- ACIL Letter from Steve Pociask - A letter from the President of the American Consumer Institute, protesting a Press Conference with Senator Fasano and Rep Kriseman.
- ACV-RCV Handout; 2011 - A paper explaining the impact on loss costs due to the prohibition against hold back on Replacement Cost claim payments.
- Approved Rate Increases 2010 -
- Articles; Citizens, Cat Fund, Reinsurance - A series of articles from the Florida Underwriter Magazine published in July 2011 that summarize the current state of affairs for assessments and exposure.
- Assignment of Benefits--Consent Order for "Emergency Services 24, INC. - The results of a 2012 investigation into fraud, including unlicensed Public Adjusting, by a water extraction company.
- Auto, Interim Report on the Effect of Repealing PIP - Senate B&I Report number 2008-102, issued in 2007 regarding what would happen if the previously enacted sunset of PIP was allowed to stand.
- AUTO--OIR CHOICES Website; Three Risk Configurations - Detailed description of the three risks (Family w/ Young Drivers, Single Female & Senior Married Couple).
- Auto; Evaluation of OIR Pip Report - Requested by FCAN; an evaluation of Data Collected by OIR In PIP Data Call by Lorilee A Medders, PhD November 4, 2011
- Auto; PCI Fraud Report. October 27, 2011. - Florida's Automobile No Fault Insurance: A System Under Siege by Fraud and Abuse.
- Auto; PIP Presentation to Cabinet - Presented by the Insurance Consumer Advocate (ICA) to the Cabinet while sitting as the Financial Services Commission, on November 1, 2011.
- Auto; Senate B&I Issue Report on PIP - Outlines the current PIP system, recent trends in PIP fraud, recent trends in PIP costs on a statewide and a regional basis, and relevant legislative proposals offered during the 2011 session.
- Auto; Statement by the American Insurance Association - August 23, 2011 provides options and recommendations, including repeal, for the 2012 legislative session.
- CFA vs Heartland; 2012--Articles on Mckinsey/Allstate & Repeat Offenders - Includes a response to the CFA report from the Insurance Information Institute.
- CFA vs Heartland; 2012--Heartland's Response to CFA - As published by various trade magazines and written by Eli Lehrer and RJ Lehman.
- CFA vs Heartland; 2012--Repeat Offenders - A report by Robert Hunter alleging the industry manufacture's crisis's.
- CFA vs Heartland; 2012--Statement on Long Term Solutions Task Force - by Bob Hunter on Florida's Hurricane Market and why regulation is necessary.
- Chip Merlins Blog - A numbered paragraph version as a reference for a blog refuting an editorial piece by Chip Merlin on Hb-245 & Sb-578.
- Citizens & Cat Fund Article by Eli Lehrer - Florida deficit is a drop in the bucket compared with what all of us will owe if a major hurricane strikes; by Eli Lehrer with the James Madison Institute & VP of the Heartland Institute.
- Citizens Assessment; Amounts Received - A breakdown of the dollars received by Citizens from assessments. These a part of the existing surplus of $5 billion.
- Citizens Bill Comparison; 2011 - A comparison of major issues contained in the House and Senate Citizens bills; CS/SB-1714 and CS/HB-1243.
- Citizens Board, Depopulation Options - A compilation, within the confines of existing statute and the Plan of Operation, of what Citizens could do to reduce the influx of new applications.
- Citizens Bond Offer; WSJ article July, 2011 - Article by Leslie Scism applies perspective to Citizens recent $900 million bond issue.
- Citizens Cabinet Presentation Q&A; June, 2011 - Questions by the Governor and Cabinet of Susanne Murphy with Citizens regarding solvency and assessments.
- Citizens Cabinet Presentation; November 2, 2011 - Presented by Scott Wallace to the Cabinet sitting as the Financial Services Commission, regarding Citizens and what it can do to reduce it's footprint.
- Citizens Commissions Compared to Private Market & Other States - A paper prepared by the FAIA showing Citizens producer commissions do not impact depopulation.
- Citizens Comparisons; RMS Models 10, 11, - A series of exhibits comparing the RMS models via PML summary charts for the CLA, PLA and HRA of Citizens by Willis Re.
- Citizens Depopulation Count--2003-2012 - Total policies removed from Citizens under takeout arrangements and the related exposure amounts removed.
