It is time to give a shout out to one of Houston’s hometown hero’s, the Houston Rockets. Until the Houston Dynamos came along, they were the only professional sports franchise to bring a championship to Houston. They brought two actually, winning the National Basketball League (NBA) crown in 1994 and 1995. Since that time it is has been a dry hole, with the Rockets only once advancing to the Western Conference finals.

However, this year the Rockets have the best record in the NBA since December 1, with a sterling 17-2. This includes road wins over the Spurs, Thunder and Warriors. Not too bad a trifecta. They are led again by a much rejuvenated James Hardin (Fear the Beard) as point guard who is in the conversation for league Most Valuable Player (MVP). This all began with the hiring of offensive guru Mike D’Antoni as coach. While I, like many others, was skeptical, it has turned out so far as an inspired choice by General Manager (GM) Daryl Morey. Morey was one of the first NBA GM’s who focused on saber metrics and is fearless in trying out new concepts, new ideas, new players or coaches who may not seem to fit the traditional NBA profile. Morey keeps the big picture goal of bringing a title back to ‘Clutch City’ yet again.

I thought about Morey, the Rockets and a best practices compliance program when I read a recent article in the New York Times (NYT) Corner Office column by Adam Bryant, where he profiled Mike Tuchen, Chief Executive Officer (CEO) of the software vendor Talend, in a piece entitled “Watch the Road, Not the Wipers. I found the article had some very interesting implications for any Chief Compliance Officer (CCO) or compliance practitioner.

An early lesson for Tuchen was to focus on what he could control, not what he could not. He learned this lesson in college crew, he was undersized both in weight and height from his teammates. He said, “I had to figure out how I could make myself as efficient as possible, pound-for-pound. I had to make sure that every ounce I had was going to be as effective as I could be. So I asked, what could I do to make my diet as effective as possible? What could I do from a training perspective to work harder than the other guys?… That approach, focused on results with incredibly detailed measurement and course correction when needed, is so transferable to a work environment.”

As a CCO you are required to use the tools at hand. If you do not have enough head count or budget (and who does) use what you can more effectively. You may even be able to outsource more mundane compliance tasks to vendors which supply such services at a cost much reduced from your employee cost. As usual, you are only limited by your imagination.

Another key lesson Tuchen learned from crew was to stay focused and stay calm. He said that “When you’re on the water, you’ve got waves, wind and whatever else is going on. You can choose to either focus on that and use it as an excuse later on or ignore it.” His rowing coach phrased it another way, “When you’re driving and rain is pouring down, with the windshield wipers going, you can either watch the windshield wiper or you watch the road. Which is going to be more successful? That was just a fabulous reminder about staying focused and calm.”

Tuchen had an approach to leadership which resonated with me and I think every CCO should consider. He believes there are three basic components to leadership. First “is getting the right team together and having it really be a team, who have shared cultural values and who work together and support each other. It’s not just about having the right people.” For any CCO, this is critical with the disparate elements you need to have in every effective compliance program. These elements can be from Human Resources (HR) to IT to Internal Audit, to Accounting and Finance, to Internal Controls, to Legal and beyond.

The second is to “have a strategy of how you’re going to win. This is the chess match part of being a” business leader. Every CCO should have a one, three and five-year strategic plan going forward, all based upon ongoing risk assessments. As your company matures, grows and expands, your compliance program should do so as well. It also leads to the documentation being ready if or when the regulators coming knocking and a road map in annual budgetary requests.

Finally, is execution. As Baker Hughes Inc. (BHI) CCO Jay Martin says, execution is not only where the rubber meets the road in compliance but it is what distinguishes an effective compliance program from a paper program. Tuchen said it’s “about having a clear set of goals, with everyone aligned around them. And we have a scorecard that we share with the board and the whole company each quarter, and it shows red, green and yellow for our progress on each of the goals.” Execution can tie into your strategic plan but you must execute on that plan for your compliance program to be effective.

