July/August 2010

In this issue:

• A message from Manging Partner of Assurance Services, Dan Gorecki 
• FASB expands fair value disclosures
• FASB reworks subsequent events guidance
• The milestone method: FASB issues revenue-recognition guidance for research or development vendors
• Additional 2010 FASB Accounting Standards Updates
• Missing Form 5500? DOL requires corrective action

A message from Managing Partner of Assurance Services, Dan Gorecki
Welcome to our inaugural issue of Baker Tilly’s Accounting Insights. We plan to offer you a bi-monthly publication with a mix of technical information and best practice insight, which we hope you find current, useful and easy to comprehend.

As you read the first few issues, we invite you to let us know your thoughts on the content and to suggest what you would like to see in future issues. There will be a reader survey in our November/December 2010 issue. Once you click through to the full articles please bookmark the Accounting Insights page as a “favorite" in your web browser so you can refer back to all archived Accounting Insight articles and other Baker Tilly insights.

This issue of Accounting Insights focuses on the 19 Financial Accounting Standards Board (FASB ) Accounting Standards Updates (ASUs) released in 2010 thus far, with special interest paid to ASUs that have universal interest and should be reviewed by all: ASU 2010-06—Fair Value Measurements and Disclosures, ASU 2010-09—Subsequent Events, and ASU 2010-17—Revenue Recognition—Milestone Method. We also list all 16 additional 2010 Updates that are industry-specific in nature with links to more information. For employee benefit plan administrators we also have information from the Department of Labor to share with you.

If you have any comments, questions, or concerns about the newsletter, or any Baker Tilly accounting and assurance communication you receive, I'd like to hear from you. Please feel free to e-mail me at daniel.gorecki@bakertilly.com.

 

	FASB expands fair value disclosures Download a printable version.

On Jan. 21, 2010, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) 2010-06, Improving Disclosures about Fair Value Measurements. The ASU develops new disclosure requirements — and clarifications of existing requirements — under Accounting Standards Codification (ASC) Subtopic 820-10 (originally issued as FAS 157).

The new rules require companies to provide greater detail about the methods and inputs they use to measure the fair values of assets, bringing U.S. Generally Accepted Accounting Principles (GAAP) in line with International Financial Reporting Standards (IFRS) 7, which already requires similar disclosures.

The quest for transparency
The goal of ASC 820-10 is to bring greater transparency to financial statements and to provide investors and other financial statement users with better tools for evaluating the quality of reported earnings and predicting future performance. The standard does not specify which assets and liabilities must be reported at fair value — that is found elsewhere in the accounting literature. Rather, it establishes a uniform definition of fair value and a framework for measuring it under GAAP. It also requires certain financial statement disclosures regarding fair value.

One of the most significant changes ASC 820-10 made was to measure fair value on the basis of an asset’s or liability’s exit price rather than historical cost or some other entry price. Thus, the standard defines fair value as “the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date." An “orderly" transaction is one that is not a forced liquidation or distressed sale.

The standard establishes a three-tier valuation hierarchy. Highest priority is given to Level 1 inputs, which are quoted prices in active markets for identical assets or liabilities. Lower priority is given to Level 2 inputs, such as prices in active markets for similar assets or liabilities. Lowest priority is given to “unobservable" inputs, such as the reporting entity’s cash-flow models or other internal data, known as Level 3 inputs.

FASB guidance recognizes that inactive markets may reflect transactions that aren “orderly" — that is, they involve forced liquidations or distressed sales. Under those circumstances, a company “may determine that observable inputs … require significant adjustment based on unobservable data and thus would be considered a Level 3 fair value measurement." Determining fair value under these circumstances “may require the use of significant judgment about whether individual transactions are forced liquidations or distressed sales."

The need for full disclosure
ASU 2010-06 reports on new disclosure rules FASB developed in response to demands from investors and other interested parties for more “granular" information regarding fair value. The requirements relate to the following two activities:
 

1. Transfers in and out. The new rules require companies to disclose separately the amounts of significant transfers into and out of Levels 1, 2 and 3, as well as the reasons for such transfers. Previously, these disclosures were limited to transfers into and out of only Level 3.
   
   Suppose, for example, that an asset is moved from Level 2 to Level 1 because the market for that asset becomes active again and more accurate price quotes become available. Disclosing this change can help financial statement users assess the company’s financial position more accurately.
    
