Identity Theft Issues for Investment Advisers and Futures Participants

A little-known provision of the Dodd-Frank Act shifted responsibility over existing identity theft rules from the Federal Trade Commission to the Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”). The rules became effective May 20, 2013 and certain entities regulated by the SEC and CFTC will need to comply by November 20, 2013.

Overview

SEC and CFTC registrants that are “financial institutions” or “creditors” and that offer or maintain “covered accounts” for their clients will need to comply with the identity theft rules:

  • Financial institution: a bank, credit union or other person who holds a transaction account belonging to a consumer (a transaction account is one that permits withdrawals, payment orders, transfers or similar means for making payments to third parties);
  • Creditor: any person that regularly extends, renews or continues credit to others.
  • Covered account: any account that a financial institution or creditor offers or maintains:
    • Primarily for personal, family or household purposes that involves or is designed to permit multiple payments or transactions; and
    • There is a reasonably foreseeable risk to customers or to the safety and soundness of the financial institution or creditor from identity theft, including financial, operational, compliance, reputation or litigation risks. Examples include: for the SEC, brokerage or mutual fund accounts that permit wire transfers or other payments to third parties; for the CFTC, margin accounts.

Who will be affected, and how?

On the SEC side, broker-dealers, investment companies and investment advisers are considered financial institutions. On the CFTC side, commodity pool operators and commodity trading advisers will be considered creditors if they:

  • Regularly extend, renew or continue credit or arrange for the extension, renewal or continuation of credit; or
  • Acting as an assignee of an original creditor, participate in the decision to extend, renew or continue credit.

Firms that meet these definitions are required to implement reasonable policies and procedures that:

  • Identify “red flags” to prevent identity theft in the covered accounts they manage, and document them in the compliance program. Red flags can exist in the types of accounts the firm manages, the manner in which accounts are opened or accessed, and the firm’s previous experiences (if any) with identity theft;
  • Provide for monitoring accounts on an ongoing basis to detect red flags;
  • Respond appropriately to red flags;
  • Is periodically updated to reflect any changes in risks; and
  • Describe the various appropriate responses to red flags.

Whether a firm will meet the definitions will depend significantly on its client base and account structures. Traditional RIAs and other firms that manage accounts for individuals or family offices should look closely at those accounts to determine the types of activities that will be processed in them. A firm that handles bills or other third-party payments on behalf of its clients will need to undertake the most review and implement the most rigorous compliance program contemplated by the rules.

At first blush, fund managers may assume that these rules will not apply to them; however, care should be taken to ensure that investors’ accounts are set up to receive and hold investment amounts, and the only transfers permitted will be for management fees, performance allocations to the manager/general partner as applicable, and withdrawals by (and most importantly, back to) the investor to minimize identity theft risks. Even so, additional procedures around investor intake and withdrawal may need to be implemented.

CPOs and CTAs may undertake a similar evaluation and should also look at their investment strategies to determine the extent to which they meet the creditor definition.

Finally, even if a firm is not registered with the SEC or CFTC, identity theft can be a significant reputational and litigation risk for if they handle third-party payments on behalf of clients or investors. Accordingly state registrants and exempt firms should consider implementation as a best practice.

Compliance Strategies:

The rules identify five specific categories that every compliance program should address:

  • Alerts, notifications or other warnings received from consumer reporting agencies or other service providers;
  • Presentation of suspicious documents;
  • Presentation of suspicious personal information (e.g., an unexpected or unusual address change);
  • Unusual usage of a particular account; and
  • Notices from customers, victims of identity theft, law enforcement agencies or others regarding possible identity theft in an account.

Employees should be trained to identify the above and any other red flags that are specific to the firm’s business.

Appropriate responses to a red flag incident will vary significantly depending on the circumstances. The rules mention:

  • Monitoring an account for evidence of identity theft;
  • Contacting the customer;
  • Changing passwords, security codes or other devices that permit access to an account;
  • Reopening accounts with new numbers;
  • Refusing to open an account;
  • Closing an existing account;
  • Refraining from collection activities on an account;
  • Notifying law enforcement; and

Determining that a response is warranted in a particular instance.

Other, proactive safeguards can include standardizing the forms and processes used to effect transactions in client accounts, designating a person or team of people to handle those transactions under supervision (and training them to detect identity theft), preparing and reviewing a daily transaction blotter, requiring additional approvals and documentations for higher risk transactions and implementing PINs or security questions and client call-backs, to name a few.

