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A computerized method and system for managing risk associated with a Hedge Fund is disclosed. Information relating to Hedge Funds is gathered and stored as data in preparation for a risk inquiry search relating to a Hedge Fund. Documents and sources of information can also be stored. A subscriber, such as a Financial Institution, can submit a Hedge Fund descriptor for which a risk inquiry search can be performed. The risk assessment or inquiry search can include data retrieved resultant to augmented retrieval methods. Scrubbed data as well as augmented data can be transmitted from a risk management clearinghouse to a subscriber or to a proprietary risk system utilized by a subscriber, such as a risk management system maintained in-house. Risk inquiry searches can be automated and made a part of standard operating procedure for any transaction conducted by the subscriber in which a Hedge Fund is involved.
1. A computer-implemented method for managing risk associated with a Hedge Fund, the method comprising:
gathering, by a computer, data relevant to a Hedge Fund from multiple sources;
aggregating, by the computer, the data gathered according to regulatory and reputational risk variables;
generating, by the computer, a certification of the aggregated data including a list of risk parameters associated with the Hedge Fund, the list of risk parameters being derived from the aggregated data and representative of a granularity level of aggregated data analysis;
receiving, via a user interface, a risk assessment inquiry relating to the Hedge Fund;
generating, by the computer, a risk quotient for the Hedge Fund by conducting data research on the certification including the list of risk parameters;
searching, in response to the received risk assessment inquiry, the aggregated data for data portions related to the Hedge Fund and associating the data portions of the aggregated data with the Hedge Fund by the computer; and
generating, by the computer, a report including an indication of the certification, the risk quotient, and the data portions of the aggregated data associated with the Hedge Fund.
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28. A computerized system for managing risk, the system comprising:
a computer server accessible with a system access device via a communications network; and
executable software stored on the server and executable on demand, the software operative with the server to cause the system to:
gather data relevant to a Hedge Fund from multiple sources;
aggregate the data gathered according to regulatory and reputational risk variables;
generate a certification for of the aggregated data to including a list of risk parameters associated with the Hedge Fund, the list of risk parameters being derived from the aggregated data and representative of a granularity level of aggregated data analysis;
receive a risk assessment inquiry relating to the Hedge Fund;
generate a risk quotient for the Hedge Fund by conducting data research on the certification including the list of risk parameters;
search, in response to the received risk assessment inquiry, the aggregated data for data portions related to the Hedge Fund and associate the data portions of the aggregated data with the Hedge Fund; and
generate a report including an indication of the certification the risk quotient, and the portions of the aggregated data associated with the Hedge Fund.
29. The computerized system of
30. A computer-readable medium storing a plurality of computer executable program code, the program code comprising instructions for causing the computer to:
gather data related to a risk subject from publicly available sources;
aggregate the data gathered according to regulatory and reputational risk variables;
generate a certification of the aggregated data to including a list of risk parameters associated with the risk subject, the list of risk parameters being derived from the aggregated data and representative of a granularity level of aggregated data analysis;
receive a risk assessment inquiry relating to the risk subject;
generate a risk quotient for the risk subject by conducting data research on the certification including the list of risk parameters;
search, in response to the received risk assessment inquiry, the aggregated data for data portions related to the risk subject and associate portions of the aggregated data with the risk subject; and
generate a report including an indication of the certification the risk quotient, and the associated portions of the aggregated data.
This application claims the benefit of the filing date of U.S. Provisional application No. 60/390,296 entitled "Hedge Fund Risk Management", filed Jun. 20, 2002. This application is a continuation-in-part of a prior application entitled "Risk Management Clearinghouse", filed Feb. 12, 2002 now abandoned, and bearing the Ser. No. 10/074,584 which is a continuation-in-part of a prior application also entitled "Risk Management Clearinghouse" filed Oct. 30, 2001 now abandoned, and bearing the Ser. No. 10/021,124, which is also a continuation-in-part of a prior application entitled "Automated Global Risk Management" filed Mar. 20, 2001, and bearing the Ser. No. 09/812,627, all of which are relied upon and incorporated by reference.
