Smart Ways to Make the Most of Your Finances
By Chris Burke
This article is published on: 10th February 2015
10.02.15
The year 2015 is picking up speed, and now is the perfect time to stop and re-evaluate our finances before we slip back into our old comfortable routines. A time to review the past year and determine those areas with potential for improvement, to make sure we are getting the most out of our investments and reaching all our financial goals.
Do you know where your money goes each month? Could you be making more if you invested elsewhere? Is your credit rating a true reflection of your financial situation, and are there things you could be doing to improve your standing?
Follow these smart ways to make the most of your finances and put you and your family on the right track for a wealthier future.
Study your Credit Report
Have you ever seen a copy of your credit report? Most people haven’t and it may surprise you to hear that they very often contain errors. Research online and get access to your report and make sure there aren’t any mistakes which could be having a negative impact on your rating. If you don’t, you could be at risk from undiscovered inaccuracies.
Study your Cash Flow
Set some time aside to study your cash flow. Go over all your statements from the past year and crunch those numbers to gain a true understanding of where your money goes each month. How much are you spending? Where is it all going? Where can you make cuts to your monthly outgoings?
Credit Cards & Banks
Check the Terms and Conditions of all your credit cards and compare terms, rates and fees with those of other cards. Are you getting the best deal or are you just renewing cards out of habit? Get rid of credit cards which don’t give anything back, and compare rewards and cash back with other offers. If your current bank is letting you down and not providing the service you need, change.
Understand Investments
Most of us don’t fully understand investments. Be the minority. Do your research and find out as much as you can about viable investment options. Use the Internet and its many free tools, and study the market to assess how to make the most of your finances.
Seek Professional Advice
Ultimately, the best advice is professional advice. The Spectrum IFA Group can assist you in reviewing your financial situation and advise you on smart ways to make the most of your finances. For more information or to contact one of our Financial Advisers please use the contact form below.
The Spectrum IFA Group Economic Forum
By Spectrum IFA
This article is published on: 2nd February 2015
We have just had our annual conference, The Spectrum Economic Forum. We had presentations from leading investment managers including BlackRock (the world’s largest investment house), J P Morgan Asset Management, Rathbones, Kames Capital, Jupiter Asset Management and Henderson Global Investors.
The conference is a great opportunity for us to hear directly from some of the investment management companies, which we recommend for the investment of our clients’ financial assets. Their collective forward-looking views on markets and key issues for 2015 provided us with a valuable insight, so that we are better able to advise our clients.
We also had presentations from several product providers, including Prudential International, Old Mutual International (formerly Skandia International), SEB Life International and Tilney Best Invest (who also provide discretionary asset management services). All companies gave interesting presentations on developments in their products, which are focused upon the needs of expatriates.
The conference is always a good opportunity to get together with colleagues from the six countries in which we operate. It’s a chance for us to exchange views and discuss issues that are common to all our clients, wherever they live.
There was agreement amongst us that one of the biggest potential ‘issues’ that the financial services industry is facing this year is the subject of pensions, as a result of the forthcoming UK pensions reform. Many Spectrum advisers expressed concern about predatory companies that are already operating, which could result in people unwisely cashing in their UK pension pots. The importance of obtaining professional advice from qualified advisers, who are regulated by the authorities in the country where the pension scheme member is living, was highlighted.
We were fortunate to have Momentum Pensions present to us, which is the first company to be able to offer a truly multi-jurisdictional pension solution for clients. Like us, Momentum has their clients’ best interests at heart and they understand that expatriates can move from one country to another. Therefore, Momentum has now added a UK Self Invested Pension Plan to their range of international pension solutions, which means that even if the client moves back to the UK, they can have a smooth transfer of the pension benefits from the overseas pension scheme back to the UK.
As can be seen from the above, we are constantly working closely with investment managers and product providers to find the best solutions for our clients, whether this is for the investment of financial capital, using tax-efficient solutions, pensions or inheritance planning. This forms an important part of our Client Charter
Planning for Le Tour de Finance 2015 is also now underway. As many people reading this know, this event is a perfect opportunity to come along and meet industry experts on financial matters that are of interest to expatriates.
We are now taking bookings for May 2015 events, please contact us here:
- Perpignan – 19th May
- Bize-Minervois – 20th May
- Montagnac – 21st May
Le Tour de Finance is an increasingly popular event and early booking is recommended. So if you would like to attend one of these events, please contact me to reserve your places.
