EIGHTEENTH JUDICIAL CIRCUIT COURT BREVARD COUNTY, STATE OF FLORIDA RESIDENTIAL FORECLOSURE MEDIATION PROGRAM MANAGER REQUEST FOR PROPOSAL RFP # 2010-01

Proposal Submission Deadline: MONDAY, MAY 3, 2010 1:00 P.M. EASTERN TIME

EIGHTEENTH JUDICIAL CIRCUIT BREVARD COUNTY, STATE OF FLORIDA REQUEST FOR PROPOSAL (“RFP”) #2010-01 RESIDENTIAL FORECLOSURE MEDIATION PROGRAM MANAGER

INSTRUCTIONS FOR SUBMITTING PROPOSALS

PROPOSAL SUBMISSION All proposals shall be submitted no later than 1:00 p.m. (Eastern Time) on Monday, May 3, 2010. Proposals received after this deadline will not be accepted. Bidders shall provide one original (marked “Original”) and five copies to: Deborah Haataja-Deratany, Administrator Moore Justice Center – 3rd Floor 2825 Judge Fran Jamieson Way Viera, FL 32940 The package containing the proposals must be sealed and identified with “RFP# 2010-01, RESIDENTIAL FORECLOSURE MEDIATION PROGRAM MANAGER.” It is the sole responsibility of the bidder to ensure that sealed proposals are received before the submission date. The bidder shall be responsible for all risks for any delays associated with delivery service or U.S. Mail.

INQUIRIES/AVAILABILITY OF DOCUMENTS All inquiries concerning this RFP must be in writing via fax, mail, or electronic mail. All inquiries must include name of bidder, address, phone number, fax number, email, and contact person. Telephone inquiries will not be accepted. RFP documents are available for review by prospective bidders. Requests to view documents and all inquiries should be directed to: Deborah Haataja-Deratany, Administrator Moore Justice Center – 3rd Floor 2825 Judge Fran Jamieson Way Viera, FL 32940 FAX: 321-633-2172 Email inquiries must include the subject line “Residential Foreclosure Program Manager” and be sent to: [email protected]

MODIFICATIONS TO RFP Any clarification or additional information that may substantially affect the outcome of this RFP will be provided in the form of a written addendum. All addenda will be posted on the Eighteenth Judicial Circuit’s website at http://www.flcourts18.org/foreclosures_brevard.html.

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EIGHTEENTH JUDICIAL CIRCUIT BREVARD COUNTY, STATE OF FLORIDA RESIDENTIAL FORECLOSURE MEDIATION PROGRAM MANAGER REQUEST FOR PROPOSAL RFP # 2010-01

I.

PURPOSE

The Eighteenth Judicial Circuit (“Court”), through the Office of Court Administration, seeks proposals from qualified program managers (“PM’s”) for the purpose of managing mediations in mortgage foreclosure cases. The PM will coordinate its efforts in communication with the Trial Court Administrator or his designee in Court Administration. The Court will select and negotiate with the qualified PM’s whose competitive proposals are responsive to this RFP. The Court reserves the right to accept or reject any and all proposals, in whole or in part, or to waive any informality, and to base all conclusions, decisions, and actions on what is deemed to be in the best interest of the Court and the State Court System.

II.

BACKGROUND

Residential mortgage foreclosure case filings have increased substantially in the 18th Judicial Circuit, and state and county budget constraints have limited the ability of the courts in the 18th Judicial Circuit to manage these cases in a timely manner The Supreme Court of Florida had convened a Task Force to study the mortgage foreclosure crisis in Florida, and make recommendations on how the State Court System may be responsive to the crisis. The Supreme Court has determined that mandatory mediation of homestead residential mortgage foreclosure actions prior to the matter being set for final hearing will facilitate the laudable goals of communication, facilitation, and problem-solving between the parties with the emphasis on self-determination, the parties’ needs and interests, procedural flexibility, full disclosure, fairness, and confidentiality. Referring these cases to mediation will also facilitate and provide a more efficient use of limited judicial and clerk resources in a court system that is already overburdened. A Program Manager (“PM”) will be selected as an independent entity that has demonstrable ability to assist the courts with managing the large number of residential homestead mortgage foreclosure actions that have recently been filed in the 18th Judicial Circuit.

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III.

