1
Q
What are the rules of Conduct?
A
- New rules effective February 2022
- Apply to both members and firms
5 Rules of Conduct
1) Act with Integrity – be honest and comply to personal and RICS obligations
2) Maintain Professional Competency – ensure individuals are competent and experienced
3) Provide good quality and diligent service
4) Treat others with respect – encourage diversity and inclusion
5) Take responsibility – be accountable for your actions and be prepared to act if necessary. Prevent harm and maintain public confidence
2
Q
Where are the Mandatory Professional Obligations found
A
- Appendix A Rules of Conduct – sets out professional obligations
3
Q
Mandatory Professional Obligations for RICS members
A
- Comply with CPD requirements (min. 20 hours per year, 10 hours must be formal)
- Cooperate with RICS
- Promptly provide all necessary information reasonably requested by the Standards and Regulation Board
4
Q
Mandatory Professional Obligations
RICS Regulated firms must:
A
1) Publish complaints handling procedure, inc. alternative dispute resolution and maintain a complaints log
2) Have adequate professional indemnity insurance (PII)
3) If a sole principal, make appropriate arrangements for their professional works to continue to the event their incapacity, death or absence
4) Cooperate with RICS
5) Promptly provide all necessary information reasonably requested by the Standards and Regulation Board
6) Designation on business literature that they are RICS regulated
7) Report to RICS any matter under Rules for the Registration of Firms
5
Q
Rationale for developing new Rules of Conduct
A
- A simpler structure – easier to understand
- Clear examples – shows real life applications
- Focuses on respect, diversity, and inclusion
- Understanding evolving technology
- Tackling global challenges – sustainability development
6
Q
Ethics Decision Tree
A
- Provides a framework of questions which members should relate to when they are unsure if their actions are potentially unethical
- Encourages considering the legality of one’s actions and their consistency with the Rules of Conduct – have clear reasoning before making a decision
- Questions include:
- Sufficient facts?
- Legal?
- In line with RICS global professional and ethical standards?
- Clear reasoning in reaching a decision?
- Content if actions were made public?
7
Q
Disciplinary Procedures
A
A disciplinary procedure can be triggered by someone:
o Complaining to the RICS
o An allegation by a client or third party
o Information received or established by the RICS
8
Q
What are the 3 Levels of Disciplinary Action
A
- Action by Head of Regulation
- Regulatory Tribunal
- Appeal Panel
9
Q
Disciplinary Procedures
A
If disciplinary action is required, one of the four actions will be considered:
1) Serve a Fixed Penalty Notice
o Procedure used for breaches of the rules relating only to the supply of information to the RICS by firms and members
2) Make a Regulatory Compliance Order
o Used for low level breaches of the Rules which could easily be corrected
o The compliance order is a written document which states terms which must be taken or desist from taking for a specified time period
3) CPD Sanctions
o Follow CPD requirements
4) Action by Regulatory Tribunal
o Used for more serious breaches of conduct
o Head of Regulation considers if the hearing is required under the discipline rules
o 50% of the panel are not RICS members
10
Q
Penalties available to the Disciplinary Panel
A
1) Issue a Compliance Order
2) Unlimited fine per breach proportionate to the offence
3) Conditions on continued RICs registration
4) Expulsion
5) Publication of the results – RICS Modus Magazine, RICS website, local newspaper
11
Q
Appeal Panel
A
- Considers members or firms appeal against review of decision relating to the disciplinary procedure
- Have regard to evidence previously presented and any new representations
- 50% of the panel are not RICS members
12
Q
Social Media: Guidance for RICS members, 2021
A
The RICS is likely to investigate concerns about social media posts where they involve:
- Discrimination
- Dishonesty
- Abusive or threatening behaviour
- Bullying, harassment, or victimisation
- Ignoring previous advice or warnings about concerns
If the most may damage public confidence or trust in the profession, may take disciplinary action
13
Q
Fee Negotiations
A
- Avoid price fixing, aggressive fee cutting or collusion
- Fees should be market based and agreed on an ad-hoc basis with clients
- Further fee negotiations can take place after submitting initial fee proposal as long as you have acted professionally
- Vary proposed level of service when renegotiating your initial fee proposal as long as you provide a high level of service
- Be transparent with your client if you are offering or receiving a referral fee
14
Q
What must TOE state
A
- Proposed fee basis
- Payment of expenses (and how calculated)
- Firms complaints handling procedure available on request
15
Q
what is the 3 step process for TOE prior to commencing instruction
A
3 steps to follow:
1) Check professionally competent
2) No conflicts of interest or personal interests
3) Confirm Terms of Engagement in writing prior to the commencement of works
16
Q
Why would you decline an instruction?