To the extent that safeguards are client or investor-facing (such as call-backs, PINs or other identity verification tools), these should be standardized and clients/investors notified of the procedures so they know what to expect. Obtaining client’s acknowledgment of these processes via the investment advisory or subscription agreement is a good way to handle this clearly and consistently.

To ensure compliance by November 20, 2013, we encourage all firms to reach out to their compliance consultant or legal counsel as soon as possible. Rolling out the program early will afford plenty of time to refine it by the deadline.

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  81. Sara skriver:Hej Isabel! Jag brukar använda ett program som heter P90X, det är amerikanen Tony Horton som drar alla program. Idén är att följa hans färdigt planerade program sex dagar i veckan under 90 dagar, och bli i bättre form än någonsin. Jag gjorde aldrig hela programmet igenom, men halvvägs märkte jag nog att det är väldigt bra. Lycka till med hemmaträningen!

  82. the girl has already had it three times that week, she won’t get it again today. The girl frowns in disappointment. Then the can ROLLS ITSELF off the shelf, down the street, dodges obstacles and cars and dogs and so forth, until it rolls into the girl’s living room and bumps her foot. She picks up the can and smiles contentedly. The commercial is a metaphor for the whole situation – parents say no, but the product still makes it’s way into the kid’s life, by force.

  83. disse:Paulo, as demais fotos estão “no forno”…. cada imagem é tratada cuidadosamente para que o trabalho como um todo fique perfeito. Logo mais liberaremos a senha para que o casal visualize as fotos e passe aos amigos e familiares.abs!

  84. Peter, I think Friedman would have been livid. I know I am. Honestly, I do not know anyone on this board who is a huge Bush supporter. Your points are spot on, and we agree.And the current administration makes Bush look like a school girl spending her girl scout money unwisely. Agree?Trey

  85. Le 28/03/2012 à 09h33 Citation:Posté par EustacheLes tomates ont besoin de beaucoup de soleil, le mieux est de les planter plein sud avec un peu d’ombre pour éviter les brûlures C’est bien ce que je pensais. Du coup ce sera un peu compromis pour les tomates. Je regrette tellement de ne pas avoir de soleil sur mon balcon et je maudit celui qui à construit un immeuble juste en face qui me cache le soleil!Je vais me rabattre sur les plantes aromatiques et la menthe. Merci!

  86. a coloro che sanno tutto di kirby ;se non perdevate il vostro tempo legendo,e scrivendo cazzate ma lo usavate per raccogliere i 25 nomi che lazzienda vi chiede al giorno sicuramente facevate sia le demo e di conseguenza le vendite questo e un lavoro per chi sa cosa vuole.i falliti non solo non riusciranno mai a vendere un kirby ,perche non fanno nulla per cambiare e quindi resteranno dei falliti per tutta la vita .viva la kirby

  87.   February 1, 2011Hi Kyle,Definitely, we will are looking at publishing the report on a quarterly basis and getting more detailed with it as well. With this we would like to start tracking the the increases, decreases and newcomers to the industry.PS, just had a look at your website. Very cool guys, keep up the good work!

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  94. Dein Bericht ist lustig zu lesen und in vielem magst du auch recht haben, aber wie würdest du unseren Wildbestand “regulieren”…? wir haben schon immer die Natur gepfuscht und wir sind Teil (leider) des ökologisch gleichgewichts.. das mit den Bären und Wölfen scheint ja auch nicht wirklich zu klappen?! …

  95. O nic nejde Jenom to byla taková “morální povinnost” trochu tÄ› opravit… Opravdu nic ve zlém. Jak jsi psal – nÄ›které články hold povedené nejsou. Tak aÅ¥ tohle jeden z nich…

  96. Perhaps this is just the beginning. I’m sure that Starbucks is considering going into the services industry, and other companies are taking advantage of the window into the future provided by the film to adapt themselves accordingly.Maybe Judge should re-brand himself as a business consultant.

  97. Soy fotógrafo profesional y las nubes siempre han sido un motivo de inspiración. Pertenezco a la CLOUD APPRECIATION SOCIETY y me acabo de enterar que existís y que hay un primer congreso en Lugo, que por cierto me lo he perdido. Quisiera unirme a vosotros y muy interesada en participar en las actividades que organiceis en el futuro,Un cordial saludo, Elisabeth

  98. Does New York have a Castle Doctrine or Stand Your Ground Law? If so, and I lived there I’d put a sign on my house that explained that New York had that law and as the paper stated, I’m armed. That would end any protestors or robbers I think.

  99. I have recently been diagnosed with rheumatoid arthritis. For the past year I have not been able to carry out my duties at work and as a result have been laid off. Not being able to work has had a pretty detrimental effect on my financial situation and it’s not getting any easier. The only thing that keeps me going is hope that I will probably be approved for the disability tax credit as a person on disability.

