Author: Site Staff

With Rep. George Miller, D-California, and the Department of Labor bearing down on them, benefits industry lobbyists and attorneys expect new disclosure reforms this year that could put a damper on fees assessed to manage defined-benefit and defined-contribution plans.

Fees associated with administering retirement benefit plans are at the top of this year’s federal government policy agenda because Miller—who officially stepped in as chairman of the influential House Education and Labor Committee on January 4—is concerned that excessive charges might be cheating plan participants of investment returns for their retirements.

“You seem to have a lot of people who in some cases appear to be somewhat fast and loose with other people’s money,” Miller said in an interview with Pensions & Investments. “I think we have an obligation to ask: Are the employees getting a fair shake here?”

Benefits industry officials say the Labor Department this year is also expected to establish sanctioned default investment options for defined-contribution plans with automatic enrollment and set ground rules for financial firms offering investment advice to 401(k) plan participants.

Industry fees have been under Labor Department scrutiny for the past several years, and the department has signaled it favors some additional disclosure.

From his new bully pulpit as chairman of the key congressional committee that oversees the Department of Labor, Miller is expected to hold the department’s feet to the fire on the issue.

Washington and a former benefits tax counsel at the Treasury Department.

Labor Department spokesman Peter Hong declined comment.

How much information
As it stands, the Labor Department is considering an initiative aimed at spelling out how much fee information sponsors should be required to disclose to plan participants and how that information should be provided.

A November 30 report by the General Accountability Office requested by Miller recommends that legislation requiring plan sponsors to disclose fee information to participants in a way that would allow them to compare their plan investment options. The agency also recommended legislation requiring 401(k) service providers to disclose to plan sponsors all compensation received from other service providers, and that the Department of Labor require plan sponsors to provide a summary of all fees that are paid out of plan assets or by participants.

In the interview, Miller, who has already called for hearings on 401(k) plan fees, said he had yet to decide whether the legislation will fully address his concerns. But he says Department of Labor representatives will be summoned to Capitol Hill to explain what they’re doing about fees.

Miller also says he hoped that adding transparency to the fees assessed for plan investment options, along with regulations ensuring the fee information is useful to participants, will put a damper on excessive fees.

“Many people work very, very hard to accumulate savings and retirement resources that they think are necessary, and they should not be victimized by those they entrust their money to,” he says.

At least some industry lobbyists are skeptical about how much additional fee information can save plan participants—on the argument that the competition among 401(k) plan money managers should keep the level of fees in check.

Not widespread
“This [excessive fees] is not a widespread problem,” says Brian H. Graff, executive director and CEO of the American Society of Pension Professionals & Actuaries in Arlington, Virginia. “When you’ve got people doing stuff [to manage your plan], you’ve got to pay them.”

Added Ed Ferrigno, vice president of Washington affairs for the Chicago-based Profit Sharing/401(k) Council of America: “One concern we have is that we have an appropriate balance between disclosure and costs [of complying with new disclosure requirements] because they [plans] use plan assets to pay these costs.”

Miller made clear he believes the focus should be on the impact that fees have on the retirement savings of plan participants, keeping in mind that what he sees as the affluent lifestyles of many in the financial services industries is often supported by fees drawn from the retirement savings of plan participants.

“I think you’ve got to ask yourself: What’s the fiduciary duty to people in middle-class families who are busting their ass to try to provide for their retirement? What’s the fiduciary responsibility to people who are managing their money?” Miller says.

“I find with interest as an avid reader of business journals that even the big guys squabble over fees. And you know, a lot of times it’s the old business with when the big guys are fighting, the grass gets trampled,” Miller adds.

Miller voted against the Pension Protection Act of 2006, the most comprehensive overhaul of the nation’s benefits law since the Employee Retirement Income Security Act of 1974. He issued a news release Aug. 17—the day President Bush signed the bill—saying the new law put “pension plans at greater risk of being cut or dumped entirely.” But in the interview, Miller said he has no immediate plans to revisit the bill with new legislation.

“I’m not so tied to the bill,” he says. “For the moment, that’s yesterday’s newspaper.

“There’s some school of thought that that’s what in fact the bill will do: It will make it easier to get away from defined-benefit plans,” Miller added. “I think we have an obligation to try to run ahead of the curve and see what’s down the road, and if that [moving away from defined-benefit plans] is going to continue to happen, where is it that these people are going to make up the resources necessary for their retirement?”

