What YOU can do to fight back - IFT limit

Well, my thought was that if we could make trades in near real time, then Ebb, Fred and others would be out of business -thus it would be an adverse impact to them.

IMO, when speaking of any adverse impact, we need to speak in terms of affecting all TSP shareholders, not the few who have a paid subscription "system".

The goal is not to appease those services, but to appease the shareholder as a whole, restoring their rights.

Hopefully my thoughts are lined up with the context of your's.:)

$.02
 
I've meant to post this for a while, just haven't had a chance. Response letter from Colleen Kelly:

December 21 (Actually mailed Jan 3)

Thank you for your remarks regarding the Federal Retirement Thrift Investment Board's proposal to limit trades in the TSP to two per month. As you probably know, the Employee Thrift Advisory Council (ETAC) met on the issue this past week on December 19, 2007. At that meeting, the Board presented us with a detailed explanation on the problem of frequent trading. Clearly, the fund is losing money because of a small number of participants who trade on an almost daily basis. At the meeting, NTEU offered a proposal to allow a small number of trades per month with a fee charged after that number. The ETAC decided not to take a position at that time.

The Board seems to be poised to charge ahead with draft regulations on the two trades a month idea. I cannot tell you if ETAC will take a position before the draft regulations come out. I can only tell you that NTEU is listening to its members and will do whatever it can to make sure that the general population is not penalized for the actions of a few.

Sincerely,
Colleen Kelly
National President, National Treasury Employees Union
 
From what I can tell, the only sallient fact, from Ms Ray's figures, is that the frequent trading is costing all accounts .08% a year for the right/flexibilty/BENEFIT/entitlement/privilage of unlimited transfers. That's only $80 dollars a year on a $100,000 account. If that's correct, it's incredibly foolish of the majority of the account holders to give up that benefit. I'm sure the majority is not aware of this basic concept. Again, if this is correct, this should be the one simple fact that is brought to the majority of members.
 
The .08% figure you cite does NOT represent how much it costs the average person. That is the number they threw out as how much impact ONLY ON THE I Fund.

Here is the average balances for ALL TSP HOLDERS- from the recent survey report. This data is chiefly from the year 2006, not the most recent, but DOES show the approximate fund balances by age.

I would also note that MOST PEOPLE are still keeping all of their money in G, which is not affected at all by any trading, and of those who ARE diversified, there are now more than 500,000 who are in an L fund, which contains a small component of I. This data, from back in 2006, shows a lower number of L fund participants than is the case at present. Today we're almost double the number of people in the L funds that there were a year ago.



As you can see, the AVERAGE buy-and-holder is carrying a very small balance compared to those who are actively managing their own accounts. You get two numbers on the bottom line- the MEDIAN, and the MEAN account balances. Even using the higher of the two, you STILL get a very small amount who are in the I fund, and are the ones who, according to the TSP Board, are "suffering" from that .08% trade costs. I would also note that those same people are actually BENEFITING from the Fair Value changes, and in fact MAKING money- MANY TIMES the .08%, that the Thrift Board is saying that interfund transfers cost.​

They aren't losing .08% because of interfund transfers. They are MAKING-- PROFITING--- at a rate of .56%.

By the way- The difference between MEDIAN and MEAN:

(From Wikipedia )​
Suppose 19 paupers and 1 billionaire are in a room. Everyone removes all the money from their pockets and puts it on a table. Each pauper puts $5 on the table; the billionaire puts $1 billion (i.e. $109) there. The total is then $1,000,000,095. If that money is divided equally among the 20 people, each gets $50,000,004.75. That amount is the mean amount of money that the 20 people brought into the room.

But the median amount is $5, since one may divide the group into two groups of 10 people each, and say that everyone in the first group brought in no more than $5, and each person in the second group brought in no less than $5. In a sense, the median is the amount that the typical person brought in. By contrast, the mean is not at all typical, since nobody in the room brought in an amount approximating $50,000,004.75.
 
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More flexibilty would not be an ADVERSE impact. Limiting interfund transfers IS an ADVERSE impact.
That's the difference.
James,
Have you thought to be sending, the above statement, and as much suppoting info as possible to retirement organizations?
- these groups all have tremendous resources;
- are commonly involved in legal actions;
- have HUGE lobby influence with members in Congress.

