McCuireWoods LLP Gateway Plaza 800 East Canal Street Richmond, VA 23219-3916 Tel 804.775.1000 Fax 804.775.1061 © www.mcguirewoods.com Steven C. Popps Direct: 804.775.4319 10 „ SCC-CLERK'S OFFICE © DOCUMENT CONTROL CENf^ps®^:u^°°J7c^ MCGUIREWCODS ZCIb JAN U P 2: 2b January 14, 2016 Joel H. Peck Clerk of the Commission State Corporation Commission Tyler Building 1300 E. Main Street Richmond, Virginia 23219 Re: Petition of Anderson Financial Services, LLC Loan Max d/b/a Loan Max, Case No. BFI-2015-00060 Dear Mr. Peck, Enclosed for filing, please find an original plus 15 copies of Loan Max's Chart of Redactions. Sincerely, Steven G. Popps Atlanta Austin Baltimore Brussels Charlotte Charlottesville Chicago Dallas Houston lacksonville London Los Angeles - Century City Los Angeles - Downtown New York Norfolk Pittsburgh Raleigh Richmond Tysons Corner Washington, D.C. Wilmington COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION AT RICHMOND, JANUARY 14, 2016 PETITION OF ANDERSON FINANCIAL SERVICES, LLC LOAN MAX D/B/A LOAN MAX CASE NO. BFI-2015-00060 To withhold its 2014 annual Report from public disclosure CHART OF REDACTIONS SUBMITTED BY ANDERSON FINANCIAL SERVICES. LLC LOAN MAX D/B/A LOAN MAX Pursuant to the Commission's January 6, 2016, Order Scheduling Additional Proceedings, Anderson Financial Services, LLC, Loan Max d/b/a Loan Max ("Loan Max"), by counsel, submits the following Chart of Redactions and the attached redacted version of its 2014 Annual Report previously filed with the Commission. The redacted version of Loan Max's 2014 Annual Report is attached as Attachment A. m @ y y © w Si Redaction Number and Annual Report Page Number Redaction 1, Page 1 Redaction 2, Pages 2, 8-11 Legal Basis Redaction No. 1 contains the names of, and contact information for officers, directors, and management, as well as additional non-public information regarding Loan Max's license number and business operations. This information should be redacted because it is subject to the confidentiality and non-disclosure provisions contained in Va. Code § 6.2-101, and is not subject to the Virginia Freedom of Information Act, §§ 2.2-3700, etseq. See Va. Code § 12.1-19(C); Christian v. S'CC, 282 Va. 392 (2011); Gannon v. SCC, 243 Va. 480 (1992); Atlas Underwriters, Ltd. v. SCC, 237 Va. 45 (1989). See also Va. Dep't ofCorr. v. Surovell, 2015 Va. LEXIS 107 (Sept. 17, 2015) (citing Christian, discussing exemptions from VFOIA, reversing circuit court's judgment requiring VDOC to produce documents, and remanding for further proceedings). Redaction No. 2 contains detailed information regarding regulatory actions and inquiries involving Loan Max in Virginia and various other jurisdictions. This information should be redacted because it is not publicly available under the Virginia Freedom of Information Act. See Va. Code §2.2-3700, et seq. Moreover, this detailed regulatory information, if disclosed, would put Loan Max at a competitive disadvantage because it would allow Loan Max's competitors to see states in which Loan Max is at increased risk for regulatory scrutiny. Additionally, the disclosure of this information could quite easily create unforeseen antitrust problems for Loan Max and other motor vehicle title lenders. Lastly, the Commission only requires disclosure of regulatory actions and/or investigations within the last three years. When Loan Max completed its 2014 Annual Report, it included information more than three years old, under the assumption that the Annual Report would not be publicly disclosed. Disclosing the information in question to the public could create a disincentive for motor vehicle title lenders to disclose information to the Commission. Lastly, the sensitive information contained in Redaction No. 2 should be redacted because it is subject to the confidentiality and non­ disclosure provisions contained in Va. Code § 6.2-101, and is not subject to the Virginia Freedom of Information Act, §§ 2.2-3700, et seq. See Va. Code § 12.1-19(C); Christian v. SCC, 282 Va. 392 (2011); Gannon v. SCC, 243 Va. 480 (1992); Atlas Underwriters, Ltd. v. SCC, 237 Va. 45 (1989). See also Va. Dep't of Corr. v. Surovell, 2015 Va. LEXIS 107 (Sept. 17, 2015) (citing Christian, discussing exemptions from VFOIA, reversing circuit court's judgment requiring VDOC to produce documents, and remanding for further proceedings). 