Archive for the ‘Public Housing’ Category
May 9, 2016
How We Could Have Saved $1 Million Dollars
I have been following the stories about the Memphis Health Education and Housing Facility Board. The story began with the low income properties owned and operated by Global Ministries. Residents complained about bedbugs, rodents and improperly maintained appliances.
I began investigating all the various boards and commissions operated under the City of Memphis and Shelby County governments. I found that there were two Health Education and Housing Facility Boards (HEHFB), one run by the Memphis and one by Shelby County. As usual, the one run by the County was better, more open to records access and less controversial. The outstanding difference was a provision of the county board statement of policies and procedures that restricted the amount of cost paid to the Board Counsel. On just 5 bonds issued by the Memphis HEHFB this difference amounted to $59,000. The Memphis HEHFB says that they have issued over 85 bonds. This overpayment to the Board Counsel could be as much as $1 million dollars at the average of the 5 bonds reviewed.
At the most recent Memphis board meeting I asked the board some questions and made some public recommendations concerning open records, ethics and conflict of interest. Here are my points.
- Board agendas should be posted online at their website on the same day they are posted in the Daily News.
- All supporting information given to board members along with their agendas should be posted online at the website along with the agenda.
- Minutes of the meeting should be posted on the website not later than 1 week after the meeting.
- Bond costs and parties to the expenses should be posted on the website when sent to the state as required by law. (Report of debt obligation)
- Adopt the same or similar ordinance as the County limiting board counsel fees.
- Adopt a strong ethics ordinance regarding conflict of interest and post online.
- When a member of the board has a subsequent financial involvement in a board bond or property transaction, that member should make a public acknowledge of that involvement on the board website.
I call on the City Council to demand these changes and I ask all citizens and taxpayers to contact the Mayor and their council members to act on this matter. If you have a further suggestion, I ask you to contact Joe Saino at email@example.com.
April 13, 2016
Further Info On The Memphis HEHFB Controversy
I recently reported on the two Health Education & Housing Facility Boards, one from the City of Memphis and one from Shelby County. One is apparently well run and the other has had its’ authority temporarily suspended by the Tennessee Housing and Development Agency because of problem with properties run by Global Ministries.
I have attended two meeting of the Memphis board. The first one was not a regular monthly board meeting, but a reading of a proposed bond issue by Charles Carpenter, the board attorney. After the formal reading, I asked a few questions concerning transparency and open records and did not get a lot of information.
The second meeting, which was a regular monthly meeting, was attended by Channel 3, the Commercial Appeal, several business interests and myself. The only person, other than the business interests, to ask questions was myself. Before the start of the meeting, I asked the secretary for an agenda and she refused to give me one until the actual meeting started. At the end of the meeting I asked why the agendas and all attachments were not published at least two days before the meetings and I received no answer. I asked about the difference between the County ordinance that limits the amount that the Board Counsel can make. Mr. Carpenter said that he was not aware of the County ordinance. I pointed out that for just five Memphis bonds, the overpayment for the Memphis board Counsel was $59,000. Then I asked about a possible conflict of interest on the bonds for the Uptown Manor Senior Project by a board member and they said that they would have to consult the minutes of that meeting to see if the member recused herself. I asked for the minutes but received no reply. After the regular public meeting, they had an executive meeting and I asked if I could attend. They said that it was a closed meeting and the public was not able to attend.
Then several days later I, in fact, received the minutes from the two past board meetings concerning possible conflict of interests. I have attached those minutes and they are interesting.
Lee Patton and Monice Moore-Hagler recused themselves from the Inducement Resolution for the Uptown Manor Senior motion. Under Discussion Items, John Baker brought to the Board’s attention for further consideration a revised short term bond fee structure. Under New Business, Nancy Willis brought to attention a request for an annual ethics statement to be signed by members of the board and provided an example copy for the Council’s review.
Under action items, Dan Reid recused himself from consideration of inducement bond resolution for Global Ministries Foundation Bent Tree Apartments. Renasant Bank was to provide a private placement loan for the property.
Then Dan Reid re-entered the meeting and Monice Moore-Hagler and Lee Patton recused themselves before consideration of final bond resolution for Uptown Manor Senior Development LLC. Mr. Carpenter recommended approval.