This invention relates generally to a method and system for facilitating the identification, investigation, assessment and management of legal, regulatory financial, market, credit, operations and reputational risks ("Risks"). In particular, the present invention relates to a computerized system and method for banks and non-bank financial institutions to access information compiled on a worldwide basis and relate such information to a Hedge Fund, wherein the information is conducive to quantifying and managing Risks associated with the hedge fund.
Although the term "hedge fund" may not be strictly defined by government statute, over time, the term generally refers to a variety of pooled investment vehicles that are not registered under the federal securities laws as public corporations, investment companies, or broker-dealers.
As money-laundering and related concerns have become increasingly important public policy concerns, regulators have attempted to address these issues by imposing increasing formal and informal obligations upon financial institutions, including hedge funds. Government regulations authorize a broad regime of record-keeping and regulatory reporting obligations on covered financial institutions as a tool for the federal government to use to fight drug trafficking, money laundering, and other crimes. The regulations may require financial institutions to file currency and monetary instrument reports and to maintain certain records for possible use in tax, criminal and regulatory proceedings. Such a body of regulation is designed chiefly to assist law enforcement authorities in detecting when criminals are using banks and other financial institutions as intermediaries for, or to hide the transfer of funds derived from, criminal activity.
Obligations include those imposed by the Department of the Treasury and the federal banking regulators which adopted suspicious activity report ("SAR") regulations. These SAR regulations require that financial institutions file SARs whenever an institution detects a known or suspected violation of federal law, or a suspicious transaction related to a money laundering activity or a violation of the Bank Secrecy Act (BSA). The regulations can impose a variety of reporting obligations on financial institutions.
Perhaps most broadly relevant for the present invention, current regulations require an institution to report transactions aggregating to $5,000 that involve potential money laundering or violations if the institution, knows, suspects, or has reason to suspect that the transaction involves funds from illegal activities, is designed to disguise such funds, has no business or legitimate purpose, or is simply not the sort of transaction in which the particular customer would normally be expected to engage, and the institution knows of no reasonable explanation for the transaction after examining the available facts.
Federal regulators have made clear that the practical effect of these requirements is that financial institutions are subject to significant obligations to "know" their customer and to engage in adequate monitoring of transactions.
The Securities and Exchange Commission (SEC) typically will receive limited information regarding the activities of various large market participants, including some hedge fund s, through reports that are filed when they acquire 5% or more of a class of security issued by a publicly traded company. The SEC will also receive limited information about hedge fund s through reports filed by managers exercising investment discretion over accounts having $100 million or more in equity securities. This information, however, does not reveal much detail about the trading activities of Hedge Funds and other large participants in our markets. In addition, the limited partnership structure of a hedge fund can make it more difficult to ascertain who the ultimate "customer" of a financial institution is.
Risk associated with a transaction involving a hedge fund can be increased due to the difficulty in gathering and accessing pertinent data on a basis timely to managing risk associated with the transaction. As part of due diligence associated with performing financial, it is imperative for a financial institution to "Know Their Customer" including whether a customer is contained on a list of restricted entities published by the Office of Foreign Access Control (OFAC), the Treasury Office or other government or industry organization. The amount of information that needs to be considered to evaluate whether an entity poses a significant risk or should otherwise be restricted, is substantial.
What is needed is a method and system to draw upon information gathered globally that relates to hedge fund s and the partners associated with a fund. The information can be utilized to assist with risk management and due diligence related to a financial transaction involving a hedge fund. A new method and system should anticipate scrubbing data from multiple sources in order to facilitate merging data from all necessary sources. In addition, data mining should be made available to ascertain patterns or anomalies in the query results. Risk information should also be situated to be conveyed to a compliance department and be able to demonstrate to regulators that a financial institution has met standards relating to risk containment.
