Avoiding the Black Swan: Barriers to Improving Risk Management

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Avoiding the Black Swan: Barriers to Improving Risk Management
November 2009
                                          Survey Results

Avoiding the Black Swan:
Barriers to Improving Risk Management

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2
Avoiding the Black Swan: Barriers
                                                                                                          to Improving Risk Management

Executive Summary                             While troubling in significant ways, these                  Nearly half of the survey respondents
Almost daily, U.S. business journals          survey results also point to important                      listed themselves as CFOs, while 17
have chronicled the failure of major          opportunities for top executive teams to                    percent said their title was vice president
corporations to discover, evaluate, and       quickly and effectively begin assessing                     of finance and another 12 percent were
mitigate the serious risks that have          their corporate risk management and                         directors of finance. They were from
crippled the companies and financial          installing programs that will go a long                     companies in every major industry, from
markets. The disastrous results felt          way toward restoring the confidence                         auto, industrial, and manufacturing to
throughout the economy have given             of investors and stakeholders where                         financial services, real estate, and retail.
new and sharp meaning to the dire             necessary.
                                                                                                          Results
need for more muscular, comprehensive
                                              Research Objectives                                         The Biggest Challenge: Managing Risk
enterprise risk management (ERM) in
                                              and Methodology                                             The survey respondents show a
corporate America.
                                              Crowe commissioned this research study                      heightened awareness that as the
This survey from Crowe Horwath LLP,           in order to determine CFOs’ perspectives                    business environment has become more
in collaboration with CFO Research            on managing risk across a number of                         complex and more global, new varieties
Services, is particularly timely for          dimensions. The study was also geared                       and levels of risk have been created in all
corporate executives at every level.          to identify how CFOs interact and                           types of business units.
Conducted in April 2008, even before          collaborate with others, including the
                                                                                                          Asked what will be “particularly
the full extent of the country’s economic     board, the audit committee, and chief
                                                                                                          challenging for your organization in
problems was clear, this study reveals        audit executives.
                                                                                                          the next 12 months,” fully 65 percent
troubling barriers to excellence in
                                              The study was conducted in April                            said “managing risk across the entire
corporate audit efficiency and risk
                                              2008 and was answered by 157 chief                          company.” Slightly less than half listed
management. It is hardly a reach to
                                              finance executives at a broad range of                      “improving financial reporting” as a
suggest that the deficiencies revealed in
                                              companies across North America, with                        particular challenge, and 43 percent
this survey could well have contributed
                                              revenues ranging from $100 million to                       chose “improving internal controls”
to the magnitude of the economic
                                              more than $10 billion a year.                               (Exhibit 1). Each of these concerns, of
collapse that has imperiled the country.
                                                                                                          course, is an important element of ERM.
At the same time, it offers a variety of
guides and lessons for improving risk       Exhibit 1: The Biggest Challenges
management at key corporate levels          “Which of the following activities do you believe will be particularly challenging for your
as the country struggles through            organization in the next 12 months?”
recovery and re-establishes its
                                                       Managing risk across the entire company                                          65%
economic strength.
                                                                    Improving financial reporting                            47%
Chief finance officers across the
                                                                     Improving internal controls                           43%
country, for example, revealed a
                                                                      Complying with regulation                      34%
surprising lack of understanding
and support within many of their            Adopting International Financial Reporting Standards           18%

corporations for effective ERM. Too                      Developing a fraud prevention program       8%

many of their C-suite colleagues,                             Monitoring whistle-blower process      6%

they said, believe such programs are              Complying with Foreign Corrupt Practices Act      5%
“unnecessary” – a startling response
                                                                                           Other     7%
in light of the dismal risk assessment
                                                                                                    0%         20%         40%         60%          80%
performance of so many corporations.