As a CCO you will probably be asked to assist in hiring employees for your compliance department or interviewing potential senior management candidates from the compliance perspective. In this regard I thought Tuchen’s thoughts on hiring were pertinent. When he interviews he noted, “The first questions are always going to be about management and leadership style. And I’ll ask a number of open-ended questions about what’s important to get right as a leader. Some people will talk about the people on the team and the best way to motivate them. The answers that kind of scare me are from candidates who talk about people as if they’re something on a spreadsheet. Leadership and management are all about people.” Clearly for Tuchen, leadership is about people and this should be so for any CCO who is interviewing as well.

Next Tuchen said he wants “to make sure that you’re resilient, because things don’t always go the way you want them to. So I’ll ask questions like, what’s the hardest problem you’ve ever solved? Why was it hard? What did you do uniquely well that someone else wouldn’t have been able to do, and why?” This is clearly appropriate for any CCO to inquire into for a new hire.

I found Tuchen’s thoughts on leadership very useful for any CCO to consider and remember to always keep your eyes on the road not the wipers.

 

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2017

Many compliance professionals in the corporate world work long and hard to rise up to the senior management level in their organizations. It takes subject matter expertise, hard work and sometime propitious good fortune to get to the C-Suite level in a large company. However, many of the skills which work to get you there do not always serve you in a senior management roll. I recently read a couple of articles which took a look at this subject and offered some remedies.

One thing many compliance practitioners, particularly those who grew up professionally, have in common is self-reliance. Not every lawyer and compliance practitioner is a Type A driven personality but many of us are. In many ways it is what makes us a success. However, in the corporate world, just like any other, there are limits to self-reliance. I was reminded of this in a New York Times (NYT) Corner Office column by Adam Bryant where he interviewed Lori Dickerson Fouché, the Chief Executive Officer (CEO) of Prudential Group Insurance.

Not simply surviving but also performing under pressure is the mark of a successful Chief Compliance Officer (CCO). In a Financial Times (FT) article, entitled “A CEO’s primer on how to manage under pressure”, Andrew Hill wrote about a CEO but I found many of his concepts applicable to any senior corporate leader, specifically including a CCO.

Driven is one of the words which spring to mind when discussing Fouché. As she noted a favorite expression she heard growing up was that “To whom much is given, much is required.” This was often paired with “Mediocrity is not a good place to be.” She went to add that around the dinner table, her parents would tell her that she needed to work harder than most other people.

Fortunately for Fouché, one of her early lessons in the corporate world was to ask for help. She said it “stemmed from the fact that I had been used to thinking, “I can get through the brick wall. I can make this happen.” I was very self-reliant, and I figured that if I could do it, so could the team. So I overworked some teams early on, and that led to an early lesson around asking for help. It’s O.K. not to have all the answers and not to be able to do everything and to put your hand up and say, “I need help.” I was so surprised by how people really wanted to help. They loved being invited into the process.”

From these experience she also learned to prioritize. She noted, “You simply can’t do everything. There were times I would walk into a new job, and my eyes would be huge and I would feel like a kid in a candy shop. I’d think, “Let’s just get after it,” instead of, “O.K., let’s pause. What’s the most important thing to really get after?” Being able to say “No” or “Not now” were important lessons for me.”

Another interesting lesson (and one far different than the corporate world I grew up in) was transparency. Fouché related “to share my thoughts so that other people could follow them. I learned an important lesson from a colleague when I was C.E.O. at another company, who said: “Lori, this is a little bit like being on the train and you’re in the front of the train and we’re in the dark. You can see the light at the end of the tunnel. But there are people who are toiling in the back, and they’re throwing coal in the engine, and they’re working the cars, and that’s all they know. You should be at the front of the train, but your job is to shorten the distance between you and the back of the train so that we can all see what you see at the front.””

