- The name of the broker, dealer, or bank with or through which the transaction was effected
- The date the access person submitted the report
Figure 9-2. Quarterly Report of Personal Securities Transactions
To: Chief Compliance Officer, (Insert the name of Investment Adviser)
From: _________________________________________
Note: in lieu of the reporting form, duplicate copies of brokerage statements may be submitted provided the statements include the information required below
Re: Quarterly Report of Personal Securities Transactions pursuant to Rule 204-2(a)(13) of the Investment Advisers Act, as amended:
During the quarter ending______, I have purchased, sold, or have otherwise obtained Beneficial Ownership in the following securities:
Signed: _____________________________ Date: __________________
Report reviewed by: _________________ Date: __________________
*Include interest rate and maturity date if applicable (Use additional sheet(s) if necessary)
*Used with permission from National Compliance Services, Inc.
Exceptions to Reporting Requirements
Certain types of personal securities transactions need not be reported. A firm's code of ethics need not require an access person to submit:
- any report with respect to securities held in accounts over which the access person had no direct or indirect influence or control;
- a transaction report with respect to transactions effected pursuant to an automatic investment plan;
- a transaction report if the report would duplicate information contained in broker trade confirmations or account statements that are held in the RIA's records, so long as it receives the confirmations or statements no later than thirty days after the end of the applicable calendar quarter.
Reportable Securities
In general, access persons must submit holdings and transaction reports for "reportable securities" in which the access person has, or acquires, any direct or indirect beneficial ownership. The term "reportable securities" consists of all securities, except those falling within the following five exceptions from the reporting requirements under Rule 204A-1:
- Direct obligations of the Government of the United States
- Money market instruments, bank certificates of deposit, commercial paper, and high quality short-term debt instruments, including repurchase agreements
- Shares of money market funds
- Shares of open-end mutual funds, unless the advisor or a control affiliate acts as the RIA or principal underwriter for the fund
- Shares of a unit investment trust if it is invested exclusively in unaffiliated mutual funds
In a July 28, 2010 no-action letter to the law firm of WilmerHale, SEC staff stated that Section 529 plans are not reportable securities. The investments in Section 529 plans present little opportunity for improper trading that transaction and access reports were designed to uncover. Therefore, the SEC would not recommend enforcement action against an RIA for failing to keep records regarding access persons' transactions and holdings in Section 529 plans. The no-action letter can be found at
Recordkeeping Requirements
When it adopted the Code of Ethics Rule, the SEC also amended Rule 204-2, more commonly known as the Books and Records Rule. An RIA must retain a copy of the following books and records:
- Code of ethics
- Records of code violations
- Records of actions taken as a result of code violations
- Supervised persons' written acknowledgment of receipt of the code
- Record of the names of its access persons
- Holdings and transactions reports made by its access persons
- Records of decisions approving access persons' acquisition of securities in IPOs and limited offerings
As noted previously, an RIA in Santa Monica, California, received severe sanctions for failing to comply with the Code of Ethics Rule. Among other violations, the SEC charged the RIA and its principals with failing to make and/or retain copies of employees' acknowledgments that they received the firm's code of ethics. The RIA received deficiency letters in 2005 and 2008 notifying the firm of that requirement. In today's compliance environment, it is very doubtful that an RIA will get more than one opportunity to correct a deficiency.
The penalties for compliance violations are also likely to become much tougher. On November 28, 2011, the SEC issued an order against Asset Advisors, an SEC-registered firm in Troy, Michigan. The RIA did not adopt a code of ethics until SEC examiners ordered the firm to do so after an examination. After the code of ethics was adopted, the firm failed to abide by it. Asset Advisors agreed to pay a $20,000 penalty, but that wasn't the extent of the SEC's sanctions. The RIA was required to de-register with the Commission and shift the firm's accounts to another advisor that maintained a viable compliance program.
Optional Provisions in Codes of Ethics Such as Gift Giving
A code of ethics only establishes a minimum standard of conduct. RIAs are free to set higher standards. A code of ethics should challenge employees to do more than just live up to the letter of the law. It might also be a reflection of the ideals to which the firm aspires.
In footnote 17 of the Adopting Release for Rule 204A-1, the SEC stated that RIAs should consider putting limitations on acceptance of gifts in their codes of ethics. Nevertheless, even though an RIA must have a code of ethics, it need not implement restrictions on accepting or giving gifts. A dually-registered advisory firm, however, is also bound by FINRA's rules governing gift giving.
Accepting gifts may lead to allegations that an RIA has breached its fiduciary duty to clients. A fiduciary must always act in the client's best interest and disclose any conflicts. Therefore, an RIA's policy on giving and accepting gifts should be disclosed in the firm's Form ADV brochure, which will be discussed in The New and Improved Form ADV. When clients read in the Form ADV that the RIA accepts gifts, they may question whether the firm has a conflict of interest. The giving or receiving of gifts may give the impression that the RIA is not giving objective advice.
Another problem is that an unscrupulous employee may have a questionable relationship with a client. The managing partner of one RIA discovered that his secretary was receiving monetary gifts from an elderly client. This conduct should be forbidden in a code of ethics, because the secretary might be exerting undue influence over the elderly client.
Best Practices for Gift Giving and Receiving
A code of ethics is only the beginning. An RIA should strongly consider raising the bar by establishing a stronger code of ethics. Best Practices go above and beyond the obligations established by the Investment Advisers Act and its rules.
As related to gift giving, here are best practices that should be considered:
- No supervised person may receive any gift, service, or other item of more than de minimis value from any person or entity that does business with or on behalf of the RIA, including clients.
- No supervised person may give or offer to give any gift of more than de minimis value to existing clients, prospective clients, or any entity that does business with or on behalf of the RIA without pre-approval by the firm's CCO.
- No supervised person may give or accept extravagant forms of entertainment, such as tickets to a concert or sporting event, to a person or entity who does or seeks to do business with or on behalf of the RIA.