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But if managing risk across the
entire company poses the main               Exhibit 2: Barriers to Change
challenge for these executives,             “In your opinion, what are the greatest obstacles to improving risk management at
                                            your company?”
the Crowe study shows that
they face daunting obstacles.                             Lack of time, attention, and resources                                                     48%
More than a third of the finance
                                             Perception of risk management as an unnecessary
                                                                                                                                       35%
executives, for example, said their                          interference with business activities
companies see risk management               Lack of shared understanding and approach to risk                                          35%
                                              management across business units/departments
“as an unnecessary interference with
                                                 Lack of dedicated risk management resources                                 26%
business activities.” And the same
percentage, 35 percent, said their             Lack of tools, frameworks, and decision-making
                                                                                                                             26%
                                                                 structures for risk management
companies showed a “lack of shared
                                                                       Organizational resistance                            24%
understanding and approach to
risk management across business                                        Lack of internal expertise                14%
units” (Exhibit 2).
                                                      Lack of senior management commitment                      12%
Nearly half of the survey respondents
said that the greatest obstacle                             Overly complex corporate structure                  12%

to improving risk management at                       Inadequate or overly complex technology
                                                                                                               10%
                                                                      and information systems
their company was “lack of time,
attention, and resources.” More                           Lack of independence of risk function       5%

specifically, the financial executives           Lack of strength and capabilities in the internal
                                                                                                     3%
                                                                                   audit function
pointed to a “lack of dedicated
                                                                                            Other         2%
risk management resources,”
“lack of tools, frameworks, and                                                                      0%         10%       20%       30%        40%         50%
decision-making structures for risk
management,” and “organizational
                                                assessing and then managing two main                            process existed to assess and manage
resistance” as key barriers to successful
                                                categories of corporate risk: financial and                     operational risk. This finding is in line
risk management in their companies.
                                                operational. Further and more important,                        with responses to another survey
Twelve percent flatly pointed to “lack
                                                the survey shows that, in light of today’s                      question showing that companies were
of senior management commitment.”
                                                corporate performance and the inability                         more tolerant of operating risk than
Clearly there is work to do in
                                                to recognize and head off serious                               financial risk.
developing and upgrading ERM
                                                financial risk, ERM is largely not working.
                                                                                                                Nearly half of the finance executives said
across corporate America.
                                                In response to one survey question, 73                          their companies were either very tolerant
More than that, the survey indicates
                                                percent of the respondents, for example,                        or somewhat tolerant of operating risk.
that these barriers to effective ERM
                                                said their companies had in place a                             Only 38 percent, on the other hand, said
are indeed having an impact. It shows,
                                                coordinated, centralized process for                            their companies were very or somewhat
for example, a potentially damaging
                                                overseeing financial risk, while fewer                          tolerant of financial risk.
inconsistency on the part of companies in
                                                than half, only 47 percent, said a similar

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Avoiding the Black Swan: Barriers
                                                                                                           to Improving Risk Management

The Causes for Concern
It has turned out, however, that many              Exhibit 3: Causes for Concern
companies were not equipped to assess              “In the past three years has your company’s performance been disrupted in a
                                                   substantial way by surprises in any of the following categories? In your opinion,
their exposure, particularly to new
                                                   which of the following categories poses a substantial cause for concern at your
financial market risk. And now, as the             company in the next year?”
economy gradually recovers, financial
executives show signs of having greater                                                                                     36%
                                                                   Financial factors
awareness of financial risk.                                                                                                      40%

                                                                                                                      31%
                                                                Operational factors
Forty percent of the survey respondents,                                                                              31%
for instance, said that financial factors                                                                            29%
                                                                Technology factors
                                                                                                                                  40%
would be a “substantial cause for
                                                                                                                    27%
concern” during the next year (Exhibit 3).                           Market factors
                                                                                                                                    44%

An equal percentage was concerned                    Infrastructure/Physical factors                          22%
                                                                                                  13%
about technological factors, such as
                                                                                                           21%
information technology systems and                             Management factors
                                                                                                                    27%
communications problems. Only “market                                                                      21%
                                                                  Employee factors
factors,” such as loss of customers,                                                                                  31%

moves by competitors, and supply and                          Organizational factors                      19%
                                                                                                          19%
distribution chain difficulties, scored as a
                                                                                                    15%
slightly higher concern than financial or                Reputational/Legal factors
                                                                                              11%
technology factors.                                                                               14%
                                                                 Regulatory factors
                                                                                                        18%
Forty-four percent of those surveyed
                                                                                       0%       10%           20%         30%       40%        50%
– and remember this was before the
subprime and credit markets imploded                                                        Negative surprise in past three years