Finally, Paige Walkup asked for an update regarding GMF Warren-Tulane property. Mr. Carpenter reported on his positive contact with Chris Lamberson and the ongoing response to correct issues and bring it up to standard.
This just goes to show that all these boards need to publish their agendas in advance along with all accompanied data and the public should see the same information that the board members get. I will look forward to your comments as you get ready to pay your federal taxes that funds all these projects.
March 29, 2016
This is a story of our two Health Education and Housing Facility Boards, one is a Shelby County HEHFB and one is a City of Memphis, HEHFB. I have asked for copies of bond information including Bond Counsel fees and other bond Issuance and Professional fees. As usual, it was fairly easy to get the information from the County Board and impossible to get it from the City board. I finally got some information about 5 bond issues (MemphisHEHFB) from the State of Tennessee Comptroller after no response from the City of Memphis board. I am still waiting for additional information from the State of Tennessee that generally has been very forthcoming. I have previously published the information about the 5 bonds issued by the Memphis board and here is a recap of the information from the Shelby County Board followed by the City of Memphis Board’s 5 bond issues that we have. Please note that the Shelby County HEHFB has a written policy limiting the Board Counsel fee. There is no such policy for the Memphis HEHFB and therefore they paid $59,000 more on just 5 bond issues on which we have information.
|Name of Project from the Shelby County HEHFB||Bond Amount||Bond Counsel Fee||Board Counsel Fee||Maximum Board Counsel Fee Allowed per County Policy||Total of All Fees for Bond Issue|
|Southern College of Optometry||$9.8M||$25,000 for Bond Counsel, Purchaser and Trustee Counsel||$12,500||$19,800||$29,000|
|Eastwood Apts 2012||$1.1M||$36,000||$3,400||$3,300||$114,528.37
|St. Agnes, 2012||$5.5M||$30,733||$13,155||$14,000||$50,388|
|Grace St. Luke’s Episcopal School 2012||$5.875M||$30,000||$14,970||$14,750||$70,533|
|The Village of Germantown 2012||$39.96M||$160,000||$48,160||$49,960||$1,418,414|
|Trezevant Manor 2013||$66.475M||$120,000||$49,805||$76,475||$1,578,135.50|
|St Benedict 2013||$10M||$15,000||$7,500||$20,000||$33,000|
|Countryside North Apartment 2013||$5M||$42,000||$18,122.50||$13,000||$191,446.45|
|Name of Project from the Shelby County HEHFB||Bond Amount||Bond Counsel Fee||Board Counsel Fee||Maximum Board Counsel Fee Allowed per County Policy||Total of All Fees for Bond Issue|
|Southern College of Optometry 2014||$9.8M||$25,000||$12,500||$12,500||$43,500|
|Presbyterian Day School 2014||$10M||$10,000||$5,000||$5,000||$15,000|
|The Village of Germantown 2014||$21.94M||$142,000||$30,140||$71,000||$1,020,587|
|St. George Independent School 2015||$32.585M||$40,000||$20,000||$50,585||$106,936|
|Rhodes College 2015||$21.35M||$55,000||$27,500||$27,500||$294,646|
|Name of Project from the Memphis HEHFB||Bond Amount||Bond Counsel Fee||Board Counsel Fee||Maximum Board Counsel Fee Allowed per County Policy||Total of All Fees for Bond Issue|
|Uptown Senior Housing Project 2006||$4M||$40,000||$25,000||$11,000||$222,550|
|Arbors of Hickory Ridge||$11.45M||$26,000||$30,500||$21,450||$235,767|
|John Madison Exum Towers||$19M||$85,000||$40,000||$29,000||$159,600|
|Uptown Manor Senior Project 2015||$2,825M||$21,000||$21,350||$8,475||$278,687|
|Total of actual Board Counsel Fee versus fee per County limitation fee||$140,350||$81,047
The savings here would have been $59,303 if county policy applied
As you will see most of the above County bond issues were for educational, medical and retirement facilities. Only two (Countryside and Eastwood) were similar to what has been financed by bonds from the Memphis HEHFB.
My investigation of these two boards was instigated by the Global Ministry story and the bond downgrade. There is a real question of transparency and adequate ethics rules, conflict of interest rules and rules concerning competition for front end bond expenses. I have not yet, in response to my open records request, received past bond information from the Memphis HEHFB. I have received past bond information from the State of Tennessee (Steve Osborne, Senior Analyst, Comptroller of the Treasury ǀ State and Local Finance). Here is some of the information that he sent showing past bond expenses and who participated.