A
- Not competent to do the work
- Insufficient facts on the issue
- Unsigned Terms of Engagement or uncomplete AML checks
- Conflict of interest or personal interest
- PII cap cannot be agreed
- Advice is for a friend or free of charge for a charity and PII will not cover works carried out on a personal basis
- Potential client is included in the UK Government sanctions list
- Would you be content if your actions were made public?
Use the RICS Ethics Decision Tree to consider whether to act for a client
17
Q
What is conflict of interest?
A
Conflict of interest arises when a firm’s independence and impartiality is threated due to the existence of a conflict between two clients.
Examples include:
- Any financial interest
- A personal interest
- Commercial relationships
- Acting on both sides of a transaction
18
Q
What is conflict avoidance
A
When you do not accept the instruction
19
Q
What is conflict management?
A
When the instruction is accepted, and steps are agreed. Such as an information / ethical barrier.
20
Q
What RICS guidance is there for conflict of interest?
A
RICS Global Professional Statement on Conflicts of Interest, 2017
- Mandatory statement, effective January 2018
- A member must not advice or represent a client where doing so would involve a conflict of interest or a significant risk of a conflict of interest, other than where all those who are, or may be affected have provided their informed consent
- Sets out high level principals for the appropriate identification and management of conflicts
21
Q
what are the three types of COI
A
1) Party Conflict – relating to work on the same or related instruction for two different parties. Do not let personal interest interfere with your professional judgement.
2) Own Interest Conflict – relating to a personal interest (e.g. family member)
3) Confidential Information Conflict – relating to work between two parties that is confidential
All firms must keep a record of compliance
22
Q
Can you move forward if there is a COI
A
Yes.
As long as Informed Consent is gotten.
This can only be given if the person explaining the position is entirely transparent about any material factors and is sure that the party affected understands what they are doing.
Surveyors should only seek informed consent if satisfied that all the relevant clients / parties will be best served by doing so.
23
Q
How do you handle a COI
A
- Consider transparency and openness
Three Step Process:
1) Conflict Avoidance
- Consider the full facts, whether the conflict is irresolvable because your impartiality is compromised and should be avoided or whether it can be properly managed maintaining transparency and openness
2) Written Advice to Both Parties
- Assuming the instruction is accepted, set the following in writing:
Nature of the conflict and circumstances
Be very clear so parties can make their own decisions
Request written confirmation (informed consent)
3) Conflict Management
- Receive written confirmation
- Set up an information barrier in accordance with the agreed provisions
24
Q
Use of Information / Ethical Barriers
A
If both parties agree in writing your firm can act for both parties where a conflict of interest exists, then the information barrier must be operated as follows:
- Barrier must be robust enough to ensure no information passes in between
- Take ‘reasonable steps’ to operate an effective barrier
- Surveyors acting on both sides must be physically separated, preferably different buildings, or different floors and separate support teams
- Information on the instruction must be stored securely
- Clear audit trail
25
Can you explain the RICS Professional Statement: Conflicts of Interest – UK Commercial Property Market Investment Agency, 2017
Professional Statement: Conflicts of Interest – UK Commercial Property Market Investment Agency, 2017
* Mandatory professional statement
* Relates only to UK commercial investment agency work where a specific risk has been identified
* Came into effect January 2018
This statement deals with the following:
1) Dual Agency
* Where an agent has a contractual agency relationship with both the seller and the buyer at the same time
* This practice must not be undertaken in any circumstances from January 2018 by any RICS member
26
Is duel agency allowed
Where an agent has a contractual agency relationship with both the seller and the buyer at the same time
* This practice must not be undertaken in any circumstances from January 2018 by any RICS member
27
Multiple Introductions?