Indexed vs. managed
One question posed by Miller is whether plan participants would be better off with their money invested in lower-cost indexed accounts than in higher-cost managed accounts. “We see the number of people who can’t beat the Street, but they’re getting big fees for trying,” he says. “Is that really where people’s money should be?”

But at the same time, he says participants should be able to call the tune on how their money is invested.

“People are still entitled to make bad decisions,” he says. “But even a bad decision should be an informed decision.”

Miller also says he had yet to decide whether to support an initiative by money managers to modify a provision in the Pension Protection Act that allows money managers to give advice to 401(k) plan participants on a plan’s investment options, including the manager’s own products.

Under the so-called “fee-leveling” provision at issue, financial firms offering advice are required to charge a single flat fee to participants, regardless of what investment options are chosen. That, according to money managers, makes the regulatory relief effectively useless to them because they charge higher fees for some strategies than they do for others.

“I don’t know yet,” Miller says on whether he favors eliminating the fee-leveling provision. At the same time, he says that cost of the advice, like the fees and commissions associated with administering a plan, come from the retirement funds.

“I think transparency becomes very, very important here,” Miller says.

According to the Center for Responsive Politics, a nonprofit Washington research group that tracks money in politics, top contributors to Miller’s 2006 re-election campaign included the AFL-CIO, the Air Line Pilots Association, the National Education Association and the International Brotherhood of Electrical Workers—groups that traditionally support the interests of employees on retirement-related issues.

—Doug Halonen is a reporter for Workforce Management
sister publication Pensions & Investments, where this story originally appeared.

New Year, Old Problem: Most U.S. workers would gladly change jobs if the right opportunity presented itself, according to a survey of 5,300 adults by Yahoo HotJobs.
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Diversity Deal: Capital H Group of Chicago has acquired a diversity training company.
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Relocaton Merger: Primacy Relocation of Memphis, Tennessee, has acquired Foursquare Relocation for an undisclosed sum.
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HR Software: HR software company Ultimate Software of Weston, Florida, has acquired RTIX Ltd., a British company that specializes in software for employee performance reviews and training.
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HR Shakeout in U.K.: Payroll and HR outsourcing company Northgate Information Solutions, based in Chester, England, is acquiring Link HR Systems for about $24 million.
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Vendor Roundup: Belfast, Northern Ireland-based ICS Computing says it is launching an HR outsourcing consulting service to complement its HR and payroll services offerings.
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Vendor Roundup: Belfast, Northern Ireland-based ICS Computing says it is launching an HR outsourcing consulting service to complement its HR and payroll services offerings. … TotalRewards Software of Rocklin, California, has launched free online software to enable small and midsized employers to create total compensation statements for employees. … Indianapolis-based BrandoHR, a provider of branded recruiting tools, says it has formed a partnership whereby small and midsize companies can receive free automatic job postings from JobCentral, a job board created by DirectEmployers Association Inc., also of Indianapolis. … Cincinnati-based HRO provider Resolve Staffing Inc. has filed for a listing on the American Stock Exchange. Its shares are currently traded over the counter. … Employment screening company Verifications Inc. of Minneapolis says it will offer screening to help companies search state databases of sexual offenders. … HR software vendor Kenexa of Wayne, Pennsylvania, has expanded its presence in Malaysia by opening a product development office there. … Philadelphia-based benefits consulting firm Mid America Group is being acquired by Arthur J. Gallagher & Co. of Itasca, Illinois, which recently agreed to pay nearly $37 million to settle a class-action lawsuit alleging it accepted improper contingent commissions.

New Year, Old Problem: Most U.S. workers would gladly change jobs if the right opportunity presented itself, according to a survey of 5,300 adults by Yahoo HotJobs. Nearly two-thirds are open to switching jobs, with an improving job market cited as the chief cause for such optimism. If true, the figure suggests concern about worker retention could intensify as companies strive to keep turnover costs low in 2007. About 39 percent of those polled cite unhappiness with wages as the chief issue, with three-quarters of that group saying their 2006 raises or bonuses were below expectations. However, only 9 percent identified salary as a key indicator of success, with 46 defining success as the attainment of a proper balance between their jobs and personal lives. Also, more than 75 percent of employees are looking for new jobs, according to a survey conducted jointly by the Society for Human Resource Management and The Wall Street Journal’s CareerJournal.com. Apparently, job seekers will have choices in the coming year. Still another survey, this one by CareerBuilder.com, found that 40 percent of hiring managers plan to add jobs.

