Lying to the DFI

Over the past week, Priority One Credit Union's President, Charles R. Wiggington, Sr., has suddenly become more lackadaisical and has spent more and more time strolling through the main branch in South Pasadena, California, piddling time that should be dedicated to working and talking loudly on his cellular to what are apparently family and friends. One would think by his conduct that the credit union has made a full financial recovery and is again, operating in the black. 

Donning more relaxed posturing, the President has resumed verbalizing criticisms about some of his staff for what he describes as their failure to increase new membership and failing to exact efforts needed to increase revenue. 

Though its not unreasonable to address areas within the business were immediate improvements are required, it is immensely hypocritical and unproductive for the credit union's highest officer to spend his days traipsing lazily though the main branch criticizing staff members when he has contributed absolutely nothing to improving business and resolving the problems he introduced that are financially taxing the credit union's financial infrastructure. 

Charles R. Wiggington, Sr. continually reminds us that he's no strategist and though his obsessive tendency is to find fault in others and issue demands, its quite clear that he is incapable of living up to his own lofty and judgmental expectations. 

Aside from introducing reductions in spending that have their most profound impact upon the livelihoods of non-exempt personnel who are also the lowest paid sector of employees at the credit union, Charles R. Wiggington, Sr. has developed absolutely nothing nothing that will spur the development of new business and increase membership, in great part because he doesn't comprehend marketing and has little understanding about the wants and needs of the culturally diverse marketplaces served by Priority One Credit Union. 

President Wiggington has shown that he is not a participant in delving out solutions to the problems he created. He's just going along for the ride, hoping that someone else is going to do the work needed to resolve the widespread damage he alone created.

Apparently, his only talent is to boast and brag and fabricate stories of non-existent growth and prosperity that he hopes in earnest, people will buy into at face value. 

A MEMBER COMPLAINS

Since publication of our first post, we've often witnessed the President and members of the Board of Directors and the executive sector, react adversely to our reports. One of his first responses to our reports was to violate state law and order that Monthly Income Statements not be posted at any of the credit union's branches. He succeeded in not posting the statements for March, April and May, but two complaints filed with the DFI by the same member eventually forced the President to resume posting of the monthly financial statements. Of course, if business were thriving as asserted by the President, then there would have been no psychological need for him to hide the statements.

President Wiggington's addiction to lying was again attested to in how he chose to respond to the DFI. The initial letter received from the DFI was responded to by the President who simply denied the allegations and wrote that all of the statements had been posted on each and every month. This was a lie. 

Several weeks later, the President received a second letter from the DFI which reminded him that under state law, he must post the credit union's Monthly Income Statements both, at every branch and in a conspicuous location which allow easy access to the information. 

This time, the President deferred the letter to COO, Beatrice Walker, for response. We understand that at the time, the President was furious and even complained that the DFI "should get off my back." Ms. Walker wasn't discombobulated, but she was nervous because she knew he ordered, in defiance to state law, that the statements not be posted. Furthermore, he was dragging her into a situation he created. Nonetheless, she followed his instructions and composed a response. However, for some inexplicable reason, the credit union was unable to issue its response within the thirty (30) days allotted by the DFI. So, Ms. Walker requested an extension and was provided an additional twenty (20) days in which to submit her written response. 

So why would the credit union require a total of fifty (50) days in which to compose a response to what really was a simple inquiry by the DFI. Wouldn't providing a simple information accompanied by evidence have served to exonerate the credit union of all alleged wrong doing? 

Days before a response was sent to the DFI, President Wiggington conferred with AVP, Rodger Smock, in the South Pasadena employee lounge room and told the AVP that neither of them should be involved in writing a response to the DFI's inquiry and suggested the entire matter be deferred to the COO. So why was the President so adamant that neither he or his number one lackey be involved in formulating a response? 

It's also important to note, that the President refused to post the Monthly Income Statements for March, April and May 2009. Ms. Walker did not start working at the credit union until June 1, 2009. Subsequently, the incident was created by President Wiggington months before Ms. Walker started working at the credit union. So why did he deem it appropriate to defer the DFI's letter to her for response? Since she was not an employee of the credit union when the incident first began, why would she be expected to provide information she had no knowledge of? 

THE RESPONSE

In her letter dated August 11, 2009, Ms. Walker states that the Monthly Financial Statements for "March and perhaps April 2009" had not been posted due to "industry-wide events." 

