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What Jobs Drive Whistleblower Tips to the SEC?

At least one of the top three may surprise you.

The Securities and Exchange Commission asks whistleblowers to provide information about their occupation when they submit a tip to the agency. Since 2011, when they launched the Office of the Whistleblower, more than 6500 people have filled out the form in the hopes of putting a stop to fraud and earning a reward.

The Wall Street Journal submitted a Freedom of Information Act request and gained access to the list of 3,600 job titles listed by whistleblowers. They published an article about the results on Monday.

In third place, and one that we wouldn’t have guessed, were engineers. 138 have submitted tips about violations. In the article, a representative of the American Society for Engineering Education ascribed this to the code of ethics among engineers.

Practically, it may have more to do with the financial markets dependence on complex computer systems these days. Engineers are programming the systems used by financial institutions and the algorithms used by traders. If they are knowledgable about the rules, then they will know when the instructions they are given to program into the system don’t comply with the regulations.

Coming in second, submitting 290 tips, were investors. This should not come as a shock. A significant number of the enforcement actions pursued by the agency take aim at companies and individuals defrauding investors. Investors can run into an assortment of violations of the rules, from the illegal marketing of securities to misappropriated investor funds.

Occupying the top spot are the 365 tips submitted by retirees. There are two reasons this group is on the list. Ex-employees are more easily able to provide information about their former employer without worrying about the potential for retaliation. Retirees, specifically, do not have to worry about the potential impact on their career if their name becomes public.

The other reason is that retirees are frequently the target and victim of fraudulent enterprises. Like investors, if you regularly have people approach you asking for money, you are more likely to encounter a violation of the securities laws and regulations.

Also interesting are the professions that were not reported by the Wall Street Journal. These include some of the jobs that have been the most controversial for the program, including attorneys, compliance professionals and accountants. Traders were also not mentioned.

It’s possible that these individuals simply did not list their job title. Only 3,600 of the more than 6,500 people who have submitted tips did so. On the other hand, it may be that many in these professions are still hesitant to blow the whistle when they encounter misconduct.

Posted on: 01 Aug 2014
Posted by: Eric Young

E-Rate Funds Not Protected By False Claims Act, According to Fifth Circuit

If you discover fraud in the FCC’s E-rate program, don’t file in the Fifth Circuit. Earlier this month, the Fifth Circuit Court of Appeals held that E-rate funds are not “provided” by the Federal Government and reversed a lower court decision on that basis.

The appellate decision raises serious questions on the viability of qui tam lawsuits in this area going forward. Defendants accused of improperly billing the FCC’s E-rate program have paid nearly $50 million in settlements to the United States Government over the years.

In U.S. ex rel. Shupe v. Cisco Systems, Inc., No. 13-40807 (5th Cir. July 7, 2014)(per curiam), the relator alleged that the telecommunications company presented false claims for payment to the government’s E-Rate program, which is funded out of the Universal Service Fund (“USF”) and administered by the Universal Service Administrative Company (“USAC”).

USAC is an independent, not-for-profit corporation assigned to administer the USF by the FCC. The USF is funded by private corporations at the direction of Congress in the Telecommunications Act of 1996 and does not receive federal funds from the treasury.

The False Claims Act defines a “claim” in relevant part as “any request or demand … for money or property … if the United States Government … provides or has provided any portion of the money or property requested or demanded.” 31 U.S.C. § 3729(b)(2)(A)(ii)(I).

Because treasury money does not fund the USF, and the money is not collected by tax, the Fifth Circuit concluded that the government did not provide any portion of the money paid out because of the false claim. “[T]he Government ‘provides any portion’ of the money requested under §3729(c) when United States Treasury dollars flow to the defrauded entity or if the false claim is submitted to a Government entity.” Shupe, slip op. at 5.

The Court of Appeals explicitly rejected the Government’s argument that funds paid by a corporation at the direction of Congress are government funds protected by the False Claims Act. It also disagreed with the contention that substantial FCC oversight was sufficient to bring the false statements within the False Claims Act even though the money was ultimately disbursed by a private organization.

At the moment, this is a blow to whistleblower actions to protect privately funded programs created by Congress and not administered by a government body. In the case, the United States argued that the FCC would ultimately end up administering the program if the False Claims Act did not apply to it as currently structured. If other courts agree with the Fifth Circuit, the United States will need to restructure the program, and others like it, in order to protect it from fraud.

