Category: SEC-2402

Securities and Exchange Commission (SEC)

February 2024 Press Releases

SEC-PR-2024-27

Categories SEC-2402
SEC NEWS - SEC-PR-2024-27SEC-PR-2024-27 (FEB. 27, 2024)
PRESS RELEASE | 2024-27

SEC Announces Departure of William Birdthistle; Natasha Vij Greiner Named Director of the Division of Investment Management

Washington D.C., Feb. 28, 2024 — The Securities and Exchange Commission today announced that William Birdthistle, the Director of the Division of Investment Management, will depart the agency, effective March 8, 2024. Natasha Vij Greiner, currently the Deputy Director of the Division of Examinations, will be named Director of the Division of Investment Management upon Mr. Birdthistle’s departure. The Division oversees regulatory policy for investment advisers and investment companies, including mutual funds and other investment products and services relied upon by retail investors.

“I am grateful to William for his service to the SEC and to the investing public,” said SEC Chair Gary Gensler. “William has overseen our work to strengthen oversight of investment companies and investment advisers – from data reporting to fund names to money market reforms. These reforms will help American investors save for homes, college, and retirement.”

Chair Gensler added, “I thank Natasha for taking on this new role as Division Director. Natasha brings deep and broad expertise to the Division, both having led the agency’s Investment Adviser/Investment Company examination program and having served in other key leadership roles over her more than two decades at the SEC.”

Mr. Birdthistle joined the SEC in December 2021. In his time at the SEC, Mr. Birdthistle oversaw the adoption of major rulemakings related to private fund advisers and their reporting on Form PF, as well as to public funds, including money market fund reforms, tailored shareholder reports, and revisions to the fund Names Rule. He also inaugurated the SEC’s annual Conference on Emerging Trends in Asset Management.

Prior to joining the SEC, Mr. Birdthistle was on the faculty at Chicago-Kent College of Law, where he earned the school’s Excellence in Teaching Award in 2010. He also has served as a visiting professor of law at the University of Chicago Law School, where he won the Award for Teaching Excellence in 2019. Earlier in his career, he practiced law at Ropes & Gray in Boston for five years as a corporate associate in the firm’s investment management practice. Mr. Birdthistle received his J.D. from Harvard Law School, where he served as managing editor of the Harvard Law Review; a B.A. summa cum laude in English and psychology from Duke University in 1995; and an M.A. in history from the University of Chicago in 2021. Following his departure from the SEC, he will rejoin academia.

“Serving at the Securities and Exchange Commission has been the highest honor of my professional career, and I’m tremendously grateful for the inspiration and example set by my dedicated colleagues in the Division of Investment Management,” said Mr. Birdthistle. “I am particularly thankful to Chair Gensler for offering me this opportunity to join a cohort of exemplary public servants in their vigilant stewardship of America’s life savings.”

In addition to serving as Deputy Director of the Division of Examinations, Ms. Greiner is the National Associate Director of the Investment Adviser/Investment Company (IA/IC) examination program, which includes the Private Funds Unit, and is the Associate Director of the Home Office IA/IC examination program. She began her SEC career in the Division of Examinations (formerly OCIE) as a broker-dealer examiner and has served in a variety of roles across the agency for more than 22 years, including Acting Chief Counsel and Assistant Chief Counsel in the Division of Trading and Markets, where she provided legal and policy advice to the Commission on rules affecting market participants and the operation of the securities markets. Before that, Ms. Greiner worked in the Division of Enforcement, including in its Asset Management Unit, where she investigated possible violations of the federal securities laws and litigated matters in federal district court and administrative proceedings. Ms. Greiner received her J.D. from The Catholic University of America, Columbus School of Law and graduated cum laude with a B.S. degree from James Madison University.

“I am excited for the opportunity to lead the exceptional staff in the Division of Investment Management,” said Ms. Greiner. “I have been fortunate to work with dedicated and talented staff across the agency during my SEC tenure and have a great respect for the staff and the work of the Commission. I look forward to bringing my unique perspective and experience to this new role and continuing to support the SEC’s tripartite mission.”