Provided below are a few -some are DoD-specific, but DoD has many civilian workers (and, also especially active, and veteran/retired military groups - which I know less of active/retired military) - but, these are for sure HIGHLY influencial!

http://www.narfe.org/departments/hq/guest/home.cfm

http://www.afge.org/Index.cfm?Page=Retirees1

http://www.nage.org/federal/leg_process.shtml

http://www.military.com/benefits/mil...t-savings-plan
(more active and veteran-military specific)
progress.gif
 
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James,
Have you thought to be sending, the above statement, and as much suppoting info as possible to retirement organizations?
- these groups all have tremendous resources;
- are commonly involved in legal actions;
- have HUGE lobby influence with members in Congress.

Provided below are a few -some are DoD-specific, but DoD has many civilian workers (and, also especially active, and veteran/retired military groups - which I know less of active/retired military) - but, these are for sure HIGHLY influencial!

http://www.narfe.org/departments/hq/guest/home.cfm

http://www.afge.org/Index.cfm?Page=Retirees1

http://www.nage.org/federal/leg_process.shtml

http://www.military.com/benefits/mil...t-savings-plan
(more active and veteran-military specific)

progress.gif

Go ahead- you can write them and get their attention. Your help is needed- not just me. We're all in this together.
 
Below,
Done!
I forwarded both a personal, and a http://tspshareholder email to the retirement orgs. below
We'll see if what happens next / if we get anything back (pretty sure we will)! Encourage others to send to these groups too!
- Confirmation:
This email has been forwarded to comments@afge.org and retbenefits@narfe.org with the following message:
- Message sent:
Many have signed petition to stop, the TSP Board, from imposing an ADVERSE action - that of limiting the number of interfund transfers a member can make - to 2 per month! 90% of members polled oppose this restriction, howerver the Board refuses to listen. Again, limiting Interfund Transfers IS an ADVERSE impact! Our "fight-back" website is http://tspshareholder.org If you are a media person and would like to conduct an interview, please send an e-mail to us at MEDIA @ TSPSHAREHOLDER.ORG

(For Military.com. & NAGE, I had to send separate, but similar messages.)
________________________
PS -AARP is another good one--Do it! - There may be others!

These retirement organizations can really help bring a firestorm - if they can just be shown the truth (that is, don't just buy the crap Tracy Ray's TSP board is pushing)!
 
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[Ensure reaching -retirement organizations!]
- these groups all have tremendous resources;
- are commonly involved in legal actions;
- have HUGE lobby influence with members in Congress.

[Provided below are a few -some are DoD-specific, but DoD has many civilian, active, and veteran/retired military groups - of which, I know less of active/retired military) - but, these are for sure HIGHLY influencial organizations!]

http://www.narfe.org/departments/hq/guest/home.cfm
http://www.afge.org/Index.cfm?Page=Retirees1
http://www.nage.org/federal/leg_process.shtml
http://www.military.com/benefits/mil...t-savings-plan
(more active and veteran-military specific)


Airlift, nice! NARFE is likely my best hope, as representing retired Feds (as well as current). Second and 3rd groups listed above though, are VERY active (and litigous) in representing Fed. employees!
I know for a fact that at least the first 3 groups are well aware of numbers of active and retired Fed. employees, both civilian, military, active & retired (and numbers of Boomer's, soon to be retired!) that TSP changes would affect.

I just hope we get a chance to explain how the THE NUMBERS that the Board presented are just simply a fiction! :worried:
VR
 
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I just hope we get a chance to explain how the THE NUMBERS that the Board presented are just simply a fiction! :worried:
VR


one thing-

the numbers aren't fiction.

The thing is the numbers are real.

The problem is they are not the right numbers to look at. Those numbers being used ot scare the ETAC and the Board mean nothing.

Put simply- it doesn't matter one iota that the amoutn of dollars being traded has gone up. That is what Tracey Ray is using to scare everyone.

The real question is what is the bottom line- not just the trading cost, but also the tracking error. Combined, they tell the story that is important. And the story that is important to communicate is that share holders --ALL SHAREHOLDERS-- are BETTER OFF, not worse off, because of the increase in the amount of money being interfund transferred.
 
