A few notes to share.
ODD: I have heard that FINRA is issuing deficiency letters to firms that have outside FINOPs if the FINOP is listed as a ‘control person’ on Form BD and if the Form BD doesn’t list every other client firm of that outside FINOP as an affiliate of the firm. So if you're using an outside FINOP, check your Form BD. If he or she is listed as a 'control person' on Schedule A, then under this interpretation, all of his or her other BD clients for whom he or she acts as FINOP must be disclosed as affiliates on Question 10A.
The reasoning (if there is any) would be that all of the entities are under common control by virtue of the outsourced FINOP being a control person of those entities. Obviously, this would unnecessarily and confusingly link completely unrelated firms.
So, the best thing to do is to file a BD amendment, removing your outsourced FINOP as a control person from Schedule A. (Of course, if that person meets the other criteria for being listed on Schedule A--through ownership, for instance--then you'll have to keep him/her listed...but that doesn't seem likely for truly outsourced FINOPs.)
END: The exemption for non-public B-D's from using a PCAOB-registered accounting firm for annual audits is now gone. It expired December 31, 2008. Your 2008 financial statements may be audited by your non-PCAOB firm, but next year is a different matter. You'll have to replace your accounting firm or make sure it got its PCAOB registration before committing to use them for next year's audit. FINRA says it's talking directly to those few firms who have January or February fiscal year-ends.
You may want to work on this before the months evaporate and you find yourself without a registered accounting firm next year. Remember that if you change your accountant you must notify SEC by December 10. Put this on you calendar!
OTHER: FINRA Notice 09-10 describes a change in their treatment of "market letters," which are now a subset of "correspondence" instead of "sales literature." As sales literature, they required pre-approval by a qualified principal--even if sent to institutional investors. Now they are treated like other correspondence and institutional sales material, and their approval requirements will depend on whom they're being sent to and how many are sent within 30 days. You should look to your existing procedures on correspondence and institutional sales material to know which approval processes to follow.
I like this distinction, because it clearly defines those communications not meeting the definition of "research report" that might have otherwise been confused with research reports. For instance, market letters are communications that discuss broad-based indices, include commentaries on economic, political or market conditions, include technical analyses of sectors, indices, or industries, statistical summaries of multiple companies' financial data, including listings of current ratings, present recommendations for increasing or decreasing holdings in particular industries or sectors, or include notices of ratings or price target changes (with certain disclosures).
OTHER: I hear that FINRA will be requiring all firms to update Forms U4 for all representatives, in order to provide answers on some new DRP questions. This will be quite a job for big firms. Stay tuned on this, as no doubt we'll all see a public announcement of the requirement. I'll be helping my clients to manage this process--you will want to make sure you appoint someone to handle it, so you that you avoid reporting deficiencies.
That's it for now. Peace out.
Friday, February 20, 2009
Monday, February 2, 2009
Shame on Who?
I have a "Yes We Can Opener" to commemorate Obama's presidency. I got it at Stupid.com. I'm not ashamed to share that with you (or it with you--c'mon over!). But Mr. Obama is ashamed: of you!
Yes, he's a little upset about the Wall Street bonuses paid for 2008. Well, even though this topic is of no value to you and will not broaden your understanding of current and changing compliance obligations, I feel like talking about it. It's my blog: I'll cry if I want to.
Is the car factory worker to blame for the auto industry's failure? Is the farmhand at fault for the effect of subsidies on our crop market inefficiencies? No. Then why are our brokers blamed for this big financial crisis we're in? Every work day last year these folks got to work by 7:30 or 8:00 a.m. , dressed quite well, by the way, and worked until an hour or two after market closing. They did what was expected of them from on-high: they bought, sold and bartered their way through the day so as to make their bosses happy. They invented or used flashy software tools, trading algorithms and order management systems in order to efficiently get the job done. They did it with skill and enthusiasm...not because they wanted to take down the free market system, but because they wanted to get paid. In their (your) world, they get paid at year-end. They all know it's coming, so they live accordingly. I would do the same. But now comes the end of the world as we know it, and some of us decide to blame the baby in addition to the bath water. What were these legions of Wall Street workers supposed to do? Fall on their superiors' swords? Not expect to get paid for a year's worth of toil and trauma? I don't think so. Yes, they can now all adjust their expectations for 2009: the gig's up. And yes, senior management--the guys/ladies who made the decisions that directly fed our slots-like odds of failure--they should go without their '08 bonuses. They can put their gold in pre-paid envelopes and walk to the post office. Responsibility for this mess falls on those at the top.