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SEC-PR-2024-28

Categories SEC-2402
SEC NEWS - SEC-PR-2024-28SEC-PR-2024-28 (FEB. 29, 2024)
PRESS RELEASE | 2024-28

SEC Investor Advisory Committee to Discuss Proposals to Improve Equity Market Structure and Examine the Use of Materiality as a Disclosure Standard

Washington D.C., Feb. 29, 2024 — The Securities and Exchange Commission’s Investor Advisory Committee will hold a public meeting on March 7 at 10 a.m. ET at the SEC Headquarters in Washington, D.C. The meeting will also be webcast on the SEC website.

The committee will host two panels:

  • Discussing the U.S. Securities and Exchange Commission’s Proposals to Improve Equity Market Structure; and

  • Examining the Use of Materiality as a Disclosure Standard – Can the Definition be Improved to Better Serve Investors?

The committee will also discuss a recommendation on Digital Engagement Practices ⊗ (PDF).

The full agenda is available here ⊗.

The Investor Advisory Committee, which focuses on investor-related interests, advises the Commission on regulatory priorities and various initiatives to help protect investors and promote the integrity of the U.S. securities markets. Established by the Dodd-Frank Act ⊗ (PDF), the Committee is authorized by Congress to submit findings and recommendations to the Commission.

Learn more about the Investor Advisory Committee here ⊗.

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SEC-PR-2024-26

Categories Fraudulent Misrepresentations Making False Statements SEC-2402
SEC-PR-2024-26 (FEB. 27, 2024)
PRESS RELEASE | 2024-26

SEC Charges Former Alfi CEO Paul Pereira with Fraud for Making False Statements on Social Media

Washington D.C., Feb. 27, 2024 — The Securities and Exchange Commission today charged Paul A. Pereira, the former CEO and co-founder of Alfi, Inc., with making materially false and misleading statements on social media about the company’s financial and performance metrics in an attempt to boost the now defunct company’s stock price.

According to the SEC’s complaint, while serving as the CEO of Alfi, a Florida-based advertising technology company, and under the pseudonym “Uptix12,” Pereira allegedly posted shortly after Alfi’s May 2021 initial public offering that he “wouldn’t doubt” that Alfi “has $10 mm to $20 mm in revenues already in their back pocket,” when, in reality, the company was set to report only $17,450 in revenue. Soon thereafter, in another alleged attempt to boost Alfi’s stock price, Pereira stated in a YouTube interview that the company was entering into a contract with the founder of a successful restaurant chain to deploy Alfi technology in the founder’s restaurants. In fact, as alleged, the restaurant chain founder never discussed such a contract with Pereira or any other Alfi personnel. The complaint further alleges that, on August 17, 2021, with the company’s stock price opening at its lowest level in nearly two months, Pereira made false and misleading statements on social media and in a company-issued press release about the company’s advertising inventory, including that “available advertising inventory by the end of 2021 is expected to be in excess of $100 million.” Contrary to Pereira’s statements, according to the complaint, the company had less than $5 million in advertising inventory at the time, and Pereira did not have a reasonable basis to believe that Alfi would achieve $100 million in advertising inventory by the end of 2021. The company filed for bankruptcy in October 2022.

“As alleged in our complaint, Pereira tried to boost the company’s stock price through his false and misleading statements,” said Eric I. Bustillo, Director of the SEC’s Miami Regional Office. “This case further demonstrates the SEC’s commitment to holding officers of public companies accountable when they violate their legal obligation of candor and fair and full disclosure to investors.”

The SEC’s complaint, filed in the U.S. District Court for the Southern District of Florida, charges Pereira with violating the antifraud provisions of the federal securities laws. The SEC seeks a permanent injunction, an officer-and-director bar, and a civil penalty against Pereira.

The SEC’s investigation was conducted by Alex Charap with assistance from Kathleen Strandell, and it was supervised by Jessica M. Weissman, Fernando Torres, and Glenn S. Gordon, all of the Miami Regional Office. The SEC’s litigation is being led by Russell O’Brien and Mr. Charap and supervised by Teresa Verges.

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SEC-PR-2024-24

Categories Insider trading Mergers & Acquisitions SEC-2402
SEC NEWS - SEC-PR-2024-24SEC-PR-2024-24 (FEB. 22, 2024)
PRESS RELEASE | 2024-24

SEC Charges Husband of Energy Company Manager with Insider Trading. Spouse purchased stock using non-public information about the planned merger.