2. Level 3 activity. Starting next year, in connection with the reconciliation of beginning and ending balances of recurring Level 3 measurements, companies will be required to provide separate information about purchases, sales, issuances and settlements of financial instruments. In other words, this information must be presented on a gross basis rather than lumped together into one net number as currently permitted.
   
   FASB believes that a net number — which indicates the overall impact on fair value of purchases, sales, issuances and settlements — is less useful than a disclosure that provides greater detail on the underlying transactions responsible for changes in Level 3 measurements. However, the FASB recognized that some companies — particularly those with significant trading activities — may need to enhance their information systems to comply with this requirement, and delayed the effective date of this provision to give companies time to make the necessary adjustments.

The new rules also clarify two existing disclosure requirements:

1. Level of disaggregation. ASC 820-10 requires companies to break down fair value measurements according to major categories of assets and liabilities. The new rules clarify that companies should, when appropriate, drill down beneath the balance sheet line items and provide disclosures for “each class of assets and liabilities." The level of disaggregation depends on management’s judgment regarding the nature and risks of the company’s investments.
   
   For example, rather than merely disclosing the total value of available-for-sale debt securities, it might be appropriate to provide details about subsets of that category, such as residential mortgage-backed securities, commercial mortgage-backed securities or collateralized debt obligations.
    
2. Valuation techniques. Previously, ASC 820-10 required companies to disclose “the valuation technique(s) used to measure fair value and a discussion of changes in valuation techniques, if any, during the period." FASB has now clarified that these disclosures, for both recurring and nonrecurring measurements, should include valuation techniques (such as the market approach, income approach, cost approach or a combination of approaches) and should also describe the inputs used to determine the fair values of each class of assets or liabilities. These disclosures are required for both Level 2 and Level 3 measurements.
   
   FASB also clarifies that, if there has been a change in valuation techniques (such as changing from the market approach to the income approach or adding a valuation technique), the company should disclose the change and the reason for making it.
   
   FASB provides several examples of disclosures about the inputs used to measure fair value. Suppose, for example, that an entity has investments in available-for-sale Level 3 residential mortgage-backed securities. In addition to describing the nature of the securities and the underlying loans, the company might also disclose the following significant inputs: yield, probability of default, loss severity and prepayment rates.

Sensitivity analysis left out
FASB’s original proposal would have required companies to conduct a sensitivity analysis and to disclose the potential impact on fair value of “reasonably possible alternative Level 3 inputs." This type of sensitivity analysis is required under IFRS 7.

In light of comments expressing concern about the cost and complexity of these disclosures, the FASB dropped the requirement from the final rule and will revisit the issue as part of its convergence project with the International Accounting Standards Board (IASB). As FASB and IASB move toward uniform international accounting standards, they will discuss whether the value of sensitivity analysis to investors and other financial statement users justifies the additional cost to reporting entities.

Effective dates, additional amendments
The new disclosure requirements apply to interim and annual reporting periods beginning after Dec. 15, 2009, with one exception: The new rules regarding purchases, sales, issuances and settlements associated with Level 3 measurements will be effective for fiscal years beginning after Dec. 15, 2010, and for interim periods within those fiscal years.

The ASU also reports on some amendments to ASC 715-20, which covers employer disclosures related to postretirement benefit plan assets. The amendments change some terminology and include a cross reference to ASC 820-10 guidance related to such assets.

If your entity is affected by the new rules, please contact your engagement team to ensure that you understand what is or will be required. We can also help you develop systems, policies and procedures for gathering, analyzing and presenting the information needed to fulfill your disclosure obligations.

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FASB reworks subsequent events guidance Download a printable version.

On Feb. 24, 2010, the Financial Accounting Standards Board (FASB) finalized Accounting Standards Update (ASU) 2010-09, Subsequent Events — Amendments to Certain Recognition and Disclosure Requirements. The ASU clarifies the requirements that apply to SEC filers, conduit debt obligors, and other entities in relation to evaluating events or transactions that occur after the balance-sheet date but before financial statements are issued or available-to-be issued.

Among other things, the ASU removes the requirement that SEC filers disclose in their financial statements the date through which they have evaluated subsequent events.