The Financial Implications of Moving Abroad
By Chris Burke
This article is published on: 30th January 2015
Moving abroad can be a stressful and confusing experience and starting from scratch in a new location can often be overwhelming.
If you have recently decided to up sticks and move to Barcelona, or if you’re a recent arrival in the sunny Catalan capital, then you will have many choices to make. Aside from the immediate practicalities of moving to a new country, such as choosing schools, buying or renting property, and setting up residency for you and your family, there are many other (often overlooked) factors to take into consideration:
Pensions:
Unlike the UK, most companies in Spain don’t provide a private pension scheme or private health insurance. However, as an Expat, you may have unique opportunities available to you. An adviser will be able to discuss each of the options enabling you to make a decision.
Banking:
Having the right banking arrangements is a key part of life overseas. It’s best to sort your finances out before you go, as local banks usually require a credit history and proof of address to set up an account – which you won’t have when you arrive.
Tax:
Dual-Country financial arrangements are complex and should not be taken lightly, as even the most innocent transaction can be costly if not well planned.
Savings and Investments:
There are many factors that go into determining the best country in which to locate your investments. Bear in mind that you may have access to, and potentially benefit from, onshore and offshore savings and investment assets.
ISAs:
If you currently have an ISA and are planning to move abroad, they are not tax efficient in Spain. You also need to be fiscally resident in the UK to pay into one.
Will & Testimony:
Your Will (and those of your family members) will need to be updated so that it is compliant in Spain
Financial Advice:
The complexities in managing currency risk, an investment portfolio, and dual-nation tax reporting are many. It is important for expats to have a trusted adviser who understands the financial nuances of living an international lifestyle.
The France Show, 23-25 January 2015
By Lorraine Chekir
This article is published on: 21st January 2015
Visit the Riviera Alliance stand (P268) at The France Show, The Olympia Exhibition Centre, 23-25 January 2015 10am-5pm
The Spectrum IFA Group is one of the founding members of the Riviera Alliance, an established network of professionals based in the south of France. Spectrum will be represented by Lorraine Chekir, one of the advisers in the Cote d’Azur region. The Riviera Alliance covers every step in the process of buying, owning, renovating, or selling real estate. Each member is a specialist in their field and will make your life in the Riviera easier.
“We are here to help you”
http://www.thefranceshow.com/
Looking forward to your pension
By Spectrum IFA
This article is published on: 21st January 2015
Welcome to 2015. Let’s all hope for a prosperous and, maybe optimistically, safe year to come. This is my 60th year on the planet, and the cracks are starting to show. Many thanks indeed to the many well-wishers who sent me messages of goodwill following my hip replacement in December. They were much appreciated. I am up and about again now and, whilst I may leave it a few more weeks before I resume training for the triple-jump, it is good to be able to get around freely. Bear with me, I will get to the financial stuff soon.
With the physical recovery going well, my mental state did take a knock however on an early foray back into the big wide world. Congratulating myself on being able to get around with only one crutch, I decided to take myself off to my local Bricomarché to buy some light fittings. With only one checkout open, I resigned myself to a long wait at the back of the queue. I suddenly realised that the people in front of me were moving aside, and I was being beckoned to the front by the cashier. How utterly charming and, yet, completely crushing. When I protested, I was told that this was normal treatment for ‘handicapped’ people. I was appalled. Not that a DIY chain should treat its clients this way, but at the fact that they should regard me as a ‘client in need’. It was like peering into my dotage. How many years before I will have a long grey beard, waving a walking stick, being pushed in a wheelchair?
Looking back on that day recently, it struck me that there is probably a link with my recent focus on old age and pensions. I know I’ve said before that the older you get, the more interesting pensions become, but I really think that it is true. What is worrying me now is the growing list of younger people who are getting very interested in our pensions, for all the wrong reasons. The younger crowd I’m referring to are politicians who are gleefully rubbing their hands and salivating over our pension assets. There seems to be no political argument over the new pension reforms due in April that are to sweep away all forms of prudent financial planning for old age. They’ve all got their eyes glued on the same pot.