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  112. Love this! Hipsters are a great example of Gen Y being conservative too. They want to do all of the cool stuff hippies did but they want to do them after they take a shower and put on overpriced shoes to show how much they don't care.

  113. it just doesn't work for him. It doesn't work because he is a demorat. However, he was polite and cordial to Mr. Corsi. The Office of President is too important to be allowing someone to deny records and act as if the individual is more important than the Office. If you are not qualified, do not apply for the Office.

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  118. deniz diyor ki:Gaziosmanpaşa da bana 225 tlye ev bulsana piç kurusu o paraya ev vardıda biz mi tutmadık sikik beyinli dangalak ! o asgari ücreti al dür bük götüne sok bu yazıyı yazarak garibanla eğlenmekten fazla haz verir!

  119. Tom Tom has a simple user interface, but garmin has better features and more products to choose from to suit your needs from GPS cycling computers to car and hiking units. It depends if you want somthing that’s easy or somthing with more features.

  120. 1) the pollution is serious, no doubt about it2) the urban people care about pollution, but the rural people have more to worry about so that pollution is low on their agenda. not that they don’t care, they just do not understand or have a lot more to worry about, e.g. they would trade pollution for a good TV or nicer house.

  121. It reminds me of the movie, X, where Malcolm X attended an all-white school in his youth. When he told his white male teacher that, because he consistently got the best grades in the class, he wanted to be a LAWYER, the teacher discouraged him and, ultimately, guided him to the more menial career choice of CARPENTER, telling Malcolm that Jesus was a carpenter, that he would recommend work to him if he went that route, and that he was GOOD W/HIS HANDS, when Malcolm was OBVIOUSLY GREAT W/HIS MIND!

  122. Now Pete, tell the truth, you’re not 5’8″… haha.In all seriousness, I am so blessed to be a part of the Cross Point family. That I get to spend the most magical, spiritual, magnificent night with my church family is the best gift I could receive.Merry Christmas to you and your beautiful family! I love you all!.-= amanda´s last blog .. =-.

  123. I meant to address this separately:“An inability to go to church does not interfere with someone’s likelihood of salvation.”Really? In what Church? I’ve been told on this very blog, quite recently, that church attendance is NOT OPTIONAL.

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  130. Congrats to the CIO team, best of luck for winning the award and may you get many more! But I think it is the the Hosts and the industry itself that this award acknowledges, cuz if the industry wouldn’t have had such phenominal achievements then the team wouldn’t have anything to write about. p.s. I think this qualifies the CIO team to do an “In Your Face” dance to the conventional media which claim there is no content in the ICT industry.

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  136. “ all- natural” or “no artificial sweetener” or “artificial flavoring” but has zero calories you should avoid them. As an example, stevia is advertised as “ all natural” because it is derived from a plant. However the chemical process it is put through to convert it to a sweetener makes it artificial. While taking Healthe Trim we ask that you eliminate all caffeiene, decaf, artificial sweetener or anything sweetened with artificial sweetener. Water, 100% juice and milk is fine.

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  139. Im a smaller ring kind of girl. Plus, I harm myself with my rings repeatedly. I used to wear a marquee cut diamond and managed to scratch my face pretty badly by using it. I scraped the kids with it repeatedly, too. The wedding ring husband gifted me for our Birthday was picked because of its settings being much less dangerous.

  140. Trout Are Made of Trees sounds like a wonderful book with a theme that is important to convey, and not only to children. By their actions, most “grownups” appear to take nature for granted.I‘m also a sticky note fan. I lay out all 32 pages of a picture book and scribble away. Very easy to rearrange or start over.

  141. You actually make it seem so easy with your presentation but I find
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  142. The U.S. would stop doing business with China if it was a righteous nation truly devoted to promoting the existence of democracy and freedom in all nations. However,it is anything but so we continue to do business with a country that treats its citizens and those who no longer want to be citizens horribly. China is not only an embarrassment to itself but an embarrassment to every free and democratic nation that insists on associating with it. If the nations of the world had any decency at all,they would force the Olympics to held somewhere other than a country like China. Word.

  143. Steve Barber wrote: “Japan gave up Matsushima (Liancourt Rocks) long before the Meiji Era. Even as early as the Anyongbok Incident in 1696 they clearly excluded Matsushima from Japanese territory.Gerry Writes: Steve, you are as “nutty as squirrel poo.” (J. K. Rowling)

  144. Thank you for this!I’ve gotten quite cynical (bordering on contempt) as I travel in the content marketing circles. Admittedly, I’m gone overboard and spent too much time studying content marketing and gotten away from my core skills: Data Management and Excel.I’m looking to ease back and find a way to do “good enough” content marketing and get back to my real business.