- Citizens Depopulation To-Do List - Exposure and Depopulation initiatives by Citizens broken down by timeline and effective date. 12/14/11.
- Citizens Inspection Results -
- Citizens letter; From Rep. Proctor to Scott Wallace. 7/14/11 - This letter asks four detailed and technical questions regarding a presentation given by Citizens to the Florida Cabinet.
- Citizens Market Share by County - Homeowners - September 2010 -
- CITIZENS MEDIA ADVISORY--Surplus Notes; 10/12 - A media announcement of the response given to Rep. Artiles on the advantages of the Surplus Note Program.
- Citizens Media Reports; weekend of 9-7-12 - A remarkable list of media reports on Citizens, regarding depopulation, staff expenses and its re-inspection program.
- Citizens New Applications by County - New applications by county for the first quarter of 2011 and for the entire year, 2011.
- Citizens New Applications by County; 1st Quarter, 2012 - Each County for the first quarter is ranked; highest to lowest based on new applications.
- Citizens Op Ed by Don Brown - Is Citizens Strong and Profitable as alleged by some in the media?
- Citizens Plan of Operation - Pursuant to statute and approved by the Financial Services Commission, this is the plan that governs the operation of Citizens.
- CITIZENS Policyholders by voting district - A press release with links to an online tool by AIF giving Citizens population based on voting districts.
- Citizens Public Adjusters by Cause of Loss; 2012 - Chart showing the percentage of PA involvement based on the top ten causes of loss.
- Citizens Rate Advantage: - Consists of three charts: one showing the rate increases for top 21 writers; one showing the weighted average compared to Citizens, and one showing market share of Citizens by county and policy type. As of September, 2011.
- Citizens Replacement Cost - A "compilation" of articles and "Letters to the Editor" regarding the unfairness of Citizens new Replacement Cost Calculator.
- Citizens Sinkhole Articles; Favorable - Two articles that appeared to understand what actually took place at the hearing and the subsequent reduction of Citizens sinkhole rate request.
- Citizens SInkhole FAQ--Inspections, definitions & procedures - Explains and answers questions regarding Citizens new sinkhole inspection rule and other matters related to Sinkhole & Catastrophic Collapse coverage with Citizens.
- Citizens Sinkhole Law Firms - A public document request of OIR showing Citizens Sinkhole payout based on the law firm involved. 2006-2010.
- Citizens Sinkhole Law Firms--Dwelling Policies - A list of the firms and the amounts paid to their claimants for sinkhole claims on Dwelling policies; includes Incurred claim amount, Claim Count, and ALAE for the years 2006 thru 2010.
- Citizens Sinkhole Law Firms; Combined Report - A combination of the claims payout by law firm of Citizens HO-3's and DP forms. Top Ten Law Firms based on Number of claims are highlighted.
- Citizens Sinkhole Law Firms;2012 - A chart showing which law firms are responsible for filing Citizens sinkhole claims
- Citizens Sinkhole Rate Phase In - The board presentation regarding the phased in approach to Citizens Sinkhole rate increase. Includes a graph of the impact on each of Citizens territories.
- CITIZENS SINKHOLE UPDATE--November, 2012 - A Claims Committee update by Lance Malcolm to Citizens board.
- Citizens Sinkholes; Statement by Robin Westcott - Regarding the pending sinkhole rate increase hearing 9-13-11 scheduled in Tampa.
- Citizens Statute - The entire Citizens Statute FS 637.351(6)
- Citizens Takeout Companies, April 2010 - Columns of information on Citizens takeout companies; the depopulation plan, financial status and relevant news items.
- Citizens, Cat Fund & Reinsurance Articles - A set of articles by the Florida Underwriter Magazine as distributed by The Florida Insurance News giving an overview of assessments and exposure; July 1, 2011.
- CITIZENS--Barry Gilway's letter to Artiles - In response to a Public Records request from Rep. Artiles this response details benefits of surplus notes and has a fact sheet.
- Citizens--ICA Report on Assessments Pulled from Web - By the Sarasota Herald Tribune; article on the ICA's report comparing Citizens assessments to those that might be made by the private market under different storm scenario's.
- Citizens--Inspector General; Op-ed from Johnson Strategies, LLC - A blog transformed into a letter to the editor favoring Governor Scott's Inspector General including outside threats as well as overseeing employee's activities.
