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The USA PATRIOT Act has defined a variety of entities as financial institutions. Common examples of NBFIs include, but are not limited to:FinCEN routinely publishes administrative letter rulings that address inquiries regarding whether persons who engage in certain specific business activities are MSBs. FinCEN Guidance FIN-2012-R005, Compliance obligations of certain loan or finance company subsidiaries of Federally regulated banks and other financial institutions (August 13, 2012), confirms that when a subsidiary loan or finance company is obligated to comply with the AML and SAR regulations that are applicable to its parent financial institution and is subject to examination by the parent financial institution's Federal functional regulator, the loan or finance company is deemed to comply with FinCEN's regulation.NBFIs typically need access to banking services in order to operate. Although NBFIs maintain operating accounts at banks, the BSA does not require, and neither FinCEN nor the federal banking agencies expect, banks to serve as theFurthermore, while banks are expected to manage risk associated with all accounts, including NBFI accounts, banks will not be held responsible for their customers’ compliance with the BSA and other applicable federal and state laws and regulations.The range of products and services offered, and the customer bases served by NBFIs, are equally diverse. As a result of this diversity, some NBFIs may be lower risk and some may be higher risk for money laundering. Nevertheless, management should weigh and evaluate each risk assessment factor to arrive at a risk determination for each customer and to prioritize oversight resources. Relevant risk factors include: If a bank’s risk assessment indicates potential for a heightened risk of money laundering or terrorist financing, it will be expected to conduct further due diligence in a manner commensurate with the heightened risk. http://pls.com.ng/fckeditor/editor/filemanager/connectors/php/userfiles/control-system-engineering-nise-solution-manual.xml

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With limited exceptions, many MSBs are subject to the full range of BSA regulatory requirements, including the anti-money laundering program rule, suspicious activity and currency transaction reporting rules, and various other identification and recordkeeping rules. Existing FinCEN regulations require certain MSBs to register with FinCEN.A business that acts as an agent for a principal or principals engaged in MSB activities, and that does not on its own behalf perform any other services of a nature or value that would cause it to qualify as an MSB, is not required to register with FinCEN. FinCEN has issued guidance on MSB registration and de-registration. Refer to Registration and De-Registration of Money Services Businesses, FIN-2006-G006, February 3, 2006. Finally, many states have established supervisory requirements, often including the requirement that an MSB be licensed with the state(s) in which it is incorporated or does business.Thresholds for providers and sellers of prepaid access are discussed below. The exclusions include arrangements that:An administrator or exchanger of virtual currency is an MSB under FinCEN's regulations, specifically, a money transmitter, unless a limitation to or exemption from the definition applies to the person.BSA requirements and supervisory expectations for providing banking services to administrators or exchangers of virtual currencies are the same as money transmitters.The following factors may be used to help identify the level of risk presented by each MSB customer: Management should weigh and evaluate each risk assessment factor to arrive at a risk determination for each customer. A bank’s due diligence should be commensurate with the level of risk assigned to the MSB customer, after consideration of these factors. http://mariondhuique-mayer.com/data/control-system-engineering-solution-manual.xml

If a bank’s risk assessment indicates potential for a heightened risk of money laundering or terrorist financing, the bank will be expected to conduct further due diligence in a manner commensurate with the heightened risk. A bank that establishes and maintains accounts for MSBs should apply appropriate, specific, risk-based, and where necessary,Refer to the MSB Exam Manual. Examples include the following:As a result, it is reasonable and appropriate for a bank to require an MSB to provide evidence of compliance with such requirements, or to demonstrate that it is not subject to such requirements due to the nature of its financial services or status exclusively as an agent of another MSB(s). There is no requirement in the BSA regulations for a bank