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  146. Vi plockade hjortron i Dalsland, sedan kokade svärmor sylt åt oss. Jag brukar koka plommonmarmelad. Så gott!Önskar jag hade en matkällare, det låter mysigt på ngt sätt.Usch i dag ösregnar det så det får bli en inne dag.Ha det gott!Kram Kristina

  147. The answer to your last question is no.The reality is that too many teachers are happy being told “this is what you will do.” They find the same safety in being told what to do as a teacher as they did when they were a student. That is after all why they were successful students, and why they choose to spend the rest of the lives in a classroom…well most anyway

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  152. – isn’t that a bit of a chicken and egg thing, mick, given that a classical rather than a specialist or ‘modern’ education was precisely the type thought to equip gentlemen (women, if I remember correctly, couldn’t graduate from Cambridge til 1921, not sure about Oxford) to rule an Empire? So there we have status and culture and their legacies once again.

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  165. Brilliant, no nonsense , practical advice, which makes me think I could do this – thanks so much Belinda! I’ve been think about making an “author type video – very similar to this one – for ages, so this is very helpful. I also want to do a book trailer for the new book and I think a lot of what you suggest here would also work for a trailer – would you agree?

  166. Why would Associate supreme court Judge Clarence Thomas say, 'That's an issue we're avoiding.' If there was no issue? Wouldn't he have willingly claimed that the issue was settled law, otherwise?Who better then a Supreme court justice could have put this 'issue' to bed and didn't or couldn't when challenged? If the issue is crap on the floor you walk around it, thus avoiding the 'issue'. If there is no crap on the floor what are you avoiding, dancing oddly around a non existent turd? I am not anonymous I'm Bob M. from Ohio

  167. Genau DAS ist der Punkt, auf den meine wesentliche Kritik zielt… :-)Die vorgeschlagene Regelung zementiert das dem BDSG immanente Verbotsprinzip. Gerade dieses jedoch bedarf – als einfachgesetzliche Schranke der grundgesetzlich geschützten Meinungsfreiheit – einer hinreichenden Rechtfertigung. Und die sehe ich (ebenso wie eine Reihe namhafterer Juristen) bei dieser Kontruktion nicht…

  168. Between me and my husband we’ve owned more MP3 players over the years than I can count, including Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etc. But, the last few years I’ve settled down to one line of players. Why? Because I was happy to discover how well-designed and fun to use the underappreciated (and widely mocked) Zunes are.

  169. No nos vamos por no molestar en demasia al amigo americano,pero pintar alli no se pinta nada,lamentablemente supongo que se perderan mas vidas antes de que a alguien le entre el sentido comun y les haga volver,saludos.

  170. S.Martel dit :Cecile, nous n’avons plus le courriel puisqu’il sagissait d’une demande via un formulaire en ligne. Mais en gros ça disait: Nous avons un ami nouvellement citoyen et voulons souligner l’événement en lui offrant un symbole canadien pour sa fête.[]

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  174. zioAlbert · martedì, 28 agosto 2012, 11:14 amNon ho capito bene come funzionerebbe. Ma a me sembra che assomigli tanto a quel che fecero in Argentina. Sbaglio ?Non preoccuparti di come funziona prof., comincia a risparmiare e a nascondere i soldini sotto la mattonella per i tempi bui.Dopo l’autunno arriva l’inverno …

  175. "I instantly thought of Yoko Ono. Where would her career have gone had she not met John Lennon?"Actually she was already an established 'artist' in the NY scene when she met Lennon. That was one of the things that attracted him to her. Lennon had gotten tired of being just an entertainer and wanted to be an ARTIST. He lent her fame, she lent him avant garde credentials as she had connections and a certain reputation in the art world.

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  181. / Sevgili Mert, bu Google'un dahi W3C yi çok fazla kafasına takmadığını gösteriyor. Genel kanının aksine Google arama sonuçlarında üst sıralarda yer almanın koÅŸulu W3C validation testinden kusursuz çıkmak deÄŸil. W3C hatalarını minimumda tutmaya çalış, ancak vaktinin büyük bir kısmını da buna ayırma. Google dahi çok fazla sallamıyor…

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  185. other housemate gets all of his info from the MSM. In fact, the first thing he did when he moved in was to buy Satellite TV so he could watch sports. I am ashamed to say that I watched a pro football game with him on his TV. I think that's the first football game I've ever watched all the way through while not wearing a band uniform, and I'm in my seventh decade on this planet.