- Business entertainment above a reasonable value must be pre-approved. An offer of travel expenses or hotel accommodations must also be pre-approved, such as the cost of attending a seminar sponsored by a vendor in a popular tourist destination.
It is a best practice for RIAs to create and retain logs of gifts given and received. The firm's CCO can then investigate accounts where gifts were given or received to see if any special treatment was given.
The firm's policies and procedures should define "gifts" to include discounts on products and services that are not available to the general public. Certain types of gifts and entertainment must always be approved, such as gifting involving public officials and government entities. As we will see in Pay-to-Play Rule, violations of the pay-to-play rule can effectively bar an RIA from doing business with government entities.
It is wise for an RIA to define what is meant by "nominal" or de minimus. Usually, the definition includes a dollar limitation, such as $100. Although $100 does not go as far as it used to, many RIAs' compliance policies stipulate that a gift greater than that amount is not nominal.
The Big Picture
In an ideal world, instituting a code of ethics would ensure that all advisory personnel would act ethically in all of their dealings with investors. Unfortunately, even if Bernard Madoff's advisory firm had implemented a code of ethics, it is still quite likely that he would have cheated investors with his Ponzi scheme. Judging from Madoff's apparent lack of a personal moral compass, it is doubtful that he would have complied with his firm's code of ethics.
Although it cannot necessarily prevent RIAs and IARs from acting improperly, the Code of Ethics Rule was enacted with good intentions. The rule requires federally-registered investment advisors to report important information about their securities holdings. Even where there is no code of ethics requirement, state-registered advisors may wish to adopt one in order to reinforce the fiduciary duty owed to clients. An RIA's code of ethics may be a separate document or it can be incorporated by reference into the firm's policies and procedures.
Certainly, an RIA's code of ethics must satisfy all of the minimum requirements set forth in Rule 204A-1. Examiners are likely to look more favorably on advisory firms that exceed the minimum requirements of the Code of Ethics Rule. Furthermore, there must be documentation to demonstrate that the RIA is enforcing the Code of Ethics Rule. Having a strong code of ethics is meaningless without enforcement.
The Code of Ethics Rule will also help an RIA to guard against insider trading by controlled persons. Under Section 21A of the Securities Exchange Act of 1934, controlling persons of an advisory firm will not be subject to civil penalties unless they "knowingly or recklessly failed to establish, maintain, or enforce any policy or procedure required under section 15(f) or section 204A of the Investment Advisers Act of 1940 and such failure substantially contributed to or permitted the occurrence of the act or acts constituting the violation."
A code of ethics can also reinforce other policies and procedures in the RIA's compliance manual. For example, a firm doing business with government entities may be required to comply with the SEC's pay-to-play rule or similar state regulations. One section of the RIA's compliance manual will establish policies and procedures for employees to follow. The RIA's code of ethics may also address the importance of following the pay-to-play rule when dealing with government entities and officials.
Implementing a code of ethics may even give RIAs a marketing advantage. Since RIAs post a copy of their code of ethics on their websites. In addition, RIAs are required to describe their code of ethics in their Form ADV disclosure brochures, which we will discuss in The New and Improved Form ADV.


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Product Description
Bring our bib clips into your diaper bag and never tote another sticky bib or carry around a messy bib!
These nifty clips turn almost anything into an instant bib: restaurant napkins, paper towels, even cloth diapers or towels. Adjustable strap, easy to clean and simple to use.
Specifications superbuy:XME1415
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PYZ is a Z-Machine interpreter for playing interaction fiction files. Text adventure games written by Infocom, such as the Zork series, used a then-revolutionary virtual machine called the Z-Machine, which saved code space on the memory-limited computers of the 1980's. People today are still writing text games, now called interactive fiction, for the Z-Machine platform. PYZ includes a mode in which you can see the instructions being executed, turned on by the --trace option. A test suite, pyztest, tests all the instructions.
PeRKy is computer software dedicated to management of software requirements with any Source Control Manager (abbreviated SCM) as a storage layer, based on a simple principle: 1 file per requirement. PeRKy helps developers keep documentation in sync with their code by using the same tools for both. It also integrates notions of distributed development, and thus highly limits the risk of encountering conflicts when merging branches of development.
Fivebit is a Python 3 compression library for short text strings. It compresses short strings of text into five bit encoding, which yields a 37.5% reduction for lowercase ASCII. There is also a dictionary for the 1024 most common English words (3 letters or longer). Punctuation, digits, and normal symbols will usually take up 10 bits each, and oddball Unicode characters will take up more space again.
Find What I Mean aims to provide a searching library that tolerates errors in queries. It will auto-correct typos, extra letters, and so on. This is extremely useful when searching for an item in a list. In traditional search methods the query must be perfect or you get zero matches.
Bletchley is a real-world cryptanalysis framework. It was created to assist with the detection, analysis, and exploitation of cryptographic flaws and aims to help automate the tedious aspects of this analysis while leaving the security expert in control of the process. It features automated token encoding detection (36 encoding variants), passive ciphertext block length and repetition analysis, a script generator for efficient automation of HTTP requests, and a flexible, multithreaded padding oracle attack library with CBC-R support.
A live CD for creating a secure, isolated working environment.
A distance-vector routing protocol for IPv6 and IPv4.


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This dataset is maintained and distributed by the National Archive of Criminal Justice Data (NACJD), the criminal justice archive within ICPSR. NACJD is primarily sponsored by three agencies within the U.S. Department of Justice: the Bureau of Justice Statistics, the National Institute of Justice, and the Office of Juvenile Justice and Delinquency Prevention.
Attitudes and Perceptions of Police Officers in Boston, Chicago, and Washington, DC, 1966 (ICPSR 9087)
Principal Investigator(s): Reiss, Albert J. Jr.