Please allow me to get slightly technical for a moment and explain GAD to you. The initials stand for Government Actuarial Department. Actuaries are very clever people, mathematicians basically, who walk around wired into computers. One of their jobs used to be to come up with a formula that worked out how much you could draw from your personal pension per year without reducing your pension pot too quickly. In short, they were there to make sure that your pension outlived you. 100% GAD meant the maximum you could safely draw from your pension.
Then the politicians started to get interested. Wouldn’t it be a good idea if we let the old fogeys have more of their pensions to spend? That way we can boost the economy for the rest of us and we can tax them as they do it. It won’t be a problem because they’ll probably still die before the pension runs out! Let’s try 120% GAD and see how we get on? Well, OK, it helped a bit but we still need more capital spending. Let’s see how we get on with 150% GAD? The next logical step is of course about to take place in April. Forget GAD! You can have the lot. Use your pension as a bank account. Treat yourself to something special. A yacht? Ferrari? The world is your lobster.
This is, in my view, tantamount to criminal recklessness. You and I may be completely confident in our ability to run our own finances, and I trust that that is in fact the case, but who is going to protect the vulnerable amongst the older generations? Who is going to protect pensioners from double glazing salesmen; roofing contractors; cowboy builders; money grabbing children looking for early access to their supposed inheritances?
And then there are the annuities. These are financial instruments that you used to have to buy with your pension funds. These gave you a guaranteed income for life. You are no longer obliged to buy an annuity with your pension fund. I do agree with this. The fall in long term interest rates meant that annuity rates fell quite dramatically over the years, and the income you bought became less and less. I suppose then it should come as no surprise when we hear that pensioners are to be allowed to sell their annuities, and receive lump sums instead. More money to spend! More tax to pay! In twenty years’ time this could turn into a monumental national scandal, but by that time our current batch of politicians will be retired, enjoying their protected pensions.
My own personal pensions are now safely housed well away from further potential meddling. I will not be drawing out huge (I wish) sums to finance cars or cruises, and barring worldwide financial calamities there will be enough money to see me out. If I do last another 15 years, whatever is left will also go to my chosen beneficiaries without any tax deducted. Did I mention the 45% tax that will be payable in the UK?
Investments: The Unconsidered Risks
By Peter Brooke
This article is published on: 17th January 2015
17.01.15
Many yacht crew have made the excellent decision to invest some of their hard earned money into an investment scheme for their future financial security. There is often much discussion about investment risk, be it bonds, equities, property, commodities or alternative investments.
What is not considered and discussed enough are the structural risks of buying into an investment scheme. It’s important to understand all of the risks to your capital, not just to what can happen to the value through poor investment performance.
Policyholder protection:
Most yacht crew investment schemes are set up via insurance policies; these often have significant tax advantages and offer levels of policyholder protection not provided by banks or investment/brokerage accounts. Unlike a bank the insurance company model means that a life company is required to hold all the assets underlying its clients’ policies at all times plus an additional amount of its own capital for a “solvency margin.” If the insurance company is put into liquidation, then the client assets are ring-fenced, and the company can pay for all of the costs of transferring the “book of business” to another insurance company or return the money to its policy holders.
The better the jurisdiction (eg EU) in which the life company is based, the stronger the regulation tends to be (eg UK FCA or Central Bank of Ireland) and the more capital it must have; therefore the less likely it will be become insolvent. Big is beautiful!
Credit Rating:
When it comes to most financial institutions, it’s important to understand the solvency of the financial institution, i.e. how likely it is to make its financial obligations. This is often measured via a credit rating from one of the rating agencies (eg Standard & Poors).
Custody:
Most life companies and investment “platforms” add another tier of protection by using a third party custodian, which avoids conflicts of interest and helps segregate your assets from those of the company. This custodian should be well rated too.
Investment Fund Structure:
Very careful consideration should also be given to the actual structure of the investment you choose. There are thousands of collective investment funds in the world, and where they are registered and how they are regulated can vary enormously.
Consider liquidity – (daily priced is vital), domicile (EU, inc Lux and UK are normally better regulated) and regulatory structure (look for SICAV, UCITS, OEIC – for most stringent reporting standards).
Rating – check the funds have been rated by one or two independent companies (Morningstar, TrustNet, etc.) and check the fact sheets of the funds carefully for SIF, EIF or QIF; these are Specialized, Experienced or Qualified investor funds that should not be bought by anyone who is not a professional or very experienced investor. If you want to buy one you should sign a disclaimer to that extent.