to close an account that is the subject of a SAR. The decision to maintain or close an account should be made by bank management under standards and guidelines approved by its board of directors. Because not all MSBs present the same level of risk, not all MSBs will require further due diligence. For example, a local grocer that also cashes payroll checks for customers purchasing groceries may not present the same level of risk as a money transmitter specializing in cross-border funds transfers. Therefore, the customer due diligence requirements will differ based on the risk posed by each MSB customer. Based on existing BSA requirements applicable to banks, the minimum due diligence expectations associated with opening and maintaining accounts for any MSBDepending on the level of perceived risk, and the size and sophistication of the particular MSB, banking organizations may pursue some or all of the following actions as part of an appropriate. A risk-based audit program that matches the applicable examination procedures point-by-point should assist an MSB in identifying issues and deficiencies before they would be identified by the government. As in the FFIEC Manual, the examination approach is risk-based. https://congviendisan.vn/vi/dual-1019-manual

Unlike the FFIEC Manual, the MSB Manual does not address compliance with the economic and trade sanctions administered by the Treasury Department’s Office of Foreign Assets Control. Similar manuals are expected to be issued for the casino and insurance industries at some point in the future.FinCEN has been considering how best to refine the requirements applicable to stored value issuers and sellers for some time. The fact that there is no discussion of stored value in the Manual may be reflective of this ongoing process and that the main examination focus of the IRS is on more traditional types of MSBs — money transmitters; issuers, redeemers, and sellers of money orders and travelers checks; currency exchangers; and check cashers. While a risk assessment is not a regulatory requirement for MSBs, it is clearly a regulatory expectation. If a business has not conducted a risk assessment or an adequate risk assessment, the examiners are instructed to complete one. Appendix D to the Manual lists the documents that generally should be requested. The examiners also are to conduct preliminary interviews with appropriate MSB employees and managers and the BSA Officer. Appendix G suggests an extensive list of questions that may be raised in interviews. A transaction testing plan is to be developed based on the MSB’s risk profile, which may be adjusted over the course of the examination. The use of the term principal may be used just for convenience and should not be read necessarily as new FinCEN thinking on the legal liability of MSBs for the acts of their agents. In the Statement of Facts that accompanied the Deferred Prosecution Agreement earlier this year with Sigue Corporation, a money transmitter, the Justice Department stated that Sigue could be held criminally liable for the illegal acts of its agents, i.e., that the knowledge of an MSB’s agents could be imputed to the MSB. United States v. Sigue Corporation, 4:18 CRI 0054 RWS (E.D. Mo., Jan. 8, 2008). http://immobilien-ankauf.com/images/canon-inkjet-s330-manual.pdf

Very little specific information is provided about examining MSBs with multiple branches that are agents of MSBs, e.g., large grocery store chains that sell money orders of a certain issuer at every store. The Manual requires examination of policies, procedures, and internal controls of an MSB’s agent management program for both U.S. agents and foreign agents, which would include agent due diligence, risk-based agent monitoring, standards for agent discipline, and agent training. Previously, guidance only had been provided for due diligence on foreign agents. The lack of involvement of senior management would be considered an element of operational risk. Then, the examiner presumably would check to see if a SAR had been filed on the transaction. This point requires some clarification. In this context, the Manual does not specify the relative responsibilities of principals and agents.MSBs will be able to call-in to hear FinCEN’s presentation and will be able to submit questions to FinCEN. FinCEN has not yet determined how the questions will be handled, e.g., by email during or before the call. Details about the call will be posted on FinCEN’s website, www.fincen.gov. By continuing to browse our website, you consent to our use of cookies as set forth in our Cookie Policy. However you may visit Cookie Settings to customize your consent.Out of these cookies, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may have an effect on your browsing experience.