This survey was designed to explore perceptions and attitudes of police officers in three metropolitan areas toward their work and the organizations and publics with which they interact. Issues of interest include (1) the nature of police careers and police work, and officers' satisfaction with their jobs, (2) officers' orientations toward policing tasks and their relationships with the public, and (3) officers' perceptions of organizations and systems that influence or change police work.
Access Notes
The public-use data files in this collection are available for access by the general public. Access does not require affiliation with an ICPSR member institution.
ASCII + SAS Setup SPSS Setup Stata Setup
Study Description
Reiss, Albert J. Jr. Attitudes and Perceptions of Police Officers in Boston, Chicago, and Washington, DC, 1966. ICPSR09087-v1. Ann Arbor, MI: Inter-university Consortium for Political and Social Research [distributor], 1999. https://doi.org/10.3886/ICPSR09087.v1
Persistent URL: https://doi.org/10.3886/ICPSR09087.v1
Export Citation:
- RIS (generic format for RefWorks, EndNote, etc.)
- EndNote XML (EndNote X4.0.1 or higher)
This study was funded by:
- President's Commission on Law Enforcement and the Administration of Justice (OLEA-006)
Scope of Study
Subject Terms: career choice, career expectations, job satisfaction, perceptions, police community relations, police officers, work attitudes
Geographic Coverage: Boston, Chicago, District of Columbia, Illinois, Massachusetts, United States
- 1966-06
- 1966-06
Universe: Police officers in major metropolitan areas of the United States.
These data are part of a larger study entitled "Field Surveys III: Studies in Crime and Law Enforcement in Major Metropolitan Areas." ICPSR distributes two related data collections: SURVEY OF VICTIMIZATION AND ATTITUDES TOWARDS CRIME AND LAW ENFORCEMENT IN BOSTON AND CHICAGO, 1966 (ICPSR 9085) and PATTERNS OF BEHAVIOR IN POLICE AND CITIZEN TRANSACTIONS: BOSTON, CHICAGO, AND WASHINGTON, DC, 1966 (ICPSR 9086).
Sample: Three sample cities (Chicago, Boston, and Washington, DC) were purposively selected to represent differences in the size, location, degree of control, and type of organization in police departments. Within each city, two police precincts (four in Washington, DC) with high crime rates were selected to represent areas with different race and class compositions. The selected sites were (1) Boston, MA: precincts Dorchester and Roxbury, (2) Chicago, IL: precincts Fillmore and Town Hall, and (3) Washington, DC: precincts 6, 10, 13, and 14. Simple random samples of approximately 25 police officers in each of the eight precincts were drawn from department rosters. The response rate was nearly 100 percent.
personal interviews
Original ICPSR Release: 1989-05-04
- 2005-11-04 On 2005-03-14 new files were added to one or more datasets. These files included additional setup files as well as one or more of the following: SAS program, SAS transport, SPSS portable, and Stata system files. The metadata record was revised 2005-11-04 to reflect these additions.
- 1999-10-07 SAS and SPSS data definition statements and a PDF version of the codebook have been added to this collection.
Related Publications
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Dreaming of hope from above for Syria
Join us throughout October in sharing your dreams for the refugees of the Syrian conflict by visiting the Share My Dream site and using the #Dreamshare hashtag.
Today, blogger Ed Cyzewski shares his dreams for the Syrian refugees: that hope rather than bombs would come from the sky.
* * *
I live in Columbus, Ohio, and am just a short drive away from the airport. I see planes cruising in to land as they fly over the local university. The sound and sight of planes is comforting and even reminds me of my hometown.
Growing up in Philadelphia, we lived in the flight path of planes landing at the Willow Grove Naval Air Station in the suburbs. Every day, I'd watch large transport planes lumber over myself and my friends as we played stick ball in the summer and hockey in the winter.
Planes followed me when I moved into my dad's new home in South Jersey near the Philadelphia International Airport. Planes flew over our home over and over again each day.
As the sun set in the evening, I could see the planes shining in the swirls of an orange, purple, and yellow sky and imagine the stories of the passengers. Some were returning home from a business trip, others were visiting family, and still others were returning from a vacation. I wondered if anyone would be waiting for them when they arrived at the airport.
That positive experience of planes changed for me when I studied in Israel during the fall of 2000.
The sonic boom of Israeli warplanes often interrupted our days while we studied in the library or strolled by the shops and food stalls in the Arab quarter. Our instructors told us that the sonic booms were a reminder of military might.
Those booms didn't stop the Palestinians from staging an uprising in the fall that led to many deaths and injuries. We heard gunfire every evening as soldiers and demonstrators fought each other to the south of Jerusalem.
Through that semester, I lived in a city where children played in the streets without fear, even if the sounds of violence were never far away. As I talked to the people who lived with this reality every day, I caught a tiny glimpse of what it feels like to live in fear of attack. However, the threat of attack also disrupted the local economy and brought concerns over how to pay for food and medical needs.
We tend to think of the terror of getting shot during war, but I've since learned that there are other terrors and fears that rise up in the midst of armed conflicts. There are fears such as where your next meal will come from, how you'll earn money, how to provide an education for children, or where you'll be able to sleep in safety.
The sound of planes above was a reminder of hope and stability during my childhood. For these children, they heralded an ongoing conflict that they will most likely inherit.
These children played outside each day with the white noise of gunshots and sonic booms in the distance, but they at least had the benefit of family networks, neighbors, and the relative security of their own homes. However, today there are millions of refugees who have fled the conflict in Syria living without any guarantees of security or stability in the near future.
They live with the full spectrum of fear, worrying about their day-to-day needs, the safety of loved ones, and the future of their nation. They've been removed from their support networks and any sense of normal life. Artillery shells and military aircraft have brought destruction from above.
During a war, an airplane in the sky could deliver bombs or relief supplies.
Millions of families fled the conflict in Syria because they feared the former and hope for the latter.
It's my dream that the refugees from the Syrian crisis can soon return to safe and secure homes in a stable nation. But for today, we can pray for their safety, share their story, and contribute toward World Vision's relief efforts that are providing education, clean water, food, and medical supplies.