Washington D.C., Feb. 22, 2024 — The Securities and Exchange Commission today charged Tyler Loudon of Houston, Texas, with insider trading ahead of a February 2023 announcement that London-based oil and gas company BP p.l.c. agreed to acquire TravelCenters of America Inc., a full-service truck stop and travel center company headquartered in Ohio. Loudon allegedly made $1.76 million in illegal profits from his trading.

According to the SEC’s complaint, Loudon allegedly misappropriated material, nonpublic information about the proposed acquisition from his wife, a BP mergers and acquisitions manager who worked on the planned deal. The SEC alleges that Loudon overheard several of his wife’s work-related conversations about the merger while she was working remotely. Without his wife’s knowledge, Loudon purchased 46,450 shares of TravelCenters stock before the merger was announced on February 16, 2023. As a result of the announcement, TravelCenters’ stock rose nearly 71 percent. Loudon allegedly immediately sold all of his TravelCenters shares for a profit of $1.76 million.

“We allege that Mr. Loudon took advantage of his remote working conditions and his wife’s trust to profit from information he knew was confidential,” said Eric Werner, Regional Director of the SEC’s Fort Worth Regional Office. “The SEC remains committed to prosecuting such malfeasance.”

The SEC’s complaint, filed in U.S. District Court for the Southern District of Texas, charges Loudon with violating the antifraud provisions of the federal securities laws. Without denying the allegations in the SEC’s complaint, Loudon consented to the entry of a partial judgment, subject to court approval, permanently enjoining him from violating the antifraud provisions of the federal securities laws, imposing an officer and director bar, and ordering that he pay disgorgement with prejudgment interest and a civil penalty in amounts to be determined by the Court.

In a parallel action, the U.S. Attorney’s Office for the Southern District of Texas announced criminal charges against Loudon today.

The SEC’s ongoing investigation is being conducted by Julia Huseman and Jamie Haussecker of the SEC’s Fort Worth Regional Office, under the supervision of Jim Etri and B. David Fraser. The litigation will be led by Jason Rose and supervised by Keefe Bernstein. The SEC appreciates the assistance of the Financial Industry Regulatory Authority, the FBI, and the U.S. Attorney’s Office for the Southern District of Texas.  

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SEC-PR-2024-22

Categories Regulation Best Interest SEC-2402

SEC NEWS - SEC-PR-2024-22SEC-PR-2024-22 (FEB. 16, 2024)

PRESS RELEASE | 2024-22

Securities and Exchange Commission Charges TIAA Subsidiary for Failing to Act in the Best Interest of Retail Customers. Broker-dealer to pay more than $2.2 million for violating Reg BI.

Washington D.C., Feb. 16, 2024 — The Securities and Exchange Commission today announced that registered broker-dealer TIAA-CREF Individual & Institutional Services LLC (TC Services), a subsidiary of Teachers Insurance and Annuity Association of America (TIAA), will pay more than $2.2 million to settle charges that it failed to comply with Regulation Best Interest (Reg BI) in connection with recommendations to retail customers to open a TIAA Individual Retirement Account (TIAA IRA).

According to the SEC order, the TIAA IRA allowed retail customers to invest in both a pre-selected “core menu” of affiliated investments, including affiliated mutual funds, and, through the TIAA IRA’s optional “brokerage window,” a broader array of securities, including a variety of mutual funds, ETFs, stocks, and bonds. During the relevant period, the brokerage window included the lowest-cost share classes of certain affiliated mutual funds offered in the core menu, but with the investment minimums waived. Due to the waivers, customers could have purchased substantially equivalent, lower-cost share classes of these mutual funds in the brokerage window. The SEC’s order finds that TC Services violated Reg BI by, among other things, failing to disclose both that substantially equivalent, lower-cost share classes of affiliated funds were available in the brokerage window and the conflicts that were created.

According to the SEC’s order, more than 94 percent of TIAA IRA customers invested only through the core menu. As a result, nearly 6,000 TC Services retail customers paid more than $900,000 combined in expenses that they could have avoided by purchasing substantially equivalent funds through the brokerage window.

“Reg BI protects retail investors by requiring broker-dealers to act in the best interest of their customers when making recommendations, and today’s action demonstrates our commitment to ensuring compliance,” said Thomas P. Smith, Jr., Associate Regional Director in the New York Regional Office.