– were concerned about those market                                                         Substantial cause for concern over the next year

factors. Even so, when they were asked
which factors had been “surprise”
                                               program would address each of                               to reduce business risk. Back then,
disruptions of company performance, 36
                                               these areas.                                                54 percent said that “more timely and
percent pointed to unexpected financial
                                               Questions About Priorities                                  accurate financial forecasting” would
developments.
                                               and Execution                                               be their highest priority. This concern
The other top unwelcome surprises                                                                          was a natural consequence of efforts to
                                               Timing obviously influences the outlook
during the past three years? Thirty-one                                                                    comply with Sarbanes-Oxley and deal
                                               of these key financial executives. Three
percent said operational difficulties,                                                                     with investor and regulatory skepticism
                                               years earlier, for example, a similar
and 29 percent said technology had                                                                         following several years of corporate
                                               survey asked them to prioritize the
caused unpredictable disruptions. A                                                                        scandal, starting with Enron and
                                               “most critical” needs for their companies
comprehensive, companywide ERM                                                                             WorldCom.

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The next most needed anti-risk
measure, picked by 34 percent of               Exhibit 4: Critical for Cutting Business Risk
respondents then, was “improving               “In your opinion, which of the following are most crucial to address to reduce business
                                               risk at your company?”
corporate governance,” followed
by “improved production” in
fifth place, with only 25 percent                   Improved production and operating processes                   41%                       41%               17%

identifying it as their company’s                    More timely and accurate financial forecasting          37%                        48%                   16%
highest priority.
                                                                          Better inventory planning         23%         24%                       53%
In the April 2008 survey, “improved
                                                                Better information security/privacy        20%                 49%                      32%
production and operating
                                              Better enterprise software for finance and accounting    16%               41%                        42%
processes” moved to the top
position as the most-needed anti-                                 Improving corporate governance       12%              48%                         40%

risk measure, picked by 41 percent                                     Better outsourcing strategy     10%        25%                        65%
of the respondents. “More timely
                                                   Better management of outsourcing relationships      9%         30%                        61%
and accurate financial forecasting”
was the number two “high priority”                                                                    0%         20%        40%        60%          80%        100%
concern but now was picked
                                                                                           High priority                Moderate priority               Low priority
by a lesser 37 percent of the
respondents (Exhibit 4). Even as the
economy was headed for decline,
                                                     Are they as unprepared now as they                           Sixty-four percent of the responding
with companies across the spectrum
                                                     seemingly were in 2005 to cope with                          finance executives described themselves
having failed to anticipate weakening
                                                     dramatic and unforeseeable downturns                         as being in the leadership role for
financial conditions, these finance
                                                     in their business and the economy?                           developing their corporation’s risk
executives had shifted their priorities
                                                     A substantial opportunity exists for                         management strategy (Exhibit 5). Sixty-
from financial forecasting to improving
                                                     improving across-the-board management                        two percent also listed the C-suite
operations and production. These results
                                                     and assessment of risk. More than that,                      executive team for this leadership role.
raise serious questions about their
                                                     it would be understandable if top finance                    These two top executive categories
abilities not only to prioritize accurately
                                                     executives and their C-suite colleagues                      outranked, by far, others that were also
but also to follow through on those earlier
                                                     were now looking hard for new and better                     listed as playing a leadership role in
high-priority issues.
                                                     ways of managing risk.                                       developing risk management strategy.
Would more timely and accurate financial                                                                          Twenty-three percent of the respondents
                                                     Who Runs the Show?
forecasting have helped companies                                                                                 said a chief risk officer and independent
                                                     If that search for better risk management
avoid the 2008 credit and market                                                                                  risk management function had a
                                                     methods does in fact develop, this survey
conditions that plunged them into                                                                                 leadership role, for instance. Just 19
                                                     shows that the push will almost certainly
recession – as well as the more general                                                                           percent listed their board of directors.
                                                     have to come from the corporations’ top
financial collapse that followed? Can
                                                     finance executives working with their
they be satisfied, looking back, with
                                                     C-suite colleagues and, to a slightly
those improvements that were made in
                                                     lesser extent, from boards of directors.
their forecasting and risk assessment
methodology?