We may feel helpless about "solving" the Syrian crisis. However, that's never been our role. We can take steps to alleviate the day-to-day fears and tensions of refugee life and give the refugees from Syria the tools and resources they need to restore stability in their lives. We can be a surrogate family that helps them reestablish themselves.
The refugees from Syria are neighbors -- distant neighbors, but neighbors nonetheless -- who are wounded along the side of the road. We can be a part of the hope that comes from above, helping people find a measure of peace and stability so that they can begin to rebuild their lives.
When the children of Syria see planes in the future, my dream is that they may remember the day their families received help as they started a new chapter in their lives.
Make a one-time donation to help World Vision provide emergency assistance for Syrian refugees. Your donation will help us provide basic hygiene kits and food vouchers for refugee families, as well as established Child-Friendly Spaces to provide affected children with a safe place to play, learn, and interact with their peers.
Pray for children and families impacted by the violence in Syria. Pray especially for families who have been separated due to the conflict, and pray for emotional and physical protection for vulnerable children and families. Consider using our prayer points to help guide your prayers.


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Burning Heart with Wings
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Cut from high quality vinyl that has an outdoor life expectancy of 5-8 years. The decal will be white, the background will be whatever you are putting the decal on, this is a single color white decal. Each decal will come on clean transparent transfer tape (not paper)for very easy application. Can be applied on outside of any smooth, flat, clean and dry surface. Great on laptops, glass, car windows, use your imagination. Instructions for application will also be provided.
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Bloomberg reports that Motorola
about 100,000 Droid phones the first weekend it was available.
Verizon Wireless reportedly had about 200,000 Droids on hand and
stores sold about half their stock on opening weekend. Analysts
predict that Motorola will sell a million phones that run Android,
counting the Droid and others, in Q4 2009.
Predictions have
Motorola selling about 10 million Android phones in 2010. The Droid
is competing against the iPhone for market dominance and is hailed by
many as one of the fittest challengers to the Apple device yet.
Still, the launch of the Droid was nothing compared to the massive
launch of the iPhone.
Analyst Jim Suva from Citigroup said,
"It wasn't as good as the iPhone, but anybody that was
expecting that had their expectations too high." Suva recommends
buying Motorola shares.
The Droid sells for $199.99 after a
$100 mail-in rebate making it more expensive than the 16GB iPhone 3GS
which can be had for $199 with no rebate required. However, the
iPhone is hamstrung by a notoriously shoddy AT&T 3G network that
results in significant amounts of dropped calls and patchy 3G
connectivity in even the largest cities.
Analyst Mark
McKechnie said, "I see the first few days as encouraging. There
seems to be pretty good demand -- they've taken the right steps and
picked a good partner with Google on the Android side."
all analysts are convinced that the Droid or Android-powered devices
in general will resonate with shoppers. Tero Kuittinen told
Bloomberg, "I have this nagging suspicion that Android is
being overestimated by technology enthusiasts." He is advising
investors to sell Motorola shares.


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Your tax invoice can be downloaded on flysaa.com under Manage & Fly 72 hours after the e-ticket has been issued.
If a Tax Invoice has been successfully generated from the South African Airways Tax Invoice System, the onus rests on the recipient to ensure that his/her mailbox has enough space to receive an e-mail - with a PDF attachment; and that his//her service provider or exchange server allows for delivery of such e-mails. South African Airways, can not take responsibility for undelivered e-mails due to any other reasons beyond our control including the above.
Prescribed details required from the South African Revenue Service on a tax invoices
Tax invoices must ordinarily reflect the following details as prescribed by the South African Revenue Service Act, 1997 (Act No. 34 of 1997):
Johannesburg. 4 December 2009
South African Airways (SAA), the leading airline on the African continent and Match, the official provider of tickets, accommodation and logistics for next year's football event, have concluded a historic partnership.
According to this agreement reached between Africa's most awarded airline and Match, South African Airways will be providing 89 000 sectors on its own fleet of aircraft to be used by Match customers.
The sectors will be operated by SAA aircraft on the Golden triangle, which include flights between Johannesburg to Cape Town, and to Durban as well as between Durban and Cape Town.
SAA is also working on other transport solutions with Match to find ways of transporting Match customers to smaller venues such as Nelspruit, Bloemfontein and Polokwane where matches will take place.
SAA is the first airline on the African continent to be concluding a deal with Match, FIFA's preferred partner for the forthcoming major football events where the best teams in the world will be battling it out for the world's foremost and most prized football trophy.
"As the national carrier we are very pleased to conclude this agreement with Match," says Chris Smyth, SAA Acting CEO. "We eagerly await next year's event and the opportunity to welcome fans from across the globe to our beautiful country".
Issued by SAA Group Corporate Affairs


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Libyan Minister of Interior visit to INTERPOL focuses on national and global security issues
LYON, France – Identifying ways to further enhance cooperation with INTERPOL was the focus of a visit by Libya's Minister of Interior, Fawzi Altaher Abdulaali to the world police body's General Secretariat headquarters today.
Minister Abdulaali met with INTERPOL Secretary General Ronald K. Noble to discuss a range of law enforcement and security issues, including increased information exchange and expanding access to INTERPOL's databases and tools to strategic border points to help track down fugitives and identify transnational organized crime and drug trafficking links.
"Libya is committed to continuing to work closely with INTERPOL in combating all forms of transnational crime, and we look forward to further developing our already strong cooperation," said Minister Abdulaali.
"The visit by Minister Abdulaali and his delegation to INTERPOL has enabled us to identify the areas where INTERPOL can provide added value and support to their national law enforcement efforts, which will benefit Libya and all of our member countries, " said INTERPOL Secretary General Ronald K. Noble.