Accordingly, the present invention provides a method for managing risk associated with Hedge Funds. In particular, the present invention includes gathering data relevant to Hedge Funds from multiple sources and aggregating the data gathered according to risk variables. An inquiry relating to a Hedge Fund can be received and portions of the aggregated data can be associated with risk variables related to the Hedge Fund. A risk variable can include, for example, a sponsor of a Hedge Fund, investments made by the Hedge Fund, partners involved in the Hedge Fund, a domicile of the Hedge Fund, a chief place of operation of the Hedge Fund, whether the Hedge Fund is available to U.S. citizens, or other factors. The associated portions of the aggregated data can then be transmitted, such as for example, to a subscriber or a risk management clearinghouse.
In some embodiments, data can be gathered exclusively from publicly available sources. An inquiry can be related, for example, to: a sponsor of the Hedge Fund; a partner of a Hedge Fund; a domicile of the Hedge Fund; investments made by the Hedge Fund; a commodity pool operator as defined in the Commodity Exchange Act; Hedge Fund window dressing; Hedge Fund portfolio pumping; a lockup provision; an alert list; or other risk subject or risk subject variable.
Embodiments can also include conditioning transmission of associated portions of the aggregated data upon receipt of a contractual obligation, such as, for example, contractual obligation not to use the associated portions of the aggregated data for any purpose covered by the Fair Credit Reporting Act or for contractual obligation.
Similarly, embodiments can include transmitting associated portions of the aggregated data in response to specified conditions being met, such as, for example: transmitting exclusively to an institution, such that the transmitter will have neither customers nor consumers as defined in the Gramm-Leach-Bliley Act; limiting use of the aggregated data for complying with regulatory and legal obligations associated with at least one of: (i) the detection and prevention of money laundering, (ii) fraud, (iii) corrupt practices, (iv) organized crime, and (v) activities subject to government sanctions or embargoes; transmitting the associated portions of the aggregated data conditioned upon receipt of a contractual obligation to limit use of the aggregated data for at least one of: (i) the prevention or detection of a crime, (ii) the apprehension or prosecution of offenders, and (iii) the assessment or collection of a tax or duty; or other condition. In addition, some embodiments can include gathered data relevant to a Hedge Fund which accurately reports on or consists of a governmental record or of insures that the source of gathered data is reputable.
In another aspect, the aggregated data can be continually monitored and any new information related the Hedge Fund transmitted to a predetermined destination.
Other aspects can include gathering data relevant to a Hedge Fund from multiple sources and aggregating the data gathered according to risk variables. An inquiry relating to the Hedge Fund can be received associating portions of the aggregated data with the Hedge Fund and transmitting the portions of the aggregated data associated with the Hedge Fund according to the inquiry. Embodiments can also include enhancing and/or scrubbing the data, such as, for example, incorporating changes in the spelling of datum or utilizing an index file. Similarly, some embodiments can include augmenting associated portions of aggregated data, such as through data mining.
Associating aggregated data can include, for example: using Boolean logic or relevance ranking.
Some embodiments can include receiving a source of gathered data and transmitting the source of the associated portions of aggregated data along with other search results.
Other embodiments of the present invention can include a computerized system, executable software, or a data signal implementing the inventive methods of the present invention. The computer server can be accessed via a network access device, such as a computer. Similarly, the data signal can be operative with a computing device, and computer code can be embodied on a computer readable medium.
In another aspect, the present invention can include a method and system for a user to interact with a network access device so as to manage risk relating to a risk subject. The user can initiate interaction with a proprietary risk management server via a communications network and input information relating to details of the risk subject, such as, for example, via a graphical user interface, and receive back information related to the risk subject.
Various features and embodiments are further described in the following figures, drawings and claims.