The Pension Benefit Guaranty Corp. has taken over and terminated Delta Air Lines’ massively underfunded pension plan covering the airline’s pilots.

The Delta plan, which covers about 13,000 active and retired pilots, is underfunded by about $3 billion, with $1.7 billion in assets and $4.7 billion in benefit obligations. The PBGC will be liable for about $920 million, the sixth-largest loss in the PBGC’s 32-year history.

Earlier, Delta said shedding the plan was essential for the Atlanta-based airline to emerge from Chapter 11 bankruptcy. Delta, though, is continuing another pension plan covering other employees. A provision in a 2006 law gives commercial airlines much more time—compared to other employers—to fund their pension plans.

Delta is the latest major airline to have at least one of its pension plans taken over by the PBGC.

Among airlines now operating, the PBGC has taken over all of United Air Lines’ pension plans, costing the agency $6.6 billion; those sponsored by US Airways Group, at roughly a $3 billion loss; and Aloha Airlines, whose plans had $117 million in unfunded PBGC-guaranteed benefits.

The PBGC also incurred big losses through its takeover of pension plans sponsored by several long-defunct airlines, including Braniff International Airways, Eastern Airlines, Pan American World Airways and Trans World Airlines.

In all, about 38 percent of the PBGC’s $18.1 billion deficit is attributable to airline pension plan failures, according to a PBGC spokesman.

—Jerry Geisel

Jerry Geisel is a reporter for Business Insurance,
a sister publication of Workforce Management.

On a day when Home Depot chairman and CEO Robert Nardelli resigned with a $210 million separation agreement, the incoming chairman of the House Financial Services Committee indicated that he will offer legislation to give shareholders more power in determining executive pay.

Rep. Barney Frank, D-Massachusetts, who will assume his new position when Democrats officially take over the House on Thursday, January 4, blasted the Atlanta-based home improvement chain.

“The action of Home Depot’s board of directors to simultaneously dismiss Robert Nardelli and provide him with $210 million in severance is further confirmation of the need to deal with a pattern of CEO pay that appears to be out of control,” Frank said in a statement Wednesday, January 3.

Later, in a speech at the National Press Club, Frank asserted that corporate boards give too much leeway to the executives they’re supposed to oversee.

“Boards of directors don’t provide any real check on CEOs,” he said. “They don’t stand up to the CEO. They may stand up to the workers.”

In legislation that he intends to introduce later in the congressional session, Frank will propose that shareholders vote on executive compensation packages. Currently, company boards set executive pay.

Most of the shareholders who weigh in will be large funds like the California Public Employees’ Retirement System, Frank said.

“They are sophisticated and thoughtful, and corporations would benefit from their increased participation,” he said.

Soaring executive pay exacerbates growing income disparity, Frank argues. He cited statistics showing that families with incomes below $92,000, or 90 percent of Americans, saw their incomes fall 4 percent after inflation between 2001 and 2004—a time when the economy was expanding.

“Business leaders who are frustrated by the unwillingness of the American voter to be supportive of their agenda for economic growth should look to the contrast of Mr. Nardelli’s consolation prize and the resistance of business to raising the minimum wage,” Frank said in a statement.

He elaborated in his Press Club speech, warning against the “increasing separation of the well-being of the average citizen from overall economic growth.”

Part of the problem is that the economy is often viewed in a Wall Street framework. “If corporate profits go up, that’s a good thing,” Frank said. “If wages go up, that’s a bad thing. That’s the perceived wisdom that I’m trying to change.”

Democrats want to shift the focus to workers. Frank advocates a “grand bargain” between congressional Democratic majorities and the business community, which usually finds Republicans more sympathetic to their causes.

In Frank’s deal, businesses would facilitate unionization, support expanded health care, raise wages and acquiesce to labor and environmental provisions in trade agreements. In return, Democrats would back immigration reform, trade pacts and an easing of rules on foreign direct investment.

Such an agreement would break political deadlock, Frank maintains. “Right now, we’re stalled,” he said. “That’s why the business community should care.”

Several members of the corporate lobby, however, were reticent to comment on Frank’s notion until they learned more about it.