These points tie most interestingly into Hill’s piece. He said the ability to handle pressure is a key component for a C-Suiter. He wrote, “One way CEOs can offset potentially overwhelming pressure is by finding small ways to exercise control. When the job’s demands threaten to swamp her, Ms Sapone tries to “deal with whatever it is point by point, and look for the controllable things”.”

In other words, prioritize and start the slogging work of going through the issues in front of you. It not only gives you some semblance of control but also helps you to focus on doing the next right thing. As a business leader, others in your team and cascading down will take their clues from you and begin to operate in the same analytical manner. This also ties into one of Fouché’s key points about her leadership style.

Not only does she strive for personal transparency, she expects it from others. She said, “I expect my leaders to listen. I expect them to ask questions. I expect them to understand what’s going on. I am somewhat infamous for saying, “So how’s it going?” And they’ll say, “Great.” Then I’ll say, “How do you know?” It’s one thing when people start telling you anecdotes and it’s another thing when they can say, “Well, because we track this and we measure that.” We make sure we’re analytical in our approaches.”

If you couple this with two characteristics Fouché looks for when hiring: resilience and perseverance; it gives you a hint on some key characteristics. This is because she believes that when “working in big companies, and you have to find a way to navigate and negotiate to an end result. It could be a winding path. So I make sure that people feel like they know how to do that, and do it in a way that is respectful of the system.”

Aesop noted many eons ago that the race is not always won by the fastest but often the strongest and the steadiest. Many of the characteristics which allow you to rise within a corporation may need to ameliorated somewhat at the C-Suite.  Fouché’s lessons and Hill’s piece give you some  good starting points.

 

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2017

to-sir-with-loveI continue my tribute to those who have recently passed away and today I leave the world of music to move to the world of literature with a name you will probably not recognize, E. R. Braithwaite. You will, however, recognize his most famous memoir “To Sir, With Love” which was made into a film in 1967 starring Sidney Poitier and who’s soundtrack included the singer Lulu’s hit single of the same name.

As noted in his New York Times (NYT) obituary, “The book chronicled his efforts — as a courtly, Cambridge-educated military veteran who had been denied employment as an engineer because he was black — to motivate a group of unruly adolescents raised in a slum in early-1950s Britain, which was still slowly recovering from the austerity of the war years. The students’ antisocial behavior, casual racism, penchant for violence and, worst of all, self-hatred horrify the new teacher, whose colleagues expect little of the pupils.”

Yet through his unorthodox teaching methods he wins the respect and trust of his students. I was surprised to learn that the title comes from words written on a pack of cigarettes given to Braithwaite as a gift by one student. Braithwaite’s portrayal of both race and the English class system of the 50s was widely praised. Braithwaite’s ability to not only see past the racial and class prejudices of the time resonated with both the book’s readers and the film’s viewers.

I found his story an excellent tie into today’s blog post. In a recent On management column in the Financial Times (FT), entitled “Technology and millennials are out to kill the org chart”, Andrew Hill discusses how the org chart may soon be relegated to a relic of the past. From his description, it might not only be a good thing but from the compliance perspective it might help companies more quickly and efficiently operationalize compliance down in the DNA of their company.

Even though the org chart is one of the most read documents in any organizations, it did not always reflect the reality of the company. Hill noted, “Even when everyone used to pay attention to the pyramid of power, though, the diagram was a poor reflection of corporate reality. Century-old examples are pockmarked with vacancies, indicating that chart makers struggled to keep up with changes. Now staff turnover is more rapid, charts are relics of a command-and-control approach, where information flowed through fixed channels, from your boss’s boss, down to your boss, to you, and back again. It need not be this way. In many such plans, the dreaded “dotted reporting line” already signals that nothing is as neat as the chart may imply.”

Hill even took it a step further, finding that many Human Resources (HR) directors find org charts to be ““uncomfortable straight-jackets, a hindrance to more natural interaction between colleagues” or simply a loathed obligation.” Although some HR professionals felt org charts helped an employee understand the context of an organization’s hierarchy, “they always “come with the caveat that aren’t true.””