* An agent has competing contractual relationships simultaneously with several buyers for commercial real estate investment opportunities
* When a client appoints an agent to act on their behalf in acquiring a commercial real estate investment, terms of engagement must be agreed in writing and the agent must make it clear whether they are acting on an exclusive or non-exclusive basis
* Exclusive basis – other prospective buyers with whom the agent was in contact with must be informed that the agent is no longer able to advise them
* Non-exclusive – the agent must obtain informed consent from the client(s) subject to necessary information barriers being in place
* On appointment the seller or seller’s agent must be advised accordingly
28
What is incremental advice and is it allowed?
* Agent is approached by another party to provide advice related to the purchase or disposal that is incremental to its existing instruction
* E.g. The agent is acting for the seller in relation to the disposal, but the buyer or lender wants them to do the valuation
* RICS members must only provide such incremental advice if consent is given and an information barrier is put in place
29
Can you carry on if there is Personal interest / own interest conflict
* When acting for a family member, a close business associate or someone whom you have a financial or personal interest or benefit
* You must not let a personal interest interfere with or influence your professional judgement
* Full transparency is required
* Declare facts promptly and in writing prior to accepting the instruction
* Section 21 of the Estate Agents Act 1971 declaration required for agency work – what interests must be declared by the agent
30
What does RICS say about Confidentiality
* Client confidentiality must be maintained for all client affairs
* If a third party wants access to your files you must get your clients approval first unless you are subject to a statutory duty overriding your client’s confidentiality rights
* All old files must be held for a minimum of 6 years before disposal and destroyed securely
* If a surveyor overhears or finds out a confidential piece of information, they cannot use this for their own purposes
o The client and sender should be advised of the error
o The matter should be recorded in a note to the firm’s compliance officer
31
Explain Complaints Handling Procedures
* RICS Guidance Note: Complaints Handling, 2016
* A firm’s written CHP must be approved by the RICS
* Always notify PII insurers as soon as possible if there is a complaint and this could lead to a claim for negligence
* Details of the CHP should be issued with the Terms of Engagement
* Complaints log must be maintained to show the details, progress and outcome
* Firms must have an RICS approved Alternative Dispute Resolution (ADR) mechanism in their CHP
32
Standard minimum procedures for handling of a complaint
* Stage 1 (in house)
o Details of the CHP should be issued whenever the firm received a complaint to whom the firm owes a duty of care
o Must be quick, clear, transparent, and impartially implemented
o Details of the complaints handling officer must be stated as the person to contact in the first instance
o Complaint must be made in writing
o Procedures and strict timescales must be followed and recorded
o A complaint should be acknowledged within 7 days and investigated within 28 days
* Stage Two (ADR – third party resolution)
o If the complainant is not happy with the review, the second stage involves using an independent redress scheme
The RICS will only become involved if a member fails to respond to the complainant or prevents stage two.
A sole practitioner must nominate a surveyor from another firm to act as their complaints handling officer.
33
What is G&S CHP?
Stage 1 of the CHP gives the local office, whose complaint it relates to, the opportunity to investigate and
respond thereof.
The local office will consider your complaint as quickly as possible and will acknowledge receipt of your
complaint within seven days. If they are not able to give you a full response, they will update you within 28day
Stage 2 of the CHP gives our Firm the opportunity to review independently and consider your complaint in full.
Our Firm will try to resolve your complaint to your satisfaction. If you are not happy with our response, you
will have the opportunity to take your complaint to Stage 3.
We will consider your complaint as quickly as possible and will acknowledge receipt of your complaint within
seven days. If we are not able to give you a full response, we will update you within 28 days
Stage 3 gives you, the client, the opportunity to have your complaint reviewed and considered by an
independent redress provider, approved by the RICS.
If we are unable to agree on how to resolve your complaint, then you have the opportunity to take your
complaint to an independent redress provider, as approved by the RICS Regulatory Board. We have chosen to
use the following redress providers:
34
Continuing Professional Development (CPD)
4 Requirements:
1) Minimum of 20 hours per annum
2) Of the 20 hours, 10 must be formal
3) Maintain relevant and current understanding of the RICS Rules of Conduct during a 3-year rolling period
4) Record CPD activity on RICS website
Formal CPD
* Structured training that has clear learning objectives and outcomes
* E.g. online training course, seminars
Informal CPD
* Self-managed learning related to your professional role
* E.g. reading Estates Gazette
35
Can you tell me about PII
* Mandatory requirement
* Protect clients, surveyors and third parties against negligence claims
* RICS Professionals Indemnity Insurance Requirements, Version 7
* Must have adequate and appropriate level of insurance in place for each instruction
* All policies must be underwritten by an RICS approved insurer
* Current minimum requirements based on a firm’s turnover are:
36
What are the bands for PII?