“It’s an interesting theory, which means nothing until there’s specific legislation on the floor,” says Martin Reiser, manager of government policy for Xerox Corp. “It’s a little all-encompassing but at the same time unspecific.”

One area where Frank is explicit is his desire for the government to help those hurt by globalization and technological advances. But he doesn’t advocate eliminating inequality, just reducing it.

“Inequality is necessary in a capitalistic system,” Frank said. “But you do not have to have government reinforce it. You can have government retarding it. The public sector needs to be valued as a partner.”

He also asserts that unions improve quality of life on the job. For instance, he is wary of a Wal-Mart’s new approach to workforce management.

The Wall Street Journal reported on January 3 that the massive retailer will assign duties to workers at times when store traffic is highest, regardless of traditional schedules.

“Yeah, and if you have to pick your kid up at school, that’s tough,” Frank said. “Unions help to protect people’s dignity in the workplace.”

—Mark Schoeff Jr.

The following is an excerpt of a proxy statement that Home Depot filed April 14. It includes a discussion of the terms of the employment agreements for the company’s named executive officers, who include Dennis Donovan, executive vice president, human resources:

“The Company also has employment agreements with Dennis M. Donovan, Executive Vice President – Human Resources, dated as of March 16, 2001, and with Frank L. Fernandez, Executive Vice President, Secretary and General Counsel, dated as of April 2, 2001. The initial term of Mr. Donovan’s agreement terminates on December 31, 2005, and beginning on January 1, 2003, automatically extends so that the remaining term is always three years. The initial term of Mr. Fernandez’s agreement terminates on April 2, 2004, and beginning on April 2, 2002, automatically extends so that the remaining term is always two years. Each agreement provides that the automatic extensions will continue until either the Company or the executive gives written notice of termination of the extension provision.

“The employment agreements provide for each of Messrs. Donovan and Fernandez to receive a base salary of not less than $525,000 per year. Mr. Donovan is eligible for an annual bonus of no less than his then-current base salary. Mr. Fernandez is eligible for an annual bonus of no less than 65% of his then-current base salary. Both Messrs. Donovan and Fernandez were guaranteed a bonus for Fiscal 2001. In connection with the commencement of employment, Messrs. Donovan and Fernandez each received awards of stock options exercisable for 320,000 shares, which vest 25% per year beginning on the second anniversary of the grant date, and awards of deferred stock units corresponding to 328,821 shares and 50,000 shares, respectively. Mr. Donovan’s units vest in one-third increments on the first, third and fifth anniversaries of his date of employment and Mr. Fernandez’s units vest in increments of 25% annually beginning on the second anniversary of the date of his employment agreement. The agreements provide that for 2002 and subsequent calendar years, Messrs. Donovan and Fernandez are eligible for an annual grant of stock options exercisable for at least 90,000 and 70,000 shares, respectively.

“In connection with their relocations, Messrs. Donovan and Fernandez received loans in the amount of $3 million and $500,000, respectively. Interest on the loans accrues at the rate of 5.8% per year. Interest will be forgiven annually on the respective anniversaries of the loans. Mr. Fernandez’ loan was fully satisfied as of the end of Fiscal 2005. Mr. Donovan’s loan must be repaid upon the earlier of (1) the fifth anniversary of the date of the loan or (2) 90 days following the termination of the executive’s employment by the Company for cause or by the executive without good reason.

“Upon the termination of the employment of either Mr. Donovan or Mr. Fernandez by the Company for cause or by the executive without good reason, the Company will pay the executive all cash compensation accrued but not paid as of the termination date. If the employment of Mr. Donovan or Mr. Fernandez is terminated by the Company other than for cause, by the executive for good reason or for any reason within 12 months after a change in control or due to death or disability, the executive will receive all cash compensation accrued but not paid as of the termination date and certain additional benefits, including salary and target bonus continuation for 24 months and immediate vesting of all unvested equity-based awards, which such award will continue to be exercisable (1) by Mr. Donavan through the end of the awards’ original term and (2) by Mr. Fernandez through the shorter of the end of the awards’ original term or third anniversary of the end of his employment with the Company. In the event of a change in control, in addition to receiving any protection that is applicable to other senior executives, all grants of equity-based awards to Messrs. Donovan and Fernandez shall become fully vested and exercisable.