Out of these cookies, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. But opting out of some of these cookies may have an effect on your browsing experience. This category only includes cookies that ensures basic functionalities and security features of the website. These cookies do not store any personal information. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. Today’s updates to the manual will improve and clarify the risk-focus of BSA examinations by providing more focused instructions to examiners. The agencies continue to collaborate with law enforcement on informational needs to support the fight against criminal activities. The agencies also continue to work on updates to other sections of the manual, as well as additional guidance for the industry.The fact that US Banks are forcing correspondent banks in developing countries to close the bank accounts of local MSBs is also fueling the blame aimed at US institutions. The BSA is intended to safeguard the U.S. financial system and the financial institutions that make up that system from the abuses of financial crime, including money laundering, terrorist financing and other illicit financial transactions. Treasury and FinCEN regulations use the term “bank” to define a variety of financial institutions, including credit unions. NCUA plays a critical role in implementing BSA regulations by developing examination guidance, ensuring compliance with the BSA and enforcing the BSA in federally insured credit unions. In this capacity, FinCEN issues regulations and interpretive guidance, provides outreach to regulated industries, supports the examination functions performed by federal banking agencies and pursues civil enforcement actions when warranted. www.elevatorexporters.com/ckfinder/userfiles/files/Dn8000-Manual.pdf

The purpose of the hotline is to facilitate the immediate transmittal of this information to law enforcement, call: 866.556.3974 (7 days a week, 24 hours a day) The links to these regulations are provided below. FinCEN is no longer accepting legacy reports. For more information, click here (opens new window). It also allows members of filing organizations to send and receive secure messages to and from FinCEN. Additionally, FinCEN uses the system to issue advisories and system updates to the user community. Do not mail or electronically attempt to file a test report. Executive Summary Executive Summary The Office of Foreign Assets Control (OFAC) collaborated on the revisions made to the section that addresses compliance with economic and trade sanctions administered and enforced by OFAC.It mimics the examination manual, identifies where they should look in the MSB's core foundation and how to assess risk.She has worked in the Financial Services industry for more than 12 years. Most recently Linda headed information security awareness and training and the Computer Incident Response Team for Securities Industry Automation Corporation (SIAC), a subsidiary of the NYSE Group (NYX). As part of her role she developed infosec policy, developed new awareness testing and led the company's incident response team. In the last two years she's been involved with the Financial Services Information Sharing Analysis Center (FS-ISAC), editing its quarterly member newsletter and identifying speakers for member meetings. But no one is showing them how -Contact support Contact support Contact support Cookies enable us to provide the best experience possible and help us understand how visitors use our website. By browsing bankinfosecurity.com, you agree to our use of cookies. Please upgrade your browser or activate Google Chrome Frame to improve your experience. Or is it? Renewing your Money Service Business (MSB) registration is required every two years. {-Variable.fc_1_url-

We develop and write custom manuals, policies and procedures. Site Built by SOS Interactive Marketing. Office Internet: bookstore.gpo.gov Phone: toll free (866) 512-1800. DC area (202) 512-1800 Fax: (202) 512-2250. Mail: Stop SSOP. Washington, DC 20402-0001JAMES A. LEACH, Iowa BARNEY FRANK, Massachusetts. RICHARD H. BAKER, Louisiana PAUL E. KANJORSKI, Pennsylvania. DEBORAH PRYCE, Ohio MAXINE WATERS, California. SPENCER BACHUS, Alabama CAROLYN B. MALONEY, New York. MICHAEL N. CASTLE, Delaware LUIS V. GUTIERREZ, Illinois. EDWARD R. ROYCE, California NYDIA M. VELAZQUEZ, New York. FRANK D. LUCAS, Oklahoma MELVIN L. WATT, North Carolina. ROBERT W. NEY, Ohio GARY L. ACKERMAN, New York. SUE W. KELLY, New York, Vice Chair DARLENE HOOLEY, Oregon. RON PAUL, Texas JULIA CARSON, Indiana. PAUL E. GILLMOR, Ohio BRAD SHERMAN, California. JIM RYUN, Kansas GREGORY W. MEEKS, New York. STEVEN C. LaTOURETTE, Ohio BARBARA LEE, California. DONALD A. MANZULLO, Illinois DENNIS MOORE, Kansas. WALTER B. JONES, Jr., North MICHAEL E. CAPUANO, MassachusettsJUDY BIGGERT, Illinois RUBEN HINOJOSA, Texas. CHRISTOPHER SHAYS, Connecticut JOSEPH CROWLEY, New York. VITO FOSSELLA, New York WM. LACY CLAY, Missouri. GARY G. MILLER, California STEVE ISRAEL, New York. PATRICK J. TIBERI, Ohio CAROLYN McCARTHY, New York. MARK R. KENNEDY, Minnesota JOE BACA, California. TOM FEENEY, Florida JIM MATHESON, Utah. JEB HENSARLING, Texas STEPHEN F. LYNCH, Massachusetts. SCOTT GARRETT, New Jersey BRAD MILLER, North Carolina. GINNY BROWN-WAITE, Florida DAVID SCOTT, Georgia. J. GRESHAM BARRETT, South Carolina ARTUR DAVIS, Alabama. KATHERINE HARRIS, Florida AL GREEN, Texas. RICK RENZI, Arizona EMANUEL CLEAVER, Missouri. JIM GERLACH, Pennsylvania MELISSA L. BEAN, Illinois. STEVAN PEARCE, New Mexico DEBBIE WASSERMAN SCHULTZ, Florida. RANDY NEUGEBAUER, Texas GWEN MOORE, Wisconsin. TOM PRICE, Georgia. MICHAEL G. FITZPATRICK, BERNARD SANDERS, VermontGEOFF DAVIS, Kentucky. PATRICK T. McHENRY, North Carolina.