Her  response is inaccurate and inconsistent with the facts. Statements were not posted for the months of March, April and May 2009.  The April 2009 Monthly Income Statement was never posted, dispelling her statement that "perhaps" that statement was not posted. Furthermore, why did Ms. Walker omit all references to the Monthly Income Statement for the month of May 2009 from her response? 

Unfortunately, when provided with an opportunity to be forthright, Ms. Walker chose what was politically advantageous which in this case was placating the dishonest and law-breaking President. 

And what are the specific "industry-wide events" that prompted the President to order that Monthly Income Statements not be posted? 

In her letter, Ms. Walker states that on March 20, 2009, the NCUA ordered Priority One "write down their ventures" formerly conducted with Wescorp. As many people know, Wescorp entered into a conservatorship earlier this year. According to Ms. Walker, the "ventures" were to be reported to the NCUA by April 23, 2009. So does her response reasonably explain why the President issued a directive in the month of March 2009, ordering that Monthly Income Statements no longer be posted at any branch? Of course, it doesn't.  

The President has now resumed posting of the Monthly Income Statements and in response, the DFI has closed the complaint. Unfortunately, the response was saturated in lies, concocted to present an excuse that the DFI might find reasonable. However, the complaint about the refusal of the President to post Monthly Financial Statements was not the only complaint submitted to the DFI regarding the President's purposeful violation of state law. The following is a copy of of a another complaint filed on June 27, 2009, by another member and proves that the credit union had withheld posting Monthly Income Statements for the months of March, April and May 2009. 

Sent: Sat 6/27/2009 8:37 PM

To: Consumer Account

Subject: Violation of Calif Code of Regulations, Title 10, Chapter 1, Section 30.701(c)

I am a member of Priority One Credit Union and am filing this complaint regarding refusal by Priority One to either post its monthly financials for public view and have refused to post instructions either in a conspicuous or inconspicuous, easily accessible area to members. This has been ongoing since March 2009 and is a violation of California Code of Regulations, Title 10, Chapter 1, Section 30.701(c). Thank you.

The complaint places a crimp in Ms. Walker's story. The member's complaint is dated June 27, 2009, indicating that Monthly Income Statement had not yet been posted on the date the complaint was filed. 

Ms Walker's response serves as evidence she lied. She states that March's statement had not been posted and "perhaps" the statement for April though the member's complaint, which was filed on June 27, 2009, clearly proves the April and May statements had not been posted.  

Ms. Walker's August 2009 response is also inconsistent with information provided by the President to the DFI on July 1, 2009. The information provided to the DFI by the President is shown, below:

From: Consumer Account Consumer@DFI.CA.GOV

Subject: RE: Violation of Calif Code of Regulations, Title 10, Chapter 1, Section 30.701(c)

Date: Wednesday, July 1, 2009, 12:15 AM

The CEO of the Credit Union was contacted, and he stated that the statements are posted at each branch office. He did mention that there was a problem at their Valencia office recently where the current statements had not been posted and what was posted was stale dated. He indicated that this was corrected and the manager of that location was informed that the financials were to be posted as soon as they were received. He also stated that you may request copies of past financial statements, if you like.

If you would like to file a complaint against the Credit Union, please let us know.

Thank you,

Consumer Services Office

California Department of Financial Institutions

www.dfi.ca.gov

1-800-322-0622

So in response to DFI inquiries, the President and his cronies provided the following three different excuses, all which are inconsistent with one another:

• The Monthly Income Statements were posted at all branches

• The March 2009 Monthly Income Statement was not posted and perhaps, neither was April's statement; and 

• Due to some unexplained problem, the Monthly Income Statements were not posted at the Valencia branch though these were posted at all other branches. 

What's more, members calling the credit union during the months of March, April and May were told by employees answering the phones that President Wiggington had not issued Monthly Income Statements to any of the branches further dispelling that it was only the Valencia branch that did not post the statements.  

Additionally, in his July 1, 2009, statement to the DFI, President Wiggington states that the statements for the months of March, April and May were not posted at the Valencia branch but had been posted at all other branches. This seems peculiar, because in her August 11, 2009, letter to the DFI, Ms. Walker states that the March statement was not posted at any branch and perhaps, also not posted during the month of April 2009. 