Posted on: 28 Jul 2014
Posted by: Eric Young

Safety of Nation’s Highway Guardrails on Trial

highway guardrail

Bloomberg had an interesting story last month about a whistleblower who claims that an unapproved change to highway guardrails by their manufacturer, Trinity Highway Products, has rendered them dangerous. The trial started on Monday.

At the beginning and end of a guardrail, there is a piece designed to minimize damage from the guardrail to a vehicle during a crash. Without the specially designed end treatment, it risks impaling the car and severely injuring or killing occupants.

The original design was approved by the Federal Highway Administration and functions properly, minimizing the risk that it becomes a danger in a collision. However, in 2005, a different design began appearing on the National Highway System. The lawsuit alleges that this change was not approved and poses a safety risk.

When Trinity sells the product, it has to certify to the buyer that it has essentially the same geometry and mechanical properties as the one approved by the Federal Highway Administration. The states will then submit the cost of the purchase to the federal government for reimbursement from the Highway Trust Fund.

The false certification has become the core claim in the whistleblower lawsuit brought by relator Joshua Harman on behalf of the U.S. government under the False Claims Act. The False Claims Act permits lawsuits to recover money spent by the federal government as a result of a false claim or fraud. The complaint asks for damages sufficient to replace the defective guardrail and three times the government’s actual damages. If the lawsuit is successful, Harman will be entitled to an award of between 25 and 30 percent of the recovery.

The Business Week article has Harman’s interesting back story. He copied the Trinity end treatment design, manufactured it and sold it in Virginia because he believed it was off patent. Trinity sued him for it. His investigation led him to examine a guardrail that had malfunctioned in a crash. That is when he first discovered that the approved design was not the same as the design on the road.

Photo Credit.

Posted on: 16 Jul 2014
Posted by: Eric Young

Supreme Court to Hear Appeal of KBR over False Claims Act Lawsuit

kbrtowerLast week, the Supreme Court granted certiorari in the case of Kellogg Brown & Root Services v. U.S. ex rel. Carter, adding another appeal involving a whistleblower to its schedule in the fall. The petition initiated by KBR asked the Court to review the appropriate statute of limitations and the application of the first to file bar in False Claims Act litigation.

The history of the case is a bit unusual. Benjamin Carter, the relator who worked for the defendant in Iraq, filed a qui tam complaint in 2006. The complaint was amended in 2008 to include allegations of false billing for labor costs. This complaint was dismissed by the district court because of similar allegations in a pending relator complaint filed prior to Carter’s allegations.

As those familiar with the False Claims Act are aware, the statute bars a person from bringing a “related action based on the facts underlying the pending action.” 31 U.S.C. § 3730(b)(5). This is commonly known as the “first to file” bar.

While on appeal, the complaint by the other relator was dismissed. Carter filed a new complaint in 2010. However, since his 2008 appeal was still pending, the new complaint was dismissed because of his own pending appeal. Strategically, Carter dismissed the appeal of the 2008 complaint.

By the time Carter refiled his complaint, another relator had filed against the company with similar allegations. The district court held that this pending complaint barred Carter’s latest complaint. Because a significant amount of time had passed since the events underlying this litigation, the district court also held that most of the allegations were now barred by the statute of limitations of the False Claims Act, set forth in § 3731(b).

Carter appealed successfully to the Court of Appeals. The Fourth Circuit held that the statute of limitations in the case was tolled by the Wartime Suspension of Limitations Act (WSLA). It also authorized him to refile his complaint because there were no other pending actions.

The defendant now contests those issues on appeal.

It contends that the WSLA applies solely to criminal cases brought by the government. It makes three key arguments:

1. The WSLA does not apply to civil fraud cases where the U.S. government is not a party;

2. The WSLA does not apply when the government has not formally declared war; and

3. The WSLA does not modify the ten year statute of repose in the False Claims Act. In other words, the WSLA does not indefinitely toll the statute of limitations.

The Supreme Court will also review whether a previous lawsuit, not dismissed on the merits, bars a subsequent relator from filing a qui tam lawsuit because of the “first to file” requirement of the False Claims Act. The defendant contends dismissal is appropriate because the government has already been put on notice of the fraud.