Turnover preceding year Minimum level of indemnity
£100,000 or less £250,000
£100,001 to £200,000 £500,000
£200,001 & above £1,000,000
37
The maximum level of uninsured excess required by the RICS
Firms Turnover Maximum uninsured excess
Up to 10 million greater of 2.5% of the sum insured or £10,000
Over 10 million no set limit
38
What else do you know about PII
* PII policies work on a ‘claims made’ basis.
* This means that the policy covers claims that are first made against the insured during the period of insurance regardless of when the negligent act occurred
* Certificate sent to RICS annually as part of the firm’s annual return to RICS
* For consumer claims, minimum of £1,000,000 of aggregate cover over a 6-year period required
* For commercial claims, RICS recommends longer cover as claims can be made up to 15 years after work is undertaken
39
Any case law about PII
Merrit Vs Babb 2001
Babb done val and company closed down so Merrit went after him personally for the valuation which missed the structural damage
40
When is PII required?
* Needed for ‘pro-bono’ (unpaid) work to charities or friends
* RICS Assigned Risk Pool is available at a cost for members who cannot arrange cover
* RICS Low Earners Scheme for retired / part time members
* RICS runs a Members Support Service (MSS) for members facing claims for work carried out by an employer who has gone into administration
* Cap liability with clients for each instruction
41
Is there any guidance for risk and liability from RICS
Guidance Note: Risk, Liability and Insurance, 2021
* Insurers must provide cover for fire safety claims on a property of 4 storeys or less
* Liability caps to manage risks associated with professional work
* Be aware of third-party reliance – advice can only be relied upon by the client named on the Terms of Engagement
42
Have you or your firm ever dealt with a conflict of interest?
- Yes, my firm were approached by the landlord of two floors of offices in Glasgow to provide advice and potentially market the properties to let or to sell
- We were already instructed by another landlord in the same building to market their floors to let however, they had recently asked for us to market this on a to let/may sell basis
- We took the view that to accept this instruction would be a direct conflict as the different floors would be in direct market competition
- Therefore, we informed the second landlord that we would be unable to advise on the disposal of their floors and recommended that they seek the advice of another agency firm
43
What does the rules of conduct say about handling clients money
* Included within Rules of Conduct – firms keep client moneys safe and have appropriate accounting controls
* Clients’ money can include holding deposits, rent, service charges and retentions
44
what RICS guidance note is relates to handling clients money?
RICS Professional Statement: Client Money Handling, 2019
6 main areas of good practice
1) Holding client money
2) Providing information to clients
3) Receipts of client money
4) Payments from client accounts
5) Accounting records and controls
6) Compliance
45
Explain some of the procedures regarding handling clients money
* Client accounts must be kept separate and clearly identifiable
* The word ‘client’ is on the bank account and cheque book
* Client must be able to have their monies on demand
* Payment of interest agreed, and accounts must be kept in credit
* Regular bank reconciliation checking that payments received are transferred to the bank account and expenditure records are checked at least monthly
* Accurate records are kept of the running balance available
* Annual audit and reporting obligations
* Cash receipts to settle transactions
* Signatories must be agreed, need 2 signatures
* A discrete account is for a single named client account only
* RICS Regulatory Review visits every 3 years
* Firms handling client money procedures need to be displayed on the website
46
How would you start a new practice?
* Inform RICS
* Appoint a Responsible Principal for all RICS communication
* Register with RICS
* Arrange PII and get approval from RICS
* Set up procedures e.g. client handling money
* Register for RICS Valuer Scheme (VRS) if undertaking valuations
* Obtain RICS approval for CHP
* Set up a complaints log
* Appoint a complaint handling officer
* Use a logo kit from the RICS for all practice material to comply with the designation ‘Regulated by RICS’
* Log CPD on RICS CPD Management system
* Complete RICS annual return each year
47
How would you close down a firm?
RICS Compliance
* Inform the RICS
* Ensure the clients are informed at the earliest opportunity and hand over arrangements made to the new firm
* Return any monies held by clients to their own accounts
* Inform your insurers and procure professional indemnity run off cover for a minimum of 6 years
* Retain a copy of files and record for a minimum of 6 years
48
What statutory stuff would you need to consider when starting a new firm?