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  187. Fíjate que la salvia no es una hierba que se encuentre con facilidad en los comercios, aunque quizá en los herbolarios sí. Pero lo curioso es que no muy lejos de mi casa está sembrada en los jardines. Pero yo no me atrevo ni a coger una hojita por si alguien me llama la atención …Con lo que nos gustan las salchichas frescas en casa. Dudo que esta forma de comerlas no nos guste también. Si es que tienes una mano …:cBesos!!

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  190. bonjour,pour moi tous ça ces du charabias lol !! je voudrais savoir s'il était possible d'ouvrir une "cyber entreprise" en tant que militaire !! cela n'a pas besoin de fond de commerce etc… juste d'un status juridique !! et quelque demarche au pret de la chambre des commerce !! si quelqu'un peut m'elcairer je le ou la remercie d'avance

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  200. lifestyle of the Irish/Scottish people.Finally, one more movie I have had seen during my transit hours in a luxory hotel of Kingdom of Bahrain, ah but I was so drowsy that I can’t recall almost anything from that movie… may be I should re-search (yes, I dont prefer to use the word for verb “googling

  201. I have long believed that Bars is correct on this, and for the early universe at any rate his construction provides a means to explain how events can apparently "precede" others (as viewed backward in E-1 time) and events are not casually related by "cause and effect" in a world of orthogonal time coordinates. There is an interesting analogy of this 12-dimensional gauge theory and H Weyl's construction of the electromagnetic field from the unspecified six components of the contracted Riemann curvature tensor of empty spacetime

  202. hi taylor,my major has pretty much nothing to do at all with what i do: i have a bsba in finance. hahai love math and finance and it’s good to know that i have other career possibilities in the future if i feel like changing it up (which i doubt will happen)as far as choosing a college path, you have to go with what you’re passionate about and what you see yourself doing in the future. i’m biased but think that a business degree is always the way to gobest of luck to you <3

  203. Great looking family! And I love the shot of the adorable Hope and friends.One of our dogs is a great mouser. She’s gotten much fatter since we moved out here, even though we’ve cut way back on the stuff we feed her. (If it were up to me, we’d stop feeding her–at least in the summer; but my mother lives with us and simply can’t bring herself to let them go without a bowl of something from us.) This dog enjoys grasshoppers in the summer, too. She gets so many that the sidewalk is littered with them some days.Mary Susan

  204. Eh bien… en employant « graphe » comme adjectif qualifiant un nom féminin, puis en faisant une ellipse. Cela se trouve en quantité sur la Toile (mais je doute fort du niveau de français des infographistes, statisticiens et informaticiens qui s’expriment ainsi).

  205. Selma: Matto on HobbyHallista, ja sohva ehdottomasti huippuostos: supermukava ja hyvännäköinenkin! Juu ja tuo talvipaino, auts toisaalta, mutta turha ottaa siitä liikaa paineita. Lähtee sillä millä on tullutkin eli oikeanlaista ruokaa ja lenkkiä kun flunssat saa taas pois :)Kirsikka: Enkelikello on niiiin basic-koriste, mutta juuri tuo patina tekee siitä kivan!Kiitos Kirsi Lido-vinkistä, kaksi ruokaihmistä on lähdössä matkaan eli varmana kokeillaan vähän kaikkea!Kiitos myös Milla, hyviä vinkkejä, jotka heti naputtelin iPhoneen muistiin!

  206. Well, I ate a giant burrito today. Sooo, I think that might be better than your 5 miles…Ugh, so annoying about the agency. They should be able to hire more people or something.Also, I love the doggy bed cover!

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  208. This study claims that the discrepancy in reported sexual partners between men and women can be explained by prostitutes. Lots of men visit prostitutes, but then the prostitutes don't end up in surveys (many go to jail, die, get ill, etc.). Men are honest about their number of partners, but reluctant to report these partner include prostitutes too.

  209. Sehr geehrter Danny,vielleicht können Sie mir noch genauer erläutern, was “diese amüsante Episode”, die ich tatsächlich lustig finde, mit dem Fall in Höngg zu tun hat? Ich denke, was der Fall Höngg angeht, ist jeder Kommentar von meiner Seite überflüssig – meinen Sie nicht auch?

  210. This conversation is interesting. I am just wondering how it is you won’t have something of which to boast about over other man. After all, you did something others were unwilling to do, and because of your choice God gave you heaven and because of their choice, God gave them Hell. It sounds like Arminian\\Traditionalists will have much for which to boast about over their fellow man.