So what version of the credit union's excuses do you find most believable? 

TERMINATIONS

We recently received an email advising us that a Branch Manager of the credit union has recently denied that four (4) employees were laid-off by the credit union. It's incredible that the Branch Manager could be so misinformed or has chosen to intentionally distort the truth which would not be unusual at Priority One. 

In August, all employees were asked to voluntarily reduce the amount of days worked each month. By voluntarily agreeing to reduce the amount of hours they work, employees would help the credit union save money. The credit union's plan to reduce spending did not ask any executive to voluntarily and temporarily, agree to to a reduction in salary. 

Several employees agreed to work less hours without pay and were thanked by the President during the September 8, 2009 all-staff quarterly meeting conducted at the South Pasadena branch. 

However, the President and COO, later determined that reduced working hours will not have the necessary financial impact needed to substantially reduce spending and so on Monday, September 14, 2009, four (4) employees were laid-off. On September 15, 2009, notice of the terminations was posted by Beatrice Walker on the credit union's Intranet. According to Ms. Walker, the terminations were part of an aggressive effort to reduce spending. 

Hopefully, this information will help clarify the Branch Manager's apparent confusion. 

As we've said in a prior post, Charles R. Wiggington, Sr., may not be an adept liar but he is a liar. With regards to the complaints filed with the DFI, he had absolutely no qualms about 

fabricating lies but his excuses were inconsistent with one another and inconsistent with the story concocted by COO, Beatrice Walker. You'd think that these two have conferred with one another before providing the DFI with different versions of what supposedly happened with the Monthly Income Statements for the months of March, April and May 2009. 

There is no argument that Charles R. Wiggington,Sr. is the cause of Priority One's financial problems. He single handedly created the dynamic of loss which has left the credit union floundering in the RED.  And though he'll never admit that he is the cause of the credit union's problems, on some level he is aware of his culpability, otherwise why find it necessary to lie, to find scapegoats to blame for his blunders, and why make daily treks through the main branch, insisting to employees that business is great? Clearly, as attested to by the credit union's own Monthly Income Statements, business isn't great- it's awful. Never has Priority One sustained this amount of losses at any time since it's founding in 1926? 

Floundering in Quicksand

REFUSAL

Since April, Priority One Credit Union's President, Charles R. Wiggington, Sr. has defied state law, refusing to post the credit union's Monthly Financial Income Statements.

We of course find his refusal more than a little peculiar when one considers his chronic declarations that business has improved. So why not post the evidence that would support your statement? He's also recently complained that he's tired of our frequent reports concerning his refusals to post the income statements. All we can say is, if your tired of reading about your refusals, then post the statements. 

Here again is the California code which describes the credit union's obligation to post the statements:

California Code of Regulations, Title 10, Chapter 1, Section 30.701(c): 

The Credit Union shall post copies of its statement of financial condition and statement of income in a conspicuous place in each office of the credit union or at a place convenient to the members as designated by the board of directors, where they shall remain posted until replaced by the financial statements of the next succeeding month. In lieu of posting copies of such financial statements, a credit union may post a notice in a conspicuous place in each office of the credit union stating that copies of the financial statements are available upon request, and the credit union shall make copies of the financial statements available to members upon request."

Having grown weary of President Wiggington's frequent defiance of state law, a member of the credit union recently filed a complaint with the DFI. The DFI contacted the President by phone and were told by President Wiggington, himself, that the financials have always been posted at all branches. The President lied. Not only did he lie to the DFI, but he immediately afterwards, called the Los Angeles, Van Nuys, Burbank, and Redlands branches and informed them that they would each be provided current statements, later that same day. 

The DFI whose investigation was minimal, at best, sent the following email to the member who filed the complaint:

The CEO of the Credit Union was contacted, and he stated that the statements are posted at each branch office. He did mention that there was a problem at their Valencia office recently where the current statements had not been posted and what was posted was stale dated. He indicated that this was corrected and the manager of that location was informed that the financials were to be posted as soon as they were received. He also stated that you may request copies of past financial statements, if you like. 

If you would like to file a complaint against the Credit Union, please let us know. 