* Disclose business name (Business Names Act 1985 & Companies Act 1985)
* Disability Discrimination Compliance (Equality Act 2010)
* Bribery Act 2010 Compliance
* Appoint a Money Laundering Reporting Officer (Money Laundering Regulations 2017)
* Health & Safety compliance (Health & Safety Act 1974)
* Asbestos Register (Control of Asbestos Regulations 2012)
* Register for Data Protection (Data Protection Act 2018)
* Estate Agency Compliance (Estate Agents Act 1979, Consumer Protection Regulations 2008, Misrepresentation Act 1967)
* Ensure compliance with current employment law i.e. national living wage, working hours
* Ensure insurance compliance for employer and public liability
49
What is the Bribery Act, 2010?
* Aims to reduce bribery in businesses
* A bribe can be giving, offering, promising, or receiving of an advantage e.g. payment or gift
Based on 6 key principles:
1) Proportionality
2) Top level commitment
3) Risk assessment
4) Due diligence
5) Communication
6) Monitoring and review
50
What are the offences under the bribery act 2010?
1) Bribing
2) Receiving a bribe
3) Bribing a foreign public official
4) Failing to prevent bribing
- Offering clients reasonable and proportionate hospitality will not constitute an offence e.g. tickets to a sporting event and meals. This must be recorded on the gifts register.
- Companies must have policies and procedures in place to meet criteria to prevent bribery e.g. staff training, regular reviews, policies
51
What are the penalties?
* Act is policed by the Serious Fraud Office
* Maximum penalty of 10 years imprisonment and / or an unlimited fine
52
What laws relate to money laundering?
Money Laundering, Terrorist Financing and Transfer of Funds Regulations, 2019
* Money laundering is when proceeds of criminal activities are disguised or converted and then realised as legitimate assets
53
Tell me about the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations, 2017 – as amended 2019
- Cover estate agency work inside and outside UK by a firm
- Key provisions are:
o Requirement to have a written risk assessment
o Implement systems, policies and control to address ML
o Adopt appropriate internal controls
o Staff training
o Comply with customer, enhanced and simplified due diligence
o Comply with polices for Politically Exposed Persons (PEP)
o Appropriate record keeping
o AML checks to confirm identity of purchaser
o Include high risk factors when assessing need for enhanced DD e.g. high risk third countries
54
What are the key provision of the Countering, Bribery, Corruption, Money Laundering and Terrorist Financing Professional Statement?
- Provide Staff training
- Have appropriate internal controls
55
What do you do if you are suspicious of money laundering or bribery?
- Go to the relevant authority aka the police first
- Do not alert party of concern
56
What is G&S Money Laundering Policy/procedure?
- Requirement to undertake a check on all parties in a buying or selling transaction
- Requirement to undertake checks on all parties in leasehold transactions where the annual rent exceeds £100,000
- Follow a risk-based approach with any high risk clients and Politically Exposed Persons escalated to the MLRO for approval
- Key checks
o Client due diligence (identity checks)
o Source of Funds Checks (if funds come from another party than the purchaser, must also be checked)
o Source of Wealth (what is known about the client is consistence with their expected income)
o Counterparty checks (other side of the transaction
- Checks must be undertaken before ‘establishing a business relationship’
- Individual client lead is responsible for assessing risk with assistance from AML analyst
- AML records are kept for 5 years after completion
- Staff provided with training when they join with additional annual training.
57
What do you do if you are suspicious of money laundering or bribery?
- As per my firms AML policy, I report to the AML/compliance officer or deputy
- Nominated officer will decider whether to report to the National Crime Agency using the Suspicious Activity Reporting System
- Go to the relevant authority aka the police first
- Do not alert party of concern as may be seen as tipping off which is a criminal offence
58
What are the penalties for breaching the MLTFPFR?
- Assisting with ML – unlimited fine and up to 14 years in prison
- Tipping off – unlimited fine and up to 5 years in prison
59
What is your firm’s gifting policy/what are the limits?