Hill recognizes that businesses need structure and that employees need to be able to refer to the structure. But by ossifying structure in an org chart, it could stifle people from making decisions applicable to their area of expertise. This is a long held key that employees must be empowered because if they are, they will execute more efficiently. But more than simply such platitudes, Hill points out that business leaders have a different role than sitting at the top of long list (horizontal and vertical) of employees. In one of the most interesting analogies Hill cited to Professor Lindred Greer of the Stanford Business School for the following insight, “leaders must behave like hippos. They can remain under water, with just their eyes protruding to observe the team, and emerge only if they need to exert their full authority.”

Hill ends by stating, “the fixed org chart is already losing potency.” Moreover, “even those HR executives who favour organigrams point out that younger staff could not care less about the hidebound hierarchy they represent. They will happily take ideas to a senior partner or divisional director, bypassing old-fashioned channels, says one. It is a reminder that the chart, love it or hate it, is not the main impediment to change; the people in it often are.”

The implications for both a Chief Compliance Officer (CCO) and the compliance profession are quite profound. Clearly a CCO wants to have as much input as he or she can receive about the company and whether it is doing business ethically and in compliance. If an org chart communicates siloed behavior is the expected norm in an organization, a CCO may well not receive information needed to prevent or detect inappropriate conduct. These are two of the three negative points that Hill raises; a straight-jacket around communications and a hindrance to natural communications between colleagues. I would add such structure could even stop employees from believing they could have such communications.

This all relates back to Braithwaite and educating his students who were written off by the other teachers. He took them to museums, many for the first time in their lives. He told about his story in rising up from a colonial existence to becoming a World War II, Royal Air Force fighter pilot. In short, he used communications to win their trust. Once he had their trust he could begin his assigned task of teaching them because they were then receptive to his message.

The same is largely true of any CCO or compliance practitioner. You do have to work to win the trust of your employee base. If there is a formal org chart sitting out there commanding communications flow in one method, it could seriously impact your ability to prevent and detect. Moreover, if there are folks in the business unit who could move compliance forward to make it more efficient or even move it more closely into the field, those opportunities may be missed if the org chart is too ossified at your company.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2016

herb-hardestyHerb Hardesty died last week. Probably only those who are fans of early rock and roll will recognize the name. But all music fans will recognize his sound, as, according to his obituary in the New York Times (NYT), he was a tenor saxophonist “whose name was synonymous with New Orleans rhythm and blues and early rock ’n’ roll and whose lyrical solos were heard on nearly all of Fats Domino’s hit songs”. He “played on the sessions that created hits like “I’m Walkin’,” “My Blue Heaven,” “Ain’t It a Shame” and “Let the Four Winds Blow.””

Hardesty’s sound was “a big, meaty tone with blues and laughter in it. John Broven, the author of “Rhythm & Blues in New Orleans,” described Mr. Hardesty in a phone interview   as an ideal sideman for Mr. Domino.” He went on to say, “Part of Domino’s success was that his songs were memorable and very hummable, and Hardesty was able to translate the lyrics into a melodic, saxophone sound. One of the things Fats said that he liked about Herb was the tone of his saxophone. When you heard Fats live, with Herb in the band, you were hearing the original studio sound.”” Hardesty also played with Little Richard, Ella Fitzgerald and Frank Sinatra. He was also a member of the greatest generation, having been a Tuskegee Airman.

Adam Bryant, in his Corner Office column, profiled Deirdre Quinn, the chief executive of Lafayette 148 New York, a women’s fashion company, in a piece entitled “If a Meeting Starts at 9, Be There at 8”. Quinn had some interesting leadership lessons for the Chief Compliance Officer (CCO) or compliance practitioner. Quinn is very passionate about the fashion industry. She said that she went to college for fashion and has worked in the fashion industry for a large portion of her professional career. The compliance profession has evolved to the point where we are now seeing college graduates coming directly into the profession. I can only hope this trend will continue and we will have more entrants into our profession who come into it with a passion that Quinn expressed for her profession.