Here is a list of past bond work done by Charles Carpenter (board counsel for the Memphis board). While Mr. Carpenter is a competent bond counsel lawyer, there needs to be more transparency in the issuance of these bonds, written conflict of interest rules, limitation of front end bond costs and competition for the various issuance costs. There is also a need for a public discussion of the best and most cost efficient method to provide adequate housing for those unable to work and provide needed housing for themselves.
March 15, 2016
The Hidden Cost of Health Education and Housing Board Bonds
The Commercial Appeal recently published a story about a downgrade of a local bond issue as follows. “On Feb. 12, the Bank of New York Mellon Trust Company, which oversees the$11.8 million bond, sent a notice of default to bondholders notifying them the U.S. Department of Housing and Urban Development had ended its contract with the borrower, Global Ministries Foundation.”
I have been researching the whole issue of City and County boards and commissions and particularly the Memphis Health Education and Housing Facility Board. I asked that board for a list of bonds issued by the Board for the last five years with cost data and information of the parties receiving payment upon the issuance of the bonds. The board has failed to respond to that request for open records. Therefore I went to the State of Tennessee and received five reports on local bond issues from Steve Osborne, Senior Analyst, Comptroller of the Treasury, State and Local Finance. Here are the five issues I received.
The five reports are very revealing but first I have to tell you about my request to the Shelby County Health, Education and Housing Facility Board (same name as the similar City HEHFB) but a completely different board. I asked for their documents on ethics and conflict of interest policy and I received it as shown. I particularly call your interest to page 6 wherein is shown a maximum fee calculation for the legal fee of Bond Counsel.
I have shown below the fee paid to the bond counsel of the Memphis HEHFB board on the five recent bond issues versus what would be the fee from the Shelby County Board HEHFB.
|Name of Project||Bond Amount||Actual Bond Counsel Fee City of Memphis HEHFB||Maximum Bond Counsel Fee of County HEHFB|
|Arbors of Hickory Ridge Project||$11,450.000||$26,000||$21,450|
|Housing and Social Services||$4,061,000||$25,255.08||$11,122|
|John Madison Exum Towers and Apartment I and II||$19,000.000||$85,000||$29,000|
|Uptown Housing Senior Project 2006||$4,000,000||$40,000||$11,000|
|Uptown Manor Senior Project||$2,825,000||$21,000||$13,062.50|
|Total Bond Counsel Fee||$197,255.08||$85,634.50|
On these five bond issues, this is $111,621 more than the County maximum amount in their ordinance. But this is just the beginning of the cost of the bond issuance. The total for these five bond issues just for the Memphis HEHFB is $967,304.03.
Then there is the question of a possible conflict of interest although apparently there is no provision that I have been able to obtain concerning a City of Memphis conflict of interest policy although I have been told that the Strickland Administration is working on such a policy.
I think that it is high time that we get a discussion going on this high cost of bond issuance and is this approach to adequate housing for low income citizens the best and most efficient method. Also there needs to be a clear and open policy on bond issuance fees, conflict of interest and ethics.
March 3, 2016
Boards and Commissions in Memphis and Shelby County
Recently I became interested in Memphis and Shelby County Boards and Commissions. My interest was piqued by all the news concerning Serenity Towers and Global Ministries. Here is a news article on the bond issue for this property.
The Health, Educational and Housing Facility Board of Memphis, Tennessee facilitated the GMF acquisition through the issuance of tax exempt 501(c)3 housing revenue bonds on behalf of the purchaser. Merchant Capital served as the bond underwriter in the placement of the bonds with investors, as the bonds were rated investment grade by Standard and Poor’s rating agency. Jones Walker served as Bond Counsel. Kristin Neun, Esquire, served as FHA counsel. Charles Carpenter, Esquire, served as counsel to the Issuer. The Bank of New York Mellon serves as Trustee. Glanker Brown serves as GMF’s corporate and owner counsel within its expanding national affordable multifamily housing portfolio.
A recent article in the Commercial Appeal stated the following.
About a third of all the units inside Serenity Towers have bedbugs, according to a Memphis Code Enforcement report released Friday.