The Libyan delegation, which included the General Director for relations and international cooperation, Brigadier Abdul Monem Ettunsi, Director of National Public Safety Department, Brigadier Snous Zraib and Head of National Central Bureau Tripoli Colonel Abdul Hamid Elgazali, was also briefed on INTERPOL's law enforcement tools and services, as well as regional and international operations.


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For your convenience, you may narrow down your search by selecting a "SERIES" from the 'SHOP BY' column located on the right side of this page. This simple feature will assist you in finding the correct replacement filter(s) for your AustinAir® air purifier.
1 item
Austin Air Baby's Breath Replacement Filter Set
Regular Price: $219.99
Lowest Price: $184.99
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Peavy lifts no-trade clause for White Sox
Chicago sends four pitchers to Padres in second try for deal
By Scott Merkin / MLB.com
"It goes back a while," said the White Sox general manager, speaking in the home dugout at U.S. Cellular Field after acquiring Peavy for Clayton Richard and three top Minor Leaguer hurlers just seconds before Friday's non-waiver Trade Deadline of 3 p.m. CT. "It goes back to last year's Trade Deadline, when I first tried to acquire Jake."
The more publicized attempt by Williams to pry Peavy from his former club came on May 21, when the White Sox had a deal in place, pending Peavy waiving his full no-trade clause. As Williams pointed out on Friday, Peavy and his family were caught off-guard at the time and the right-hander never said no.
Regardless of the semantics, Peavy did not join the White Sox that day, the same afternoon when Minnesota hung a 20-1 home loss on the South Siders. At that point, the White Sox had a 17-23 record and sat 6 1/2 games out of first place in the competitive American League Central, while the Padres were in National League West contention.
Clearly, those respective situations have changed.
"In May, we didn't think it was the right time," said Peavy, speaking during a press conference in San Diego on Friday. "Now, things are a little bit different on a lot of fronts. I'm excited to go to an organization that has made winning a priority."
"He said not yet," said Williams of Peavy's initial response. "Those words meant just that. If you allow the process to play out sometimes and you are patient in your pursuit, then sometimes you can get what you want."
Williams said the conversations with San Diego general manager Kevin Towers literally didn't start again until Friday morning. Towers admitted that he began Friday not expecting to move Peavy, but Williams wanted to avoid the potential trade being discussed and dissected in the court of public opinion as it was in May.
There was contact made by Williams with Peavy's agent, Barry Axelrod, to see if Peavy would now waive his no-trade clause. Peavy couldn't be reached early Friday morning because his cell phone was turned off as he and his family slept in, but Axelrod went over to Peavy's house to get the official word.
As the Trade Deadline quickly approached, Williams wasn't sure if the deal would be done in time -- even with Peavy's approval in tow.
"Literally, with two minutes left, I'm on the phone with Axelrod and I'm on the phone with Kevin Towers, and [assistant general manager] Rick Hahn is on the phone with Major League Baseball because it has to be in," said Williams with an exasperated laugh. "I really didn't think it all was going to come together in the end. I was prepared for it to not meet the deadline. It all came together with 23 seconds on the clock."
Adding Peavy meant that the White Sox gave up Friday's scheduled starter Richard, who had allowed two runs combined in his last 16 innings over two starts, Aaron Poreda, Adam Russell and Dexter Carter. Poreda, a hard-throwing left-hander, was the team's top pick in the 2007 First-Year Player Draft. They were the same four players agreed upon when the deal was first put in place back in May.
Peavy has been on the disabled list with a strained tendon in his right ankle since June 13. Williams said he is not expected back until the White Sox 11-game road trip to Boston, New York, Minnesota and Wrigley Field from August 24 to Sept. 3, but the good news is that this particular injury is exacerbated more by running the bases-not an American League concern for Peavy.
With the AL Central as tight as it currently stands, Williams can handle the wait for this possibly mammoth September callup.
"He's champing at the bit right now, but we are going to be conservative with our approach," said Williams of Peavy, who will start a rehab assignment in the middle of August and has a 6-6 record with a 3.97 ERA this season. "This thing is going to come down to winning games in September in our division, and we want to be as strong as we possibly can be in September. That's what we are focused on."
"A couple of mound sessions and I'll do whatever the White Sox want," Peavy said. "I've thrown on flat ground, and we were certainly going to take it as slow as we could [in San Diego] because the goals were different. I think I'm healthy. I'm a little weak in the ankle and the arm isn't as caught up as where it should be this time of year."
Peavy, 28, is signed through 2012 and is owed $48 million over the next three seasons. The White Sox did not receive cash considerations along with Peavy, but they did not have to guarantee Peavy's $22 million club option in 2013.
Even if Peavy's contributions are limited in 2009, the team has an extremely solid rotation in place over the next two years with Peavy, Mark Buehrle, John Danks and Gavin Floyd. And, after much deliberation, Peavy is happy to be in Chicago.
"This wouldn't have happened if we hadn't [sat] down and thought about it [in May] and worked through all the different factors," Peavy said. "When there is one team that comes after you as hard as Chicago did, you're excited to play for them."
Scott Merkin is a reporter for MLB.com. This story was not subject to the approval of Major League Baseball or its clubs.


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Find a Doctor Near Me
Find a doctor or other healthcare provider located in or near Kansas City using the search options below. For further assistance, call our free healthcare referral service, Nurses On-Call, at (816) 276-6405. Get tips for picking a doctor.
Make an Appointment Online
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While many traditional fossil fuel technologies show slow growth in efficiency and design, solar power has instead yielded steady and rapid advances. While many question why a "killer app" solar product has not yet reached the market after years of hype, it is hard to deny the fact that solar costs both subsidized and unsubsidized have been dropping dramatically, being halved every 10 years.
With current costs ranging from 15 to 20 cents per kWh, and wholesale coal power costs between 1.5 and 2.5 cents per kWh (and nuclear in a similar range -- 1.7 cents per kWh by estimates from the Nuclear Energy Institute), solar still has a ways to go and likely a few decades before being ready for full deployment. Still, few technologies show the rapid growth in efficiency solar has and few utilize such a common resource as silicon, so the value of ongoing solar research is apparent.