From http://www.planadviser.com/article.php/1655 today:


IMHO: Trading Places

Nevin E. Adams – 01/14/2008

Back in 2003, when then-New York Attorney General Eliot Spitzer launched his investigation into mutual fund trading practices, two distinct areas were highlighted.

late trading, which was illegal on its face (particularly so when facilitated by the fund companies themselves), and market-timing, which, as we were reminded in a parenthetical comment in nearly every story regarding the scandal, was not (though nearly every fund prospectus claimed to discourage such patterned trading and promised to take steps to deter it).

That distinction was frequently glossed over in the coverage that followed—and the settlements that ensued. When all was said and done, a large number of chastened fund complexes had forked over a large amount of money (much of it to the coffers of the Empire State) and agreed to adopt new controls and procedures designed to ensure that the wrongdoing they never admitted to doing never happened again. So much commotion was raised, in fact, that the Securities and Exchange Commission was roused from its slumbers—just in time to adopt a “solution” to the problems resulting from the not-illegal-but-nonetheless-apparently-troubling practice of market-timing. Of course, the solution—initially set forth by a trade group that represents the mutual fund industry—was already available to those fund companies. But now, thanks to the codification in SEC Rule 22c-2, even the most casual mutual fund investor—including those who do so only via their 401(k) plan—has been forced to be aware of redemption fees—and we’re not just talking about cases of quick in-and-out, round-trip trades, either.

Setting aside what, IMHO, is still an absurd result, it’s all old news by now. Been there, done that, bought the T-shirt….

Here We Go Again

That’s why it’s been interesting to watch the debate over market-timing once again raise its ugly head—this time among the participants of the federal government’s own Thrift Savings Plan, or TSP. Apparently, there are a couple of thousand participants (out of a universe of 3.8 million in the TSP) who are trading “frequently”—and the TSP is taking steps to rein them in.

The Washington Post has reported that 2,018 participants who sold holdings in an international fund on October 24 had transferred in just a few days earlier (10/19). And, of that group, 323 participants were trading $250,000 or more. Moreover, during the previous 60 days, those 323 traders had made 5,804 exchanges in the international fund worth $1.9 billion, according to TSP officials (one participant has traded more than $1 million back and forth a number of times). These participants aren’t trading in mutual funds, of course, so the SEC’s 22c-2 strictures don’t apply.

Moreover, an analysis by fedsmith.com (a Web site devoted to federal workers) claims that those who bought in on 10/19 did so at $25.13/unit, and those who sold on 10/24 did so at $25.32/unit, making 19 cents per unit in just a few days. A feat that looks pretty good until you consider that, at 10/31, that particular TSP fund closed at $26.31.

But the TSP’s issue isn’t with the money these folks are making on those transfers. Rather, they are concerned about the cost impact of that activity on the folks who don’t trade; higher broker fees and transaction costs—especially in the international fund, where it's more difficult for the TSP's investment manager (BGI) to match buy and sell orders. They have—rightfully as fiduciaries, IMHO—expressed concern that a (relatively) few participants are driving up the costs for the vast majority who, like their counterparts in the private sector, never trade. Those trading costs stand out in the TSP, which enjoyed a total expense ratio of 3 basis points (that’s not a typo) in 2006. The trading costs for their international fund that year? Eight basis points (again, no typo). Now, those expense ratios may be a “problem” that your average 401(k) would love to have, but we’re talking about a $235 BILLION dollar fund. So, in crafting a recommendation to deal with this situation, the TSP’s chief investment officer looked to—mutual fund practices in the 401(k) industry and the SEC’s mandate under Rule 22c-2 (see). Ultimately, unable to come up with a transaction fee that would be big enough to cover the trading costs, the TSP has decided to impose limits on the number of trades per month. Those limits—two per month—should be enough to satisfy anybody who isn’t trading funds for a living. Moreover, the TSP has imposed NO restriction on transfers from any of the funds to the G fund, the TSP’s most conservative option, to address the concerns of participants who might want to move their balances out of the way of some economic tsunami. More importantly, IMHO, it sends a message both to those participant-traders and to “everybody else.”