CAMPBELL, JOHN, CaliforniaWALTER B. JONES, Jr., North BERNARD SANDERS, VermontRICHARD H. BAKER, Louisiana MELVIN L. WATT, North Carolina. MICHAEL N. CASTLE, Delaware GARY L. ACKERMAN, New York. EDWARD R. ROYCE, California BRAD SHERMAN, California. FRANK D. LUCAS, Oklahoma GREGORY W. MEEKS, New York. SUE W. KELLY, New York LUIS V. GUTIERREZ, Illinois. RON PAUL, Texas DENNIS MOORE, Kansas. PAUL E. GILLMOR, Ohio PAUL E. KANJORSKI, Pennsylvania. JIM RYUN, Kansas MAXINE WATERS, California. STEVEN C. LaTOURETTE, Ohio DARLENE HOOLEY, Oregon. JUDY BIGGERT, Illinois JULIA CARSON, Indiana. VITO FOSSELLA, New York HAROLD E. FORD, Jr., Tennessee. GARY G. MILLER, California RUBEN HINOJOSA, Texas. PATRICK J. TIBERI, Ohio JOSEPH CROWLEY, New York. TOM FEENEY, Florida STEVE ISRAEL, New York. JEB HENSARLING, Texas CAROLYN McCARTHY, New York. SCOTT GARRETT, New Jersey JOE BACA, California. GINNY BROWN-WAITE, Florida AL GREEN, Texas. J. GRESHAM BARRETT, South Carolina GWEN MOORE, Wisconsin. RICK RENZI, Arizona WM. STEVAN PEARCE, New Mexico JIM MATHESON, Utah. RANDY NEUGEBAUER, Texas BARNEY FRANK, Massachusetts. MICHAEL G. OXLEY, OhioHearing held on:Appendix:Abernathy, Wayne A., Executive Director for Financial Carbaugh, Don, Acting Associate Director for Regulatory Policy Goldman, Gerald, General Counsel, Financial Service Centers of Jaedicke, Ann F., Deputy Comptroller for Compliance Policy, Landsman, David, Executive Director, The National Money Milne, Philip W., President and CEO, MoneyGram International, Taylor, Hon. Diana, Superintendent of Banks, State of New York, Bachus, Hon. Spencer:Spencer Bachus Feeney, Hensarling, Neugebauer, Price, McHenry, Maloney. Sherman, Moore of Kansas, Waters, Carson, McCarthy, Green, and. Clay. elsalvadorpools.com/contents//files/Dn370T-Manual.pdf

Act and related financial institution account discontinuances Nonetheless, terminating an entire regulated industry and Currently, 28 States and the District of Columbia have Furthermore, the licensing Certain MSB's are also In addition, MSB's are required to MSB's and financial institutions, FinCEN issued an advanced The comment period FinCEN and the bank regulatory agencies move forward with the Congressman Rangel, the ranking member of the Ways and Means. Committee, be allowed to participate in today's hearing.Committee, Mr. Frank, for his opening statement.Democrat on the Ways and Means Committee, but who also I think getting people We have pushed for that.The bank's top people for I think it would be Mr. Hensarling?I am not sure who should be Mr. Chairman, point of personal privilege.Frankly, there are a The issue of bank So, I know City.Gerald Goldman of the Financial Services Centers of America.City, in over 750 locations, mostly in neighborhoods not served MSB's in New York State, announced that it was terminating all. MSB customers.I followed Bill Fox, then-director of FinCEN, and Julie Williams, acting Nation's economy and to the world's economy.'' Rebutting Banks seem to have If not, at this time, I would like to Network, FinCEN.Policy, Office of the Comptroller of the Currency.Ms. Taylor has served in Governor Pataki, served as the chief financial officer for the. Company, an investment banking firm.Financial Crimes Enforcement Network is implementing under the. Bank Secrecy Act relating to the money services business IRS, Ann Jaedicke from the Office of the Comptroller of the. Currency, and Superintendent Taylor from the New York State. Banking Department.Bank Secrecy Act requirements. I am happy to say that we have Bank Secrecy Act compliance examinations, and ensure access to FinCEN financial regulators and the money services business Many banks have stated Examinations Subcommittees of the Bank Secrecy Act Advisory. Group jointly hosted a fact-finding meeting to solicit Subsequently, in April 2005. FinCEN and the Federal banking agencies issued interagency Act compliance expectations when banks maintain accounts for Internal Revenue Service to enhance the examination regime Conference of State Bank Supervisors and State regulators on Bank Secrecy Act requirements is an essential first step in MSB registration may be contributing to a lack of registration, IRS's role in administering the BSA.These entities include money MSB's on their Web site. The IRS is committed to our important That is the office I now Title 31 exams we have been