Thank you, 

Consumer Services Office 

California Department of Financial Institutions

President Wiggington may not be an expert liar, but he is a liar. The member accepted the DFI's invitation and filed a second complaint. During the week of July 6th, the President received a letter from the DFI, accompanied by a form requiring his completion and signature. On Monday, July 13, 2009, the financials for the month of June were finally posted at all branches. The President was forced to concede to state law. It's obvious that President Wiggington would never have tried to hide the financials if business were actually as good as he says it is and his refusal to post the statements attests to his character and dishonest proclivities. 

MEANINGLESS ASSURANCES

As reported previously, during this year's annual meeting, the apparently nervous and heavily perspiring President assured attendees that the credit union remains financially sound though exerting every effort to hide the credit union's Monthly Income Statements. 

During the same meeting, Board Chair, Diedra Harris-Brooks said little about the credit union's actual documented financial performance and she announced that the Treasurer's Report would be read, however, the report was never read. 

Supervisory Committee Chair, Cornelia Simmons, declared as she does year after year, that the credit union is financially sound. If Priority One's performance were sound, why hide the monthly financials in defiance to state law and why would Mrs. Harris-Brooks have announced during the annual meeting that the Treasurer's Report would be read and then fail to read it? 

Prior to the start of the meeting, copies of the 2008 Annual Report were distributed though the contents of the report were never read or discussed during the 30-minute meeting which followed. However, we've reviewed the report and it shows that the year-to-date amount of Net Income is $4 million in the RED.  So how did Cornelia Simmons determine that $4 million in the negative is an indicator that Priority One's financials are sound? 

Last March, a reader sent us the following message:

If the NCUA takes over POCU..... and if you ask me to bet, I would say the clock is ticking... your blog is well known in the industry so I gotta believe that the DFI and NCUA are watching.I was looking around the POCU web site for the Annual Meeting date because one of your readers inquired, but before I could find the date, I found something that should catch some attention and make for an entertaining post if you’re interested. 

On the front page of their site they are advertising a $100k CD at 3.3% APY and a new auto loan rate of 3.49% APY. It doesn't take a rocket scientist to know that when you only have a spread of 19 basis points you’re going to lose money. Even if they had 0% charge-offs, which of course they won’t, they would lose money because their overhead per loan costs more than 19 bp. And that’s not including marketing costs or the fact that since they are already hemorrhaging money. How exactly can the afford to do this?

A few weeks later, the same reader sent us another message:

I do not see how they can save this ship. I seriously have to believe that 

1) They will be merged by 12/31; or, 
2) they will be liquidated by 12/31/09. 

Sad, really sad

We also received the following comment from another reader in response to our last post:

What happened to the election? The balance on the 20 million that was borrowed has not gone down. Or are they are making interest payments only!!!!!!!!!! $600,000.00 in interest payments

We've not calculated the actual amount that has been spent in interest alone against the $20 million loan borrowed in mid-2008 by President Wiggington. The credit union's finanical statements reference that payments made by the credit union approximate between $30,000 and $33,000 per month. What's more, the payments are only submitted to pay interest on the loan amount. Depending on when the loan may eventually be paid off in its entirety, the amount paid in interest may in fact exceed $600,000. Is this an example of the President's effort to work "smarter"?  

The June 2009 
Monthly Income Statement

The President has finally posted the credit union's Monthly Income Statement, albeit it against his will. Here are the figures:

ASSETS
Loans $114,441,315.16

Less: Allowance for Loan Losses

$2,600,000.00

Net Loans:

$111,841,315.16

Accounts Receivable

$1,036,230.02

Cash

$2,997,023.33

Investments

$62,057,332.22

Investment in COOP

$40,000.00

Investment in FSCC

$24,000.00

NCUA Deposit

$1,284.522.90

Accrued Income

$843,700.12

Prepaid Expenses

$476,376.77

Other Assets

$0.00

Sub-total

$180,709,370.61

Fixed Assets

$9,175,751.99

Less Accumulated Depreciation

$5,838,158.02

Net Fixed Assets

$3,337,593.97

Total Assets

$184,046,964.58

LIABILITIES AND EQUITY

LIABILITIES

Accounts Payable

$120,038.94

Notes Payable

$20,000,000.00

Accrued Expenses

$364,530.64

Dividends Payable

$0.00

Suspense Accounts

$0.00

Other Liabilities

$13,888.06

Shares

$150,756,281.89

Total Liabilities

$171,254,739.53

EQUITY

Regular Reserve

$5,128,606.33

Undivided Income

$7,663,618.72

Total Equity

$12,792,225.05

Total Liabilties and Equity

$184,046.964.58

Operating Income

$535,454.75

Income from Investments

$136,895.09

Fees and Charges

$231,672.78

Miscellaneous Operating Income

$16,478,12

TOTAL OPERATING INCOME

$920,500.74

OPERATING EXPENSES

Employee Salaries/Bonus

$323,737.86

Temporary Personal

$0.00

Personal Time Off

$16,916.34

Employee Pension Plan

$6,167.06

Workers Compensation Insurance

$4024.25

Employee Medical Insurance

$28,328.25

Medicare Expense-Employer

$4169.67

Social Security Taxes-Employer

$17,828.94

FUTA Expense- Employer

$143.66

SUI Expense- Employer

$736.24

Life/Disability Insurance- Employer

$1867.14

Credit Union League Dues

$2268.67

Membership, Dues, & Subscription

$2428.67

Branch Lease

$15,460.98

Property Taxes

$2542.01

Janitor Expense

$4035.75

Utility Expense

$5151.85

Building Maintenance

$1045.00

Depreciation-Building

$14,277.24

Security Expenses

$5924.69

Telephone Expenses

$24,608.94

Postage

$9807.51

Share Draft Expenses

$2463.83

Equpment Maintenance

$28,280.91

Stationeries and Supplies

$10,282.62

Surety Bond Premium & Other Insurance

$9857.67

Depreciation- Furniture and Equipment

$32,611.76

ATM Expense

$19,564.80

Check Card Expense

$20,788.15

Technology and Computer Expense

$18,960.35

Miscellaneous Bank Charges

$1951.87

Education Expense-Staff

$79.00

Education Expense-Senior Management

$0.00

Education Expense-Supervisory Committee

$0.00

Education Expense-Board of Directors

$0.00

Training Expense

$0.00

Advertising Expenses

$1200.00

Loan Promotions

$5,298.62

Promotional Items

$0.00

Member Research

$0.00

Ambassadors

$743.96

Business Development Expense

$488.50

Collection Expense

$1251.54

Real Estate Expense

$0.00

Indirect Dealer Fee

$0.00

VISA Expense

$0.00

Credit Investigation Expenses

$5248.44

Lending Center

$3858.81

Lending Expense

$$0.00

Legal Expenses

$19,241/93

Audit Expenses

$3500.00

Consultancy Fees

$5156.62

Associated Management Company

$0.00

Shared Branching Expense

$5371.00

CUSO Expense

$0.00

Provision for Loan Losses

$66,792.01

Borrower's Insurance

$0.00

NCUSIF Stablization Expense

-$160,551.94

DFI Admin. Fee

$2842.00

Cash Short (and Over)

$535.09

Interest on Borrowed Money

$58,561.65

Annual Meeting Expense

$39,908.43

Board of Directors/Supervisors

$801.35

Annual Retreat

$0.00

ADP Charges

$3140.70

Credti Union Car Expenses

$116.87

Commissary

$608.34

Mileage and Reimbursements

$3310.85

General Expenses

$9078.62

Courier Services

$9954.11

Storage Expenses

$2827.82

Branch Expenses

$0.00

Other Losses

$3727.05

Merger Expense

$0.00

Succession/Strategic Planning

$0.00

Ballot Incident Expense

$0.00

Total Operating Expenses

$733,323.44

Income (loss) from Operations

$188,177.30

Dividends Paid

$148,956.35

Loss (Gain) on Disp of Assets

$0.00

Loss (Gain) on Disp of investment

-$886,456.66

Franchise Tax Board

$0.00

Total Dividends & Other Income

-$737,500.31

Net Income (Loss)

$925,677.61

Net Income (Loss), Year-to-Date

-$3,915,781.79

NET INCOME obtained from the credit union's Quarterly Financial Reports filed with the NCUA 

Quarter Ending June 2008

$63,517

Quarter Ending September 2008

$73,364

Quarter Ending December 2008

-$690,652

Quarter Ending March 2009

-$3,470,435

Quarter Ending June 2009

-$3,915,782

No wonder the President felt emotionally driven to hide the credit union's financials. Priority One remains in the negative, but didn';t President Wiggington; Board Chair,  Diedra Harris-Brooks; and Supervisory Chair, Cornelia Simmons, describe the credit union as financially sound? Is there anytime when a negative Net Income balance indicates financial soundness? 