UNSW's ARC Photovoltaic Centre of Excellence reported a significant milestone this week, with the announcement of the world's first 25 percent efficient unconcentrated solar silicon cells. They had previously held the 24.7 percent efficient silicon cell record, but were denied the 25 percent milestone due to gaps in the understanding of sunlight and its effect on silicon.
New research has led to revisions in how incident light efficiency is calculated. As a result, their record-holding design has reached the 25 percent mark, a "magic" number according to many industry experts. The cell, designed by Professors Martin Green and Stuart Wenham has a wide lead over competitive offerings, according to the Centre. UNSW holds six solar world records now.
Centre Executive Research Director, Scientia Professor Martin Green described how the new research improved the understanding of the efficiency. He states, "Since the weights of the colours in sunlight change during the day, solar cells are measured under a standard colour spectrum defined under typical operational meteorological conditions. Improvements in understanding atmospheric effects upon the colour content of sunlight led to a revision of the standard spectrum in April. The new spectrum has a higher energy content both down the blue end of the spectrum and at the opposite red end with, dare I say it, relatively less green."
While suggesting less green of anything may seem like heresy in the alternative energy industry, it's good news for the Centre as it means their cells are operating more efficiently than expected. The Centre's cell posted larger gains than its competitors following the revision. It is now 6 percent more efficient than the next most efficient competitor, according to Professor Green.
The Centre's cell is approaching the important 29 percent efficiency threshold -- the maximum theoretical efficiency for a first generation silicon photovoltaic solar cell. Dr Anita Ho-Baillie, who heads the Centre's high efficiency cell research effort, says the new research is a big boost "because our cells push the boundaries of response into the extremities of the spectrum."
She states, "Blue light is absorbed strongly, very close to the cell surface where we go to great pains to make sure it is not wasted. Just the opposite, the red light is only weakly absorbed and we have to use special design features to trap it into the cell."
Professor Green states, "These light-trapping features make our cells act as if they were much thicker than they are. This already has had an important spin-off in allowing us to work with CSG Solar to develop commercial 'thin-film' silicon-on-glass solar cells that are over 100 times thinner than conventional silicon cells."
The biggest goal of UNSW is now to adapt the ultra-high efficiency cells for mass production which should lead to more cost reductions. ARC Centre Director, Professor Stuart Wenham, adds,"Our main efforts now are focused on getting these efficiency improvements into commercial production. Production compatible versions of our high efficiency technology are being introduced into production as we speak."
The center has a close relationship with the world's biggest solar manufacturers, thanks in part to Dr Jianhua Zhao and Dr Aihua Wang, who fabricated the record-setting cell and have since left the Centre to establish China Sunergy, one of the world's largest photovoltaic manufacturers. Professor Green describes, "China was the largest manufacturer of solar cells internationally in 2007 with 70 per cent of the output from companies with our former UNSW students either Chief Executive Officers or Chief Technical Officers."


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[Video] Beekeeping strengthens communities in Kenya and Rwanda
Nalangu once could not afford to send her four children to school for lack of fees. But now, through beekeeping, many children in her community can enjoy a decent education.
* * *
When Nalangu Loigero formed a 40-member group and sought assistance from World Vision last year, a transformation began in her community.
Nalangu, from Oloshoron village in Kenya's Rift Valley, and other women formed the Lomayana Women's Group and have become bee farmers, a business that has helped improve their lives, thanks to support from World Vision.
World Vision trained the group on beekeeping and management before supplying it with 20 beehives, adding to 15 hives that the Kenyan Ministry of Agriculture donated earlier. World Vision also provided them with bee harvesting equipment as well as protective clothing, including harvesting gowns, helmets, gloves, and gumboots.
One hive produces about 20 kilograms (44 pounds) of honey upon harvesting, which is done after two or three months. The women sell a kilogram of honey for about US$8. They can accumulate about US$5,600 from the hives in one harvest.
"I never knew that I could earn income from keeping bees. Bee farming can give you all the things that you dream to have. I can now provide my family with a decent lifestyle," says Nalangu.
Sometimes the women barter and exchange honey for goats, which has helped them diversify into goat farming. Additional training from World Vision on goat and chicken rearing has helped the group members successfully venture into these businesses to generate extra income.
Even the children can see transformation. "My mother can now afford to buy me [a school] uniform, books, and provide three meals a day, unlike before when we only ate one meal a day and we went to school with tattered uniform," explains Lamayan Nkuruna, 9.
Through the group, Nalangu pays school fees for her children and 12 other students. The economically empowered women now have money to send all their children, boys and girls, to schools. Initially they would concentrate on sending only their boys to school and pulling their daughters from school to marry older men, who would pay a bride price.
"We allowed our daughters to get married, even at the age of 13," says Shani, one member of the group. "We were poor, and all we wanted was the bride price, which comes in the form of several cows, and cows are precious in the Maasai culture. But now we know the value of education, and we are advocating for girls to complete their education."
Through economic empowerment, these women are transforming their whole community.
* * *
Watch this video to see the story of a community in Rwanda that has also found economic transformation through beekeeping. With savings groups, microloans, and investments in other kinds of livestock, this community, too, can now send its children to school.
Child sponsorship is the cornerstone of World Vision's approach to community development. Join us! Change a child's life for good. Sponsoring a child provides life-saving basics and helps break the cycle of poverty. Consider sponsoring a child today!
You can also help change the life of an entrepreneur like Nalangu. Visit World Vision Micro to choose your entrepreneur today!


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CU Board Director Pay: Essential in Brave New World, CEOs Say
We compensate board members more out of a sense of fairness than anything else," explained Lin Hodges, president/CEO of Associated Credit Union of Norcross, Ga.