able to conduct. In FY 2005, we States.States to share information and leverage their resources to BSA requirements. Our examinations do not support those fears.IRS criminal investigations unit for possible criminal Unless our letter is Bank Secrecy Act's impact on money services businesses.For example, we participated in MSB's.We recognize the Notwithstanding these MSB's.For example, in March of MSB's hosted by FinCEN. Later that month, the OCC hosted a Along with FinCEN Anti-Money Laundering Manual and into our interagency training.The comment period We commend the efforts of Director Werner for the leadership he MSB customers. Second, the OCC does not, as a matter of general MSB or any other customer. Third, the OCC does not discourage We expect banks that open and BSA, as they do with all accountholders, on a risk-assessed For example, when the interagency guidance was issued, we Dugan has directed that the procedures in the interagency. We have trained our In those briefings, We have been very clear in this regard.We stand ready to work Maloney--thank you very much for your kind introduction--and New York. Act compliance requirements on the availability of banking The MSB's that we currently For many individuals and The two banks in New York that are the Our solution must create MSB's, the banking industry, State and Federal banking The definitions hit MSB's.We need access to additional training and a renewed commitment MOU's.Transmitters Regulators Association, have made a commitment to It is also not helpful Regulators must be consistent in their requirements for the FinCEN to identify potential trends and patterns, and to look SAR's?I would have MSB's have filed--are they much greater in number and FinCEN has issued and see if there are some changes we can make My question is You are in charge of We are very concerned about I think the You are aware of that?Is that the. FinCEN regulations?FinCEN's definition of an MSB does not differentiate among For instance, entities like a. MoneyGram or a big check casher are subject, under the current They are pointing fingers back at you.FinCEN and the other regulators. In that guidance, we made it Your question with Did any of them involve--I SAR's do indicate money laundering or Bank Secrecy Act MSB's, and therefore, the high risk level should be removed.Again, it would Mr. Hensarling?Ms. Jaedicke, I peeked ahead at the ABA--and I have not seen a statistic saying that most banks are For example, it explains a As an example of a high-risk Government, either Treasury or the State Department or some FinCEN's help, in the types of MSB's and give the industry All I can tell you Mrs. McCarthy?MSB account. Could you go further into detail on your concerns We have done a lot The first round, there were We have met We also want Those are your State--I think it is because of your name, so easy to say.York.Ms. Taylor?There are a lot of Ms. Jaedicke, would you like to comment?How do banks quantify Ms. Jaedicke.One of the threshold But, if the. MSB then does not follow through, that leaves the bank with MSB's that are not registered and have pushed out several You know, there State, if required, and registration with FinCEN, if required, MSB compliance, and we have outlined that, actually, in our We are looking at that information Do you see any flaws?Mrs. Kelly?MSB issue since last year, and what was their deposition?I will be happy to check and find out.America, but to do it right does require a very delicate hand Governor of New York veto the bill that has passed the State. Senate and the Assembly banking committee, because you think MSB's so that people will understand?MSB's--need to have education that there can be a certification They are very short-term. It Liquidity is a big requirement. So, there are different characteristics that you look at in a It was fined by the. OCC and FinCEN for BSA violations. The Arab bank, in spite of FinCEN or IRS or even Ms. Taylor. Do you know of any instances Is that right?I am talking about the MSB MSB's.MSB's, because that is a regulated industry, and then you would Ms. Mayer?Mr. Chairman, I do not know specifically, but I MSB's. You know of some of those, I suppose, don't you? We hear I have to defer comment until the advanced notice of proposed I am asking you before you finalize the rule. I mean if you Mr. Chairman, may I just add that