The present invention includes a computerized method and system for managing risk associated with a Hedge Fund. The computerized system gathers and stores information as data in a database, or other data storing structure, and processes the data in preparation for a risk inquiry search relating to a Hedge Fund. An inquiry will relate to a Risk Variable, such as, for example, a principal of the Hedge Fund. Documents and sources of information can also be stored and retrieved via the inquiry. A subscriber, such as a Financial Institution, can submit a Hedge Fund descriptor for which a risk inquiry search can be performed. A risk assessment or inquiry search is performed relating to the descriptor and can include data retrieved resultant to augmented retrieval methods. Scrubbed data as well as augmented data can be transmitted from a risk management clearinghouse (RMC) to a subscriber or to a proprietary risk system utilized by a subscriber, such as a risk management system maintained in-house. In some embodiments, a Risk inquiry search can be automated and made a part of standard operating procedure for any transaction conducted by the subscriber in which a Hedge Fund is involved.
Financial Institution: Financial Institution refers to any person, entity, company, corporation or statutory "person" in the business of providing Financial Transactions. As such, as used herein, a Financial Institution can collectively and individually include: Bank and non-bank financial institutions, including: investment banks; merchant banks; commercial banks; securities firms, including broker dealers securities and commodities trading firms; asset management companies, other hedge fund s, mutual finds, credit rating finds, securities exchanges and bourses, institutional and individual investors, law firms, accounting firms, auditing firms, any institution the business of which is engaging in financial activities as described in section 4(k) of the Bank Holding Act of 1956, and other entities subject to legal and regulatory compliance obligations with respect to money laundering, fraud, corruption, terrorism, organized crime, regulatory and suspicious activity reporting, sanctions, embargoes and other regulatory risks and associated obligations.
Financial Transaction: a Financial transaction refers to any action that anticipates a transfer of money from a first set of one or more Transaction Participants to a second set of one or more Transaction Participants. Examples of Financial Transactions can include: investment and merchant banking, public and private financing, commodities and a securities trading, commercial and consumer lending, asset management, rating of corporations and securities, public and private equity investment, public and private fixed income investment, listing to companies on a securities exchange and bourse, employee screening, auditing of corporate or other entities, legal opinions relating to a corporate or other entity, or other business related transactions.
Hedge Fund: As used herein, a Hedge Fund will include limited partnerships, including foreign limited partnerships or other vehicle to provide pass-through tax treatment of investor earnings. When organized abroad, Hedge Funds are usually structured to avoid U.S. taxation of the earnings of foreign investors. A U.S. Hedge Fund will include a private limited partnership. Often a U.S. Hedge Fund will have 99 or fewer limited partners.
To maximize flexibility, Hedge Funds operating in the U.S. may be structured so that the fund will be exempt from regulation under the Investment Company Act of 1940. A Hedge Fund may also rely on the trader exception from broker-dealer registration. In addition, interests in Hedge Funds can be and typically are, sold privately to sophisticated, high net worth individuals to avoid registration of the interests under the Securities Act of 1933, other traditional customers of Hedge Funds can include institutions, endowments and foundations.
Like other market participants, such as securities firms, banks, and insurance companies, Hedge Funds can vary widely in size, trading strategies, degrees of leverage, and market influence. An active Hedge Fund may trade a broad range of financial products, including equities, U.S. and foreign government securities, commodities, financial futures, options, foreign currencies, and derivatives. A Hedge Fund may also participate in merger and acquisition investments and various forms of direct investment activity around the internationally.
Hedge Fund Sponsor: A sponsor of a Hedge Fund is a person responsible for managing the investments of the Hedge Fund. The limited partners' investments are pooled and managed by a general partner or sponsor that is also typically an investor. A sponsor may be registered as an investment adviser under the federal securities laws, but is not so required. As compensation, a sponsor will typically receive a management or administrative fee based on the amount of a fund's assets, together with an allocation based on the fund's investment performance, such as a share of profits. Typically, the sponsor does not share responsibility to any losses incurred by the fund.