The SEC’s order finds that TC Services violated Reg BI’s General Obligation as well as Disclosure, Care, and Compliance Obligations. Without admitting or denying the findings, TC Services consented to the entry of an order that requires it to cease and desist from violating Reg BI, censures the firm, and orders it to pay disgorgement of $936,714 together with prejudgment interest of $103,424.91 as well as a civil monetary penalty of $1,250,000.

The SEC’s investigation was conducted by Rebecca Reilly and Alison Conn of the SEC’s New York Regional Office, under the supervision of Mr. Smith. The SEC examination that led to the investigation was conducted by Michael Altschuler, Sabrina Rubin, and Linda Lettieri.   

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SEC-PR-2024-20

Categories Disclosure Failures ETF Launch SEC-2402

SEC NEWS - SEC-PR-2024-20SEC-PR-2024-20 (FEB. 16, 2024)

PRESS RELEASE | 2024-20

SEC Charges Van Eck Associates for Failing to Disclose Influencer’s Role in Connection with ETF Launch.

Washington D.C., Feb. 16, 2024 — The Securities and Exchange Commission today announced that registered investment adviser Van Eck Associates Corporation has agreed to pay a $1.75 million civil penalty to settle charges that it failed to disclose a social media influencer’s role in the launch of its new exchange-traded fund (ETF).

According to the SEC’s order, in March 2021, Van Eck Associates launched the VanEck Social Sentiment ETF (NYSE:BUZZ) to track an index based on “positive insights” from social media and other data. The provider of that index informed Van Eck Associates that it planned to retain a well-known and controversial social media influencer to promote the index in connection with the launch of the ETF. To incentivize the influencer’s marketing and promotion efforts, the proposed licensing fee structure included a sliding scale linked to the size of the fund so, as the fund grew, the index provider would receive a greater percentage of the management fee the fund paid to Van Eck Associates. However, as the SEC’s order finds, Van Eck Associates failed to disclose the influencer’s planned involvement and the sliding scale fee structure to the ETF’s board in connection with its approval of the fund launch and of the management fee.

“Fund boards rely on advisers to provide accurate disclosures, especially when involving issues that can impact the advisory contract, known as the 15(c) process,” said Andrew Dean, Co-Chief of the Enforcement Division’s Asset Management Unit. “Van Eck Associates’ disclosure failures concerning this high-profile fund launch limited the board’s ability to consider the economic impact of the licensing arrangement and the involvement of a prominent social media influencer as it evaluated Van Eck Associates’ advisory contract for the fund.”

Van Eck Associates consented to the entry of the SEC’s order finding that it violated the Investment Company Act and Investment Advisers Act. Without admitting or denying the SEC’s findings, Van Eck Associates agreed to a cease-and-desist order and a censure in addition to the monetary penalty.

The SEC’s investigation was conducted by Salvatore Massa, Gregory Padgett, and John Farinacci under the supervision of Virginia Rosado Desilets, Mr. Dean, and Corey Schuster, all with the Enforcement Division’s Asset Management Unit.

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SEC-PR-2024-23

Categories SEC-2402
SEC NEWS - SEC-PR-2024-23SEC-PR-2024-23 (FEB. 16, 2024)
PRESS RELEASE | 2024-23

SEC Small Business Advisory Committee to Discuss the Accredited Investor Definition and the State of the IPO Market

Washington D.C., Feb. 16, 2024 — The Securities and Exchange Commission’s Small Business Capital Formation Advisory Committee ⊗ today released the agenda ⊗ for its meeting on Tuesday, Feb. 27, which will include a discussion of the accredited investor definition and initial public offerings (IPOs). Members of the public can watch the live meeting via webcast on www.sec.gov.

The Committee, which provides advice and recommendations to the Commission on rules, regulations, and policy matters relating to small businesses, will start the morning session by hearing from its members about marketplace trends in small business capital raising. The SEC’s Office of the Advocate for Small Business Capital Formation will also provide an overview of its 2023 Annual Report, which includes in-depth data on the state of capital raising activity from startup to small cap along with the Office’s policy recommendations. The Committee will spend the rest of the morning considering potential recommendations regarding changes to the accredited investor definition, building upon ideas generated during a previous Committee meeting.