2 types of subsequent events
In May 2009, FASB issued Statement of Financial Accounting Standards (FAS) No. 165, Subsequent Events, later codified as Accounting Standards Codification (ASC) Topic 855. The statement incorporated auditing standards regarding subsequent events into the accounting literature, making management responsible for monitoring and disclosing them.

ASC 855 defines two types of subsequent events:

1. Recognized subsequent events, which provide additional evidence about conditions that existed at the balance sheet date, and
2. Nonrecognized subsequent events, which provide evidence about conditions that arose after the balance sheet date but before the financial statements were issued or were available-to-be issued.

Recognized subsequent events must be recognized in financial statements. Nonrecognized subsequent events are not recognized, but may need to be disclosed to prevent financial statements from being misleading.

ASC 855 provides several examples to demonstrate the difference between the two. Suppose, for example, that events giving rise to litigation took place before the balance sheet date, and the entity recorded a liability in its financial statements. Settlement of the litigation after the balance sheet date but before the financial statements are issued or available-to-be issued is a recognized subsequent event, and the entity should adjust the estimated liability to reflect the settlement amount.

If, instead, both the events giving rise to litigation and the settlement occur after the balance sheet date but before the financial statements are issued or available-to-be issued, then a nonrecognized subsequent event has occurred, which need not be recognized in the financial statements but may have to be disclosed in a footnote.

Issuance dates
As originally drafted, ASC 855 required public entities, as well as nonpublic entities with a current expectation of widely distributing their financial statements, to evaluate subsequent events through the date the financial statements were issued.

Under ASC 855, issued means “widely distributed to shareholders and other financial statement users for general use and reliance in a form and format that complies with Generally Accepted Accounting Principles (GAAP)."  In the SEC’s view, financial statements are issued when they are widely distributed or when they are filed with the SEC, whichever is earlier.

ASC 855 required nonpublic entities that did not widely distribute their financial statements to evaluate subsequent events through the date the financial statements were available-to-be issued. That means the date the financial statements were complete, in a form that complied with GAAP, and all approvals needed for issuance had been obtained.

The original guidance required all entities to disclose in their financial statements the date through which subsequent events had been evaluated and whether that date was the issued date or the available-to-be-issued date.

It also required entities that reissued their financial statements to evaluate and disclose subsequent events occurring between the date the original financial statements were issued (or available-to-be issued) and the date they were reissued. The reissued statements also had to disclose the date through which subsequent events had been evaluated.

Disclosure requirements relaxed for SEC filers
After FASB issued its subsequent events guidance, some observers raised practical concerns about disclosure of the issuance date or revised issuance date by SEC filers. For nonfilers, this disclosure is important because it informs investors and other financial statement users of the cutoff date after which subsequent events were no longer evaluated.

For SEC filers, however, it is not a concern because the SEC has specific requirements regarding the identification and disclosure of subsequent events. For example, rules prohibiting registrants from filing false and misleading statements effectively require them to evaluate subsequent events up until the date financial statements are filed.

Requiring SEC filers to disclose the date through which subsequent events have been evaluated could potentially create a conflict between the accounting guidance and SEC rules. Suppose, for example, that a public company widely distributes its financial statements on date X and later files them with the SEC on date Y. ASC 855 would require the company to disclose date X as the date through which subsequent events have been evaluated, even though SEC rules require it to evaluate subsequent events through date Y.

To avoid this conflict, ASU 2010-09 provides that SEC filers need not disclose the date through which subsequent events have been evaluated. This change affects only the disclosure requirement — it does not alter the requirement that SEC filers evaluate subsequent events through the date the financial statements are issued.

ASU 2010-09 also clarifies that conduit bond obligors for publicly traded conduit debt securities are public entities and, therefore, should evaluate subsequent events through the date their financial statements are issued. However, as non-SEC filers, they must disclose that date. Conduit debt securities are debt instruments, such as industrial revenue or development bonds, issued by a state or local government to provide financing for a third party.

“Wide distribution” concept eliminated.
Mny commentators were concerned about ASC 855’s requirement that entities with a current expectation of widely distributing their financial statements evaluate subsequent events through the “issuance date." For one thing, there are no established criteria for determining whether an entity has such an expectation. In addition, entities often distribute their financial statements to different users at different times, and they might have to reevaluate subsequent events each time.