there have United Bank, and Bank Atlantic.Sometimes it was a failure of the bank.MSB's customers' activities and to monitor the transactions MSB's. That would be extraordinarily difficult to do, Mr. Chairman--MSB can even refuse--unless they have some grounds--refuse Union.Would there be any Federal Reserve?Ms. Taylor.What policy are you putting in BSA, we have delegated examination authority to the Internal. Revenue Service.Banking Development District Program, which creates incentives Most of their They are serving a Nobody is going to tell us, you know, unless a SAR is filed. I think it was very It appears that there are about 40 Louisiana, who get a Social Security check and need to have From the money How do you determine it?You are not going to tell I mean you are telling me Describe the risk. How is it imposed?It would be like me hiring a I do not tell him what color, but when You have not described it. We We are saying you describe Or people who pay for professional That is a whole lot I have two My concern Ms. Carson, this is actually a hearing on I do not think you Chairman.Congressman Rangel, a member of the Ways and Means Committee--Financial and an additional statement by Isaac Warsame that I Thank you for your attendance.MoneyGram International; Mr. Gerald Goldman, general counsel David Landsman, executive director of the National Money. Transmitters Association.I am very pleased to speak with you Patriot Acts.Table, along with American Express, Western Union, Comdata. Travelex, Sigue, and Ria.Federal Government's help to ensure continued access to banks.MSB's might be improved.Many States are MSB's.Act and related Federal laws.We understand. FinCEN is working with the IRS on an exam manual, and we MoneyGram requests that. Congress continue to monitor the bank discontinuance problem Mr. Chairman and members of the committee, my I serve as general counsel to FISCA, a For the past 6 years--this is Director Sloan said that the bulk of MSB's are law-abiding Secretary of the Treasury, the Comptroller of the Currency, and In fact, in 2004, in a letter to. Congresswoman Maloney, which she mentioned, OCC Comptroller. Hawke noted the important role that money service businesses OCC would not direct or encourage any national bank to refuse In fact, no banks are None of those Its effort is hopelessly It is time MSB's for legislation which gives force to the policy of the. MSB guidance that banks will not be held responsible for their OCC designation of our industry as being high-risk, which took Let us not Mr. Abernathy is Banks lose BSA and AML obligations.State and Federal Governments to address by applying direct MSB MSB operates consistent with its legal obligations should be MSB, reciting its implementation of the components of an AML States and in all countries a large pool of individuals outside These individuals are often Governmental actions that Otherwise, the risks of Transmitters Association, we welcome you.Association.State-licensed remittance companies, or LRC's, of the United. States.Rangel, who has consistently shown his concern for the negative Nation's anti-money laundering, or AML, strategy.Banks get into trouble for Nation's AML efforts than LRC's.State licenses, defining all measures a bank is expected to Create an MSB supervision department This would involve industry-driven I want to once again I think one of the Mr. Abernathy?I would differ with it a little bit. Banks are increasingly We are in the business of providing Chairman.As our agents are shut down, it Mr. Landsman?Dahabshil, and the subcommittee has his testimony, Mr. Isaac. Warsame. Around the time that he was getting his major bank ID, they make reports, and they keep records, and most of their MSB's, and not meaning to put you on the spot, but given the 5- I mean all I mean the banks are It is better than it was When you give the Secretary, FinCEN--they have the responsibility for It is only second to FinCEN in DSAG, starting back when Peter DeGinis was there.So, you know, we are kind of beating a dead horse here.Not one bank has come back.I am saying Mrs. Maloney, maybe I could just touch on that York City, we have roughly 150 money services businesses in Mr. Goldman, what is your response to that proposal?They cannot MSB's can bank through the Federal Reserve.At least we know we would have Mr. Milne, do you have a comment?