If in doubt take at least two opinions from properly regulated advisers (oh.. and check their regulatory structure too!!)
Smoothing: Reduce Volatility and Increase Growth
By Jonathan Goodman
This article is published on: 15th January 2015
15.01.15
Investment Smoothing
Investment Smoothing is a process used in pension fund accounting by which unusually high returns in a given year are spread over a multi-year period. By taking an average of all the different values, smoothing can deliver a constant figure for shorter time periods.
Instead of simply sharing out what the fund makes or loses each year, a smoothed growth fund aims to even out some of the variations in performance. This process is what we call ‘smoothing’.
How Smoothing Mitigates Volatility
The logic behind smoothing is that it lowers the volatility of profit and loss credit from pension fund returns. During positive markets, some profits are retained by the underlying fund manager as reserves to be paid out during market downturns. This process dampens the volatility typically seen when investing in other types of long term mutual funds.
Smoothing from the Pru
The PruFund funds are designed to deliver smoothed growth by investing in many different investment areas. By investing in a range of assets the fund is less exposed to significant changes in the values of individual assets.
Prudential’s investment specialists will constantly look for the best opportunities for growth within a wide range of investment areas. Prudential apply a unique smoothing process to these funds to provide a more stable return, than if you were directly exposed to daily changes in the fund’s performance.
Prudential Smoothing: Reduce investment volatility, but keep the potential for growth.
Inheritance Tax in Italy
By Gareth Horsfall
This article is published on: 14th January 2015
14.01.15
You may not be aware but from an Inheritance tax point of view, Italy is actually considered a bit of a fiscal paradise (after you have picked yourself up off the floor because I just called Italy a ‘fiscal paradise’, you might want to read on). If your estate or part of it is likely to be subject to Italian Inheritance Tax on your death then the latest developments could interest you.
Italian Inheritance tax law dates back to the Napoleonic period which requires parents, on death, to leave a major proportion of their wealth to their children instead of just their spouse.
At the moment Italy’s Inheritance tax works as follows:
* If the estate is passed to your spouse or relatives in a direct line (i.e children) then they are required to pay 4% on the value of the inheritance that exceeds € 1million.
* Brothers and sisters must pay 6% with an allowance of €100,000
* Other relatives must pay 8% but without any allowance.
Despite Italy having approximately 1.5 million people who are subject to Inheritance tax each year with a combined value of approximately €56 billion, the tax collection is relatively small due to the high allowances and also the fact that that ‘successione’ for a property is based on the catastale value, not the market value.
WHAT ARE THE PROPOSED CHANGES?
Italy, like most other countries, is in desperate need of cash and they naturally see inheritance tax as a way of increasing tax revenues. In addition, the EU is encouraging Italy to review the present system to bring it into line with other, ‘less financially rewarding’, European countries.
The ideas, which are just ideas at this stage, are as follows:
* For spouse and direct line relatives, to increase the taxable rate to 5%. But, reduce the non-taxable allowance from €1 million to €200,000.
* Whilst the taxable rate will rise from 6 to 8% for brothers and sisters, and the allowance will reduce to between €50,000 and €100,000.
* The rates for other relatives will likely increase to 8% without any allowance.
This means that a lot of people will now be caught in the Italian Inheritance tax trap whereas previously they might not have been. Although, it should be said, the rates are still quite low.
However, as part of any inheritance tax /succession planning that you may undertake you may want to look at ways in which you can hold any asset, in a more tax efficient way. The polizza assicurativa (or Life Assurance Bond) meets exactly that criteria.
Any money that you hold in one of these tax efficient accounts is completely free from Italian Inheritance tax and is kept outside of the estate when the value is calculated. The not so good news is that if the majority of your estate is in your property, unfortunately, this cannot be placed inside the tax protective structure. However any other invested/investable assets can be, generally, from €50,000 upwards.
One of the great advantages is that there is no upper limit to contributions. You can protect a large part of your estate from Italian Inheritance tax easily and with maximum flexibility to access the capital and any income from it during your lifetime. The other big advantage is that the monies (whilst held inside the account) are not subject to Italian income and capital gains tax.