"I just don't think we should use the argument that people should serve on a volunteer board because we have a higher calling. I just don't think that recognizes today's busy world and the way our financial institutions have changed. It has become dramatically more difficult," Hodges added.
Only a small percentage of credit unions pay directors in states where board compensation is permitted to pay directors. What's more, most credit unions pay small stipends that range from a few hundred dollars or about $1,000 to $7,000 a year. However, in at least one instance, that pay exceeds $90,000 a year.
For this article, Credit Union Times compiled charts that list three of the largest state-chartered credit unions from each state that pay their board members. The charts also review how these credit unions performed financially in 2012 compared to their peers to see if they tended to perform any better, any worse or about the same as credit unions in their peer group, the vast majority of which do not pay their board members.
Credit Union Times reviewed more than 250 IRS Form 990 documents filed by state-chartered credit unions in 2011. To maintain their tax-exempt status, federal law requires state-chartered credit unions to submit an IRS Form 990 annually to report financial and operational information, including compensation of directors and executives. The IRS Form 990s revealed that many credit unions are paying their board members sizeable stipends for working one to five hours a week on board business, while a few others are working eight, nine or 10 hours a week.
More on Board Director Pay:
Part One – Surprised to Learn Volunteers Paid
Editorial – Time to Talk Turkey on 'Volunteer Boards'
Of the 26 CEOs at credit unions that pay board members contacted by Credit Union Times, eight agreed to an interview. The other CEOs either declined an interview or did not respond to our interview requests.
The CEOs interviewed said their boards are made up of professionals, such as small business owners, certified public accountants, lawyers, executives, real estate developers, insurance brokers and doctors who leverage their expertise and talents that keep the credit union financially sound and help it grow.
(CLICK on each of these graphics at the right and below to see expanded versions.)
The CEOs were asked three main questions: Why do they compensate board members? How do they determine what is reasonable compensation? And what value does the credit union get from paying board members?
Hodges, CEO of the $1.3 billion Associated Credit Union, said the challenges that credit unions face today require board members to spend more time and more work than ever on board business because of greater liability risks.
"In today's environment, the liability issue is more in your face, if you will, and regulators are quick to point that out," Hodges said. Associated paid $76,000 in total compensation to its 15 board members in 2011, with a median annual stipend of $5,500.
Dave Root, president/CEO of the $229 million Coventry Credit Union in Coventry, R.I., agrees.
"I know there are some credit unions that are up in arms saying we might as well be banks if we compensate board members," Root said. "But in this day and age, when you want to attract people who have some financial savvy, it's difficult to do that when you are asking people to volunteer their time, particularly when you have regulators who stare at board members in the face saying that they are subject to civil and monetary penalties if they don't do this or they don't do that." Root said.
CU paid its 12 board members total compensation of $103,800 in 2011, with a median annual stipend of $8,400.
Gregory Smith of the $4.1 billion Pennsylvania State Employees Credit Union in Harrisburg said there is no question that boards are doing far more work than they did 10 years ago because the board's duties and responsibilities have become far more complex.
Smith said his board chair attends 10 to 12 meetings a month. He also said directors meet twice a month and go to committee meetings and special meetings that can number up to eight every month.
"It's a working board and it's not a job for the faint of heart," Smith said. "It's not a cake type of job."
Smith believes paying a PSECU board member a median annual stipend of $12,429 is reasonable compensation because they do "an awful lot of work." The credit union, which paid nine board members total compensation of $122,622 in 2011, reports in its IRS 990 form that directors work eight to nine hours a week
But how do credit unions determine what is reasonable compensation?
IRS regulations require nonprofit organizations to compare what would ordinarily be paid to board members for similar services, duties and responsibilities among similar organizations in the region whether taxable or tax-exempt, according to Linda Lampkin, a Washington, D.C.-based research director for the ERI Economic Research Institute, a compensation and benefits research firm. Like circumstances account for the value of additional benefits such as insurance.
Every two years, the $2.3 billion Teachers Credit Union in South Bend, Ind., hires Mercer, a well-known HR consultancy to help determine what is reasonable compensation for directors and executives.
"It's something we make sure we get done by a well-regarded third party because [compensation] is a very delicate and sensitive topic," said Teachers CU President/CEO Paul Marsh. "We want to make sure that what we are paying is very reasonable and is right for our members and right for the board members because they do give a large amount of their time. They have fiduciary responsibilities. They have liability. It is a big job and we want to make sure we are fair to all parties involved."
Collectively, the Teachers CU board was paid $356,749 in 2011. One board member was paid $93,109, while two board members were paid $42,822 and $40, 914. The remaining eight board members were paid within the range of $8,491 to $33,645.
Marsh would not comment about compensation for individual board members but added that Mercer helped the credit union set its compensation philosophy and determined what is reasonable compensation for a financial institution with $2.3 billion in assets and serves more than 255,000 members.
Bert Hash, president/CEO of the $1.2 billion Municipal Employees Credit Union in Baltimore, said his credit union reviewed what other Maryland credit unions and credit unions in other states were paying board members to determine reasonable compensation for board members.
"Other banks pay their board members and we are in competition with them," explained Hash. "If we want to attract board members who are accountable and responsible, they should be compensated."
MECU's median board compensation is an annual stipend of $10,500. Total board compensation was $144,550 in 2011. Hash indicated the credit union's board compensation is reasonable when considering it's not nearly as much as what board members at competing banks are receiving in compensation.
But some executives disagree about what is reasonable compensation.
Richard Howdeshell, president/CEO of the $803 million Fort Worth Community Credit Union in Fort Worth, Texas, said paying board members too much may invite problems.
"If you compensate too highly you would attract an element that may not be in the best interest of the credit union," he said. "I think those people serve on boards in large part for their own benefit, to get something back for their business or for themselves personally. It's been our experience that people who are motivated with the idea that they are helping their fellow credit union members tend to be better board members." Fort Worth Community CU provides its nine board members with a $125 monthly stipend to pay for incidental expenses such as gas for attending meetings. In 2011, the credit union's total board compensation amounted to $12,544 with a median board compensation of $1,953.