6
Avoiding the Black Swan: Barriers
                                                                                                                          to Improving Risk Management

                                                                                                                          The survey showed that to the extent
   Exhibit 5: Where the Buck Stops                                                                                        there is any pressure to increase
   “What role do the following stakeholders play in developing your company’s risk                                        resources devoted to risk management,
   management strategy?”
                                                                                                                          that pressure comes first from C-suite
                                                                                                                          management, second from the board
     CFO and corporate finance function                           64%                           28%           7%    1%    of directors, and third from the board’s
                 C-suite executive team                          62%                         25%      6% 3%5%             audit committee. That pressure, however,
       Chief risk officer and independent                                                                                 appears to be less than intense. Only
                                                   23%          11%    8% 6%                    52%
                risk management function                                                                                  15 percent of the respondents said
                      Board of directors          19%                25%               39%               8%    8%
                                                                                                                          that their C-suite team was calling
             Business unit management             16%                   50%                    26%            5%    3%    for a “substantial increase” in risk

                        Audit committee       14%              25%               30%         11%         20%
                                                                                                                          management resources. Nearly half, 48
                                                                                                                          percent, said that their top management
                   Internal audit function    6%         23%               31%         12%            28%
                                                                                                                          team was pushing instead for “some
 External auditors/third-party consultants 4%       16%                    45%                 29%             9%         increase.”

                                             0%           20%          40%         60%             80%             100%

                                                   Leadership role                            Key contributor role

                                                   Supporting role                            Little or no role

                                                   Don’t know/Does not apply

The boards, business unit managers,                        Who’s Managing Risk? No One?
audit committee and, to a slightly                         Perhaps most startling, though, 52
lesser degree, internal audit team, do,                    percent of the top finance executives
however, play important supporting                         indicated that either they didn’t know or
roles in developing risk policy. Seventy-                  their “chief risk officer and independent
six percent of the respondents said,                       risk management function” played no
for instance, that their business unit                     role in developing strategy because their
management team played either a “key”                      companies did not have either role.
or a “supporting role” in this process.
                                                           A chief risk officer who can act
Sixty-four percent put their board of
                                                           independently – free of influence from the
directors in those key or supporting roles.
                                                           top corporate power structure – and an
And 55 and 54 percent, respectively,
                                                           independent risk management function
said their audit committee and internal
                                                           are among the cornerstones of effective
auditors had key or supporting roles in
                                                           ERM. That position and an ERM team
developing risk management strategy.
                                                           that functions independently does,
                                                           however, require a commitment and
                                                           funding from corporate leadership.

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    Exhibit 6: How Are We Doing?
    “In your opinion, how well does your company perform each of the following risk
    management tasks?”

           Incorporation of risk analysis in investment decisions          22%            36%                 35%          8%

                               Response/mitigation formulation            19%                   53%                  27%        1%

                    Implementation of risk mitigation strategies          16%              51%                      31%         1%

                                  Risk monitoring and reporting           16%              47%                   36%            1%

                            Risk assessment and quantification        15%                 49%                    34%            2%

           Information gathering for risk management purposes         14%                52%                     33%            1%

                Incorporation of risk analysis in strategy setting    14%               46%                    36%              4%

                                               Risk identification    13%                 56%                        29%        1%

                                                                     0%          20%      40%         60%      80%           100%

                 Excellent performance           Adequate performance             Room for improvement      Don’t know/Not applicable

At the same time, a hefty 37 percent                    C-suite colleagues were not equally                   Ranking Their Performance:
of the top management teams in the                      impressed by this challenge. Only 20.5                No Applause, Please
survey were asking for no or just a                     percent of the respondents reported that              Just 21 percent of the respondents were
limited increase in such resources. And                 their finance team would be devoting                  willing to say that their company was
that applied to 58 percent of the boards                “much greater attention” to companywide               “performing well,” meaning ahead of
as well. All this would seem to indicate                risk management in the next 12 months.                peers, in its management of business
a disturbing sense of satisfaction with                 Even more of them, close to 26 percent,               risk. A nearly equal proportion, 20
existing ERM efforts and a decided lack                 said that ERM would be getting “the                   percent, conceded there was “room
of urgency toward any moves to upgrade                  same amount of attention.” In the middle,             for improvement.” Close to 57 percent
them. That lack of urgency, however, may                nearly 54 percent judged that risk                    indicated that their company was simply
no longer exist in the current economic                 management would receive “moderately                  “performing adequately.”
and business climate.                                   more attention.” This response is not
                                                                                                              When the respondents were asked to
Still, although the survey showed                       exactly a standing ovation for more ERM
                                                                                                              rate eight specific risk management
awareness – by top finance executives                   support, with nearly 80 percent reporting
                                                                                                              tasks the numbers were disturbing
at least – that ERM was expected to be                  only moderately more or the same
                                                                                                              (Exhibit 6).
significant corporate challenge going                   amount of effort.