- Citizens--Letter from Weatherford to Lacasa - From Speaker Designate Will Weatherford requesting the board of Citizens to hold off on the Surplus Note Program.
- Citizens--Public Adjuster advertising - Federal Law dealing with Emblems, Insignia's and names.
- Citizens--Public Adjusters by Cause of Loss; 2012 - Chart Showing the top ten perils with PA's based on average indemnity paid:1/01/2009 to 07/20/12
- CITIZENS--Public Adjusters involved in Citizens Claims - A list of the PA's and the number and amount of the claims each has filed with Citizens for the period represented.
- Citizens--SNL Article on Gilway & 2012 - A perspective distributed by Citizens Newsroom on the happenings of 2012 and the goals going forward.
- Citizens: Internal Complaints--a list of internal personnel complaints released by Citizens February, 2012 -
- Citizens; A blank application for coverage - Shows the detailed information and certifications requested of agents, policyholders and applicants of Citizens.
- Citizens; Bill Newton's Blog Response - A response by Bil Newton, President of FCAN, to a blog I wrote on what Citizens board could do to depopulate without the need of a change in statutes. 10/16/11
- Citizens; Builders Risk Policies - A chart showing the builders risk exposure and policy count for each of three accounts of Citizens.
- Citizens; CFO Atwater's Letter to Governor Scott - The CFO requests that the Inspector General that "might" be created to oversee Citizens employee's, report directly to the FSC.
- Citizens; Consumer Choice - FS 637.351 Consumer Choice.
- Citizens; dual opinions in the Tallahassee Democrat - Published here for ease of reference to an opinion published on this site about the two Op-eds on 8/28/12.
- Citizens; Idea's To shrink it's Size - This document was used during the November, 2011 board meeting to discuss idea's for reducing Citizens policy count as requested by the Governor and the Cabinet.
- Citizens; Moody's report on Citizens Bond Issue, July 2011 - The report referenced in WSJ article giving Citizens an A2 and MIG1 rating for $900 million bond issue.
- Citizens; OIR order, Glide Path increase; October 2009 - The OIR final order regarding the first glide path rate increase for Citizens of 5.4% statewide average.
- Citizens; PA comments about limits on remuneration for Citizens claims - President of FAPIA, Pat Cucarro, comments on the law limiting PA remuneration for Citizens claims to 10% of the difference between what was paid and originally offered.
- Citizens; Plaintiff Attorney Pending Suits, 2012 - Shows those firms with pending lawsuits against Citizens as of 9-30-12. The top firms are broken out and include the usual suspects.
- Citizens; Sinkhole increase, articles and announcements - A compilation of articles and announcements for quick reference when reading the post titled: Citizens Sinkholes; Not a Pretty Sight! Posted August 7, 2011.
- Citizens; Statewide Windpool Article by Aisling Swift, 6/19/12 - Sean Shaw suggests the decoupling of Citizens perils other than wind.
- Citizens; Statewide Windpool Article by Fasano; 6/15/12 - Published in the East Lake Blister & written by Senator Mike Fasano, mentioning decoupling of perils away from Citizens.
- Citizens; Statewide Windpool Article by John Reiners; Hernando Today, 6/18/12 - The Only Windstorm Insurer Possible, he calls it--State Government Controlled.
- Citizens; We Will Not Budget for Growth - Best Week article from Dan Luby regarding philosophies of Citizens new/interim President, Tom Grady.
- Complaint Ratio Report--2010 - An OIR report on the complaints filed against Fla. Homeowners Carriers including a calculation of the ratio of complaints.
- Complaint Report Analysis by Brent Winans--2010 - Ranks the top 50 homeowners writers according to their complaint ratio published by OIR and explains the criteria used.
- CPIC Rate Inadequacy -
- Deductibles Statute, Fs 627.701 - Includes Case notes, and statutory change history as of October, 2011.
- Demotech explanation of Financial Service Ratings -
- Dispelling Myths About MGA's - A white paper by FPCA (Florida Property Casualty Association) on Myths vs Facts about Florida's MGA system for Property & Casualty Insurance.
- Fasano's Letter to Senator Richter; 12/14/11 - Senator Fasano requests the Chairman of the Senate Banking and Insurance Committee to summon Scott Wallace before the committee to answer questions.