FASB decided to eliminate the concept of “wide distribution." ASU 2010-09 provides that entities other than SEC filers and conduit bond obligors should evaluate subsequent events through the date their financial statements are available-to-be issued.

Reissuance requirements revised
ASU 2010-09 revised ASC 855’s reissuance disclosure requirements to include only financial statements that are revised either to correct an error or to apply GAAP retrospectively. One reason for this change was to allow SEC filers to incorporate previously issued financial statements by reference without triggering updated disclosures.

Review your accounting policies
ASU 2010-09 may have a significant impact on the way your organization monitors and discloses subsequent events. The amendments have already taken effect, with the exception of those related to conduit debt obligors, which applied to periods ending after June 15, 2010. So be sure to discuss the changes with your engagement team and be prepared to adjust your accounting policies accordingly.

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The milestone method: FASB issues revenue-recognition guidance for research or development vendors Download a printable version.

The Financial Accounting Standards Board (FASB) recently released Accounting Standards Update (ASU) 2010-17, Revenue Recognition — Milestone Method (Topic 605): Milestone Method of Revenue Recognition (a consensus of the FASB Emerging Issues Task Force). The ASU amends the FASB Accounting Standards Codification (ASC) that provide guidance on when vendors may apply the milestone method of revenue recognition in arrangements involving research or development deliverables, as well as the associated disclosure requirements.

The issue
Revenue recognition is an issue for vendors that provide research or development deliverables to their customers, because these arrangements often involve multiple payment streams that are contingent on achieving uncertain future events or circumstances — that is, milestones. Milestone consideration might be contingent, for example, on the achievement of clinical trial results or regulatory approval for the product under development.

Under the commonly applied milestone method, a vendor recognizes revenue in the period during which the milestone is achieved. Each milestone is essentially treated as a separate contract for accounting purposes.

As FASB acknowledged, no authoritative guidance on the use of the milestone method was previously available. The amendments included in ASU 2010-17 are intended to remedy that situation. They apply to vendors that provide research or development deliverables in an arrangement in which payment provisions provide that a portion or all of the consideration is contingent on achieving uncertain future events, such as the successful completion of phases in a drug study.

What is a “milestone"?
The amendments covered by ASU 2010-17 add a specific definition of “milestone” to the ASC master glossary. According to that definition, a milestone event must carry a substantive uncertainty when the arrangement is entered as to whether the event will be achieved. A substantive uncertainty can exist even if a vendor expects to achieve the milestone.

Further, a milestone event must be contingent solely on the vendor’s performance. It can only be achieved based in whole or in part on either 1) the vendor’s performance or 2) a specific outcome resulting from the vendor’s performance. If an event is contingent solely on the passing of time or the result of a counterparty’s performance, it is not a milestone. Finally, a milestone event must result in additional consideration due to the vendor if achieved.

Is the milestone “substantive"?
The amendments reported in ASU 2010-17 allow a vendor to recognize revenue under the milestone method in its entirety in the period that a milestone is achieved only if the milestone is considered “substantive." The amendments explain that the determination of whether a milestone is indeed substantive is a “matter of judgment” that must be made at the inception of the arrangement.

The following criteria must be satisfied for a milestone to be deemed substantive:

• The milestone consideration must be proportionate with 1) the vendor’s performance to achieve the milestone or 2) the delivered item’s enhanced value resulting from the specific outcome of the vendor’s performance to achieve the milestone.
• The milestone consideration must be related solely to the vendor’s past performance.
• The milestone consideration must be reasonable relative to all deliverables and payment terms in the arrangement.

A milestone is not substantive if any portion of the associated consideration relates to the remaining deliverables. It also must be substantive in its entirety — milestone consideration cannot be bifurcated into substantive and nonsubstantive components. And, if part of the milestone consideration is refundable or subject to adjustment based on future performance (such as through a penalty or clawback provision), the consideration does not relate solely to past performance, and the milestone is not substantive.

If a milestone is substantive, other revenue recognition methods that result in the recognition of milestone consideration in its entirety in the period the milestone is achieved are not allowed. But a vendor may elect to apply a different accounting policy that results in the deferral of revenue relating to some portion of the milestone consideration.