Wait, if you're conjuring WWII images, don't. Soldiers know slaughter is wrong; most brokers don't have the tools or knowledge necessary to morally object to their crimes. Or didn't. Now they do. This transition to less fun, less money and great social responsibility will be tough for brokers. I wish you well. And I wish Obama a stronger will to avoid rhetoric.
If you stop by to use my Yes We Can opener, we'll be drinking Iron City. (The Steelers six pack is in the house.)
Yes, he's a little upset about the Wall Street bonuses paid for 2008. Well, even though this topic is of no value to you and will not broaden your understanding of current and changing compliance obligations, I feel like talking about it. It's my blog: I'll cry if I want to.
Is the car factory worker to blame for the auto industry's failure? Is the farmhand at fault for the effect of subsidies on our crop market inefficiencies? No. Then why are our brokers blamed for this big financial crisis we're in? Every work day last year these folks got to work by 7:30 or 8:00 a.m. , dressed quite well, by the way, and worked until an hour or two after market closing. They did what was expected of them from on-high: they bought, sold and bartered their way through the day so as to make their bosses happy. They invented or used flashy software tools, trading algorithms and order management systems in order to efficiently get the job done. They did it with skill and enthusiasm...not because they wanted to take down the free market system, but because they wanted to get paid. In their (your) world, they get paid at year-end. They all know it's coming, so they live accordingly. I would do the same. But now comes the end of the world as we know it, and some of us decide to blame the baby in addition to the bath water. What were these legions of Wall Street workers supposed to do? Fall on their superiors' swords? Not expect to get paid for a year's worth of toil and trauma? I don't think so. Yes, they can now all adjust their expectations for 2009: the gig's up. And yes, senior management--the guys/ladies who made the decisions that directly fed our slots-like odds of failure--they should go without their '08 bonuses. They can put their gold in pre-paid envelopes and walk to the post office. Responsibility for this mess falls on those at the top.
Wait, if you're conjuring WWII images, don't. Soldiers know slaughter is wrong; most brokers don't have the tools or knowledge necessary to morally object to their crimes. Or didn't. Now they do. This transition to less fun, less money and great social responsibility will be tough for brokers. I wish you well. And I wish Obama a stronger will to avoid rhetoric.
If you stop by to use my Yes We Can opener, we'll be drinking Iron City. (The Steelers six pack is in the house.)
Friday, November 28, 2008
Update on FACT Act
First, let me share my appreciation for FINRA's effort to explain the applicability of the FACT Act's Red Flag and other rules to member firms. The folks in OGC said they were working on it, and they did. Here's the link to Notice 08-69: http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p117448.pdf
Now, let me express my dismay at the extreme lack of distinct clarity on this topic--not necessarily from FINRA, but embedded in the Act's definitions. Your firm may be subject to the regulation, or not--just read and re-read the definitions of 'financial institution,' 'transaction account, 'creditor' and 'covered account.' It's a little like solving a Rubik's cube. If all like colors end up on the same side, then yes, your firm has to implement Red Flag Rules under the Fact Act. But good luck getting there.
In reading the definitions provided in FINRA's notice, my first reaction is, "If they wanted broker-dealers to be covered, why didn't they just say so?" For instance, the term“financial institution” is specifically defined as “a State or National bank, a State or Federal savings and loan association, a mutual savings bank, a State or Federal credit union, or any other person that, directly or indirectly, holds a transaction account . . . belonging to a consumer.” And a “transaction account” is specifically defined as “a deposit or account on which the depositor or account holder is permitted to make withdrawals by negotiable or transferable instrument, payment orders of withdrawal, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others. Such term includes demand deposits, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers, and share draft accounts.” See what I mean? If they wanted B-D's to be subject to the regs, why not just include "SEC registered broker-dealers" or "brokerage accounts" or some such other simple identifiers in the definitions? That would have made it real easy... but instead, these definitions overtly exclude the whole subject of brokerage accounts and broker-dealers. And then your favorite SRO puts the onus on firms to twist and retwist the cube in order to solve the puzzle by themselves. Frankly, for most of the 5100 registered B-D's, I think this is like trying to force a square cube through a round hole: I don't think these rules should apply.