KBR is the second case involving a whistleblower to be scheduled by the Supreme Court. In May, it agreed to hear the appeal of Homeland Security in the case of TSA air marshall Robert MacLean, Department of Homeland Security v. MacLean. MacLean informed the media that the TSA had discontinued posting air marshals on certain overnight flights because of budget concerns despite an alert about a plot to hijack airlines. He was terminated when the TSA learned of his role blowing the whistle. The Federal Circuit Court of Appeals sided with MacLean in his retaliation claim under the Whistleblower Protection Act.

The Supreme Court has already weighed in on two cases involving whistleblowers this year.

A few weeks ago in June, the Supreme Court decided Lane v. Franks. Lane, in his capacity as director of a statewide program for underprivileged youth, terminated an individual on the payroll that had not been reporting to her office. Subsequently, Lane was compelled to testify in the ex-employee’s criminal trial. He alleged that he was terminated in retaliation for the testimony. In a 9-0 opinion written by Justice Sotomayor, the Court held that the First Amendment protects a public employee providing truthful sworn testimony, compelled by subpoena, outside the course of the employee’s ordinary job duties.

In March, it extended SOX protections against retaliation to whistleblowers who work at private contractors to public companies in Lawson v. FMR LLC. The decision reversed the First Circuit decision denying protection to two employees of a privately held financial institution providing services to mutual fund clients.

Posted on: 09 Jul 2014
Posted by: Eric Young

Canada to Pay Some Tax Whistleblowers; Australia Report Suggests Rewards

ConnaughtBuilding

Although the whistleblower programs in the United States gets a lot of attention, the U.S. isn’t the only country to have a program to pay informants about corporate misconduct.

Earlier this year, Canada followed the lead of the United States and started offering rewards for tax whistleblowers. The Canada Revenue Agency will pay for tips about international tax noncompliance through its Offshore Tax Informant Program. The program allows for an award of between 5 and 15 percent when more than $100,000 in federal taxes are collected.

The initial process for providing information to Canada is a bit different than here in the United States. Submitting information to Canada starts with an initial call to their hotline to discuss the information the caller can provide. If the information is of the type that they are interested in, they provide the caller with a case number to include on the cover letter of their written submission.

International Antitrust Awards: Four countries pay for information when the United States doesn’t!

In our research, we discovered that Canada isn’t even the first country outside of the United States to pay for tips. Several members of the international community have adopted rewards programs in an area where the United States does not have one: antitrust. South Korea, United Kingdom, Hungary and Pakistan all pay informants for information about cartels engaged in price fixing. Strangely, this is an area where the United States does not pay. The United States investigated the wisdom of creating a program to pay for information about cartels, but there was substantial internal skepticism. Government employees were concerned that the prosecution could not meet the high burden of proof in a criminal case if the defendant could accuse the informant of bias because of the potential reward.

Australia May Be Next to Pay: Australian Senate Committee Recommends Corporate Regulator Explore Incentives.

The Economics References Committee (“Committee”) of the Australian Senate recently released a report on the Performance of the Australian Securities and Investments Commission (ASIC), their version of the Securities and Exchange Commission (SEC). In the report, the Committee recommended exploration of incentive-based compensation for whistleblowers either by allowing qui tam lawsuits or establishing a reward program similar to the SEC.

Because of the growth of the financial sector in Australia, the Committee examined the performance of their financial regulator. Two case studies it relied upon left it with the firm impression that ASIC had limited resources and power. These limitations may have played a role in allowing misconduct to happen at Commonwealth Financial Planning Limited (CFPL) between 2006 and 2010. The Committee also concluded that ASIC was too slow to act on information provided by whistleblowers about fraud happening at CFPL. The report spends nearly 100 pages of the roughly 500 page report on ASIC’s investigation and enforcement action against CFPL.

Among the suggestions it explored to improve the office was its handling of whistleblowers. Australian law offers protection to certain private sector employees who reveal information about violations of the Corporations Act to the Australian Securities and Investments Commission. But news stories broke in 2013 about the inability of ASIC to protect whistleblowers and consumers after issues were discovered at Commonwealth Bank.

The time may be ripe for Australia to implement this. According to the research cited in the report, the public there overwhelmingly supports whistleblowers. The country is also fresh off the implementation of its Public Interest Disclosure Act (PIDA), adopted last July to protect public sector employees reporting suspected legal violations. The law went into effect earlier this year, setting procedures and protections for government employees to internally and externally disclose waste, fraud and safety issues.