- FCAN Supports CAT Fund Bill - An article to assist as a reference for a blog published on Bill Newton's opposition to the Citizens Depop bill.
- FIGA 2012 Assessment Notice - Includes, letter to Commissioner McCarty, stating that the "largest impact" was due to Sinkhole Claims.
- FIGA 2012 Assessment--Impact - A per carrier breakdown by SNL Financial, showing the impact on each carrier of the assessment.
- Flood Reforms--2012 - A summary and line-by-line analysis of the Biggert-Waters Reform Act
- Florida Property Loss Reimbursement -
- Florida Surplus Report June 2009 -
- FOUITFWCR - An offer of interest in forming a group called Floridians Opposed to Unfair Insurance Taxes Favoring Wealthy Coastal Residents.
- Homeowners Choice Agent Contract - The limited appointment agreement of Homeowners Choice offered following the insolvency of Homewise Insurance; November 11, 2011.
- Homewise Receivership Consent Order - 2nd Circuit Court; Leon County, DFS is named receiver for purposes of rehabilitation, injunction and notice of automatic stay.
- Insurance Reform Bill Comparison; 2011 - A line-by-line comparison of the Senate and House bills from the 2011 Session; CS/CS/CS/SB-408 and CS/CS/HB 803.
- Insurance Regulatory Report Card--2011 - By Eli Lehrer with the Heartland Institute. Florida get's an "F" and has the worst numerical rating in America.
- Insurance Regulatory Report Card--2012 - A state by state ranking based on selected criteria of regulatory and political performance. Florida receives an "F" from RStreet.
- Insurance Residual Markets White Paper -
- Insurance Residual Markets: Historical & Public Poicy Perspectives - Written by James W. Newman Jr, & sponsored by The Florida Catastrophic Storm Risk Management Center; describes issues associated with residual markets.
- Kevin McCarty letter to Governor Crist in support of SB-2044 -
- Letter on The Hidden Hurricane Tax; April 25, 2011 - Written by Locke Burt to Representative Fred Costello; an excellent summary of the impact of Citizens assessments and the importance of raising Citizens rates.
- Magnolia Liquidation Order -
- Mitigation White Paper; Press releas by FAIA - An announcement from FAIA in 2009 about its Mitigation White Paper and generally some of the conclusions therein.
- Newton & Stevans; comments about the sinkhole rate increase of Citizens - In response to a blog I wrote on the rate increase, two consumer activists respond with comments of their own; addressed in a 9-11-11 blog.
- NGIC Rehabilitation Order; August 2011 - Order appointing the DFS as receiver of National Group Insurance Company for Rehabilitation
- OIR Memorandum on 100-year Requirement -
- PA Advertorial by Pat Cucarro - Published by the Tallahassee Democrat in March 2012 this op-ed is cited in a blog written and published March 26, 2012; titled Citizens & Public Adjusters
- Pat Cucarro Advertorial - Published by the Tallahassee Democrat; January 3rd, 2012.
- PCI - Chamber Poll Findings -
- PCI - Chamber Poll Topline -
- Peoples Trust Complaint Analysis - A 2012 response to questions regarding the carrier having the highest complaint ratio.
- Peoples Trust Flyer; Circa 2009 - Promises, 70% savings.
- PIA Claims Victory - A newsletter released following the 2013 legislative session in which PIA takes the credit and blasts Representative Kevin Rader. (See Post dated: 5/12/13)
- Property Insurance Commentary by Sen. Richter and Rep. Nelson - A three part paper titled "How Critical is Property Insurance in Florida?". Published June, 2012.
- Public Adjuster Advertising Laws - Excerpts of Florida Statutes pertaining to Public Adjuster advertising.
- Public Adjuster Referral Network - An email sent to all 2-20 agents about a "network" of 300 PA's they should use.
- Public Adjuster Rule; Draft--March 2012 - As referenced in a corresponding blog post.
- Public Adjuster, Martyn Belben's Response - Martyn Belben responds to a blog on PA Advertorials and misuses the OPPAGA study results.
- Public Adjuster--Amended Complaint challenging the Fee Statutes - 2nd DCA arguments from D'Alembert firm to overturn both the Citizens and the private market statutory fee limits for PA's.
- Public Adjusters Alabama: Article and ABA Notice - Public Adjusting is illegal in Alabama. The state bar warns against engaging in the practice. A related article provides background and insights.