SCOPE OF SERVICES A. GENERAL SERVICES The PM shall provide a comprehensive response to homestead residences mortgage foreclosure cases by fully managing the mediation process for parties involved in residential mortgage foreclosure litigation. Additionally, the PM shall also provide other foreclosure mediation services as requested by the Court. The PM shall be fully compliant with all requirements as set forth in the Florida Supreme Court Administrative Order AOSC09-54. It is the sole responsibility of the PM to ensure compliance for the entire duration of any contract issued for the performance of these services. B. SPECIFIC SERVICES The PM will provide and manage all services as described in the Supreme Court AOSC09-54, to include but not be limited to, the following services:

1. Receive mediation referrals, and within designated time limit, schedule and coordinate mediations, reserve and provide venues for mediation and caucus, manage continuances and re-scheduling; 2. Maintain financial books and records to insure transparency and accuracy of receipts and expenditures; 3. Prepare financial statements, financial and performance reports, for example, attendance and failure to attend mediation reports; 4. Establish and maintain performance standard for staff and mediators, including maintaining a roster of mediators comprised of persons who are properly trained in accordance with the attached, and who are otherwise qualified, and effective in foreclosure mediation; 5. Assist in specialized training for workout options and resources; 6. Arrange and pay interpreters; 7. Bill, collect, deposit and disburse mediation fees and refunds; pay for necessary services and costs incidental to mediation managing as required to implement mediation administrative order; 8. Establish procedures for managing and communicating with pro se litigants and attorneys. This includes implementing a process for prompt outreach to borrower-owners immediately after suit has been filed; the goal of the outreach is to inform mortgagors about the mediation program, invite their participation, and to start the process of referral to consumer debt counseling and the collection of required financial information; 9. Establish procedures for complying with confidentiality rules; 10. Establish a system for managing mediators that: a. Provides for the impartial assignment of mediators, for example, by the use of a rotating list; b. Is open to qualified Supreme Court Certified Mediators who are capable of providing effective services in the residential foreclosure setting; c. Allows for more than one mediation managing entity in the circuit if approved by the Chief Judge; 11. Monitor or supervise the preparation of mediation settlement agreements; 12. Establish the schedule for division of fees between mediators, managers and others; 13. Prepare operational reports as required by the chief judge, regarding number of cases mediated, impasse or successful mediations, etc.; 14. Solicit qualified mediators and maintain current list of mediators available for residential foreclosure cases; 15. Establish procedures for disqualifying and replacing mediators with ethical or other conflicts; 16. Coordinate the referral of mortgagors to certified credit counselors pre-mediation; 17. Refer unrepresented parties to legal aid, or panels of pro bono or reduced fee attorneys; 18. Facilitate the exchange of documents between the parties, pre and post mediation, including the establishment and maintenance of a secure web-based internet communication system 4

19. 20. 21. 22. 23. 24.

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between the mediation manager and all parties to mediation using a platform capable of transmitting financial data, email, mediation forms and attachments, and able to track participant payments and refunds; Maintain for dissemination to owner-borrowers a list of approved foreclosure counselors willing to perform services at the rates established by the court; Answer inquires from mediators and parties regarding the mediation process and forms Establish a system for resolving grievances against mediators and other persons involved in the Residential Foreclosure Mediation Manager program; Establish procedures for participant evaluation of mediation program services, including satisfaction surveys; Develop the forms and procedures necessary to verify compliance with the residential foreclosure mediation program by the lender/servicer representatives, their attorneys and borrowers. Review and comply with applicable administrative orders issued by the Florida Supreme Court and the 18th Judicial Circuit Court. Comply with data collection requirements as defined by the Court, including but not limited to, providing a monthly list of the rotation and/or assignment of mediators to cases and case outcomes.