2 [sc3 © Redaction Number and Annual Report Page Number Redaction 3, Page 3 Legal Basis Redaction No. 3 contains the names of Loan Max's officers, directors, and management, as well as the details of Loan Max's ownership structure and management. This information should be redacted because it is subject to the confidentiality and non-disclosure provisions contained in Va. Code § 6.2-101, and is not subject to the Virginia Freedom of Information Act, §§ 2.2-3700, et seq. See Va. Code § 12.1-19(C); Christian v. SCC, 282 Va. 392 (2011); Gannon v. SCC, 243 Va. 480 (1992); Atlas Underwriters, Ltd. v. SCC, 237 Va. 45 (1989). See also Va. Dep't of Corr. v. Surovell, 2015 Va. LEXIS 107 (Sept. 17, 2015) (citing Christian, discussing exemptions from VFOIA, reversing circuit court's judgment requiring VDOC to produce documents, and remanding for further proceedings). Redaction 4, Page 4. Redaction No. 4 contains financial data and loan data relating to Loan Max's business. This information constitutes trade secrets under the Uniform Trade Secrets Act because it is information with an independent economic value that is not generally known or readily ascertainable to Loan Max's actual or potential competitors. See Va. Code §§ 59.1-336. The financial and loan data in this redaction also should be redacted because it is subject to the confidentiality and non-disclosure provisions contained in Va. Code § 6.2-101, and is not subject to the Virginia Freedom of Information Act, §§ 2.2-3700, et seq. See Va. Code § 12.1-19(C); Christian v. SCC, 282 Va. 392 (2011); Gannon v. SCC, 243 Va. 480 (1992); Atlas Underwriters, Ltd. v. SCC, 237 Va. 45 (1989). See also Va. Dep't of Corr. v. Surovell, 2015 Va. LEXIS 107 (Sept. 17, 2015) (citing Christian, discussing exemptions from VFOIA, reversing circuit court's judgment requiring VDOC to produce documents, and remanding for further proceedings). Redaction 5, Page 4 Redaction No. 5 contains detailed data regarding legal actions and judgments pursued by Loan Max against borrowers. This information should be redacted because it is subject to the confidentiality and non-disclosure provisions contained in Va. Code § 6.2-101, and is not subject to the Virginia Freedom of Information Act, §§ 2.2-3700, etseq. See Va. Code § 12.1-19(C); Christian v. SCC, 282 Va. 392 (2011); Gannon v. SCC, 243 Va. 480 (1992); Atlas Underwriters, Ltd. v. SCC, 237 Va. 45 (1989). See also Va. Dep't of Corr. v. Surovell, 2015 Va. LEXIS 107 (Sept. 17, 2015) (citing Christian, discussing exemptions from VFOIA, reversing circuit court's judgment requiring VDOC to produce documents, and remanding for fhrther proceedings). 3 t=a m Redaction Number and Annual Report Page Number Redaction 6, Page 5 Redaction 7, Pages 12-13 Legal Basis Redaction No. 6 contains the name and title of a senior Loan Max officer and a Loan Max employee. This infonnation should be redacted because it is subject to the confidentiality and non-disclosure provisions contained in Va. Code § 6.2-101, and is not subject to the Virginia Freedom of Information Act, §§ 2.23700, etseq. See Va. Code § 12.1-19(C); Christian v. SCC, 282 Va. 392 (2011); Gannon v. SCC, 243 Va. 480 (\ 992)-, Atlas Underwriters, Ltd. v. SCC, 237 Va. 45 (1989). See also Va. Dep't of Corr. v. Surovell, 2015 Va. LEXIS 107 (Sept. 17, 2015) (citing Christian, discussing exemptions from VFOIA, reversing circuit court's judgment requiring VDOC to produce documents, and remanding for further proceedings). Redaction No. 7 contains financial data (profit and loss statement) relating to Loan Max's business. This information constitutes trade secrets under the Uniform Trade Secrets Act because it is information with an independent economic value that is not generally known or readily ascertainable to Loan Max's actual or potential competitors. See Va. Code §§ 59.1-336. The proprietary financial and loan data contained in Redaction No. 7 should be redacted