The milestone method in action
For example, a vendor agrees to perform research on a new medication for a customer — a pharmaceutical company. According to the arrangement, the vendor will earn $500 per hour, plus $10 million in milestone consideration on the successful completion of clinical trials. The parties expect the clinical trials to be completed about halfway through the vendor’s projected total of 55,000 hours of work.
During the accounting period that the arrangement began, the vendor performs 30,000 hours of work, and the trials are successfully completed. The vendor continues to expect that 55,000 hours total will be required to finish the project.

The vendor has earned $25 million during the accounting period: $15 million for 30,000 hours of work plus $10 million for achieving the clinical trials milestone. The vendor expects to earn an additional $12.5 million in hourly fees in future accounting periods. As long as the clinical trials milestone was substantive, the vendor can recognize the $10 million of milestone consideration in the period the trials were completed.

Required disclosure
The amendments included in ASU 2010-17 also add the requirement that a vendor must disclose its accounting policy for the recognition of milestone consideration. For each arrangement that includes milestone consideration accounted for in accordance with the amendments, a vendor must disclose in its financial statement notes:
 

• A description of the overall arrangement,
• An account of each milestone and related contingent consideration,
• A determination of whether each milestone is considered substantive,
• The factors that the vendor considered in determining whether each milestone is substantive, and
• The amount of consideration recognized during the period for the milestone or milestones.

Vendors that adopt the milestone method must include certain related disclosures in the year of adoption. Those disclosures should allow users of the financial statements to understand the effect of the change in accounting principles.

Effective date and additional disclosures
The amendments covered by ASU 2010-17 are effective on a prospective basis for milestones achieved in fiscal years — and interim periods within those years — beginning on or after June 15, 2010. Early adoption is allowed, and vendors can elect to adopt the amendments retrospectively for all prior periods.

A vendor that elects early adoption must disclose, at a minimum, the following information for all previously reported interim periods in the year of adoption: revenue, income before income taxes, net income, earnings per share and the effect of the change for the captions presented.

Other options
The amendments reported in ASU 2010-17 make clear that the milestone method isn’t the only acceptable revenue recognition model available for research or development deliverables or consideration contingent on the achievement of a substantive milestone. But research or development vendors must apply their policy for recognizing such consideration consistently to other similar deliverables or milestone-contingent consideration. If you have questions, or need assistance, contact Baker Tilly.

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As of July 1, 2010 the Financial Accounting Standards Board (FASB) has issued 19 Accounting Standards Updates (ASUs). Below are industry-specific ASUs not covered in detail in the July/August 2010 issue of Accounting Insights. These updates are available at www.fasb.org. Please click on the Update to view the full ASU.

• Update No. 2010-01—Equity (Topic 505): Accounting for Distributions to Shareholders with Components of Stock and Cash—a consensus of the FASB Emerging Issues Task Force
• Update No. 2010-02—Consolidation (Topic 810): Accounting and Reporting for Decreases in Ownership of a Subsidiary—a Scope Clarification
• Update No. 2010-03—Extractive Activities—Oil and Gas (Topic 932): Oil and Gas Reserve Estimation and Disclosures
• Update No. 2010-04—Accounting for Various Topics—Technical Corrections to SEC Paragraphs (SEC Update)
• Update No. 2010-05—Compensation—Stock Compensation (Topic 718): Escrowed Share Arrangements and the Presumption of Compensation (SEC Update)
• Update No. 2010-07—Not-for-Profit Entities (Topic 958): Not-for-Profit Entities: Mergers and Acquisitions
• Update No. 2010-08—Technical Corrections to Various Topics
• Update No. 2010-10—Consolidation (Topic 810): Amendments for Certain Investment Funds
• Update No. 2010-11—Derivatives and Hedging (Topic 815): Scope Exception Related to Embedded Credit Derivatives
• Update No. 2010-12—Income Taxes (Topic 740): Accounting for Certain Tax Effects of the 2010 Health Care Reform Acts (SEC Update)
• Update No. 2010-13—Compensation—Stock Compensation (Topic 718): Effect of Denominating the Exercise Price of a Share-Based Payment Award in the Currency of the Market in Which the Underlying Equity Security Trades—a consensus of the FASB Emerging Issues Task Force
• Update No. 2010-14—Accounting for Extractive Activities—Oil & Gas—Amendments to Paragraph 932-10-S99-1 (SEC Update)
• Update No. 2010-15—Financial Services—Insurance (Topic 944): How Investments Held through Separate Accounts Affect an Insurer’s Consolidation Analysis of Those Investments—a consensus of the FASB Emerging Issues Task Force
• Update No. 2010-16—Entertainment—Casinos (Topic 924): Accruals for Casino Jackpot Liabilities—a consensus of the FASB Emerging Issues Task Force
• Update No. 2010-18—Receivables (Topic 310): Effect of a Loan Modification When the Loan Is Part of a Pool That Is Accounted for as a Single Asset—a consensus of the FASB Emerging Issues Task Force
• Update No. 2010-19—Foreign Currency (Topic 830): Foreign Currency Issues: Multiple Foreign Currency Exchange Rates (SEC Update)