Also, while I'm ranting, this whole thing is crazy!! B-D's already have CIP rules to follow. And remember that AML rules are not just about preventing money laundering. We all know that most AML-triggered investigations end up focusing on fraud, including mail fraud and credit/debit card fraud. So firms are already obligated to attempt to identify and report fraud....why do they have to now be subject to seemingly duplicative rules? And at what cost? ...read the Notice... do you really have time to create a "Written Identity Theft Prevention Program"? One that will confuse your already confused Reps about the account opening process? This reminds me of redundant local ordinances--instead of having one rule that requires safe and responsible behavior on sidewalks, they have in place six different rules, pertaining to different possible ways to conduct unsafe and irresponsible behavior on sidewalks: skateboarding, bicycling, rollerblading, dog walking, etc.... get my point? I guess I just feel sorry for firms whose business has nothing at all to do with credit cards, withdrawals, payment transfers, etc. To think that they will have to adopt lengthy and complicated procedures on top of what they already have in place (which are already hardly deemed necessary and applicable): what a waste of resources.
But who am I ranting at, here? The Federal Trade Commission? That's a big target for a little person like me. And I don't want to trash FINRA--they did something cool by addressing the subject. I guess I would like if FINRA would go a bit farther out on the limb by actually giving its opinion on how application way firms, M&A/PP shops, and introducing firms who do not actually extend margin to clients fit into this definitional puzzle. I know they state up front that they're not the rulemakers or interpreters on this subject, but c'mon, since they go on to say that NOT complying would be a violation of just and equitable principles of trade, can't they show a little more mercy?
Another topic within this one: check out Part C of the Notice. It's about policies you have to have in place re: use of consumer reports. If your firm requests a consumer report about a new or existing customer and receives a notice of address discrepancy from a CRA, you'll have to be able to form a reasonable belief that the consumer report actually relates to the customer in question. FINRA did a nice job of laying out these responsibilities. I'm assuming the effective date of these requirements is the same delayed date as for Red Flag Rules: May 1, 2009 (although I could be wrong.)
Lastly, FINRA mentions in the Notice that FTC has indicated a willingness to work with them to "resolve on a consistent and industry-wide basis, interpretive questions that arise under these rules as applied to broker-dealers. " I love that! My advice to you and all your B-D friends: call OGC at (202)728-8071 to ask about this. Perhaps that kind of dialogue will result in 'interpretive challenges' being met head on with concrete directives from FINRA. Then you can throw that darned Rubik's cube out the window. Puzzle solved.
Now, let me express my dismay at the extreme lack of distinct clarity on this topic--not necessarily from FINRA, but embedded in the Act's definitions. Your firm may be subject to the regulation, or not--just read and re-read the definitions of 'financial institution,' 'transaction account, 'creditor' and 'covered account.' It's a little like solving a Rubik's cube. If all like colors end up on the same side, then yes, your firm has to implement Red Flag Rules under the Fact Act. But good luck getting there.
In reading the definitions provided in FINRA's notice, my first reaction is, "If they wanted broker-dealers to be covered, why didn't they just say so?" For instance, the term“financial institution” is specifically defined as “a State or National bank, a State or Federal savings and loan association, a mutual savings bank, a State or Federal credit union, or any other person that, directly or indirectly, holds a transaction account . . . belonging to a consumer.” And a “transaction account” is specifically defined as “a deposit or account on which the depositor or account holder is permitted to make withdrawals by negotiable or transferable instrument, payment orders of withdrawal, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others. Such term includes demand deposits, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers, and share draft accounts.” See what I mean? If they wanted B-D's to be subject to the regs, why not just include "SEC registered broker-dealers" or "brokerage accounts" or some such other simple identifiers in the definitions? That would have made it real easy... but instead, these definitions overtly exclude the whole subject of brokerage accounts and broker-dealers. And then your favorite SRO puts the onus on firms to twist and retwist the cube in order to solve the puzzle by themselves. Frankly, for most of the 5100 registered B-D's, I think this is like trying to force a square cube through a round hole: I don't think these rules should apply.