Expats in Italy and bank accounts
By Gareth Horsfall
This article is published on: 13th January 2015
13.01.15
During the course of my many conversations, one particular issue comes up all too frequently which I thought I just have to write about. It is something which has been on my radar for some time now. Now the time has come.
What am I talking about?
I am referring to basic bank accounts that expats use in Italy, those bank accounts which were probably set up when you first moved to Italy, either because the person who you were buying a house from suggested you open an account at the same branch to make life easier, or you were referred to the local branch because most people used it, or someone knew someone who could open you an account when you may not have even been a resident at the time. I am sure these reasons may sound familiar to some of you.
But unfortunately, you are more than likely being charged an extremely high amount of bank charges for little to no service.
Monte Pashi di Siena;
Monte Paschi di Siena keeps coming up as the worst culprit, by a long stretch, but yet, seemingly used most frequently by the expats I meet. One person I met last week was paying 34 euros a quarter for the bank account and then on 210 euro transfers to another Italian bank account (a simple bonifico) a commission of 4.50 eur. (2% commission PHEW!).
I did not even get to see what they were paying for exchange rate conversions (the mind boggles) or transaction fees for taking money from the hole in the wall and other services.
I estimated the costs could be as high as 800 Euro a year.
But it is simply daylight robbery and too many of you could be getting ripped off (I have no better words for it I am afraid) because you think that ‘it is just not worth the hassle of changing’ or ‘they are all alike’ or ‘banking back home is much better’.
However, this is no longer the case. In the last few years, Italian banks have really started to compete for business and there are options available. If you are happy with internet banking, then that’s even better.
I personally use 2 banks (personal and business). My personal account is Fineco (who? I hear you say). Fineco! (part of the Unicredit group). I am VERY satisfied with the service they offer. It is an exceptionally well operated online bank and even won the Global Finance Award for Best bank in Italy in 2013. It is 100% online. Now, I imagine that you might be thinking, online – Italy – errr, not sure, I need to keep an account where I can talk with someone if things go wrong. But, for basic banking it operates very smoothly. And I have emailed them many times and got responses within 24 hours.
And the best part is, at the time of writing:
ZERO canone. In other words no monthly, quarterly or annual charges just for having an account. FREE withdrawals from ANY cash machine throughout the whole of Italy. FREE credit card cash withdrawals from any Unicredit machines in Italy (and there are many). ZERO cost bank transfers in Italy.
My other bank for the business is Banca Popolare del Commercio e dell’Industria. This does not mean much, but it is part of the larger UBI banca group network.
I chose this account at a branch as it is a business account and I need to speak with my bank Director from time to time, but otherwise I operate everything online.
I pay only 5 EUR a month for this account and 0.50 Eur to make bank transfers. I can also withdraw cash from the UBI Banca group bancomats for FREE. The account, in general, is more expensive than the Fineco account but it is a business account and it has to be expected.
However, there are other personal account options with similar cost structures to Fineco, such as Ingdirect, Webank, Chebanca or Hellobank.
A good comparison website is www.confrontaconti.it
My simple message is to pay some attention to your bank account in Italy if you have not done so for some time. It is not difficult to change or use accounts, as in the past. With basic Italian you can do it without any problems.
You could be making huge savings just through changing bank accounts. They are as easy to operate as online bank accounts abroad and if, in this person’s case, a saving of 800Eur a year can be made then I would think it is definitely worth it. Any savings made can compensate for the increased taxes in recent years!
Take some time and have a look at your old bank statements to see what charges you are paying and compare this on the web link above to find out how much you ‘could’ be paying.
Tax and residency in Italy
By Gareth Horsfall
This article is published on: 12th January 2015
No 1. Expat tax Grief
Not a week goes by these days, where I am not contacted by someone who has a question about their residency in Italy, and what that means for them fiscally. Either by people who are about to move to Italy or others who have already been living here for some time and want to become ‘in regola’.
The conversation then naturally flows into the minutiae of exactly what are the taxes that need to be paid in Italy.
So, I would write and explain those pesky taxes that apply to expats who have income being paid and/or assets held in other countries. It may act as a good guide for those who are thinking about, or in the process of, doing something about their Italian tax returns for 2014.
Where to start?
Well, firstly I start by confirming that, as a resident in Italy, you are subject to taxation on your worldwide assets and income (with some exceptions). That means that if you are a resident in Italy then you are required to declare your assets and income, wherever they might be located or generated in the world.