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  215. Oi Bárbara! E esses dados também servem para a quinoa em flocos???Beijo, excelente trabalho o teu![] Respondeu:November 30th, 2012 em 4:34 am, serve sim querida… existem variações mas é tão nutritivo qto o grão inteiro! bjinhus e eobrigada pelo apoio []

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  220. By Daniel 12 noviembre, 2012 – 12:42Hola,de antemano quiero agredeceros la ayuda que nos prestáis.El caso es que tengo una sentencia firme ejecutoria de 3 meses de prisión y pago de una indemnización por un delito de lesiones. Al carecer de antecendentes penales, solicito la la suspensión de la pena privativa de libertad pero se me impone el pago de la indemnizacion a razon de 100 euros al mes durante 18 meses.En este momento no trabajo ni tengo ningún ingreso.Qué me puede ocurrir si no pago la sanción?Un saludo y gracias

  221. Though I love wi-fi and web radio, I still turn to SWL for the big broadcasters (like BBC WS, DW and Radio Australia). I like the sonic texture of SW radio, thus enjoy seeking out the odd stuff. I’ve also become a BIG fan of the TuneIn app. It’s the best one I know of for sorting through the millions of online stations out there. Just used it today in my car to listen to a station in Paris, one in Moncton, New Brunswick and Perth, Australia. Yes, I love the higher tech stuff too!

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  229. Gonsalo:Você esqueceu-se de mim. Qual galinha, qual caniche, qual hiena. Eu disse que eles têm mentalidade de "gaja". E mantenho.O Bairro Alto já era o Centro de Trabalho da Revolução. Agora já abrem bares de alterne. E as funcionárias fazem horas voluntárias para o Partido nas caixas de comentários dos blogs, entre uma ou outra passita. Depois, neste estado, admiram-se de só dizerem parvoíces…

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  231. How lovely, and meaningful, Loretta. Funny, I just wrote about my grandmother on my blog. She would be 134 as of yesterday. I love the photos you use to illustrate your work. They, too, are gifts from God.Love,Carol

  232. I’d go Moeaki. Tamme has the potential to emerge as a usable option in all formats, but until we know exactly how the Colts plan to use him, he’s a big risk.As for the WR, I’d go with the pair of WR. With Gonzalez, we don’t know if he’s going to work as WR3 or WR4 behind Blair White. He’s got a ton of upside, but like Tamme, he’s a big risk.

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  234. DGI you are quite correct. Always read the quarterly reports. One time charge-offs have to be considered. Often I find that companies I am interested in or already own have fine earnings, masked by a one-time charge. Do your homework, take the time to read what a company has to say, the press sometimes only tells part of the story, don't rely on them alone. It's even possible to get a bargain like this as in the case of JNJ, a stock I have held for some time. Good work, really enjoy your stuff.

  235. (The last sentence in the first paragraph should read, “Illegal aliens from Mexico have done NOTHING but bring their crap with them; they have turned a once-beautiful country into the toilet they thought they left behind.”

  236. Caros colegas,Sou professor aqui no Estado de São Paulo, Brasil. E, pasmem, das 8 turmas de Ensino Médio que tenho, 6 tem mais de 40 alunos. Algumas chegam a ter 50 matriculados.Espero não ver Portugal chegar em um patamar parecido, lutem para que isso não ocorra!Abraços.

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  238. Whoa, I had to read that twice to make sure I was indeed reading that right. Mitting fornicating deer. Now that is something you don’t say everyday!Ooh, where is this class? And who teaches it? Share me your wisdom when you ace it! Miss you too. Please visit soon 🙂

  239. CIP,I agree with Lubos, the main ingredient of theGW hypothesis (warming of the troposphere) is not very well supported by the available evidence.The link you provided does not explain much, exceptstating the obvious that this is a complicated issue.Unfortunately, the scientific questions about atmosphericand climate physics are difficult enough, the politicalaspects do not make it easier.But fortunately it seems that the GW effect (if it exists)is weak enough that we have probably enough time to studyit better 8-)Best regards,Wolfgang Beirl

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  247. The problem is that there are clear policies in place for Board rights and responsibilities – they are outlined in the Co-op’s Bylaws and in the Co-op’s Policy Governance Documents. These documents clearly state the role of the Board, but Sue and ESPECIALLY Linda refuse to follow those documents. The employees felt backed into a corner because those documents have been ignored for so long, and the overstepping has been happening for so long with no reprocussions. When grievances are filed, they go ignored or are literally written off as lies.