- Public Adjusters--AAPIA letter of Explanation - Attorney Holly Soffer explains AAPIA's position in opposition to the New Jersey fee cap legislation endorsed by NAPIA.
- Public Adjusters--Arrest Affidavit - Information on the arrest of Alberto Alvarez and others for defrauding Citizens.
- Public Adjusters--NAPIA letter to New Jersey Assembly - National Adjusters Association embraces a 12.5% contingency fee; across the board.
- Public Adjusters--New Jersey Assembly bill SB 2472 - Limits PA fee's under certain circumstances to 12.5%.
- Public Adjusters-Advertorial by FAPIA President - Included here as reference for a blog written on August 30th regarding the truth about the cost of PA's and the industry response to similar adds.
- Public Adjusters: Espinosa Case - An article published by P&C 360 of a blog I had published regarding the infamous "Yellow Hammer Case".
- Public Adjusters: Espinosa Case - Police documents showing the facts in support of an arrest of Jorge Espinosa and others in the famous "Yellow Hammer Case."
- Public Adjusters; article for Miami Herald - Written by defense attorney Jason Wolf it extols how PA's are driving up costs in Florida with frivolous claims.
- Quinnipiac Poll 2011 -
- Rate Hikes, 2012 - Data excerpted from OIR spread sheet on approved 2012 homeowner rate increases.
- Rate Hikes; articles by Julie Patel, 2011 - Included here for ease of reference to a blog regarding the Rstreet ranking of Florida as the worst regulatory environment in America.
- Ratings Paper Executive Summary - A comparison of Demotech to other ratings firms
- Rebating Issues; History & Background, Florida - A paper explaining the historical background of insurance rebating and the Florida law restricting the practice.
- Rebating; Federal Memo Prohibiting - April 4, 2012 FEMA issues memorandum prohibiting rebating of NFIP Flood commissions
- Rebating; Original Florida Case - A paper titled "Can a 19th Century Idea Protect Modern Consumers?" by the Dade County Consumer Advocates Office regarding the court decision repealing Florida's anti-rebating statute.
- Report of Aggregate Net PML & Assessments; February 2011 - A chart and talking paper regarding assessments and PML for Citizens and the Cat Fund; February 2011
- Residual Mrkt Plans: From Markets of Last Resort to Market of First Choice - I.I.I.’s latest analysis adds to what is now a well-documented body of research that many residual markets have morphed to become major insurance providers in their states.
- RMS Model Comparison for Monroe County - Charts comparing the difference in Monroe County for its 100-yr PML and its % of County PML Contribution for the RMS model 10, 11 and 12.
- SB-408; 2011's General Property Reform Package - The final "enrolled" version of the 129 page bill.
- Sean Shaw article: Advocates Won't Stop Fighting - Published in the Tallahassee Democrat, November 18, 2011 in response to an op-ed by Steve Pociask with the American Consumer Institute.
- Senator Mike Fasano Press Release - Statement from Senator Mike Fasano to Governor Scott:Please Veto SB 408
- Sinkhole Articles - A compendium of articles to assist readers as a reference to the blog post titled: Citizens Sinkhole Rate Increase...Being Truthful or Being Right?
- Sinkhole Articles - A compendium for a blog titled; Citizens Sinkhole Rate Increase; Being Right or Being Truthful.
- Sinkhole Handout; 2011 - Opportunism at it's worst--A brief bullet point summary of the sinkhole crisis & the solution
- Sinkhole Structural Damage Decision - Thirteenth Circuit Court decision denies retroactive application of the Statewide Building Code definition of structural damage for sinkhole losses.
- Sinkholes 2011; Wallstreet Journal article by Leslie Scism - "As more Florida homeowners seek insurance payments for sinkhole problems, lawmakers are considering measures to curb dubious claims and...ensure that...proceeds are used to repair properties."
- Sinkholes; By Steve Pociask - Opinion piece in the Tallahassee Democrat by the American Consumer Institute regarding the false consumerism banner of law firms and public adjusters.
- Stander vs Trigaux -
- State Regulatory Report Card; "F" for Florida - 2011--The Heartland Institute's annual analysis of which states have the best/worst regulatory environment. Florida get's an "F"
- Statewide Wind Pool; Crane Group Proposal--March 30, 2008 - Written by Dan Montgomery it transforms the FHCF into Florida's sole "hurricane" insurer, including all government and institutional risks. Carriers write the more manageable wind risk.