"Not many would consider [$125] to be much of a benefit, to be honest," said Howdeshell. "We don't compensate them for their time and expertise, but we didn't feel it was appropriate to cost them money to serve on the board."
When asked what value their credit unions are getting in return for compensating board members, some CEOs struggled with providing specific examples.
"As a CEO, I can see the things the board contributes, and no, we don't document every comment that is made and every idea that they come up with and attribute it to an individual director," said James Irving, president/CEO of the $370 million Greenwood Credit Union in Warwick, R.I. "As a CEO, it is an easier job to run the ship when you have people who understand what is going on."
Greenwood CU paid its seven board members a total of $141,100, with annual stipends ranging from $10,000 to $33,200 and a median stipend of $22,400.
Next Page: Examples of Contributions
Some CEOs provided examples about how board members contributed to the growth of their credit unions.
Hash said the longtime leadership and strategic planning oversight of MECU Board Chair Herman Williams Jr. and Vice Chair Ernest Glinka, as well as other board members, were critical to the credit union's growth. Hash also said Williams provided him with valuable coaching and advice.
"MECU was at $350 million with 35,000 members when Herman took over as board chair 22 years ago," he said. "Today, MECU has 105,000 members and $1.2 billion in assets."
Hodges of Associated CU also said the guidance and coaching he received from a board member opened his eyes to the importance of political activism, advancing the credit union's interests and growth.
Nonetheless, other credit union executives are not sure whether paid directors tip the odds in their favor. "I don't know whether I can speak statistically on that," said Root of Coventry CU. "But when I look at the Call Reports to see how our state-chartered credit unions are doing, there are a few that are losing money, the larger ones always make a ton of money and there are those that get a good return."
Indeed, the financial performance of credit unions that do pay their board members compared to their peers, which includes the vast majority of credit unions that don't pay their board members, seems to be a mixed bag.
Data compiled from IRS 990 reports by Credit Union Times (see charts) show some credit unions that pay their board members have performed better than their peers, while a few have performed worse than peers and others have performed about the same as their peers.
For example, Rhode Island Credit Union paid its board members $224,675 in total stipends in 2011 and has posted a net income loss in four out of the past five years. In 2008, 2009, 2011 and 2012, the credit union had a total net loss of $3.1 million. What's more, at the end of the 2013's first quarter, the credit union lost $176,433, according to NCUA financial performance reports In 2010, the credit union recorded a net gain of $405,765.
Though Rhode Island CU has a strong net worth/total assets ratio of 11.40, higher than peer average of 10.54, its return on assets is negative 0.31, lower than the peer average of 0.62 last year. The credit union's loan growth was 7.34 in 2012, above peer average of 3.97, but it has been losing members. Rhode Island CU's membership has fallen by more than 2,400 from 27,089 in December 2008 to 24,674 in March of this year.
Meanwhile, Philadelphia's Trumark Financial Credit Union, which paid nine board members a total amount of $452,567 in 2011, has posted strong financial results, doubling its net income from $7.6 million in 2008 to $14.5 million in 2012, though in its peer group of credit unions with more than $1 billion in assets, the average net income was $26.2 million.
However, NCUA financial performance reports show Trumark's loan income has fallen from $45.4 million in 2008 to $40.7 million in 2012 but has more than doubled its fee income from $8.5 million in 2008 to $17.6 million in 2012.
The credit union also posted a net worth/total assets ratio of 10.32, only slightly below peer at 10.35, while its return on average assets was 1.05, versus peer average of 0.93 in 2012. Trumark's loan growth was 10.81, significantly above peer average of 6.24, but its membership growth was 1.48, below peer average of 3.87 last year.
The $2.7 billion State Employees Credit Union of Maryland in Linthicum, which paid a total of $216,462 to its 11 board members in 2011, has produced positive financial results as well.
Although it had a net loss of $16.5 million in 2008, it posted a net gain of $7.1 million in 2009 and more than doubled its income to $25.6 million by 2012, primarily by increasing fee income from $26 million in 2008 to more than $41 million in 2012.
The credit union's loan income has declined, however, from $89 million in 2008 to $86 million in 2012, and so has its investment income from $13 million to $7 million in the same years.
SECU's net worth/total assets ratio was 9.72, below the peer average of 10.35 in 2012, while its return on average assets was 1.07, above peer average of 0.93. The credit union's loan growth was 15.87, above peer average of 6.24 and its membership growth was 4.75, above peer average of 3.87 last year.


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CTE FCU to Merge Into Visions FCU
The financially troubled $77 million CTCE Federal Credit Union in Reading, Pa., will merge with the $3.2 billion Visions Federal Credit Union in Endwell, N.Y., on Dec. 1, according to a VFCU statement.
CTCE FCU's net worth has plunged from 7.65% in 2008 to 3.76%, at the end of the third quarter 2013, according to NCUA financial performance reports. The credit union also has posted declining loan, fee and investment income for more than four years, which contributed to its total net income losses of $2.7 million from December 2009 to Sept. 30, 2013, NCUA financial performance reports show.
Chartered in 1970, CTCE FCU served employees and families of Carpenter Technology Corp. Over the years, the cooperative opened its members to other select employer groups.
CTCE FCU serves 12,242 members. Post merger, the credit union's four branches will remain open, VFCU said.
"This merger opportunity will not only provide our membership with greater access to resources in Pennsylvania but will allow us to grow within that region while providing the CTCE members with improved rates, enhanced product selections, and additional services," Tyrone Muse, VFCU president/CEO, said in a prepared statement. "We look forward to continuing CTCE's rich history of supporting the community and are excited about the future of our combined organization."
Serving 155,709 members, VFCU operates about 30 branches in central New York State, northern Pennsylvania and northern New Jersey.