- For Public Sector gifts over £15 and entertainment over £30 require pre-authorisation
- For Private Sector
o Gifts over £60 and entertainment over £120 must be reported
o Gifts and entertainment over £500 require pre-authorisation
- Overnight stays always required pre-authorisation and all travel and accommodation costs must be borne by recipient, same for spouse
- Any facilitation payments are prohibited
- Cash and cash equivalents are not to be excepted, including retail vouchers
60
What are Money Laundering, Terrorist Financing and Transfer of Funds Regulations, 2019 Estate Agents Legal Obligations
* Act was amended in 2019 to require letting agents to register with HMRC within 12 months of May 2020 if they let individual properties for more than equivalent of 10,000 euros pcm.
* Government guidance: Estate agency guidance for money laundering supervision, June 2021. Includes requirements for sales agents as well
* CDD checks on vendors, purchasers, landlords and tenants will have to be undertaken on new sales or any letting or reletting
* EDD undertaken if red flags occur (e.g. involving high risk countries or non-face to face business relationships)
61
What are the types of due diligence?
1. Customer due diligence
- Identify client and verify identity via reliable doc (passport)
- If a company – name, company number, address of registered owner
- For a company, names of directors required unless the company is listed on a regulated market such as LSE
2. Enhanced due diligence
- If a person from a high-risk country
- PEP and/or their family members
62
What due diligence would you undertake prior to commencing an instruction?
- Confirmation of client entity
- Confirmation of property address
- Conflict check
- Inspection and measurement of property
- Review of title documents
- If occupied, review leases and check tenant covenant
- Check planning history
63
Money Laundering, Terrorist Financing and Transfer of Funds Regulations, 2019
Other key requirements of the regulation:
* Firms must register with HMRC annually
* Limit of 10,000 euros for acceptance in cash
* Monitor ongoing business relationship
* A nominated person must be appointed to report any suspicions to the National Crime Agency
* Maintain records for a minimum of 5 years
64
Money Laundering, Terrorist Financing and Transfer of Funds Regulations, 2019
Penalties
* Maximum 14 years prison sentence and or unlimited fine for assisting
* Maximum 5 years prison sentence and or unlimited fine for tipping off a person by informing them they are under suspicion or for failing to report suspicion
65
Typical requirement for CDD checks:
* Public Limited Company – London Stock Exchange Listing
* Publicly Accountable Body - Government Ownership / Control
* Private Limited Company – Certification of incorporation, full name, registered number and office, business address, name of all directors and names of all shareholder with 25% or more
* Private Individual – Copy of passport or driving licence, bank statement, credit card bill, council tax statement or utility bill to show proof of address (not more than 3 months old)
66
Red Flags
* Inability or unwillingness of parties to provide identity documents
* Changes to parties involved in transactions
* Unusual transaction features e.g. unexpected urgency required by parties, potential loss-making or an unusual transaction for a client
* Payment of fees, purchase, or rental monies in unusual currencies
67
What RICS guidance is there for ML and bribery?
RICS Professional Statement: Countering Bribery, Corruption, Money Laundering and Terrorist Financing, 2019
Divided into 3 parts:
1) Mandatory requirements for anti-bribery, corruption, anti-money laundering and terrorist financing
2) Guidance setting out supporting good practice for the above
3) Supplementary guidance on some of the concepts
68
What must rics regulated firms do under the RICS Professional Statement: Countering Bribery, Corruption, Money Laundering and Terrorist Financing, 2019
RICS regulated firms must:
* Not facilitate or be complicit in ML and TF
* Have systems in place to comply with laws
* Report suspicion
* Evaluate and review the risks presented to the firm
* Use third party reliance for checks only where there is a level of confidence for the quality of information provided by the third party
* Understand the client and the purpose of the instruction
* Verify the client by undertaking basic ID checks
* Retain records to show the firm has met the requirements of the professional statement
APC
flashcards
Decks in class (20)
# Cards
-
Local Taxation140
-
Valuation SOE14
-
Case Study27
-
Local Taxation - Regulations29
-
Things I forget80
-
Inspection33
-
Accounting principles and Business planning15
-
Valuation41
-
Red Book43
-
Conflict Avoidance18
-
Development appraisal34
-
Leasing and Letting60
-
Ethics68
-
Health and Safety16
-
Data Management10
-
Sustainability14
-
Inclusive Environments12
-
Diversity and Inclusion5
-
Loan Security33
-
Loan Security SOE32