D. MINIMUM REQUIREMENTS OF THE PM 1. Compliant with ADR principles as promulgated by the Supreme Court, ADR statutes and rules; 2. Non-profit entity, or associated with a reputable organization of proven competence, autonomous and independent of the judicial branch; 3. Capable of efficient administration of large case loads; 4. Sensitive to cultural, diversity and ADA issues; 5. Politically and professionally neutral; 6. Knowledgeable of court procedures, current trends, laws, rules, and regulations affecting residential foreclosures; 7. Fiscally transparent and accountable; 8. Quickly adaptable to a dynamic and rapidly evolving legal environment; 9. Financially stable; 10. Capable of sustained operation without fiscal impact on the courts; 11. Capable of effectively implementing information technology systems and web-based programs; 12. Alert to ethical and confidentiality issues; 13. Agreeable to acting as manager for voluntary pre-suit mediation 14. Responsible for all costs associated with obtaining case information from the Clerk of Court or other sources. 15. Provides a venue to conduct all mediations in Brevard County 16. As applicable and appropriate, makes referrals for borrowers to obtain assistance from Legal Aid 17. If PM offers foreclosure training, they shall not mandate that mediators train with them as a condition of being included on the PM’s mediator rotation list

E. PAYMENT Payments shall be consistent with the Supreme Court Administrative Order AOSC09-54. The PM will operate separate and apart from the state courts system. There will be no financial impact to the courts.

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F. SCHEDULE This project is expected to begin no later than June 1, 2010. If the Court determines, at its sole discretion, that it is necessary to change any of these dates and times, notice of such change will be disseminated in the same manner as the initial RFP. Issue RFP April 8, 2010 Bidders’ Conference (Optional) April 16, 2010 1:00-2:00 p.m. (ET) Location: Moore Justice Center, 2825 Judge Fran Jamieson Way, Viera, FL 32940 Courtroom 2A Proposals Due May 3, 2010 at 1:00 p.m. (ET) Bidders’ Presentation (at Court’s discretion) Week of May 10, 2010 Intent to Award May 17, 2010 Program Start Date June 1, 2010

G. SELECTION CRITERIA All competitive proposals will be evaluated with respect to the completeness of data provided, support for all claims made, and the overall approach taken. At the Court’s sole discretion, one or more successful bidders may be chosen. The following factors will be used to evaluate the proposals: 1. Management and scheduling system to be used to coordinate mediations. 2. Financial history of proposing entity, including the current state of solvency and stability. 3. Performance standards used to assess the quality of mediator and counselor services, including under what conditions, and through what method, roster disqualifications would occur. 4. The manner in which mediators and counselors would be assigned to specific cases, including what system would be used to recruit and select mediators. 5. Compliance with monthly data collection and reporting as defined by applicable documents, including reporting the mediator rotation and assignment as requested by the Court. 6. Schedule for division of fees between mediators, managers, and others. 7. Facilities that bidder will use, including the number of locations and thresholds for quality and scheduling availability; and the presence of a local office within Brevard County. 8. Communication technology that bidder will use, including capability to use a secure dedicated email address or a web-enabled information platform with XML data elements.

H. RESTRICTIONS ON COMMUNICATIONS WITH COURT PERSONNEL Bidders shall not lobby for a contract or communicate with any State Court System personnel, including Judges and Judicial Assistants, concerning this RFP, except for the contact person identified on Page 2. Violation of this requirement may result in rejection of the submitted proposal and disqualification of the bidder.

I. PROPOSAL EXPENSES Bidder shall be solely responsible for all expense incurred in the preparation of its proposal. Under no circumstances shall the Court be responsible for any such expense.

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J. PROPOSAL EXAMINATION AND ERRORS Bidder shall carefully make all necessary investigations in order to be thoroughly informed as to all aspects of the services to be rendered pursuant to the requirements of this RFP. No pleas of ignorance or mistake as to conditions or difficulties that may be encountered in the services to be rendered will be accepted, nor will they be accepted as a basis for any claims whatsoever for compensation. The bidder is solely responsible for reading and completely understanding the requirements of this RFP and all applicable and referenced documents. The successful bidder(s) shall be required to execute an agreement substantially consistent with the content of this RFP. Where the proposal has erasures or corrections, each correction must be in ink and initialed in ink by an authorized representative of the bidding entity. Any blank spaces, qualifying notes, exceptions, counteroffers, and/or lack of required submittals may cause the bidder to be declared non-responsive.

K. WITHDRAWAL, TRANSFER, OR MODIFICATION OF PROPOSAL Proposals may be withdrawn via a written and signed request received by the contact person listed on Page 2 of this RFP, provided the request is received prior to the proposal deadline. All proposals shall remain in full force and effect for a period of forty-five (45) calendar days after the proposal deadline and shall not be revoked, withdrawn, or canceled within that time frame. The award of a contract shall not nullify this requirement. The bidder may not assign or otherwise transfer its proposal prior to or after the proposal deadline. The bidder shall not modify its proposal after the proposal deadline for any reason, unless the Court modifies its requirements.