because it is subject to the confidentiality and non-disclosure provisions contained in Va. Code § 6.2-101, and is not subject to the Virginia Freedom of Information Act, §§ 2.2-3700, et seq. See Va. Code § 12.1-19(C); Christian v. SCC, 282 Va. 392 (2011); Gannon v. SCC, 243 Va. 480 (1992); Atlas Underwriters, Ltd. v. SCC, 237 Va. 45 (1989). See also Va. Dep't of Corr. v. Surovell, 2015 Va. LEXIS 107 (Sept. 17, 2015) (citing Christian, discussing exemptions from VFOIA, reversing circuit court's judgment requiring VDOC to produce documents, and remanding for further proceedings). Dated: 14 January 2016 Respectfully submitted, Christopher R. Nolen (VSB No. 44404) Robert W. Loftin (VSB No. 68377) Steven G. Popps (VSB No. 80817) MCGUIREWOODS LLP Gateway Plaza 800 East Canal Street 4 Richmond, Virginia 23219 Telephone: (804)775-1000 Facsimile: (804) 775-1061 cnolen@,mcauirewoods.com rloftin@mcguirewoods.com spopps@,mcguirewoods.com Attachment A Redacted Version of Loan Max?s 2014 Annual Report §5) CCB-5529 (Rev. 11/14) © [=5 COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION BUREAU OF FINANCIAL INSTITUTIONS ANNUAL REPORT OF MOTOR VEHICLE TITLE LENDERS. FOR THE YEAR ENDING DECEMBER 31, 2014 0) a Bureau of Financial Institutions 1300 East Main Street, Suite 800 Post Office Box 640 Richmond, Virginia 23218-0640 FILE IN DUPLICATE SECTION I GENERAL INFORMATION 1. Name and mailing address of licensee: Anderson Financial Services, LLC LoanMax 3440 Preston Ridge Road, Suite 500 Alpharetta, GA 30005 3. Number of motor vehicle title loan offices in Virginia: 2, Virginia License Number: 73 4. E-Mail Address: Hi 5. List any trade name or fictitious name used by the licensee to conduct the motor vehicle title lending business in Virginia: LoanMax 6. Name, title and business address of the chief executive officer of licensee: 7. Provide the name, title, address, telephone number, fax number and e-mail address for the individual to be contacted with respect to: 3440 Preston Ridge Road, Suite 500, Alpharetta, GA 30005 B) Scheduling Examinations: (C) Consumer Complaints: 3440 Preston Ridae Road, Suite 500. Alpharetta. GA 30005 3440 Preston Ridge Road, Suite 500, Alpharetta, GA 30005 8. Indicate below any other businesses conducted in the location(s) where the licensee makes motor vehicle title loans in Virginia: (A) Check Cashing Conducted by: (B) Payday Lending _ Conducted by: (C) Money Transmission/Money Order Sales _ As an agent for: (D) Tax Preparation/Electronic Tax Filing Conducted by: (E) Tax Refund Anticipation Loans. . Conducted by: (F) Other (specify each type of other business conducted and the name(s) of any legal entity or entities that operate the other businesses): 1 m p SECTION I (Continued) LIST OF OFFICES 9. List the physical location and mailing address of each office where motor vehicle title lending is currently conducted pursuant to Chapter 22, Title 6.2 of the Code of Virginia or where Virginia motor vehicle loan records are stored. (Attach an additional 8 1/2" X 11" paper if necessary.) See Attached REGULATORY ACTIONS 10. Has the licensee or any of its senior officers, directors, trustees, managers, principal owners or affiliates been the subject of any regulatory investigation, or action taken or pending, by any state or federal agency within the last three years? If YES, attach a complete explanation and copies of all related documentation. 2 2 ^ & @1 ^ !=a & SECTION I (Continued) m DIRECTORS, MANAGEMENT AND OWNERSHIP 11. If the licensee is a limited liability company or corporation, list all members, managers, directors and senior officers (those within three reporting levels of the CEO), their titles, and their ownership interest, if any, direct or indirect, in the licensee. If the licensee is a partnership, list the partners, along with their ownership interest, direct or indirect, in the licensee. If the licensee is a business trust, list the trustees along with their ownership interest, direct or indirect, of the licensee. Itemize any Individuals and/or companies not listed above with a ten percent or greater ownership Interest, direct or Indirect, in the