TAX ON INCOME
If you are in receipt of a pension income, for example, and it is being paid from a private pension provider overseas or a state pension, then that income has to be declared on your Italian tax return (nb. different rules apply to Government service pensions, where tax is generally deducted at source in the country of origin and there is no further requirement to report the income in Italy). If tax is deducted at source in the country of origin, the income must still be declared again in Italy. A tax credit will be given for the amount of tax paid in the country of origin (assuming that country has a double taxation agreement with Italy), but any difference between the tax rates in the country of origin and Italy will have to be paid.
It is a similar picture for income, generated from employment. This is a slightly more complicated issue that depends on many factors and, therefore, I shall not dwell on it here. If you have any questions in this area you can contact me on the details at the bottom of this page.
INVESTMENT INCOME AND CAPITAL GAINS
This is one area where Italy excels above other countries, in that its system of calculation is very simple. As of 1st July 2014, interest from savings, income from investments in the form of dividends and other income payments are taxed at a flat 26%. Capital gains tax is the same rate of 26%.
** Interest from Italian Government Bonds and Government Bonds from ‘white list’ countries is still taxed at 12.5% rather than 26%, as detailed above. This is another quirk of Italian tax law as this means it is more convenient, from a tax position, to invest in Government Bonds in Pakistan or Kazakhstan, than it is to buy corporate Bonds from Italian corporate giants ENI or Unicredit. **
PROPERTY OVERSEAS
Property which is located overseas is taxed in 2 ways. Firstly, there is the tax on the income and, secondly, a tax on the value of the property itself.
1. Income from property overseas.
Unlike rental property located in Italy, which is taxed at the rate of approx 23% depending on what kind of rental you operate, overseas income from property is added to your other income for the year and taxed at your highest rate of income tax.
There is one advantage to this, in that tax in the country of origin has to be applied to the income in the first instance. Therefore, the net income (after expenses) in the country of origin is added to your other income in Italy for the year. This can be quite useful if the property/ies are investment properties, the expenses are high, the country of origin allows multiple deductions and the net income position is low. However, as I have written before, if you are reliant on the income to live on, then a high net income position (before declaration in Italy) can result in a much lower net amount (after Italian tax) depending on the amount of other income you receive each year. Once your total income for the year moves above €28,000 you enter into the punishing 38% tax bracket in Italy.
This can prove to be a tax INEFFICIENT income-stream for those hoping to live in Italy by relying on income from property overseas.
2. The other tax is on the value of the property itself, which is 0.76% of the value.
However, value must be defined in this instance. For EU based properties, the value is the Italian cadastral equivalent. In the UK (the area I am most familiar with), that would be the council tax value NOT the market value. You will find that the market value will, in most cases, be more than the cadastral equivalent value.
In properties located outside the EU, the value for tax purposes is defined as the market value of the property ONLY where evidence cannot be provided of the purchase value of the property, in which case this would be used instead.
TAXES ON ASSETS
It would not be right that other assets escaped Scot free!
BANK ACCOUNTS AND DEPOSITS
A very simple to understand and acceptable €34.20 per annum is applied to each current account you own. However, from 2014 every deposit account that you own overseas with an ‘average’ balance of €5,000 in it, each calendar year, is taxed at the rate of 0.2% of the average balance throughout the year. This includes fixed deposits, short term cash deposits, CD’s etc. The charge is the equivalent of the ‘imposta da bollo’ which is applied to all Italian deposit accounts each year.
Lastly, we have the charge on other foreign-owned assets (IVAFE). This covers shares, bonds, funds, portfolio assets or most other types of assets that you may hold. The tax on these is 0.2% per annum, (from Jan 1st 2014) based on the valuation as of 31st December each year.
This guide is only meant to be a broad outline of the taxes that affect most expats. It is not a full tax list and does not take into account personal circumstances. It is intended to be a guideline to help you make the right decisions.
My experience over the last 4 years has been, in most cases, that expats will end up paying more by being resident in Italy (which most seem to accept as OK, for the lifestyle they can lead) but, there are often a number of financial planning opportunities, to protect, reduce, and avoid certain taxes, that few take advantage of.
If we haven’t discussed these already or if you would like an initial chat to discover whether any of those opportunities are open to you then please feel free to contact me. There are no fees for enquiries and consultations.