The report says 134 units have bedbugs inside the senior high rise apartment complex. Other code enforcement violations included cockroaches, broken or damaged windows, leaks in the ceiling, broken thermostats, damaged toilet and faucets among other things.
City code enforcement officers inspected the 396 units in the property on Feb. 11, 2015. The inspection came after several tenants complained of bedbugs and other problems.
Rev. Richard Hamlet, founder of Global Ministries Foundation, said in a statement he was aware of the bedbug problem since his nonprofit bought the property. His staff is working to eradicate the infestation. GMF bought the senior property in 2014 using a $14.5 million bond issued by the Health, Educational and Housing Facilities board of Memphis.
With that background, I started investigating the various boards and commissions. What I found was 46 City Boards and Commissions and 36 County ones. Some are joint boards but many are stand alone ones. It was interesting that the City Health, Education and Housing Facility Board and the County Health, Education and Housing Facility Board have the same names but are completely different and separate
The City HEHF Board states its purpose as follows.
Function & Authority:
The Health, Education and Housing Facility Board a public nonprofit corporation issues tax exempt revenue bonds for the development or rehabilitation of multi-family housing facilities to be occupied, according to the state statute ?by persons of low and/or moderated income, and/or elderly and/or handicapped persons.
The County HEHF Board states its purpose as follows.
Functions & Authority
The function of the Health, Education, and Housing Facility Board is to assist in the financing of health facilities, educational facilities, and housing facilities for low and moderate income families, disabled individuals and the elderly. The financings are accomplished through the issuance of revenue bonds payable solely from the revenues of the project. The taxpayers and the County of Shelby are never liable for the repayment of the bonds.
I asked both boards for their ethics documents and conflict of interest policies. From the County Board I received a prompt answer with the statement of policies and procedures revised 11/4/15 and By-Laws revised 2007.
I attended a meeting of the Memphis HEHF on February 29th for a required hearing concerning a request that the board issue its Multifamily Housing Revenue Bonds (Patterson Flats Project), Series 2016 in an aggregate amount not to exceed $12 million dollars. After the required reading I asked some questions concerning fees related to recent bond issues. Mr. Carpenter did not know but referred me to the State of Tennessee for this information. I asked him who was paid the $110,000 in legal and professional fees shown in the 2014 financial statement and he said that he was paid those fees. I asked about the details of the recent resignation of John L. Baker, 17 years as director of the Memphis HEHF board, and was told that that could be discussed only at a regular monthly meeting of the board and that the March meeting on the first Wednesday was cancelled as there was no business to discuss.
This whole matter of this housing for low and moderate income individuals and families, the cost and effectiveness of this approach needs a public discussion and possible alternatives to this expensive program. What do you think?
April 28, 2015
Memphis Urban Development In Action
Memphis Bass Pro is set to open tomorrow and I for one hope that it is successful and pays off the millions that the City of Memphis has put into it. But I would like to point out a past example of big government and their programs for downtown. Take a look at the Peabody Place Project.
Peabody Place was a 300,000-square-foot shopping and entertainment mall intended to aid Downtown’s revival. The mall opened with a Muvico cinema complex, retail and restaurants in June 2001 but started to empty as the recession deepened in 2008. When the theater closed in July 2008, the Belzes announced plans to renovate part of the mall into a suites hotel, but lack of financing kept the project from going forward. Now look at the funding sources and amounts that financed the original project. UDAG, CDBG, Section 108 and City CIP to the tune of $41.8 million. What are UDAG, CDBG, Section108 and City CIP?
UDAG (Urban Development Action Grant)
The Secretary is authorized to make urban development action grants to cities and urban counties which are experiencing severe economic distress to help stimulate economic development activity needed to aid in economic recovery.
CDBG (Community Development Block Grants)
The Community Development Block Grant (CDBG) program was enacted in 1974 by president Gerald Ford through the Housing and Community Development Act of 1974 and took effect in January 1975. It had the goal of extinguishing poverty and urban blight.
Section 108 is a loan guarantee program administered by the Department of Housing and Urban Development (HUD), which, since 1978, has committed more than $6 billion to almost 1,500 capital projects aimed at ameliorating housing conditions and creating economic opportunities, particularly for the benefit of low- and moderate-income persons.
City CIP (City of Memphis Capital Improvement Program)
This is City of Memphis capital money.