I also was struck by the TSP’s comparison of their solution with that adopted by the mutual fund industry. Though we frequently bemoan the bane of participant inertia, our industry has long been concerned about participants that would fritter away their day—and their balances—trading their retirement savings. That was the mantra against daily valuation in the first place, why we fretted over day traders in the middle of the tech-bubble, and, now, why a relatively few market-timers (setting aside for a minute that the incidents taken to task by regulators involved the complicity and/or active acquiescence by the fund companies; let’s face it, we all know the odds are against participant timers) have managed to burden an entire industry with an additional layer of costs, another complicated message, and random restrictions.

I can understand why the fund managers are in favor of these impediments. I’m (still) not altogether sure why the rest of us have been so willing to go along.



Footnote:


In the interim, a group calling itself TSPSHAREHOLDERS.ORG has launched a web site and a petition campaign to block the new transfer policies – and they have just under 3,000 signatures on that petition (one can’t help but wonder if it’s the SAME 3,000 that have been doing the frequent trading). They have some issues with the calculation of trading costs – and they claim that the big trading surge last October resulted in a “tracking error” (basically a difference between the price at which transfers were credited and the real cost of the transaction) – and they claim that the tracking error accounted for 56 basis points in the favor of those who stayed in the fund (see http://tspshareholder.org/newsletters/Vol2_No2.html).

Now, what’s missing in that analysis, of course, is the reality that that tracking error COULD have cut the other way – and those left sitting in that investment fund could just as easily have been stuck with a loss. But then, that’s how free markets work. Some people win and others don’t (what’s also more than a bit ironic, IMHO, is that up until the past couple of years TSP participants could only transfer once a quarter).
++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++




(Note: Here is the link to the original posting of this article. You can see it, and you can post a message to Mr. Adams here: http://plansponsorinstitute.blogspot.com/ ) .


(The really good news is that we now have a senior Wall Street guy who has read and understands the arguments made by TSP SHAREHOLDER.ORG. Excellent start. Be easy on the guy on any comments- but please feel free to make some comments up there).
 
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I got this via email. I can't confirm what has happened though...
I'm blocked out of trading...Has this already begun where we cannot trade daily? I wanted to try to balance my account before this happened...Looks like I'm too late? Will we know when they open it again? Is there a set schedule? Ughhhhhhhh...Thanks for your help.
 
one thing-

the numbers aren't fiction.

The thing is the numbers are real.

The problem is they are not the right numbers to look at. Those numbers being used ot scare the ETAC and the Board mean nothing.

Put simply- it doesn't matter one iota that the amoutn of dollars being traded has gone up. That is what Tracey Ray is using to scare everyone.

The real question is what is the bottom line- not just the trading cost, but also the tracking error. Combined, they tell the story that is important. And the story that is important to communicate is that share holders --ALL SHAREHOLDERS-- are BETTER OFF, not worse off, because of the increase in the amount of money being interfund transferred.

Thank you James,
Please recognize that THIS is the part where I get real fuzzy - is explaining the math, and the tracking error. I'm just not, without benefit of real close study, able/good at adequate explanation, or presentation of the facts (like you of course, and others that have been studying-up on these details).
I have only tried to get the word out. I do recognize my limitations in areas you point out, therefore would not try, and would definitely prefer (and refer) for others to address that part with any organizations that do respond!
VR
 
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Friday there was a glitch on TSP site which has happened before. Last time it was due to a MS patch update to IE. Our tech people were working with TSP to resolve it. This may be the case here.

If FRTIB has in fact already blocked the site then it's illegal because they haven't sent the letters yet. They must WARN EACH "excessive trader" via letter prior to blocking the account, and they can't block it until after the 2 "allowed" trades for January are made. If they have blocked you and you haven't received a letter, get a lawyer.

The tsp.gov website still says letters to be mailed in Feb and put into practice in April.
 
I downloaded my 4th Quarter TSP statement this morning. No notification came with it. Must have to wait until the yearly statement? I am one of the 3000 Ya know!
 
James,

I received the following response from Mr. Joe Ickenberry of NARFE. Since your data base contains fundamental rebuttals to his opinion, I suggest you send him clarifying information.

Best wishes!