Also, while I'm ranting, this whole thing is crazy!! B-D's already have CIP rules to follow. And remember that AML rules are not just about preventing money laundering. We all know that most AML-triggered investigations end up focusing on fraud, including mail fraud and credit/debit card fraud. So firms are already obligated to attempt to identify and report fraud....why do they have to now be subject to seemingly duplicative rules? And at what cost? ...read the Notice... do you really have time to create a "Written Identity Theft Prevention Program"? One that will confuse your already confused Reps about the account opening process? This reminds me of redundant local ordinances--instead of having one rule that requires safe and responsible behavior on sidewalks, they have in place six different rules, pertaining to different possible ways to conduct unsafe and irresponsible behavior on sidewalks: skateboarding, bicycling, rollerblading, dog walking, etc.... get my point? I guess I just feel sorry for firms whose business has nothing at all to do with credit cards, withdrawals, payment transfers, etc. To think that they will have to adopt lengthy and complicated procedures on top of what they already have in place (which are already hardly deemed necessary and applicable): what a waste of resources.
But who am I ranting at, here? The Federal Trade Commission? That's a big target for a little person like me. And I don't want to trash FINRA--they did something cool by addressing the subject. I guess I would like if FINRA would go a bit farther out on the limb by actually giving its opinion on how application way firms, M&A/PP shops, and introducing firms who do not actually extend margin to clients fit into this definitional puzzle. I know they state up front that they're not the rulemakers or interpreters on this subject, but c'mon, since they go on to say that NOT complying would be a violation of just and equitable principles of trade, can't they show a little more mercy?
Another topic within this one: check out Part C of the Notice. It's about policies you have to have in place re: use of consumer reports. If your firm requests a consumer report about a new or existing customer and receives a notice of address discrepancy from a CRA, you'll have to be able to form a reasonable belief that the consumer report actually relates to the customer in question. FINRA did a nice job of laying out these responsibilities. I'm assuming the effective date of these requirements is the same delayed date as for Red Flag Rules: May 1, 2009 (although I could be wrong.)
Lastly, FINRA mentions in the Notice that FTC has indicated a willingness to work with them to "resolve on a consistent and industry-wide basis, interpretive questions that arise under these rules as applied to broker-dealers. " I love that! My advice to you and all your B-D friends: call OGC at (202)728-8071 to ask about this. Perhaps that kind of dialogue will result in 'interpretive challenges' being met head on with concrete directives from FINRA. Then you can throw that darned Rubik's cube out the window. Puzzle solved.
Friday, November 21, 2008
Networking Rocks!
Big shout out to Christine at IMS. Prompt, thorough assistance on a compliance issue. Gracias, Amiga!
r-e-s-p-e-c-t
...that's what binds both you and me.
I made that rhyme for your auditory pleasure. Say it out loud, go ahead.
I want my clients to know that, not only do I like you, I respect you--that is, I think the work you are doing is hard and you should be praised for that. Many in the media are trashing investment bankers, brokers and bankers, alike, as if they alone are to blame for the market turmoil. We know that's not true. You, my clients, are creative individuals who choose to make a living by making other people money. That ain't no crime. And the more creativity, energy and motivation you have, most likely, the more money your clients will make. (That came out a bit like Yoda-speak.)
Oh, and what I really want to say is thank-you for likewise respecting me and my work. It's an honor to help you out and I benefit everyday from your appreciation for what I do.
Oh my gosh, this touchy feely stuff is hard to take, non? Okay, back to my Rule Conversion/WSP update work...
I made that rhyme for your auditory pleasure. Say it out loud, go ahead.
I want my clients to know that, not only do I like you, I respect you--that is, I think the work you are doing is hard and you should be praised for that. Many in the media are trashing investment bankers, brokers and bankers, alike, as if they alone are to blame for the market turmoil. We know that's not true. You, my clients, are creative individuals who choose to make a living by making other people money. That ain't no crime. And the more creativity, energy and motivation you have, most likely, the more money your clients will make. (That came out a bit like Yoda-speak.)
Oh, and what I really want to say is thank-you for likewise respecting me and my work. It's an honor to help you out and I benefit everyday from your appreciation for what I do.