Now I ask the question, does any of this investment of our federal tax money or our City of Memphis tax money fit these definitions or objectives?
Then more recently there was this information in a Commercial Appeal article from 2014. The Belz family plans to refinance Peabody Place in a move that Downtown officials say is unrelated to talk of converting the vacant complex into a convention-related facility.
The Center City Revenue Finance Corp. on Tuesday approved a refinancing request from Hotel Peabody L.P., the Belz unit that owns The Peabody hotel and adjoining retail and entertainment site.
Refinancing required the board’s approval as a condition of a 25-year property tax abatement that was granted to the project in 1997.
This and other projects and questionable financing and use of federal tax money need a public discussion and open record information on how this money is to be repaid and who benefits.
April 16, 2015
Happy Tax Day!!!
Yesterday was April 15th and your taxes hopefully were paid or your check was in the mail. Most working people and retirees are tax payers and pay more in taxes than they receive in government benefits.
One huge item most of us do not understand is nonprofits. One definition of non profits is “A business entity that is granted tax-exempt status by the Internal Revenue Service. Donations to a nonprofit organization are often tax deductible to the individuals and businesses making the contributions.” Donations to non profits also come from Federal, State and local governments from taxpayer funds.
Information about nonprofits is available from Guidestar. Guidestar is a 501(c)(3) public charity that collects, organizes, and presents the information you want in an easy-to-understand format while remaining neutral. Guidestar provides nonprofit information to a broad audience at no cost to the users.
Why Should You Care about Nonprofit Information?
Because the nonprofit sector is incredibly powerful. According to the Center for Civil Society Studies at Johns Hopkins University, more than 70 million people work and volunteer in the nonprofit sector. Nonprofit employees make up the third-largest workforce among U.S. industries, behind only retail and manufacturing, and nonprofits create total revenue of more than 1.9 trillion annually, exceeding the total GDP of Canada, Australia, Russia, or India
Locally, according to Guidestar, we have 3705 non profit organizations just in the City of Memphis. I am in the process of trying to gather information of Memphis nonprofits. It is not easy. I have attached a spreadsheet on just 413 local nonprofits and I am up to $3.5 billion dollars of income. At the top of the list are well known and respected medical organizations like St. Jude and Baptist Hospital and charitable organizations like Autozone.
But then you get organizations like Global Ministries Foundation and take a look at their Form 990. You probably read the recent CA article about Global and the Rev Richard Hamlet who is paid a salary $485,000. Read the article and make your own decision as to the benefits of such a nonprofit. I am reaching out to the public to send me information on local non profits, where their money comes from, where their money goes and the cost of administration. Many people have called for better coordination of local non profits so that those that work on housing for the homeless (for example) could work together and reduce the cost of administration and get more of the money to those in need. The real question about any non profit is this. What is the percentage of benefits out versus money in? Hopefully the cost does not get above 15% with the benefits at 85%. Is that reasonable?
April 14, 2015
Subsidized Housing, MHA, HCD, HUD, HEHF, Say What?
Recently I attended a MHA board meeting and at the end of the session I asked the board in the future to post all recent financial statements. Until recently they had not posted 2013 and 2014 statements. I also asked that in the future that they post the board agenda and all supporting documents at least two days in advance of the monthly board meetings. We will see in the future whether they do this.
They did in fact post the financial statements for 2013 and 2014 so that now we have posted 2009 through 2014 posted online.
At this point I do not pretend to understand this organization which is headed by Robert Lipscomb as well as the City of Memphis department of Housing and Community Development which is also headed by the same Robert Lipscomb. Then you add in HUD (Housing and Urban Development), HEHF (Health, Education and Housing Facilities Board) and then all the non profits like Global Ministries Foundation which was recently written about in the Commercial Appeal and you have a real witches brew brought on by big government spending in an attempt to solve social problems and garner votes. The real question is what is the most efficient way to help those truly in need? Is big government the answer or should rent money be given to those truly in need and let them make their own housing decisions? What do you think?
In order to get a better understanding of the financial structure and purpose of the MHA and HCD a friend asked for a meeting with MHA accounting (Ms. Vickie Aldridge) and here is the answer he got.
“I am not available to meet however if you submit your questions in writing, I will respond at my earliest convenience.” My friend will no doubt respond but here are my thoughts on these posted financial statements.”