Missing Form 5500? DOL requires corrective action Download a printable version.

Department of Labor’s Employee Benefits Security Administration (EBSA) pursues voluntary compliance as a means to encourage plan administrators to bring their plans into compliance with ERISA’s filing requirements. In FY 2009 the EBSA received more than 26,603 annual reports through their compliance assistance program. The Department of Labor (DOL) also periodically sends formal Notice of Rejection (NOR) letters to plan administrators that fail to attach an audit report to their Form 5500.

What should you do if you receive a Notice of Rejection (NOR) letter?
Upon receipt of a NOR letter, the plan administrator has 45 days to make any necessary corrections to the Form 5500 filing. You should contact your auditor immediately as they will most likely have to correct audit reports which may require performing additional fieldwork in audit areas where work was deemed by the DOL to be insufficient.

Ramifications of not correcting Form 5500
If after the 45 day period the Form 5500 filing remains deficient, the DOL will provide a written notice of intent to assess a penalty (NOI). The NOI will include the amount of the penalty, the number of individuals involved, the period of time to which the penalty applies, and the reasons for the penalty.

While most deficiencies are penalized at $150 per day with penalties capped at $50,000, the maximum penalty permitted is $1,100 per day. These penalties are imposed from the day after the original due date of the filing, which is seven months from the end of the plan year or month where plan assets are completely liquidated, whichever is earlier.

After receipt of the DOL notice, the plan administrator has 35 days to file a written statement of reasonable cause explaining why the penalty should be reduced or not assessed. As a rule the DOL will not consider abatement of any penalties in cases where deficiencies still exist.

If the plan administrator does not file a statement of reasonable cause within the 35 day period, it is considered an admission of the facts alleged in the notice. The notice itself becomes the final order and the plan administrator forfeits all rights to appeal.

If the plan administrator submits a statement of reasonable cause, the DOL will review and make their final order. The agency will issue a notice of determination which contains the final penalty amount assessed against the plan administrator. The plan administrator may choose to pay the penalty amount or if unsatisfied with the final decision, may request a hearing with an administrative law judge, appealing the penalty. If requesting a hearing, one must do so within 35 days of the receipt of the notice of determination.

The plan administrator is personally liable for payment of any penalty. Failure to make all efforts to file an accurate and complete Form 5500 may result in future enforcement correspondence from the DOL, Internal Revenue Service (IRS) or Pension Benefit Guaranty Corporation (PBGC).

What can you do if you have not filed prior years’ Form 5500?
Before the DOL, IRS or PBGC contacts you, file your delinquent annual reports immediately. In an effort to encourage pension and welfare plan administrators to file overdue annual reports the Department of Labor’s Employee Benefits Security Administration (EBSA) provides plan administrators with the opportunity to pay reduced civil penalties for voluntarily complying with the annual reporting requirements through the Delinquent Filer Voluntary Compliance Program (DFVCP).

Any questions regarding the DOL DFVCP or penalty process should be directed to the DOL Employee Benefit Security Administration’s Office of Chief Accountant (OCA) at (202) 693-8360. You can also find more information including a penalty calculator on the DOL Employee Benefit Security Administration Office website. In 2009 an online DFVCP filing and payment option was added to the site and has made the program even easier to use.

You may also contact Baker Tilly. We provide in-depth Employee Benefit Plan Audit knowledge and an experienced audit team that is ready to help you any time of year. Baker Tilly is an involved member of the AICPA Employee Benefit Plan Audit Quality Center and devoted to developing “best practices" for their clients.
 

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