It was the event that led to her professional growth in the fashion industry that I found a key lesson to be learned for an incoming compliance practitioner. She started out in a pattern room and then was moved to become an admin to the head of production. She described her first big break, “I was sitting in a meeting taking notes one day, and they were discussing how short skirts were suddenly in style. So the guys — there were only men sitting around the table — said that someone had to go to Korea tomorrow to shorten about 200,000 skirts. Nobody said a word. So I said, “I’ll go.” The next day, I went to Korea for three months. I got the job done.”

There is nothing like taking initiative to get people to notice you or as Quinn allows, “Don’t be afraid to go the extra mile. Just embrace it every day”.  But it is more than simply taking initiatives to accept more work or responsibility. It is executing on the assigned tasks. As I related yesterday, Baker Hughes Inc. (BHI) CCO Jay Martin says that it is execution which separates successful compliance programs from mere paper programs. The same is true for individual assignments. Quinn took an opportunity, then successfully executed upon it. As she went on to note, “After then, whenever there were problems, people would say, “Send Dee.” I went everywhere — El Salvador, Haiti, Sri Lanka, India. I became vice president of operations when I was 28 and had a whole team.”

Quinn also has some other Interesting thoughts useful for both the CCO or compliance practitioner. She related that many people in the fashion industry believe they are very good at one thing. In the general corporate world, that is called being siloed. She breaks these silos through her management style, which is “to either build around what you’re not good at, or move you to another place where I think you could be better. Finding the best in people is like a chess game for me, rather than saying, “Well that didn’t work — we don’t need you anymore.” And once in a while you’ll find a utility player who is good at every job.”

There are multiple lessons in these remarks. First and foremost is the problem of siloing in corporate America. This concern even reaches into the Department of Justice (DOJ) and its evaluation of compliance programs under its FCPA Pilot Program. In its remediation prong, it notes companies will be evaluated, in part, on whether the CCO and the compliance discipline within an organization have the opportunity to move into other areas of the business. This concern is also reflected in the insight that a compliance practitioner should know how to read a balance sheet and if you do not know how to, you had better learn now.

Quinn also had some interesting thoughts about the mentee role in a mentor relationship. While she (and myself) wish you only work for bosses who you like and are easy to get along with, it does not always work out in that manner. She says, “You can learn from a good boss and a bad boss.” In my professional experience, the three lawyers I learned the most from were the most difficult people I ever worked for; as in very difficult to work under. However, these were the three lawyers who taught me the most.

Whether it was because they pushed me unceasingly or demanded what I considered an unreachable quality of work, I learned more from these two men and one woman than any other myriad of others I worked for. The key is that you can learn from anyone you work under. It is incumbent on you to take away the appropriate lessons. We cannot all play with Fats Domino but we can learn from the Fats Domino sound and one day you may well have your own sound.

 

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2016

moody-bluesOne of the favorite sobriquet’s I have recently received was from Alison Taylor who called me the ‘rock and roll compliance blogger’. I love to listen to classic rock and enjoy live performances even more. With that moniker and passion in mind I recently caught the Moody Blues’ gig celebrating the 50th anniversary tour. It is the Fly Me High Tour which honors the first single released after singer-guitarist Justin Hayward and bassist John Lodge joined the group.

Early Moody Blues music was informed by their second album, “Days of Future Passed”; which I had always thought of as the first rock concept album. However, it is seen by many rock critics as a precursor to progressive rock music. Bill Holdship, Yahoo! Music, said that the band “created an entire genre here.” Robert Christgau noted that it was “closer to high-art pomp than psychedelia.” And, finally, Allmusic editor Bruce Eder calls the album “one of the defining documents of the blossoming psychedelic era, and one of the most enduringly popular albums of its era.”