TWISTED

President Wiggington has a convoluted perception of what constitutes "thinking smarter." He implements a company wage freeze and reduces budget and then hires a COO. His alleged efforts to stabilize losses are chronically undermined by excessive spending. Not only have his decisions, like choosing to spend money on a $600,000 phone system and unnecessary updated email system, diminished the credit union's financial standing but his personal undisciplined behaviors, like his sexual harassing of a former female employee, have forced the credit union to spend monies on attorneys, investigators and consultants. What's more, during his approximate 6-week suspension, during which an investigation was conducted, the Board Chair, Diedra Harris-Brooks, deemed it prudent to place him on suspension with pay though all non-exempt personnel when suspended, are done so without pay. 

What's more, a few weeks following his reinstatement, the President was paid over $7000 for unused sicktime. Shouldn't he  have been ordered to pay for all attorney and investigation costs, particularly when the evidence proved he had indeed sexually harassed the former employee?

President Wiggington, the Board Chair and some of his other executives are depleted the credit union's financial resources, making certain that they remain employed and that they are allotted wage increases and bonuses. 

CONSCIENCE IS GOD'S PRESENCE IN MAN

Emanuel Swedenborg, Arcana Coelestia, sec. 4299

Breaking the Law: The President's Favorite Pastime

DEFYING THE LAW

Tomorrow is the day that Priority One Credit Union conducts its long awaited, Annual Meeting during which the President and officers from the Board and Supervisory Committee will provide information about the credit union's performance in 2008 and describe forthcoming plans for the year of 2009.   

President Charles R. Wiggington, Sr. will as he's done since 2007, meet with Board Chair, Diedra Harris-Brooks, during which they'll review what they'll talk about and make certain to that nothing is mentioned that they don't want attendees to hear. Most importantly, is to create the impression that things are just find and under control and moving forward as planned. They know exactly what they want to discuss and the notice mailed to members just a few weeks earlier make it very clear that nothing will be discussed that is not contained in the meeting's agenda. 

A reader of this blog recently forwarded a copy of a letter received from the California Department of Financial Institutions ("DFI") in response to a complaint filed against the President Wiggington's refusal to post the credit union's Monthly Income Statements as mandated under state law. 

The President's refusal is a reaction to this blog. As we've stated in past posts, he's man ruled by emotions- unstable emotions. Last February, he said he would no longer post the credit union's Monthly Income Statement because he was going to personally bring a stop to the source of some of our information. Rarely, have we ever witnessed this level of drive in Mr. Wiggington. It would have been impressive had it not been illegal. 

Publication of the credit union's actuarials has put a serious crimp in the President's stories of a credit union that is thriving and growing though its own financial statements reveal a Priority One is a credit union in decline. 

As we approach the end of May, the President continues to defy state law and is now refusing to post April's Monthly Income Statement. Of course, his violation of state law is being enabled by the equally corrupt, Diedra Harris-Brooks. 

Here is an excerpt of the DFI's response to the complaint: 

According to the California Code of Regulations, Title 10, Chapter 1, Section 30.701(c):

"The credit union shall post copies of its statement of financial condition and statement of income in a conspicuous place in each office of the credit union or at a place convenient to the members as designated by the board of directors, where they shall remain posted until replaced by the financial statements of the next succeeding month. In lieu of posting copies of such financial statements, a credit union may post a notice in a conspicuous place in each office of the credit union stating that copies of the financial statements are available upon request, and the credit union shall make copies of the financial statements available to members upon request."

If this is not the case at Priority One, please provide your mailing address to file a complaint formally.

Thank you,

Consumer Services Office

California Department of Financial Institutions

www.dfi.ca.gov

1-800-322-0622

Our reader has now filed a another complaint regarding the President's continuing refusal to adhere to state law. This by the way, isn't the only complaint recently filed with the DFI against Priority One Credit Union. 

Priority One has a new public reputation and one that is detrimental to its relationship to the communities it services.  It seems the President and his patron, Board Chair, Diedra Harris-Brooks, have resigned themselves to ruin Priority One as a business and employer and have no concern about how the ruination of its reputation may potentially undermine the Credit Union's efforts to acquire new business. They may consider changing their tagline from "You are Our First Priority" to "Rules are Made to be Broken."