I have attached one page out of each of the last six financial reports (2009 thru 2014). These pages list the notes, loans and mortgages receivable for various local housing projects. If you read on through the following pages of the reports you will see the following statement for each of the projects.
No payments were received on this note during 2014, 2013, 2012, 2011, 2010 and 2009.
My request to the MHA would be that I want to see these financial documents on the loans and mortgages to understand the terms and conditions and who is benefiting from these finances. You will note that the long term notes receivable has gone from $92 million in 2009 to $155 million in 2014. The public should be made aware of these finances, the cost to the taxpayers and the benefits to the tenants of this housing.
October 7, 2013
The Sears Crosstown Project
I am old enough to remember going to the Curb Market in crosstown with my mother and buying a bushel of snap beans for canning. I would have to spend the rest of the day cleaning and preparing them. On many occasions we then went to the Sears Crosstown store. It was huge and impressive. It was built for a certain time and market and whether it paid for itself over time I do not know. Looking at the Sears Company today, you have to wonder about their long term business knowledge. The Sears catalog was the amazon of its day and this store I believe was a catalog sales and warehouse center. Too bad they did not keep up with technology.
Now we have a choice. Tear down the old Sears building or spend at least $175 million to turn it into another Robert Lipscomb non tax producing renovation project. Where is the financial pro forma report on this project? If it is available I would like to see it.
Meanwhile let us look at how this is currently being financed according to a recent CA report.The Crosstown Development team says it has essentially assured $160 million in
funding — $25 million raised privately, $30 million in historic preservation tax credits,
$15 million in new market tax credits, $10 million in grants and other sources, and an
$80 million loan. Add the $15 million requested from the City of Memphis and you have the $175 million supposed front end cost.
- $30 million in historic preservation tax credits. The legislative incentive program to encourage the preservation of “historical buildings”. Congress instituted a two-tier Tax Credit incentive under the 1986 Tax Reform Act. A 20% credit is available for the rehabilitation of historical buildings and a 10% credit is available for non-historic buildings, which were first placed in service before 1936. Benefits are derived from tax credits in the year the property is placed in service, cash flow over 6 years and repurchase options in year six.
- $15 million in new market tax credits. The New Markets Tax Credit (NMTC) Program was established in 2000 as part of the Community Renewal Tax Relief Act of 2000. The goal of the program is to spur revitalization efforts of low-income and impoverished communities across the United States and Territories. The NMTC Program provides tax credit incentives to investors for equity investments in certified Community Development Entities, which invest in low-income communities. The credit equals 39% of the investment paid out (5% in each of the first three years, then 6% in the final four years, for a total of 39%) over seven years (more accurately, six years and one day of the seventh year) . A Community Development Entity must have a primary mission of investing in low-income communities and persons.
If it goes forward, will it throw off tax money to the City of Memphis? If there are new small businesses that rent space or locate in the general area because of new traffic and people who live in the renovated building, I suppose there could be new sales tax money and employment opportunities. However it sounds like most of the occupiers of the space will be non-profits and art enterprises. There will be people living in the building but many of these will be rent subsidized people under section 8 or other federal and state programs. Taxpayers will be funding the whole project funded through these various federal tax credits.
As far as the building is concerned, I think it is ugly and really not worth saving. Possibly the architects can make it beautiful but at what cost compared to tearing it down and doing something else? I would like to see a financial analysis of this proposed project and no decision should go forward without this being presented to the public for discussion.
January 28, 2013
As we discuss paying for local government with property taxes, sales taxes, fees, penalties, income taxes, capital gain taxes, etc. etc. and on and on, I decided to look into the cost of housing assistance. I went to the Memphis Housing Authority site and found a document on eligibility as shown below.
- You are 18 or over; AND
- Your family earns less than 50% of the Area Median Income, ($28,650 a year), AND
- You have lived in Shelby County for at least one year, AND
- You want to rent an apartment within Shelby County, AND
- You are a United States Citizen OR an eligible immigrant, AND
- Your household’s members are all citizens or eligible immigrants, which includes permanent residents and lawful temporary residents.
I then decided to ask for financial statements on a local public housing site, University Place on Lamar near Crump Blvd. This was the site of the old Lamar Terrace. I have attached three financial documents about the three phases of the development, University Place Southeast, University Place II and University Place III. (more…)