The band had its core members of Justin Hayward, who turns 70 on Friday, John Lodge, 71 and Graeme Edge, 75; all playing at the concert and I can assure you that even in their 70s, they can still rock. There were the MTV hits such as “Gemini Dream” and “The Voice” and of course the show ended with the classics “Question” and “Ride My See-Saw”. It was great night for the Moody Blues, their fans and rock and roll.

I thought about how they are still great rockers when I read a recent piece in the New York Times (NYT) Corner Office Column by Adam Bryant, entitled “The Incalculable Value of a Good Boss, where he profiled Aron Ain, the Chief Executive Officer (CEO) of Kronos, a maker of workforce management software. It turns out that Ain was deeply informed by his parents when he said, “My parents cared deeply about people, particularly people who needed a little bit of help getting on in life. They were community activists in a very quiet way. They didn’t have a child with developmental disabilities, yet they were involved for more than 50 years with the Association for the Help of Retarded Children. They just weren’t a little bit involved; they were neck-deep involved.”

Most interestingly Ain believes a key lesson he has learned and one that he continues to try to put into practice is the following, “managing and leading people is a privilege.” He finds it so important because, “I don’t think we always understand the impact that we have as managers on the people on our teams. I talk to our managers all the time about this. Do you really understand the impact you have? And if you really understand the impact, then how do your actions reflect that you understand that?”

Moreover, his key insight is that people do not so much want to work for a nice person but a great boss. He said, “I believe that people would rather have a lousy job working for a great person than a great job working for a bad manager.” If you can achieve this as a boss, the results back to you and your organization will be the best investment you can make. Ain continued, “I believe very strongly that the single largest component of a business that adds to shareholder value is great management, and the single largest destroyer of shareholder value is bad management.”

But Ain cautioned, this will not be easy. However, I took from his comments that you can become a great business manager by working at it. He said, “being a good manager is really, really difficult. And the sooner people who are managers recognize that, the sooner they’ll start being a good manager. It takes unbelievable courage to be a good manager. It is hard to have difficult conversations with people when they’re not doing well. Who likes to do that? That takes courage. You can’t slide out of the way and hope it’s going to take care of itself.”

Ain said that at Kronos, they continually strive to engage up and down the chain. He specified, “We’ve also just introduced a new component to annual employee surveys. We’ve added about 15 new questions that are focused specifically around manager effectiveness. How does the staff truly feel about how effective their manager is at creating great teams?”

Yet Ain recognizes his role as CEO is simply more than being the boss. He said he views “my role as the keeper of the culture, and so I spend my time in a relaxed way getting to know the person. If, for example, they know someone I know professionally, I’ll say, “Let’s compare notes on that person. What’s your take?””

When hiring he believes this is a key inquiry and will “listen for whether they judge that person the same way I do, and whether we share the same values. I’ll also ask about their families, about work-life balance, about the successes that they’ve had, both personally and professionally. I want to hear how they like to work, and the expectations they have of the people who work for them.”

I found this final point not only very gratifying but an important insight into leadership. It is not only up to a business leader to set the tone but also to maintain a healthy corporate culture. He or she must ask the ‘How are we doing?’ question to a Chief Compliance Officer (CCO) or other corporate function which deals with culture on a day-in and day-out basis. Imagine if Wells Fargo CEO John Stumpf had understood his role as the keeper of the culture at the bank instead of being the head cheerleader for the “Eight is Great!” mantra of sales.

The other key point is that you can learn to be a great boss. Leadership is not determined by genes alone. One of the reasons I founded the podcast 12 O’Clock High – A podcast on business leadership, was to communicate simply that. One can learn to be a great leader. But it does require work and as Ain reminds us, it requires constant vigilance. When you think about it, that concept is not far from any best practices compliance program. It is constantly monitoring and evolving to meet new challenges. You should be doing that too to become a great boss.

 

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2016