L. SUBCONTRACTING A vendor who elects to sub-contract any part of this project will be fully accountable for subcontractor’s responsibilities and deliverables. Vendor will define the subcontractor’s scope of work as strictly defined in Section C.

M. PROPOSAL CONTENT Proposals shall not exceed 25 pages in length, exclusive of required forms or attachments, and contain, at a minimum, the following information: 1. Bidder Information a. Bidder’s official business name, address (both physical and mailing), telephone and fax numbers; type of business such as sole proprietorship, partnership, or corporation, including the state of incorporation; b. Length of time in business; c. Location(s) of business operations; d. Firm’s qualifications; e. Qualifications and experience of corporate officer(s) and/or key personnel; f. Evidence of meeting qualification requirements set forth herein; 7

2. Statement of understanding – Include a statement indicating an understanding of the project and all requirements. 3. Quality Assurance – Include the firm’s statement of commitment to quality assurance. 4. Conflict Disclosure – Include the names(s) of any employee or officer of the Florida State Courts System who owns, directly or indirectly, an interest of 5% or more in the firm. Also, include the names(s) of any employee, officer, or agent of the firm that has any conflict of interest associated with this project. 5. References – Include the name, address, and telephone number of at least (3) clients for whom similar services are performed. 6. Financial Information – If requested by the Court, bidder must provide financial information for the business and/or principals which validate the bidder’s solvency and/or financial stability. 7. Mandatory Cover Sheet – Bidder must provide information requested on this Cover Sheet, which is Appendix A of this RFP. 8. Sworn Statement on Public Entity Crimes – Statement is in accordance with Section 287.133(3)(A), Florida Statutes, on public entity crimes and is attached as Appendix B.

N. EVALUATION OF PROPOSALS AND PROPOSAL REVIEW COMMITTEE Selection criteria are contained in this RFP, and these criteria will be used to determine the best proposal. Oral presentations may be requested of any or all bidders for purposes of clarification. The Court reserves the right, at its sole discretion, to determine a bidder’s ability to perform in accordance with the requirements, terms and conditions of this RFP. The Court reserves the right to reject any or all proposals, award on a “none or all basis”, multiple awards, negotiate the award, make no award and/or proceed with whatever proposal the Court deems to be in its best interest. A review committee will be appointed by the Chief Judge of the Eighteenth Judicial Circuit Court to evaluate all proposals. The Review Committee reserves the right to request interviews of any or all respondents, as necessary, toward a fair and equitable proposal evaluation. The chief judge or his designee will make the award.

O. AWARD OF CONTRACT/REJECTION OF PROPOSALS Any contract to be awarded shall be awarded to the responsive bidder(s) whose proposal indicates that the award will be in the best interests of the Court. The Court reserves the right to reject any and all proposals, the right to waive any and all formalities, the right to disregard any nonconforming, nonresponsive, or conditional proposal and the right to make modifications to any proposed contract. The Court reserves the right to reject any proposal if it believes it would not be in the best interests of the Court. Nothing contained in this RFP shall preclude the Court of awarding a contract to multiple bidders. Additionally, nothing shall require the Court to award a contract or reject proposals based upon anything than its sole discretion. By submitting a proposal, the bidder recognizes and accepts that the Court may reject the proposal based upon the exercise of its sole discretion. The bidder waives any claim it may have for damages or other relief resulting directly or indirectly from the rejection of its proposal based upon these grounds, including the disclosure of any pertinent information relating to the reasons for rejection of the proposal.

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The successful bidder will be notified via fax and telephone. This information will also be posted on the Eighteenth Judicial Circuit Court website at http://www.flcourts18.org/foreclosures_brevard.html. The successful bidder shall sign a written contract which will be substantially consistent with the content of this RFP. The contract must be signed by the successful bidder within seven (7) calendar days of receipt of the contract from the Court. If it fails to do so, the award may be withdrawn by the Court; and the Court may award the contract to any other bidder at its sole discretion.