In the afternoon session, following remarks from the Acting Director of the SEC’s Office of Minority and Women Inclusion, the Committee will explore the state of the IPO market. Recognizing that IPO activity has fallen significantly in recent years and that there is a declining number of smaller public companies, invited speakers will share relevant IPO data and their views on contributory factors and trends in the marketplace. As part of the discussion, the Committee will consider how decreased IPO activity and market shifts are impacting smaller companies and related capital-raising challenges.

The full agenda ⊗, meeting materials, and information on how to watch the meeting are available on the Committee webpage ⊗.

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SEC-PR-2024-21

Categories SEC-2402
SEC NEWS - SEC-PR-2024-21SEC-PR-2024-21 (FEB. 16, 2024)
PRESS RELEASE | 2024-21

Securities and Exchange Commission Publishes Annual Staff Report on Nationally Recognized Statistical Rating Organizations.

Washington D.C., Feb. 16, 2024 — The Securities and Exchange Commission’s Office of Credit Ratings published its annual Staff Report ⊗ to Congress today on Nationally Recognized Statistical Rating Organizations (NRSROs), commonly known as credit rating agencies, to provide findings on its examinations of the agencies, and to discuss the state of competition, transparency, and conflicts of interest among them.

“The oversight of Nationally Recognized Statistical Rating Organizations is critical to the Commission’s focus on investor protection,” said SEC Chair Gary Gensler. “The Office of Credit Ratings’ work and oversight benefits our efforts to protect investors as well as ensure the integrity of the rating process.”

“To protect investors, our examinations focus on specific activities of the credit rating agencies to assess whether or not they are compliant with applicable rules and regulations,” said Lori Price, Director of the Office of Credit Ratings. “The staff’s work is summarized in a comprehensive annual report that discusses the findings of our examinations as well as market information about credit rating agencies and the credit rating industry.”

The staff’s NRSRO examinations during 2023 considered a number of factors, including:

  • NRSRO surveillance of highly leveraged companies that had experienced increased debt service payments due to a sustained rise in interest rates;
  • NRSRO ratings on single-family rental income securitizations; and
  • NRSRO uses of analytical tools, the process by which an NRSRO distinguishes between analytical tools and models, and NRSRO approval processes for analytical tools and models.

The SEC’s Office of Credit Ratings examines credit rating agencies to promote compliance with applicable federal securities laws and rules by identifying potential instances of non-compliance by credit rating agencies. Information obtained during an examination can also inform SEC staff of noteworthy industry developments. It provides its findings to Congress and the public in its annual staff report.

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SEC-PR-2024-19

Categories SEC-2402

SEC NEWS - SEC-PR-2024-19SEC-PR-2024-19 (FEB. 14, 2024)

PRESS RELEASE | 2024-19

Securities and Exchange Commission Proposes Rule to Update Definition of Qualifying Venture Capital Funds. The proposal would inflation adjust the dollar threshold to be considered a qualifying venture capital fund.

Washington D.C., Feb. 14, 2024 — The Securities and Exchange Commission today proposed a rule that would update the dollar threshold for a fund to qualify as a “qualifying venture capital fund” for purposes of the Investment Company Act of 1940 (Act). The rule would update the dollar threshold to $12 million aggregate capital contributions and uncalled committed capital, up from the current standard of $10 million.

Qualifying venture capital funds are excluded from the Act’s definition of an “investment company.” The Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 requires the Commission to index the dollar figure for this threshold to inflation once every five years.

The proposed rule is designed to implement this statutory directive and would adjust the dollar amount to $12 million, based on the Personal Consumption Expenditures Chain-Type Price Index (PCE Index). The proposed rule also would establish a process for future inflation adjustments every five years.

The proposal will be published on SEC.gov and in the Federal Register. The comment period will remain open for 30 days after publication in the Federal Register.

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SEC-PR-2024-18

Categories Electronic Communications Recordkeeping Failures SEC-2402

SEC NEWS - SEC-PR-2024-18SEC-PR-2024-18 (FEB. 9, 2024)

PRESS RELEASE | 2024-18

Sixteen Firms to Pay More Than $81 Million Combined to Settle Charges for Widespread Recordkeeping Failures. The Huntington Investment Company self-reported and was ordered to pay lower civil penalties than other firms

Washington D.C., Feb. 9, 2024 — The Securities and Exchange Commission today announced charges against five broker-dealers, seven dually registered broker-dealers and investment advisers, and four affiliated investment advisers for widespread and longstanding failures by the firms and their employees to maintain and preserve electronic communications.