COPY:


[FONT='Arial','sans-serif']"The TSP information is that the daily transfers have now increased the administrative cost by 50% since they were instituted. The main use has been in transfers in the I Fund. [/FONT]

[FONT='Arial','sans-serif']One problem is that transfers are often entered in the evening. These transfers do not take place until the next day. Even if the price has decreased, the TSP is obligated to transfer in at least the amount of the previous close. [/FONT]

[FONT='Arial','sans-serif']If the price has actually decreased, the TSP takes the loss, and adds this to all enrollee’s administrative costs. To discourage this increase in administrative costs, the TSP plans to pass on this additional cost. [/FONT]

Retirement Benefits Service Department
National Active & Retired Federal Employees Association
"NARFE - Your Future is our Focus[FONT='Verdana','sans-serif']" '[/FONT]
 
James,

I received the following response from Mr. Joe Ickenberry of NARFE. Since your data base contains fundamental rebuttals to his opinion, I suggest you send him clarifying information.

Best wishes!

COPY:


[FONT='Arial','sans-serif']"The TSP information is that the daily transfers have now increased the administrative cost by 50% since they were instituted. The main use has been in transfers in the I Fund. [/FONT]

[FONT='Arial','sans-serif']One problem is that transfers are often entered in the evening. These transfers do not take place until the next day. Even if the price has decreased, the TSP is obligated to transfer in at least the amount of the previous close. [/FONT]

[FONT='Arial','sans-serif']If the price has actually decreased, the TSP takes the loss, and adds this to all enrollee’s administrative costs. To discourage this increase in administrative costs, the TSP plans to pass on this additional cost. [/FONT]

Retirement Benefits Service Department
National Active & Retired Federal Employees Association
"NARFE - Your Future is our Focus[FONT='Verdana','sans-serif']" '[/FONT]

This shows you the financial knowledge and capability of the people who are supposed to represent employees.

Enough said.

Gentleman, ( and Ladies)- it's time to educate the people who are supposed to be looking out for you.

I now have Joe's e-mail address- thanks.

I look forward to giving Joe an education.

Education is a powerful tool. It broadens the mind.
 
James,

If I recall correctly, I think your position has always been all-encompasing and intense in its outreach objectives. I believe many other people to whom we have written, are also in need of more information. I don't know how to do it, but perhaps they can be reached again ln order to send them the correct perspective on the accuracy of the issues!
 
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TO: Joe Lkenberry, NARFE,
CC: ALL ETAC MEMBERS
January 14, 2008


Dear Joe:

I recently saw a copy of a message you sent out- and I think, after reading it, that you are not getting the full story.

My name is Jim XXXXX, and I am the organizer of TSPSHAREHOLDER.ORG. I also serve on the Finance Committee of my Union, XXXXXX (URL FOR UNION)

And I am experienced in dealing with TSP financial matters, financial planning, and have worked to help hundreds of federal employees and Army Soldiers plan their financial futures.

After reviewing the data the Thrift Board is putting out, I am greatly concerned. I sincerely believe the TSP Board is misleading you on several accounts. The data you are seeing regarding the TSP Costs are not the full picture, and it appears you all are not getting the full story.

I hope to be able to explain it more clearly for you- and I ask that I be allowed to meet with all of you to explain this in more detail.

Joe, in your recent email, you said: “The TSP information is that the daily transfers have now increased the administrative cost by 50% since they were instituted. The main use has been in transfers in the I Fund. “

First of all, this is simply not true. There are two types of costs in dealing with the TSP. The first is Administrative costs. The second is Trading costs.

First, let’s compare TSP Administrative costs to those in private Mutual funds. TSP’s current administrative costs are just 1 basis point per year. That’s .0001%.

In the Mutual Fund world, that is an unheard of low amount of cost. Mutual funds typically run 60 to 75 basis points. You said “Daily transfers have now increased the administrative costs by 50% since they were instituted.” In fact, in 2003, Administrative costs were 10 basis points. IN 2007, they were 1 basis point. Administrative costs have GONE DOWN BY A FACTOR OF TEN.

Next, let’s compare “trading costs”.

The Thrift Board told your ETAC member that trading costs were increasing. That is not true.

The briefings given to the Thrift Board in October cited:
2005 trading costs were 8 million.
2006 trading costs were 16 million.
2007 trading costs were 25 milion.