Two of the concerns about the PIDA was that it didn’t cover private sector employees and didn’t provide incentives for whistleblowers to come forward. It now looks like Australia will begin the process of correcting those deficiencies.

United Kingdom Passes on Rewards For Now

Last month, the United Kingdom released its response to the Whistleblowing Framework Call For Evidence and said that it did not believe financial incentives were needed. The effect of this decision is somewhat limited. Both the Financial Conduct Authority and the Prudential Regulation Authority are still considering whether they should implement an incentive program.

Photo Credit.

Posted on: 07 Jul 2014
Posted by: Eric Young

Government Intervenes in $100 Million Best Price Lawsuit Against CA.

Last week, the government intervened in a whistleblower lawsuit brought under the False Claims Act against CA Technologies, an IT software provider headquartered in New York. CA is accused of overcharging government customers for software under the terms of its “best price” contract with the General Services Administration.

The federal government requires suppliers to give them the same price and discounts they offer to other large customers or explain the reasoning behind any price discrepancy. During contract negotiations, they must provide information about their pricing policies. If, after entering into a contract with the government, the company provides larger discounts to their commercial customers, they are required to pass on those discounts to the government as well.

Instead, CA increased their discounts to commercial customers without telling the government about the lower prices they were charging. According to the lawsuit, a private sector customer paid $3,400 for a software license that the federal government was charged $34,487.

Dani Shemesh, an ex-employee of CA Israel Ltd., tipped the government off to the larger discounts. If the government successfully recovers money as a result of the allegations, Shemesh may be entitled to between 15 and 25 percent of the recovery as a whistleblower pursuant to the False Claims Act.

A Quick History of Best Price Litigation

There has already been one settlement this year of a case involving a company that failed to give a government body their best price. Office Depot paid $475,000 to settle allegations brought under the New York False Claims Act that it overcharged state government entities in New York. The contract required the office supply store to charge New York no more than it charged the U.S. government under its GSA contract.

In 2011, Oracle settled similar allegations related to their pricing and discounting policy with the Government. The settlement, $199.5 million, was the largest by a company for failure to meet the obligations of a contract with GSA. The whistleblower, a former Oracle employee, received $40 million for initiating the qui tam lawsuit.

The largest settlements for this type of litigation have been collected for Medicaid fraud. The Medicaid Rebate Statute requires pharmaceutical manufacturers to report prices to the government to ensure that Medicaid is not being overcharged. Drug companies have paid hundreds of millions to resolve allegations of overcharging and misreported prices.

Posted on: 06 Jun 2014
Posted by: Eric Young

New York Considering Awards for Bank and Insurance Industry Whistleblowers

Whistleblowers at banks and insurance companies may have another option to receive compensation for reporting misconduct if legislation written by two New York State Senators is ultimately adopted. Last year, State Senators James Steward (R-Milford) and Joseph Griffo (R-Rome) introduced a bill, S4362, into the New York State Senate to compensate and protect individuals providing information to the New York State Department of Financial Services (DFS). It offers eligible whistleblowers between 10 and 30 percent of monetary sanctions imposed in a covered judicial, administrative or related action.

Details of the Legislation

The bill models the DFS program after the Securities and Exchange Commission program created by the Dodd-Frank Act. Unlike the procedure under New York’s False Claims Act, an individual would not need to file a qui tam lawsuit to become eligible for a reward. Instead, there would a tip submission procedure for informing DFS. Following a successful enforcement action based on the information, an award would be issued to an eligible individual upon submission of a valid claim form.

The legislation also takes steps to protect the identity of whistleblowers. It permits anonymous filing of claims for awards and does not allow the release of any information which could reasonably be expected to reveal the identity of a whistleblower “unless in the judgment of the superintendent the ends of justice and the public advantage will be served by release of such information.”

It prohibits retaliation against employees, contractors and agents. If discrimination happens, remedies for the individual include two times back pay and special damages such as litigation costs and attorneys’ fees. Perhaps more importantly, it explicitly includes hiring decisions by prospective employers in the future. If an employer refuses to hire an individual who has acted as a whistleblower under the law, they may be required to hire the employee to the position or an equivalent one.