“Pursuant to their respective agreements, each of Messrs. Donovan and Fernandez has agreed that during the term of his employment and for two years thereafter, he shall not, without the prior written consent of the Company, participate (as defined in the agreements) in the management of certain competitors of the Company. During the same period, each executive has also agreed not to solicit any employee of the Company to accept a position with another entity or to solicit any vendor or customer of the Company to alter its relationship with the Company in any way that would be adverse to the Company.

“Under the terms of the agreements with Messrs. Nardelli, Donovan and Fernandez, termination of employment for good reason generally means the occurrence of certain events without the executive’s consent, including, among other things, (1) the Company assigning him duties inconsistent in any material respect with his duties and responsibilities as contemplated by the employment agreement or taking any other action that results in a significant diminution in such executive’s position, duties or responsibilities, (2) failure of the Company to comply with any material provision of the employment agreement, or (3) in Mr. Donovan’s case, cessation of a direct reporting relationship with Mr. Nardelli.

“Termination for cause means, among other things, that the executive (1) has engaged in conduct that constitutes willful gross neglect or willful gross misconduct with respect to employment duties that results in material economic harm to the Company, subject to certain conditions, or (2) has been convicted of a felony involving theft or moral turpitude. Any determination that cause exists must be approved by a majority of the Company’s Board of Directors after giving notice of such meeting to the executive and providing the executive and his legal counsel an opportunity to address the Board at such meeting. In addition to these and other benefits set forth in the applicable employment agreements, Messrs. Nardelli, Donovan and Fernandez are entitled to participate in the benefit plans offered to all executive officers of the Company and to receive the same perquisites as are commonly provided to other senior executives of the Company. The Company will also reimburse them for income taxes applicable to certain specified benefits and payments under the agreement and for excise taxes imposed in the event payments or benefits received by the executive under their respective agreements, or otherwise, result in “parachute payments” under the Internal Revenue Code.”

Click here to read the full proxy statement.

Employers that have migrated from traditional newspaper ads to online advertising to meet recruitment objectives may want to reconsider their strategy. Upwards of two-thirds of job seekers say they use both print and online ads to seek work, according to a study conducted by the Conference Board.

“Print and online tools are not mutually exclusive,” says June Shelp, an economist and director of new initiatives at the New York City-based Conference Board. “There is no question that the Internet has become an established me­thod that is used when looking for work, but people are still relying on traditional newspaper ads as well.”

Slightly more than 71 percent of survey participants say they use online ads when looking for a job, statistically equal to the 70.6 percent who reported using newspaper ads. The Conference Board polled a nationally representative sample of 5,000 households for the study, which was released in early November.

Job board experts, however, disagree with the study’s findings. They estimate that online tools are much more widely used than newspapers are. They do agree, however, that employers should not underestimate the significant role that newspapers can play in certain recruitment missions.

When looking to fill positions in rural areas or where there are low rates of Internet connectivity, newspapers may be a more effective recruitment tool, says Jonathan Duarte, president and CEO of Go Jobs Inc., a job board and recruitment consultancy in Orange, California. Recruiters staffing manufacturing jobs also may have better luck using traditional print ads, he says.

San Francisco, Los Angeles or New York, advertising online could be more effective, according to Duarte.

Geography is not the only factor that recruiters should consider when deciding whether to advertise a job opening in a newspaper versus online. Certain pockets of the population, such as office professionals, have more access to the Internet, making them better targets for online ads.

“It is important for companies to know who they are targeting, because it will have an influence on where to advertise,” Duarte says.

The study shows that job seekers use a variety of tools when looking for work, with print and online ranking highest. Fifty percent of participants report networking with friends and colleagues when looking for work. Employment agencies ranked lower: Only 26 percent of the survey respondents said they used them to aid their job search.

While use of newspapers and online ads as employment tools is virtually equal, the perception of their effectiveness differs widely, according to the study. Almost 40 percent of survey respondents who have been extended a job offer attribute it to an Internet search. By comparison, just 23.9 percent of survey participants who received a job offer cite newspaper ads as the source of employment—below employment agencies at 29.9 percent and networking with friends and colleagues at 27.1 percent.

Duarte isn’t surprised by the findings. The quality and quantity of information that job seekers find on the Internet allows them to better target their prospective employers, which could play a part in landing a job, he explains.

Job seekers can find details about the company, its address and a better description about the job opening than they probably could find in a newspaper advertisement.