forward, it seems that their boards and

8
Avoiding the Black Swan: Barriers
                                                                                          to Improving Risk Management

More than 30 percent of the respondents     Managing Risk More Effectively:               animosity toward ERM, for example,
declared there was “room for                More Collaboration and a                      wrote: “Do not let pessimistic auditor-
improvement” in the way their companies     Companywide Approach                          types put you out of business by
performed six of the eight tasks. And for   The survey gave respondents an                overcontrolling everything. Life comes
the other two, “risk identification” and    opportunity to provide more complete          with risk. You cannot eliminate all of it.
“response/mitigation formulation,” 29.5     written answers to suggest better ways        Get over it!”
percent and 27.5 percent, respectively,     to assess and manage risk.
                                                                                          Fortunately, this opinion did not
put their companies in the “room for
                                            They saw the need not only for focusing       prevail. One CFO called internal audit
improvement” column. That between 36
                                            on the financial and operational business     a “key agent in spreading the word on
percent and 56 percent of the finance
                                            functions more equally but also for more      incorporating risk management into day-
executives rated their company’s
                                            top management collaboration on the           to-day activities” and which, as another
performance just “adequate” in these
                                            design, development, and execution of         CFO put it, “is well suited to pursue,
eight important risk management
                                            ERM. Nearly 40 percent said they already      unearth, and identify exposures.” One
functions is hardly reassuring.
                                            have “very close collaboration” with          of the CFOs emphasized the need to
At the time of the survey, slightly         chief compliance or risk officers, general    “eliminate all adversarial relationships
more than 42 percent did say that the       counsels, and the heads of internal and       with the (internal audit function), and, as
weakening U.S. Economy “would put           external audit. At the same time, though,     another said, “treat (IA) as a partner, not
the most strain” on risk management         27 percent admitted to having “not very       as police.”
processes and practices during the          close collaboration” with the head of
                                                                                          A great many of the free-form answers
next 18 months. But fully half said that    internal audit. And nearly as many, 26.4
                                                                                          also pointed to the importance of more
another kind of unexpected change,          percent, said they had the same distant
                                                                                          comprehensive collaboration. “Managing
“mergers, acquisitions, divestitures,       relationship with their chief compliance or
                                                                                          risk should be incorporated in the day-
or organizational restructuring,” would     risk officer.
                                                                                          to-day process,” one executive wrote.
pose even bigger problems. These two
                                            In their open-ended replies, the finance      “It needs to be part of every decision at
categories of risk, perceived then and
                                            executives urged more respect and             every level – not a separate checkpoint
presented as distinct, may now have
                                            collegial involvement specifically with       late in the process.” Another urged
become more intertwined. They now
                                            the internal auditors and their teams.        colleagues to “be as deeply involved in
appear to describe the single and often
                                            The replies highlight an undercurrent         functional operations as possible. Timely
most overwhelming challenge to present-
                                            of animosity, or at least an adversarial      visibility into issues and events is critical.”
day corporate financial health.
                                            relationship that is not only unnecessary
                                                                                          “You need full collaboration from the
                                            but also destructive. One finance
                                                                                          rest of the organization,” wrote another
                                            executive typifying an organizational
                                                                                          respondent. “You cannot do it alone.”