P. APPLICABLE DOCUMENTS AND GENERAL CONTRACT CONDITIONS All proposals must be fully compliant to following documents, incorporated by reference: A. Florida Supreme Court Administrative Order AOSC09-54 http://www.floridasupremecourt.org/pub_info/documents/AOSC09-54_Foreclosures.pdf B. 18th Judicial Circuit-Brevard County Administrative Order No. 10-09-B http://www.flcourts18.org/PDF/Foreclosures_Brevard/10-09-b.pdf C. Florida Rules of Civil Procedure, Revised February 11, 2010 http://www.floridasupremecourt.org/decisions/2010/sc09-1460.pdf D. Florida State Courts System – General Contract Conditions for Services, effective 6/11/09, excluding item #2-Invoicing and Payment.

http://www.flcourts.org/courts/crtadmin/bin/gcc_services_02-16-10.pdf E. Sworn Statement Under Section 287.133(3)(A), Florida Statutes, on Public Entity Crimes – Appendix B of this RFP

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Appendix A

EIGHTEENTH JUDICIAL CIRCUIT MANDATORY COVER SHEET FOR RESPONSES TO RFP #2010-01 Name of Program Manager Bidder: Federal ID: Address: Email: Telephone/Fax: Contact Person: 1.

2.

3.

4.

5.

6.

7.

8. 9.

Describe management and scheduling system to be used to coordinate mediations, within designated time limits. Indicate technology to be used and experience managing such systems. Preference will be given to systems with ability to best measure deadline performance. Describe the financial history of the proposing entity, including current state of solvency. Indicate the methods and technology used to maintain financial books, prepare financial statements, and manage mediation fees and refunds. Preference will be given to bidders that are solvent and financially stable. Describe the manner in which performance standards will be used to assess the quality of mediator and counselor services, including under what conditions, and through what method, roster disqualifications would occur. Preference will be given to proposals that provide specialized training related to workout options and assess the quality of service provided at each event, including complaint resolution. Describe the manner in which mediators and counselors would be assigned to specific cases, including what system would be used to recruit and select mediators. Additionally, what method would be used to create and maintain a current roster of mediators. Preference will be given to bidders that establish a fair rotation of mediators. Describe the bidder’s schedule for division of fees between mediators, managers, and others. Indicate how due process considerations (unrepresented parties, interpreters, etc.) will be managed. Preference will be given to bidders demonstrating economic efficiency and effectiveness. Describe the facilities that bidder will use, including the number of locations and thresholds for quality and scheduling availability. Indicate if there will be a local office, and if not, where the closest office will be located. Preference will be given to bidders with a local office and multiple facilities throughout the circuit. Describe the nature of the communication technology that bidder will possess, including capability to use a secure dedicated email address or web-enabled information platform with XML data elements. Detail method that bidder will use to answer inquiries from parties, coordinate referrals, communicate with pro se litigants, refer unrepresented parties to legal aid, and comply with confidentiality rules. Preference will be given to bidders that provide technical specifications with regard to communications technologies. Indicate the time required for the bidder to be fully operational. If additional time beyond the estimated start date of June 1, 2010, is required, please provide explanation. Describe the type and nature of specialized training of mediators that bidder plans to offer, if any. Additionally, provide details of the selection process used to select all trainers to be used for mandatory foreclosure mediation training.