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  258. Feb04 Il faut garder en mémoire qu’exposer aux USA en tant que “made in France” peut être une arme a double tranchant. L’a priori est généralement positif -culture, langue, savoir faire artisanal et culinaire par exemple- , mais pas au niveau des relations d’affaires. Il faut savoir profiter de l’un sans pâtir de l’autre tout en prenant une couleur “locale”

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  260. Hugo Stiglitz dit :Il y a 3 ans, on avait annoncé un programme de Quantitative Easing ?J’aimerais avoir tes éclaircissement la dessus.Désolé, le sujet du billet est le cout de l’essence…

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  263. John- sorry. You missed the sarcasm of my earlier post. For most Americans, carnage in Africa BY Africans, doesn’t matter to them. The only ‘acceptable sacrifice’ is the [sic] Hollow Hoax, and/or what the ‘Jews’ are doing today.That was my point. People won’t connect the bestiality of Africa with the Bestiality of THE AFRICAN here in the USA, because they have been brainwashed to believe that only one ‘race’ (Chosen People) matters to us, today. Which is nothing more than Talmuddied propaganda, to both enfranchise the Black in teh USA, as well as to downplay the reality of the nigger gene pool.

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  278. 範例1.檔案的建立時間、副檔名、大小Dim getInfo As System.IO.FileInfogetInfo = My.Computer.FileSystem.GetFileInfo("C:\\WPD04.DOC")MsgBox("這個檔案的建立時間為" & getInfo.CreationTime & Chr(10) & _"這個檔案的副檔名為" & getInfo.Extension & Chr(10) & _"這個檔案的大小為" & getInfo.Length & "位元組")My.Computer.FileSystem.CopyFile("C:\\WPD04.DOC", "D:\\WPD04.DOC")Close()

  279. Jason: You are just running with my comment. Look at this exchange.Jason: What is the antithesis to Conservatism is the usurpation of rights and powers of the people. Zachriel: As you are simply defining anti-conservatism as tyranny over the people, well, then, the vast majority of liberals are conservatives too! Is your definition consistent?Jason: The excesses of the French Revolution appalled just about every thinker worth mentioning. Jefferson, among others, was an ardent supporter of the French Revolution.

  280. Afigucan / Hola Toni:Gracias por leernos y darnos tu opinión.Es verdad que por ahora nos “movemos” a base de rumores, pero tampoco iban muy desencaminados los del iPad 2.Me he hecho “eco” de esta noticia por resultarme interesante. Siempre he tenido la idea de que Apple de vez en cuando “suelta” algún rumor de estos para ver la reacción de la gente.Lo realmente importante, es que vuelva a sorprendernos como lo ha hecho con el iPad 2.Un saludo cordial.

  281. J’ultra co-signe. Et encore, tu dis top 5, mais c’est plus top 3, en ce moment… Le reste est incroyablement décevant et/ou irrégulier. Mais bon, j’en avais déjà parlé: c’est toujours mieux que l’an dernier où il n’y avait QUE Nadal pendant 5 mois…

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  283. Où meilleur Valls?! ….Ce carriériste sera le tombeur non de ces dames en digne Hidalgo mais celui d’Hollande tant il est pressé de prendre sa place calife à la place du calife.Le Grand Vizir Iznogoud.Hélas qu’il le veille ou non ses débuts ne sont pas une réussite ni dans la multiplication des délits et crimes « atteintes à la personne » ni dans les actes de terrorismes.Laissons le enfler…La fontaine lui rappellera le sort de la grenouille.

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  288. Ciao Paolo, volevo far notare come la California con le sue tre città L.A. S.F. e S.D.sia la dominatrice assoluta di questa classificaSicuramente questo è dovuto alla presenze nel territorio delle maggiori aziende teconlogiche, di semiconduttori e di sviluppo telematico nel mondo, nn per caso la zona sud della bay area che avvolge San Francisco è stata nel 1971 denominatà silicon valley!Questo propio per l'utilizzo del silicio nella costruzione di computer e semiconduttori.Argomento interessante, grazie per l attenzione.Porgo i miei saluti a tutti.Sghig.

  289. Tim, If you had any commitment to democracy you wouldn’t be insisting on Crown sanctioned race based representation for the new super district in Auckland.”He is an enemy of democracy and of this country.”Once you insist on the same being dealt out to Tame Iti and the rest of the Tuhoe scum then maybe you’ll have some credibility.