- Surplus & Underwriting Totals; as of 12/31/09 - A listing of the net underwriting gains or losses for the top 46 domestic carriers that are unaffiliated with any national or regional company.
- TAX WATCH...Special Report; April 2010. - By the Florida Council of Economic Advisor's this report is on the financial exposures created by Citizens and the Cat Fund.
- The Bottom Line--article rebutting attacks on Reinsurance Industry - Jonathan Kent writes and rebuts award winning journalist, Paige St. Johns accusation that reinsurers "rigged" rates.
- The Ten Worst Insurance Companies in America - From the American Association for Justice
- Tricks of the Trade--How Insurance Companies Deny, Delay, Confuse & Refuse - Published by the American Association for Justice
- Universal Order--Article by Herald Tribune - Report by The Herald Tribune on the OIR order fining the company $1.26 million.
- Universal Order--Article by Palm Beach Post - Report by the Post on the $1.26 million fine against Universal for post claims underwriting.
- Universal P & C--Claim Denials - An Agency Notice from Universal as a result of Robin Wescott's call for an investigation of its pattern of claim denials due to post claim underwriting.
- Universal P & C--Claim Denials - Robin Westcott's letter to OIR requesting an investigation into claim denial by Universal P&C
- Universal P & C--Claim Denials - An article by David Thompson (FAIA), giving real claim denials under FS 627.409.
- US BANK RESCINDS SINKHOLE REQUIREMENT - U.S. Bank; effective December 7, 2011 or after sinkhole coverage will not be required; with exceptions.
- Voluntary Market Commission Percentages - Prepared 1/25/12 as a comparison to commission percentages paid by Citizens. Source: The Florida Association of Insurance Agents
- Waiting For Hurricane Charlie; WSJ Article - Editorial regarding Charlie Crist's legacy of assessments from the Cat Fund and Citizens. 2011
- Windstorm Coverage Fund (WCF) - Actuarial analysis by Vogel Actuarial Consulting.
Marsh Kickback Scandal/Compensation Disclosure
- Agent Groups Rage Over Contingent Fee Issue -
- Agent Leaders Counter RIMS Pres -
- AON SETTLES CORRUPTION PROBE -
- Broker Fees -
- Committees Ex Broker Settlement -
- Crist attacks insurance firms after his rate-cut vow is ignored -
- Definition of Contingent Commissions -
- IIABNY Appeals Decsision--9/1/2011 - Article from the Insurance Journal about the New York Big I's appeal of the lower court decision regarding the Insurance Commissioners rule on compensation disclosure.
- KICKBACK by Scott Johnson - A rendition of events, taken from news reports, court documents, and several books, including my own experience; regarding the original probe of Marsh bid rigging.
- Marsh & McLennan Companies -
- Marsh Settlement -
- NAIC Documents -
- New York Lawsuit Exhibits -
- PIA National Takes Issue with Plumeri's Comments -
- Producer Compensation Issue Update -
- Signed Settlement -
- Spitzer NY Testimony -
- Spitzer Suit Dismissed-- - Federal Judge dismisses suit against Spitzer by William Gilman.
- Spitzer US Senate Testimony -
- Spitzer's $60 Million Libel Lawsuit - A compendium of articles regarding the lawsuit in response to an article written by Spitzer in the Wall Street Journal. It was filed by William Gilman and Edward McNenney who were both acquitted of bid rigging and anti-trust violations when Spitzer was Attorney General.
- Spitzer/Cuomo Editorial; WSJ - This is the editorial that prompted Elliot Spitzer to write an opinion piece on Wall Street fraud and abuse; which resulted in his $60 million libel case from Gillman and McNenney.
- STATE SETTLES PROBE OF WILLIS -
- The original complaint with Supreme Court -
- THE SMALL LAWS: ELIOT SPITZER AND THE WAY TO INSURANCE MARKET REFORM -
- Timeline and Chronology -
- Timeline and Chronology of Events and Issues -
- USA Today account of the charges -
- Wharton Study -
- Willis Group calls on insurance industry to end practice of contingent agreements with insurance carriers -
- Zurich Class Action Settlement Memo -