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Appendix B RESIDENTIAL FORECLOSURE MEDIATION PROGRAM RFP# 2010-01 SWORN STATEMENT UNDER SECTION 287.133(3)(A), FLORIDA STATUTES, ON PUBLIC ENTITY CRIMES THIS FORM MUST BE SIGNED AND SWORN TO IN THE PRESENCE OF A NOTARY PUBLIC OR OTHER OFFICER AUTHORIZED TO ADMINISTER OATHS. 1. This sworn statement is submitted to the Eighteenth Judicial Circuit, Brevard County, by ______________________________________(print individual’s name and title) for ______________________________________ (print name of entity submitting sworn statement) whose business address is ________________________________ and (if applicable) its Federal Employer Identification Number (FEIN) is _____________. (If the entity has no FEIN, include the Social Security Number of the individual signing this sworn statement: ________________________ .) 2. I understand that a “public entity crime” as defined in paragraph 287.133(1)(g), Florida Statutes, means a violation of any state or federal law by a person with respect to and directly related to the transaction of business with any public entity or with an agency or political subdivision of any other state or of the United States, including, but not limited to, any bid, proposal, reply or contract for goods or services, any lease for real property, or any contract for the construction or repair of a public building or public work, involving antitrust, fraud, theft, bribery, collusion, racketeering, conspiracy, or material misrepresentation. 3. I understand that “convicted” or “conviction” as defined in paragraph 287.133(1)(b), Florida Statutes, means a finding of guilt or a conviction of a public entity crime, with or without an adjudication of guilt, in any federal or state trial court of record relating to charges brought by indictment or information after July 1, 1989, as a result of a jury verdict, nonjury trial, or entry of a plea of guilty or nolo contendere. 4. I understand that an “affiliate” as defined in paragraph 287.133(1)(a), Florida Statutes, means: (A) A predecessor or successor of a person convicted of public entity crime; or, (B) An entity under the control of any natural person who is active in the management of the entity and who has been convicted of a public entity crime. The term “affiliate” includes those officers, directors, executives, partners, shareholders, employees, members and agents who are active in the management of an affiliate. The ownership by one person of shares constituting a controlling interest in another person, or a pooling of equipment or income among persons when not for fair market value under and arms’ length agreement, shall be a prima facie case that one person controls another person. A person who knowingly enters into a joint venture with a person who has been convicted of a public entity crime in Florida during the preceding 36 months shall be considered an affiliate. 5. I understand that a “person” as defined in paragraph 287.133(1)(e), Florida Statute, means any natural person or entity organized under the laws of any state or of the United States with the legal power to enter into a binding contract and which bids or applies to bid on contracts for the provision of goods or services let by public entity, or which otherwise transacts or applies to transact business with a public entity. The term “person” includes those officers, directors, executives, partners, shareholders, employees, members, and agents who are active in management of an entity.

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6. Based on information and belief, the statement I have marked below is true in relation to the entity submitting this sworn statement (indicate which statement applies). _______ Neither the entity submitting this sworn statement, nor any officers, directors, executives, partners, shareholders, employees, members or agents who are active in the management of the entity, nor any affiliate of the entity has been charged with and convicted of a public entity crime subsequent to July 1, 1989. _______ The entity submitting this sworn statement, or one or more of its officers, directors, executives, partners, shareholders, employees, members or agents who are active in the management of the entity, or an affiliate or the entity has been charged with and convicted of a public entity crime subsequent to July 1, 1989. _______ The entity submitting this sworn statement, or one or more of its officers, directors, executives, partners, shareholders, employees, members or agents who are active in the management of the entity, or an affiliate of the entity has been charged with and convicted of a public entity crime subsequent to July 1, 1989. However, there has been a subsequent proceeding before a Hearing Officer by the State of Florida, Division of Administrative Hearings and the Final Order entered by the Hearing Officer determined that it was not in the public interest to place the entity submitting this sworn statement on the convicted vendor list. (attach a copy of the final order). I UNDERSTAND THAT THE SUBMISSION OF THIS FORM TO THE CONTRACTING OFFICER FOR THE PUBLIC ENTITY IDENTIFIED IN PARAGRAPH 1 ABOVE IS FOR THAT PUBLIC ENTITY ONLY AND THAT THIS FORM IS VALID THROUGH DECEMBER 31 OF THE CALENDAR YEAR IN WHICH IT IS FILED. I ALSO UNDERSTAND THAT I AM REQUIRED TO INFORM THE PUBLIC ENTITY PRIOR TO ENTERING INTO A CONTRCT IN EXCESS OF THE THRESHOLD AMOUNT PROVIDED IN SECTION 287.017, FLORIA STATUTES, FOR CATEGORY TWO OF ANY CHANGE IN THE INFORMATION CONTAINED IN THIS FORM. THE UNDERSIGNED PROPOSER, BY THE SIGNATURE BELOW, REPRESENTS THAT THE FOREGOING INFORMATION IS TRUE AND CORRECT. IN WITNESS WHEREOF, this Request of Proposal/Qualifications is hereby signed as of the _________ day of __________________, 2010. ATTEST:

___________________________ Witness

_______________________________________ Printed Name of Corporation or Individual (Party)

___________________________ Witness

___________________________________________ Signature of Authorized Corporate Officer or Individual

Sworn to an subscribed before me this ______ day of ________________________. Personally known to me _____ or who has produced __________________________________ as identification.

___________________________________ ______________________________ Notary Public Type or Print Name My Commission expires¨ _____________

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