In actuality, trading costs in 2007, through the end of October, were actually just $11,276,176. True, the last two months have not yet been reported, but there is NO WAY that 2007 costs will be 25 million. Tracey Ray gave the ETAC incorrect numbers. Trading Volume went up, but COSTS went down.

As a percentage of the amount traded, trading costs have been cut almost in half between 2006 and 2007. In 2006 is was 8 basis points for the I fund. IN 2007, as of the end of October, it was 5.6 basis points. October is the last month that data is publicly available. As the amount of dollars being traded has increased, but the costs has actually gone DOWN.

I’ll give you two sources to learn more about that: The Thrift Board’s October 2007 report of data, located at: http://tspshareholder.org/data/Nov_2007_2.pdf

And the TSPShareholder.org newsletter Vol. 1, number 4, at:
http://tspshareholder.org/newsletters/Vol1_No4.html

Next: You stated:

“One problem is that transfers are often entered in the evening. These transfers do not take place until the next day. Even if the price has decreased, the TSP is obligated to transfer in at least the amount of the previous close.”

That is not true either. The transfers are all placed before noon. The trade is then executed overnight. What you are referring to is called “Fair Valuation”, and will not be affected at all by the proposed limits. Fair Value is used by the TSP Board, but it doesn’t have to be. If they chose to price the fund value at 7 a.m. the next morning instead of 7 pm., the fair value issue would be eliminated. But Fair Valuation is not bad. It allows Barclays, the trader, to skim pennies off of those who trade their funds, and puts the money into the hands of those who buy-and-hold. In 2007, through October, this Fair Value skimmed 216 MILLION dollars off those who traded shares, and put it into the hands of those who are “buy-and-hold” I fund share holders.

TSPSHAREHOLDER.ORG wrote about this issue in http://tspshareholder.org/newsletters/Vol2_No2.html


Finally, you wrote: “ If the price has actually decreased, the TSP takes the loss, and adds this to all enrollee’s administrative costs. To discourage this increase in administrative costs, the TSP plans to pass on this additional cost. “

Unless you know something we don’t know, this is not true either. It is our understanding that passing on additional costs are not on the table as an option. It is our understanding that the Thrift Board, and it’s ETAC members, are planning to limit interfund transfers, not pass on costs.

What really hurts those of us who actively manage our accounts is that WE KNOW the numbers being pushed by Tracey Ray at the Thrift Board are not the whole picture, and the ETAC NEEDS to ask the right questions in order to see the big picture. We can help- if we can just talk to you all, and show you the data.

To put it as simply as I can, let me say this:

Those who make regular interfund transfers HELP those who buy-and-hold. Trading HELPS them, it doesn’t hurt them.

If your ETAC member needs some more information to better understand this, we would be happy to meet with him, and give him a presentation to show him the facts in this case. We’ve got data, and can very clearly explain the information they are getting from the Thrift Board is not the complete picture, and that they need to understand ALL the information before they can properly represent employees, and give feedback to the Thrift Board.

I plan to travel to Washington D.C. the first week in March. I’d love to meet with Richard, and any other ETAC member who will meet with us, to sit down and discuss the real numbers, and a whole host of options that the ETAC COULD recommend that would improve the TSP. I will be arriving in D.C. March 1st, and will be in town for a few days. I am willing to sit down with ANY ETAC member or rep and explain all this.

Please let me know how we can meet and discuss this issue.
I am availabe at any time, 24/7, to talk to any ETAC member or their rep to discuss these issues and offer alternative suggestions.

My phone number is (XXX-XXX-XXXX_)
My e-mail is XXXX@XXXXX.net

Sincerely,


Jim XXXXXX,
Federal Employee,
Retired Army National Guard Officer,
and
Member, TSPSHAREHOLDER.ORG

e-mail: XXXXX@XXXXXX.net
 
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James,

I can't improve this excellent letter. I commend you. Time is of the essence to change the attitude of people in authority. I suggest that Tom and other fine colleagues at TSPtalk get their minds together to disseminate a similar letter as this one, even if the persons have already been contacted to support us. Many do not understand the intricacies of operations.

Somehow, the financial commitees of The Senate and House of Representatives should be apprised of the situatiion. The truth must be clarified before the distortions spread their roots. Promptly and deliberately.

Best wishes!
 
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