The firms admitted the facts set forth in their respective SEC orders, acknowledged that their conduct violated recordkeeping provisions of the federal securities laws, agreed to pay combined civil penalties of more than $81 million, as outlined below, and have begun implementing improvements to their compliance policies and procedures to address these violations.

  • Northwestern Mutual Investment Services LLC (NMIS), together with Northwestern Mutual Investment Management Co. LLC (NMIM) and Mason Street Advisors LLC (Mason Street) (collectively, Northwestern Mutual), agreed to pay a $16.5 million penalty;
  • Guggenheim Securities LLC (Guggenheim Securities), together with Guggenheim Partners Investment Management LLC (GPIM) (collectively, Guggenheim), agreed to pay a $15 million penalty;
  • Oppenheimer & Co. Inc. (Oppenheimer) agreed to pay a $12 million penalty;
  • Cambridge Investment Research Inc. (CIR), together with Cambridge Investment Research Advisors Inc. (CIRA) (collectively, Cambridge), agreed to pay a $10 million penalty;
  • Key Investment Services LLC (KIS), together with KeyBanc Capital Markets Inc. (KBCM) (collectively, Key), agreed to pay a $10 million penalty;
  • Lincoln Financial Advisors Corporation, together with Lincoln Financial Securities Corporation (collectively, Lincoln), agreed to pay an $8.5 million penalty;
  • U.S. Bancorp Investments Inc. (U.S. Bancorp) agreed to pay an $8 million penalty; and
  • The Huntington Investment Company (HIC), together with Huntington Securities Inc. (HSI) and Capstone Capital Markets LLC (Capstone) (collectively, Huntington), which self-reported, agreed to pay a $1.25 million penalty.

“Today’s actions against these 16 firms result from our continuing efforts to ensure that all regulated entities comply with the recordkeeping requirements, which are essential to our ability to monitor and enforce compliance with the federal securities laws,” said Gurbir S. Grewal, Director of the SEC’s Division of Enforcement. “Once again, one of these orders is not like the others: Huntington’s penalty reflects its voluntary self-report and cooperation.”

The SEC’s investigations uncovered pervasive and longstanding uses of unapproved communication methods, known as off-channel communications, at all 16 firms. As described in the SEC’s orders, the broker-dealer firms admitted that, from at least 2019 or 2020, their employees communicated through personal text messages about the business of their employers. The investment adviser firms admitted that their employees sent and received off-channel communications related to recommendations made or proposed to be made and advice given or proposed to be given. The firms did not maintain or preserve the substantial majority of these off-channel communications, in violation of the federal securities laws. By failing to maintain and preserve required records, some of the firms likely deprived the SEC of these off-channel communications in various SEC investigations. The failures involved employees at multiple levels of authority, including supervisors and senior managers.

Guggenheim Securities, CIR, Huntington, Key, Lincoln, NMIS, Oppenheimer, and U.S. Bancorp were each charged with violating certain recordkeeping provisions of the Securities Exchange Act of 1934 and with failing to reasonably supervise with a view to preventing and detecting those violations. CIRA, GPIM, HIC, KIS, Lincoln, NMIM, and Mason Street were each charged with violating certain recordkeeping provisions of the Investment Advisers Act of 1940 and with failing to reasonably supervise with a view to preventing and detecting those violations.

In addition to the significant financial penalties, each of the firms was ordered to cease and desist from future violations of the relevant recordkeeping provisions and was censured. The firms also agreed to retain independent compliance consultants to, among other things, conduct comprehensive reviews of their policies and procedures relating to the retention of electronic communications found on personal devices and their respective frameworks for addressing non-compliance by their employees with those policies and procedures.

The SEC’s investigations into Guggenheim, Oppenheimer, and U.S. Bancorp were conducted by Karolina Klyuchnikova, Austin Thompson, and Alison R. Levine and supervised by Thomas P. Smith Jr. of the New York Regional Office. The SEC’s investigations into Northwestern Mutual, Cambridge, Key, Lincoln, and Huntington were conducted by Som P. Dalal, Ruta G. Dudenas, Regina LaMonica, Amy S. Cotter, and Anne C. McKinley and supervised by Paul A. Montoya and Kathryn A. Pyszka of the Chicago Regional Office.

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