Oh my gosh, this touchy feely stuff is hard to take, non? Okay, back to my Rule Conversion/WSP update work...
Just a few notes on AML
Hey there, busy over here. Year-end always comes too quickly. I wish you all well in the markets and in your securities business. Hang in there.
Kinda recently, FinCEN published their newest SAR Activity review… here is the link: FinCEN Publishes SAR Activity Review- By the Numbers – Issue 11
Here is their summary analysis regarding SAR filing increases in the first 6 months of 2008:
Suspicious Activity Reports characterizing the suspicious activity type as Credit/Debit Card Fraud increased 58%, compared to the corresponding six month period in 2007.
In 2008, Suspicious Activity Reports characterizing the suspicious activity type as Mail Fraud increased 49%, compared to reports filed during the same period in 2007.
The total suspicious activity reporting volume in the first six months of 2008 increased 18%, compared to the same period in 2007.
Suspicious Activity Reports characterizing the suspicious activity type as Money Laundering/Structuring increased 15%, compared to the corresponding six month period in 2007.
And, this came out last month… as you know, investment advisers are not currently required to have AML programs in place, although most these days are adopting programs to meet the expectations of investors and broker-dealers. The announcement (see below) informs us that the proposed rule to require IA’s (SEC-registered IA’s and unregistered IA’s with $30mm under management) to have AML programs has been dropped. They say that if IA’s in the future are to be subject to FinCEN AML program requirements, a new rule will have to be proposed and adopted.
What that means for you, maybe: if you as a BD had hoped your unregistered IA friends would have their own darned AML rules to follow, so that you could rely on them to do it for you when they introduce investors to you, well, forget it. The currently-effective SEC no-action letter (effective 1-12-08) allows you to rely on federally-regulated IA's to do that--not unregulated IA's. I have that letter in my files; if you want me to email it to you, just ask.
Here is FinCEN's announcement, pulling the proposed IA rule proposal:
From: http://www.fincen.gov/news_room/nr/html/20081030.html
October 30, 2008
FinCEN Withdraws Dated AML Rule Proposals for Unregistered Investment Companies, Commodity Trading Advisors, and Investment Advisers
VIENNA, Va. – As part of its overall effort to increase its efficiency and effectiveness in administering the Bank Secrecy Act (BSA), the Financial Crimes Enforcement Network (FinCEN) has withdrawn its proposed anti-money laundering (AML) program rules for unregistered investment companies, commodity trading advisors and investment advisers. The withdrawals of the proposed program rules have been submitted for publication in the Federal Register.
Given the passage of time since these rules were first proposed in 2002 and 2003, FinCEN has determined that it will not proceed with BSA requirements for these entities without publishing new proposals and allowing for industry comments. FinCEN will continue to consider whether and to what extent it should impose requirements under the BSA on these entities.
Since the proposed rules were first published, FinCEN has concluded rulemakings for banks, broker-dealers and futures commission merchants. The financial transactions of unregistered investment companies, investment advisers, and commodity trading advisors and their clients must be conducted through, and their assets carried by, other financial institutions that are subject to BSA requirements. Thus, as FinCEN continues to consider the extent to which BSA requirements should be imposed on these entities, their activity is not entirely outside the current BSA regulatory regime.
In an effort to make its rulemaking processes more transparent, FinCEN today also established a section of its website entitled "Pending Rules" where those rules that are still awaiting comments or finalization will be made easily available.
Thursday, October 30, 2008
I'm Going as a Conversion Chart for Halloween
Reason? It's the scariest thing I can think of.
Remember when NASD Reg. merged with NYSE reg.? And they said they'd be consolidating the rulebooks? Well, the first set of Rule Conversions was released by FINRA on October 16. For 34 pages of fright, see Notice 08-47 at: http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p117255.pdf
This shows the changes that are effective in 60 days. Many changes are simply adopting current NASD Rules and incorporating old NYSE Rules into brand new FINRA Rules—with no substantive changes. But the quantity of information is scary: 564 items in the handy “Conversion Chart.”
http://www.finra.org/Industry/Regulation/FINRARules/p085560 . This chart shows the old NASD Rule number and the new, corresponding FINRA Rule number (I'm not addressing NYSE Rule changes here, since that's not my area of expertise). That’s helpful, but not as great as it could be. I mean, each of these conversion listings has links to the old and new Rules, the Federal Register with the Rule Filings and approval orders, and any amendments to Rule Filings. The chart doesn’t comment on the nature of the changes represented: minor, technical or substantive. You have to cross reference the Notice (above) for any mention of that. Or open up the Rule Filing and start reading… a lengthy process, for sure.