  290. mai, nu as zice ca e asa nasol… mie 80% din cazuri chiar imi place mult(altfel nu m-as scula la orele alea)si eu aveam cosmare cu aia din gangsta paradise care veneau cu kalashnikoave la curs… turns out, am o grupa aproape identica -sortof- cu cea pe care am avut-o in zilele mele de student, as in nice ppl. Ma rog, si 3x mai numerosi decat pe ‘vremea mea’.

  291. Francesca,This is a great overview of the different backup options. I’m using Google Drive for work stuff at the moment but may switch back to Dropbox simply because GD keeps crashing on my machine. I feel it still needs some work doing on it before it’s as reliable as Dropbox. Also use Skydrive for personal stuff and Carbonite for general backup.thanks, Valerie

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  296. September 22, 2011  9:45 pm by Much of this information is shocking, 100 million street children worldwide and 100,000 girls as child soldiers are the two that stuck out for me. Not that the others are not also terrible, but these two were ones I had not encountered before. It would be interesting to know how girl’s lives have improved over the past decade or so – are more girls in school, fewer young girls married etc. And if so, what has contributed to these improvements (though I realise that might be difficult to determine).

  297. Steve, they're doing it in Dallas. Check out the background on Woodrow Wilson High in East Dallas. SWPL parents have carved out a significantly white haven in the midst of DISD, which is almost 90 percent black and brown.And they were doing it till they caught at Preston Hollow Elementary, which serves the most heavily Jewish part of town and feeds into Hillcrest High.

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  299. Kris & 黃頌竹:如果我沒理解錯,你們指稱的「難」是指「原著主要理論的核心重點」,那正是彭教授所稱的「易」。二手書的貢獻確實是將這些部分講得更清楚,舉更多淺近的例子讓初學者容易上手,這是不可否認的。然而,原著主要理論在核心重點以外的其他複雜聯繫部分,也就是你們認為非重點且被二手傳播作者刪去的部分,正是彭教授認為的「難」的部分,而他認為那些是很重要的精華,丟了那些很可惜。

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  305. Egalement tout à fait d’accord !Et le jour où la pub s’installe, je déménage… mais je sais que cela n’arrivera pas.Et pour terminer, il ne me reste qu’à souhaiter à l’équipe Piwigo et à tous ses utilisateurs de bonnes fêtes de fin d’année

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  314. Well, you did post it. And for that I'm thankful.Two points:We Libertarians ARE AYN RANDISTS WHO SMOKE POT. That's about as precise a definition of libertarians as you could ever come up with. Secondly, Real Libertarians ARE WAR HAWKS. Phony "Libertarians" are War Pussies, who are cowards, yellow bellies and bend over in the face of Muslims invading the United STates of America. You'll recognize them by their cries of, "Oh, yes Mr. Muslim, please push it in harder. I'll do whatever you want. Just don't kill me Mr. Muslim…"

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  333. Carissimi Dario e Paola,con grande piacere ho letto il Tirreno di venerdi scorso …..30candeline!!!Anche se sono passati più di 10 anni da quando ho cambiato lavoro, è ancora vivo in me il ricordo di “Dataport”Sono contenta di aver trascorso con voi un lungo periodo che mi ha fatto crescere e mi ha formatoAuguro a voi e ai miei “ex colleghi” ancora un grande successo.Congratulazioni e, di nuovo, buon lavoro!Un abbraccioFedericaDipartimento dei Servizi dell’Istruzione e delle RisorseServizio Gestione Risorse Finanziarie e UmaneUO Organizzazione e Sviluppo delle Risorse UmanePROVINCIA DI PISA – PISA

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  341. RD, what would our government do if it were short a few politicians?!?JTW, it is impossible to “bear” arms without ammunition. Also in Heller. See dfwmtx’s comment.Btw guys, I wasn’t actually being serious with this. Think of it as a sort of a pixelated “wouldn’t it be nice” moment.

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  343. I attended the one in Qualicum Beach (Vancouver Island) last weekend & it was great fun. We had Linda Gilkeson speak first thing in the a.m. & there were quite a few ‘ah-ha’ moments experienced by the audience. There were so many seed & bulb & garden vendors, it was hard not to have a few hot flashes as spring fever seemed to be present. I managed to control the urge to splurge & found myself the proud owner of a white mulberry. Can’t wait to find a home for it!Have fun!!

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  453. The revision of the mass was sorely needed! In my opinion the mass of Paul VI was a drastic watering down of the liturgy which opened the door for many liturgical abuses in the past 47 years or so and a mass apostasy from the faith which was due to “the disntigration of the liturgy” as Pope Benedict called it when he was still Cardinal. These modernists need to be obedient and be less concerned about this and more concerned about their souls and the souls of those entrusted to them

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