The bill also limits attempts by companies to hamper the effectiveness and purpose of the program through employment agreements. It specifically bars waiver of whistleblower rights and remedies in pre-dispute arbitration agreements or in severance packages. It also eliminates efforts to clawback wages or consideration from the severance package. This has been an issue that has arisen from the Dodd-Frank Act because some have argued that only prospective waivers are limited, rather than existing claims.

Rewards for Violations at Financial Institutions

The bill is timely as DFS has been involved in several major enforcement actions, including BNP Paribas and Credit Suisse. The Department of Financial Services was created in 2011 when the functions and authority of the New York State Banking Department and the New York State Insurance Department were transferred to it. Given its role overseeing the conduct of banks operating in New York, the bill could lead to payouts for information in amounts rivaling the largest made by the United States government.

Significantly, it would provide individuals with information about financial institutions violating economic sanctions and anti-money laundering laws an opportunity to be compensated when New York sanctions them. The DFS has played a leading role in the investigation of BNP Paribas, the French bank that is accused of violating sanctions against Iran and may be fined up to $10 billion by U.S. authorities.

The legislation would provide another avenue for whistleblowers to report offshore tax evasion facilitated by a financial institution operating in New York. Currently, individuals who desire compensation report these cases to the Internal Revenue Service, which already has its own program for compensating informants. In the recent settlement by Credit Suisse, $715 million out of the $2.6 billion to be paid was earmarked for DFS.

Incentives for Reporting Violations of Insurance Laws

Employees in the insurance industry with operations in New York should take note, because DFS regulates conduct by insurance companies as well. The bill specifically includes enforcement actions that result from a company acting in violation of an insurance law. What types of insurance cases might the New York regulator be interested in if the law is passed?

DFS has pursued multiple enforcement actions recently where an insurance company was charging rates out of line with actual loss ratios. In 2013, New York settled with multiple force-placed insurance companies, including Assurant, QBE, Balboa and American Modern, for violating the state’s insurance law. Among the accusations was that actual loss ratios were far below the expected loss ratios filed with New York.

Force-placed insurance is not the only area where loss ratios come into play. DFS also fined Markel Insurance Co. nearly $1 million for overcharging students for health insurance. The student health plans failed to pay out at least 65 percent of the insurance premiums on medical care.

DFS also would be interested in information about an insurance company operating in the state without the appropriate license. It received a large settlement in 2014 from an enforcement action against MetLife for two subsidiaries that inappropriately sold insurance in the state. American Life Insurance Co. (ALICO) and Delaware American Life Insurance (DelAm) violated the law while they were subsidiaries of AIG, prior to their acquisition by MetLife. MetLife agreed to pay $60 million to settle the charges.

Chances of Passage

There hasn’t been much coverage of this bill since it was introduced. Still, the leadership role taken by the Department of Financial Services in prominent enforcement actions could create momentum for the bill to aid in the discovery of other companies breaking the law. Enforcement.

Posted on: 05 Jun 2014
Posted by: Eric Young

SEC Rejects Late Filing of Whistleblower Claim.

If you have submitted a tip to the Securities and Exchange Commission, either as an individual or an attorney representing a client, it is crucial that you check the Notices of Covered Actions monthly. The Securities and Exchange Commission has denied another whistleblower claim because the individual did not submit it within the deadline. The denial order in Securities Exchange Act Release No. 72178 (May 16, 2014) is available at http://www.sec.gov/rules/other/2014/34-72178.pdf.

After a successful enforcement action that results in monetary sanctions exceeding $1 million, the SEC posts a Notice of Covered Action. The whistleblower has 90 calendar days from publication of the Notice of Covered Action to file Form WB-APP. 17 C.F.R. § 240.21F-10(b).

In requiring whistleblowers to stick to the deadline, they cited two reasons. The deadline ensures “fairness to all potential claimants by giving all an equal opportunity to have their competing claims evaluated at the same time, and to bring finality to the claims process so that we can make timely awards to meritorious whistleblowers.”

Rule 21F-8(a) allows the Commission to waive the deadline “upon a showing of extraordinary circumstances.” 17 C.F.R. § 240.21F-8(a). However, it declined to do so in this case. According to the explanation, the Commission will only allow a late filing when the reason for the late filing was beyond the claimant’s control and the applicant filed as soon as reasonably practicable. Attorney misconduct or serious illness were identified as two potential justifications for granting relief from the deadline.