licensee, including beneficial owners. Number of Shares Owned 3 Percentage Ownership SECTION II MOTOR VEHICLE TITLE LOANS MADE DURING THE CALENDAR YEAR 12. Loan Data (A) Total number of motor vehicle title loans made in Virginia during the calendar year; (B) Total principal amount of motor vehicle title loans made in Virginia during the calendar year; S (C) Total number of individual borrowers to whom motor vehicle title loans were made by the licensee; (D) Provide the minimum, maximum and average principal loan amount of motor vehicle title loans made by the licensee: Minimum; $£8li H[ ^H_; Maximum: $JE9HH H ^; Average: $ KMMBBBI (E) Provide the minimum, maximum and average Annual Percentage Rate of motor vehicle title loans made by the licensee: M i n i m u m : M a x i m u m : J E H H m 0 / " ; A v e r a g e : _ K H H H i l B . 0 / / n (F) Provide the minimum, maximum and average term1 of motor vehicle title loans made by the licensee: Minimum: Maximum: Average: 13. Analysts ofDelinquent Accounts and Repossessions (A) Total number of individual borrowers that failed to make a monthly payment on a motor vehicle title loan for at least 60 days: 14. Legal Action (A): Provide the total number of personal money judgments against borrowers that were obtained by or on behalf of the licensee based on the following borrower actions: I. Intentionally damaging or destroying a motor vehicle that secures a title loan: J II. Intentionally concealing a motor vehicle that secures a title loan: III. Giving the licensee a lien on a motor vehicle that is already encumbered by an undisclosed prior lien: _ IV. Subsequently giving a security interest in, or selling, a motor vehicle that secures a title loan to a third party, without the licensee's written consent: (B) Total amount of personal money judgments against borrowers that were obtained by or on behalf of the licensee: $ 1 For the purpose of this report, the term of a motor vehicle title loan is the number of days between the execution of a written motor vehicle title loan agreement and the maturity date specified in the loan agreement. 4 AFFIDAVIT State of Georgia & , being the _ (Title) (Name of Officer of Licensee) of swear or affirm that, to the best of my Anderson Financial Services. LLC LoanMax (Motor Vehicle Title Lender Licensee) information and belief, the facts in this report, including any accompanying schedules and statements, are true. Officer of Licensee Subscribed and sworn to before me this ,20 day of 15 Notary Public PUBL,0,f! Registration Number of Notary: My commission expires: My M PLEASE MAKE SURE THIS REPORT AND THE FINANCIAL STATEMENT OF THE LICENSEE ARE FILED IN DUPLICATE BEFORE THE MARCH 25TH DEADLINE. IF AUDITED FINANCIAL STATEMENTS ARE BEING PREPARED BUT ARE NOT READY, PLEASE INDICATE BELOW THE APPROXIMATE DATE THAT THEY WILL BE FILED WITH THIS BUREAU AND ATTACH CURRENT INTERNAL STATEMENTS. (If an audit of the licensee is not conducted, current internal statements alone arc acceptable and should be attached.) Anticipated filing date of audited financial statement of licensee: 5 Anderson Financial Services, LLC LoanMax Motor Vehicle Title Lender Annual Report Response to Question 9 W © Corporate Name Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services^LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial ServicesJLLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial ServicesJLLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Address DBA 2010 Blvd LoanMax 4377 Electric Rd. LoanMax 2320 Wards Rd. LoanMax 3607 N. Military Hwy. LoanMax 4700 E. Virginia Beach Blvd LoanMax 10723 Jefferson Ave LoanMax 15486 Warwick Blvd LoanMax 1003 Greenville Ave LoanMax 2626 Riverside Drive LoanMax 6109A Virginia Beach Blvd LoanMax 4802 S. Laburnum Ave. LoanMax 1150 Memorial Blvd LoanMax 7181 Lee Highway LoanMax 2360 Main St LoanMax 3216 Western Branch Blvd LoanMax 8375 Centreville Rd. LoanMax LoanMax 4001 Halifax Rd. 1883 S. Crater Road LoanMax 1605 LaskinRd., BldgA LoanMax 2105 Roanoke Street SE LoanMax 2608 Valley Avenue LoanMax 3501 Mt. Vernon Ave. LoanMax 6900 Midlothian Turnpike LoanMax 334 Amaret Street LoanMax 800 