“The Internet has billions of pages of information,” Duarte says. “There are about 120 pages in any given Sunday edition.”

—Gina Ruiz

 

Talent management is the top strategic HR issue that companies expect to face in 2007, according to a recent survey by ORC Worldwide.

Specifically, respondents say they are concerned about acquiring, developing and retaining talent at all levels of the organization.

The survey is based on responses from 35 members of the Senior HR Officers Network, MidCap Senior HR Officers Network and Human Resources Solution Network. Participating companies have operations in more than one country and have workforces ranging up to 90,000 employees.

Previous studies by ORC had found that succession planning was a top concern for organizations.

“While succession planning remains a key activity, it is clearly no longer the sole activity of talent management,” the study says.

In fact, when asked about the highest-priority HR initiatives for 2007, 37.1 percent of survey respondents say talent management, while only 2 percent mention succession planning.

“While we believe that succession planning continues to be an important initiative in most organizations, the processes and programs may be in place and working well, allowing member companies to expand their focus into other areas of managing talent,” the study says.

Companies have started to take a broader approach to talent management because they have begun to recognize there is a shortage of talent, particularly in industries like engineering, says Jodi Starkman, director of talent management at ORC.

“We have moved from companies beginning to think about this to actually managing the whole human supply chain,” she says.

Talent management has already started to take up a lot of HR executives’ time, according to the survey. Twenty-nine percent of respondents say the majority of their time was spent on talent management activities.

The second-highest priority for 2007, according to respondents, is strategic HR management. These activities include HR outsourcing, aligning HR activities with the business and implementing common global HR processes.

Twenty-three percent of respondents say that recent business growth will affect the company’s HR strategy next year. Another 23 percent cite mergers and acquisitions and divestitures as a factor that will affect their HR strategies.

The biggest challenge for companies trying to create broad-based programs to attract, train and retain talent is workforce planning, Starkman says.

“Companies need to get a handle on defining their global talent demands over the next five years,” she says.

—Jessica Marquez

Dear Evolving:

Rapid growth is a double-edged sword. On one side it implies increased business opportunities, rising market share and enhanced competitive advantage. On the other side, it can put a strain on your organization to achieve more goals. This strain can put pressure on internal initiatives including training, reward and recognition programs, and the performance management system.

Introducing a formal performance management system can be challenging, especially if your employees are used to a more informal system. People resist change unless they can see its benefit to them, and especially if they haven’t assisted in developing the new initiative. The more ownership people have of a system, the more of an impact it will have on goal attainment. Consider using the IMPACT acronym when establishing performance management:

• Investigate the pros and cons of the current system and build from there. There may be very strong elements of the current system that can be adapted to fit the new system. Take the best of the old system to maximize results in the new system.

• Manage work by creating daily opportunities for feedback. A formal performance management system must be supported by an informal system. Daily feedback demonstrates to people that their job is important and that management is interested in their success. It also enhances overall communication.

• Partner with employees to create the system. This may take longer, but the end result will be better. Employees will have a clearer perspective on their jobs/roles within the company as well as their connection to company goals.

• Accelerate performance by promoting benefits. Create momentum by helping employees see how performance management enables them to improve. Consider promoting these benefits in company newsletters or on intranets.

• Coach employees by focusing on their strengths. Your system is only as good as your delivery. If supervisors are not effective coaches, then don’t expect employees to be motivated to perform at high levels. Coaching requires a dedicated effort and should not be taken lightly.

• Target specific observable behaviors for performance. Every job function should have tangible results aligned with the business. Performance management systems need not be long and complicated. Keep it simple and focus on specific behaviors distinctive to each job, to get everyone driving toward the same end result.

A performance management system focuses light on the most important behaviors and results your organization wants achieve. When a company is growing rapidly, it is important to take a step back to ensure that internal initiatives match your business goals.

SOURCE: Dana Jarvis, human resources director,Snavely Forest Products, Pittsburgh, March 6, 2006. Jarvis also is an adjunct professor at Duquesne University.

LEARN MORE: Please read How to Move From a Paternalistic Culture to One That Measures Performance for another view. Also, how to combine different formats for appraisals.

The information contained in this article is intended to provide useful information on the topic covered, but should not be construed as legal advice or a legal opinion. Also remember that state laws may differ from the federal law.