I've added two columns to the chart: "Summary of Changes" and "In WSP? Changes Necessary?" This way, I'll record the results of my painstaking investigation into each and every cited change. Process: open up 'filing number' link on chart; read summary; open up 'text of proposed rule change' and any amendment links, read 'til I'm cross-eyed, then summarize changes on the table. Next, go to WSP, look for old Rule citations, change them, and add any text necessary to incorporate substantive Rule changes. That's it! I only have 547 items to go. I'm on a roll.
Seriously though, many of these changes relate to things like arbitration claims procedures and other administrative Rules that are generally not included in a firm's WSP. So, maybe in the end only a handful of these announced conversions will result in real written procedural changes. (Wait, this reminds me of the difference between the 'real America' and the, well, not-so-real America and that silly Congresswoman's call for Congressional hearings to route out the fakers... oops, wrong scary blog site...) Anyway, I'm not one to make assumptions and will therefore poke through every item on this chart. I'm praying to the Great Pumpkin and Santa Claus that the next released Conversion Chart will be waaaaaay less lengthy/frightening.
I encourage you to take the time to look at the recent Notice and to open up subsequent bi-monthly Notices. Scroll down through the list of Rule changes for those that are relevant to your business. It certainly won't pay to put off attention to this. Face these demons now: 'tis the season.
Have a sweet Halloween.
Remember when NASD Reg. merged with NYSE reg.? And they said they'd be consolidating the rulebooks? Well, the first set of Rule Conversions was released by FINRA on October 16. For 34 pages of fright, see Notice 08-47 at: http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p117255.pdf
This shows the changes that are effective in 60 days. Many changes are simply adopting current NASD Rules and incorporating old NYSE Rules into brand new FINRA Rules—with no substantive changes. But the quantity of information is scary: 564 items in the handy “Conversion Chart.”
http://www.finra.org/Industry/Regulation/FINRARules/p085560 . This chart shows the old NASD Rule number and the new, corresponding FINRA Rule number (I'm not addressing NYSE Rule changes here, since that's not my area of expertise). That’s helpful, but not as great as it could be. I mean, each of these conversion listings has links to the old and new Rules, the Federal Register with the Rule Filings and approval orders, and any amendments to Rule Filings. The chart doesn’t comment on the nature of the changes represented: minor, technical or substantive. You have to cross reference the Notice (above) for any mention of that. Or open up the Rule Filing and start reading… a lengthy process, for sure.
I've added two columns to the chart: "Summary of Changes" and "In WSP? Changes Necessary?" This way, I'll record the results of my painstaking investigation into each and every cited change. Process: open up 'filing number' link on chart; read summary; open up 'text of proposed rule change' and any amendment links, read 'til I'm cross-eyed, then summarize changes on the table. Next, go to WSP, look for old Rule citations, change them, and add any text necessary to incorporate substantive Rule changes. That's it! I only have 547 items to go. I'm on a roll.
Seriously though, many of these changes relate to things like arbitration claims procedures and other administrative Rules that are generally not included in a firm's WSP. So, maybe in the end only a handful of these announced conversions will result in real written procedural changes. (Wait, this reminds me of the difference between the 'real America' and the, well, not-so-real America and that silly Congresswoman's call for Congressional hearings to route out the fakers... oops, wrong scary blog site...) Anyway, I'm not one to make assumptions and will therefore poke through every item on this chart. I'm praying to the Great Pumpkin and Santa Claus that the next released Conversion Chart will be waaaaaay less lengthy/frightening.
I encourage you to take the time to look at the recent Notice and to open up subsequent bi-monthly Notices. Scroll down through the list of Rule changes for those that are relevant to your business. It certainly won't pay to put off attention to this. Face these demons now: 'tis the season.
Have a sweet Halloween.
Subscribe to:
Posts (Atom)