W. Atlantic Street LoanMax LoanMax 4201 West Broad Street 7109 Columbia Pike LoanMax 14226 Jefferson Davis Hwy LoanMax LoanMax 4266 James Madison Parkway 3201 Williamson Road, NW LoanMax LoanMax 3009 Hull Street LoanMax 2149 Jefferson Davis Highway LoanMax 805 North Main Street 10805 Fairfax Boulevard LoanMax LoanMax 312 South Battlefield Blvd 1010 Airline Boulevard LoanMax LoanMax 5302 Jefferson Davis Highway 100 James Madison Highway LoanMax 525 Orange Avenue, NE LoanMax 8301 Sudley Road LoanMax LoanMax 1112 South Lynnhaven Pkwy LoanMax 692 J, Clyde Morris Boulevard LoanMax 1640 Seminole Trail LoanMax 4740 Martinsburg Pike 3914 Plank Road LoanMax LoanMax 8909 Centreville Road LoanMax 1160 East Main Street 802 England Street LoanMax LoanMax 4842 South Amherst Highway LoanMax 4142 Melrose, Unit 33 A & B 3173 Lee Highway LoanMax 6 City Colonial Heights Roanoke Lynchburg Norfolk Virginia Beach Newport News Newport News Staunton Danville Norfolk Richmond Martinsville Falls Church Harrisonburg Chesapeake Manassas South Boston Petersburg Virginia Beach Christiansburg Winchester Alexandria Richmond Fredericksburg Emporia Richmond Annandale Woodbridge King George Roanoke Richmond Stafford Suffolk Fairfax Chesapeake Portsmouth Fredericksburg Culpeper Roanoke Manassas Virginia Beach Newport News Charlottesville Clear Brook Fredericksburg Manassas Wytheville Ashland Madison Heights Roanoke Bristol St VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA Zip 23834 24014 24502 23518 23462 23601 23608 24410 24521 23502 23231 24112 22046 22801 23321 20111 24592 23805 23451 24073 22601 22305 23225 22401 23847 23230 22003 22191 22485 24012 23224 22554 23434 22030 23322 23707 22408 22701 24016 20109 23452 23601 22901 22624 22407 20110 24382 23005 24572 24017 24202 Anderson Financial Services, LLC LoanMax Motor Vehicle Title Lender Annual Report Response to Question 9 Corporate Name Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Anderson Financial Services, LLC LoanMax Address 1135 Richmond Avenue 447 Denbigh Boulevard 1314 North Royal Avenue 4100 W. Mercury Blvd 1224 W Broad St 1816 Peery Drive 902 W. Mercury Blvd. 4004 Walney Rd. 1361 S. Military Hwy 1051 N. Main St. 3102 Columbia Pike 4116 Lankford Hwy 3006 W. Main St. 7221 Little River Turnpike 609 E. Atlantic St. 2127 College Ave. 110 E. Stuart Dr, 7224 Columbia Pike 2401 Fairhaven Ave. 950 E. Stuart Drive 5301 Midlothian Turnpike 3505 Franklin Rd., SW DBA LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax LoanMax 7 City Staunton Newport News Front Royal Hampton Waynesboro Farmville Hampton Chantilly Chesapeake Marion Arlington Exmore Danville Annandale South Hill Bluefield Hillsville Annandale Alexandria Galax Richmond Roanoke St VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA VA Zip 24401 23608 22630 23666 22980 23901 23666 20151 23325 24354 22204 23350 24541 22003 23970 24605 24343 22003 22303 24333 23225 24014 Anderson Financial Services, LLC LoanMax Motor Vehicle Title Lender Annual Report Response to Question 10 2 8 & ^ 11 Anderson Financial Services, LLC Profit and Loss Statement For the twelve months ending December 31, 2014 © p © JS., 7 12 Anderson Financial Services, LLC Balance Sheet December 31, 2014 © © CERTIFICATE OF SERVICE I certify that on this 14th day of January, 2016,1 caused an original and fifteen copies of the foregoing to be hand-filed in the Clerk's Office of the State Corporation Commission. I also caused the foregoing to be served on the following counsel of record and persons via electronic mail: John R. Mumford, Jr. Eileen R. Geller Hancock, Daniel, Johnson & Nagle, P.C. 4701 Cox Road, Suite 400 Glen Allen, Virginia 23060 i m umford@.hdi n.com egeller@,hdin.com Molly T. Cusson Venable LLP 575 Seventh Street, N.W. Washington, D.C. 20004 mtcusson@.venable.com DeMarion Johnston Todd Rose Bureau of Financial Institutions State Corporation Commission P.O.Box 1197 Richmond, Virginia 23218 DeMarion.Johnston@scc.virginia.gov Todd.Rose@,scc. virginia.gov Peter Bale Chief Executive Officer Center for Public Integrity 910 17th Street, N.W. 17th Floor Washington, D.C. 20006 pbale@,publicintegri ty.org ^ M © © W ^