The Commission showed little sympathy for the claimant’s excuses for late filing, which included a lack of awareness of the existence of the whistleblower program. The number of days the claim form was late and other information that might identify the whistleblower were redacted.

For late filing whistleblowers, the Commission did leave open the possibility in footnote 5 that they might use their general exemptive authority under Section 36(a) of the Exchange Act to set aside the deadline in a future case notwithstanding the lack of a showing of extraordinary circumstances. Section 36 allows the Commission to exempt persons from any rule. It must be in the public interest and consistent with the protection of investors. However, in footnote 2, the Commission indicated that an award was unlikely for this claim even if they set aside the deadline.

Posted on: 21 May 2014
Posted by: Eric Young

First Whistleblower Award Issued by CFTC

chicagoboardoftrade

The Commodity Futures Trading Commission announced today that they are making a payment of approximately $240,000 to a whistleblower for information under the authority granted to it by the Dodd-Frank Act. It is the first award by the CFTC Whistleblower Program.

Additional details about the case and the individual paid were not released. They are committed to protecting the identity of people submitting tips and treat information as non-public and confidential, so we don’t expect to hear more about the specific case from them. Sometimes, based on the timing of announcements, it is possible to speculate about the underlying enforcement action. The CFTC probably collected between $800,000 and $2.4 million because of the tip.

The CFTC program receives tips about violations of its regulations and the Commodity Exchange Act. It had rejected approximately 25 applications for awards through the end of 2013. Their press release about the payment can be found here.

The CFTC receives fewer tips than the other programs. It received 138 submissions of Form TCR in Fiscal Year 2013 compared to the approximately 3,000 tips received by the Securities and Exchange Commission.

The SEC paid its first award to a whistleblower in August 2012. The initial payment was for $50,000. In April, they announced payment of an additional $150,000 to the individual after collecting additional funds from one of the defendants in the case. The follow up award represented 30 percent of the $500,000 collected, the maximum the agency is allowed to pay.

The first mandatory award under 26 U.S.C. § 7623(b) by the Internal Revenue Service program went to a Young Law Group client in 2012. The client was awarded $4.5 million by the IRS.

Photo Credit.

Posted on: 20 May 2014
Posted by: Eric Young

Whistleblower accuses DuPont of Failing to Report Environmental and Health Issues

A whistleblower lawsuit filed under the False Claims Act accuses DuPont of failing to report a chemical leak of cancer-causing gas from a plant in Louisiana, according to The Times-Picayune.

The Toxic Substances Control Act requires manufacturers, processors and distributors of chemical substances to report when a substance poses a substantial risk of injury to health or the environment. Failure to submit a report constitutes a violation of the law with a civil penalty of up to $25,000 for each day in violation.

The False Claims Act imposes civil liability for knowingly and improperly avoiding an obligation to pay money to the U.S. Government. This is known as a reverse false claims act case because it involves the avoidance of an obligation to pay rather than a wrongful payment by the federal government.

The leak of sulfur trioxide was reportedly ongoing for months. The chemical is used in the manufacturing process at the chemical plant, which is located near a residential neighborhood and school.

The lawsuit was filed by Jeffrey Simoneaux, a 22 year employee of DuPont working in the Burnside sulfuric acid plant. Simoneaux reported the leak to his superiors and says he lost out on a potential job opportunity at the company as a result.

Even though it isn’t the largest segment of cases under the False Claims Act, environmental fraud is not unusual. Past environmental lawsuits under the Federal False Claims Act have also involved false claims for payment by the U.S. Government for environmental cleanup and disposal of toxic waste.

States have also pursued false claims against companies recently for payments made in cleanup efforts. In February, Massachusetts settled a claim under the state version of the False Claims Act for false claims made by Shell Oil in the cleanup of contaminated gas stations. Shell sought and received payments from the Underground Storage Tank Petroleum Product Cleanup Fund even though insurance reimbursed Shell for the cost of the cleanup. They paid a total of $4 million to the state and cleanup fund in order to settle the case.

Young Law Group represents whistleblowers reporting fraud through the False Claims Act. If you would like a free, confidential consultation with an attorney at the Young Law Group regarding reporting fraud, please call 1-800-590-4116 or complete our contact form.

Posted on: 03 Apr 2014
Posted by: Eric Young
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