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Finally and hopefully, these chief financial   Where Are We Today?                         „„ Most ERM programs do not clearly
executives had little doubt that there         The first three quarters of 2009               define, or completely overlook, roles
are significant, crucial benefits from a       continued to validate our findings. As         and responsibilities for top audit, risk
systematic, effective, companywide             a result of Crowe’s work with clients          management, and C-suite executives.
risk management program. Sixty-one             and discussions with others, we can         „„ Often there are no clear links between
percent pointed to “fewer performance          identify some of the more significant          ERM efforts and broader business
surprises,” and 57 percent listed “better      trends today:                                  strategies.
business planning.” “More effective            „„ “Black swans” continue to loom.          „„ The executives responsible for
resource allocation” was the third most           While rare, major crises are extremely      developing and executing ERM often
often mentioned benefit, and “improved            damaging and difficult to predict.          have had little or no understanding
ability to identify business opportunities”       They usually result from interrelated       of how to assess risk exposures for
was fourth. Surely, corporations these            risks, such as the recent combined          likelihood, impact, and speed of onset.
days would like to see more of those. Not         economic, banking, and housing crisis.   „„ Soft issues are critical. Risk
to mention one of the last mentioned, but      „„ “Silo-based” risk management                management is not likely to be
surely far from least important, perceived        programs have proved to be                  effective in an organization with an
benefits: “higher profits.”                       dangerous. They contributed to AIG’s        adverse culture, inappropriate values,
                                                  failed risk management efforts, for         or misplaced incentives.
                                                  example. Highly interrelated risks       „„ Some organizations, we believe, are
                                                  should not be isolated and managed          putting off the ERM journey because
                                                  independently.                              of concern about what they might find
                                               „„ Corporate governance – including            and then have to address.
                                                  business practices and ethics,           „„ Many organizations are struggling
                                                  ERM, transparency and disclosure,           to develop an effective monitoring
                                                  monitoring, legal and regulatory,           process.
                                                  boards and committees, and
                                                                                           „„ The current economic climate has
                                                  communication – continue to be
                                                                                              diverted resources and managers’
                                                  weak or overlooked altogether.
                                                                                              attention away from the ERM process.
                                                  Risk management and compliance
                                                  cannot be effective without good
                                                  corporate governance.

10
Avoiding the Black Swan: Barriers
                                                                                         to Improving Risk Management

Conclusion and                                 Finally, as noted previously, the most
Recommendations                                basic recommendation is for more
The study shows clearly that there             collaboration on a risk assessment
is considerable work to be done                program among chief finance executives,
designing, developing, and implementing        their C-suite colleagues, their boards
high-impact ERM programs in too                of directors, and the managers of their
many corporations. It highlights               corporation’s operating units. There
surprisingly fundamental barriers to           should be a sense of real urgency,
doing so, from a significant belief            now more than ever, to ensure that this
among top management that ERM is               collaboration produces a companywide
an “unnecessary interference” with             approach to ERM.
managing their business, to a “lack of
shared understanding” within companies
of the need for better risk assessment.
The survey found more than half the
respondents rating their company’s ability
to perform major risk assessments across
business units as merely adequate.

At the same time, the survey points to
the strong leadership roles that chief
finance executives and their C-suite
colleagues can have developing ERM
in their organizations. Certainly, given
the risk assessment mistakes that have
been made and the present need to
restore confidence in corporations and
their management teams, there has
never been a more timely opportunity.
An excellent start, indicated in this study,
would be the hiring of a chief risk officer
and the installation of an independent risk
management function in the companies
that have neither.

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Contact Us                                                          About Crowe
Rick Julien, CPA, is a partner with Crowe                           Crowe Horwath LLP (www.crowehorwath.com) is one of the largest public
Horwath LLP in the Chicago office.                                  accounting and consulting firms in the United States. Under its core purpose of
He can be reached at 630.586.5280                                   “Building Value with Values,®” Crowe assists public and private company clients
or rick.julien@crowehorwath.com.                                    in reaching their goals through audit, tax, risk and consulting services. With 25
Jonathan T. Marks, CPA, CFE, CFF, is                                offices and 2,500 personnel, Crowe is recognized by many organizations as
the partner-in-charge of the fraud and                              one of the country’s best places to work. Crowe serves clients worldwide as an
ethics practice with Crowe Horwath                                  independent member of Crowe Horwath International, one of the largest networks
LLP in the New York office. He can                                  in the world, consisting of more than 140 independent accounting and management
be reached at 212.572.5576 or                                       consulting firms with offices in more than 400 cities around the world.
jonathan.marks@crowehorwath.com.
For more information, please contact
Vicky Ludema at 800.599.2304 or
vicky.ludema@crowehorwath.com.

www.crowehorwath.com
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