Informational Artifact: Informational Artifact refers to a media item that contains information that can be interpreted into a humanly ascertainable form. Examples of Informational Artifacts include: a news article, a news feed portion, a video segment, a newscast, a report, an identifiable document, an agency listing, a list, a government publication, other identifiable publication, a sound byte, a sound recording, or other media item.
Risks: Risks associated with a financial transaction can include factors associated with security risk, financial risk, legal risk, regulatory risk and reputational risk. A Security Risk refers to breach of a safety measure that may result in unauthorized access to a facility; unauthorized access to data; physical harm, including threat of immediate risk of harm to a person or goods. Financial Risk refers to factors indicative of monetary costs that the Risk Bearing Institution or a Transaction Participant may be exposed to as a result of a particular Financial Transaction. Monetary costs can be related to fines, forfeitures, costs to defend an adverse position, lost revenue, or other related potential sources of expense. Regulatory Risk refers to factors that may cause the Risk Bearing Institution or Transaction Participant to be in violation of rules put forth by a government entity or regulatory agency. Reputational risk relates to harm that a Risk Bearing Institution or Transaction Participant may suffer regarding its professional standing in an industry or the public eye. A Risk Bearing Institution and Transaction Participant can suffer from being associated with a situation that may be interpreted as contrary to an image of diligence, honesty and forthrightness.
Risks may be related to the duty to disclose material information, to report and possibly prevent: fraud, money laundering, foreign corrupt practices, bribery, embargoes and sanctions. Timely access to relevant data on which to base a regulatory or reputational Risk related action can be critical to conducting business and comply with regulatory requirements such as those set forth by the Patriot Act in the United States.
Risk Management Clearinghouse (RMC): RMC refers to computerized systems and methods for managing Risks and associating information and/or informational artifacts useful for quantifying Risk with a Risk subject, as more fully described in the related patent applications: Ser. No. 10/074,584 entitled "Risk Management Clearinghouse" filed Feb. 12, 2002, and U.S. patent application Ser. No. 10/021,124 entitled "Risk Management Clearinghouse" filed Oct. 30, 2001.
Risk Quotient: Risk Quotient refers to a quantitative value of an amount of Risk, a Risk Quotient can be based upon a weighted algorithm applied to the Risk criteria and informational artifacts.
Subscriber: Subscriber refers to any person or entity authorized to access an RMC system 106.
Transaction Participant: Transaction Participant refers to a person who will partake in a Financial transaction.
Referring now to
The information received can be constantly updated and can be related to a Hedge Fund or an alert list related to a Hedge Fund, in order to facilitate risk management and/or compliance with regulatory requirements. The RMC system 106 can facilitate due diligence on the part of a subscriber 111 by gathering, structuring and providing to the subscriber 111 data that relates to risk variables involved in a Hedge Fund.
A risk variable can include any datum associated with a specified Hedge Fund that can cause a risk level relating to the specified Hedge Fund to change. A Financial Institution may have an obligation to relate such variables to suspicious activity and also to know their customers. An RMC system 106 can compare and relate received information associated with a Hedge Fund with information from government sources, and the like, identifying high risk individuals, entities or organizations.
For example, a Financial Institution may request information on a Hedge Fund that has requested that the Financial Institution execute a particular transaction. The Financial Institution may submit an inquiry requesting information related to risk variables such as, who is associated with the Hedge Fund, the source of the Hedge Fund's investment, the Hedge Fund's manager or other related information. In addition, the Financial Institution may need to know if any of the parties or jurisdictions associated with the Hedge Fund is included on any list issued by the government relating to high risk activity. It may also be useful to ascertain whether a fund manager is a commodity pool operator. A commodity pool operator as defined by the Commodity Exchange Act can include a person engaged in the business of soliciting or accepting funds from other s for the purpose of trading commodity futures contracts in connection with a commodity pool.
Other risk variables can include, for exemplary purposes, a sovereign state involved, a geographic area, a shell bank, a correspondent account, a political figure, a person close to a political figure, a history of fraud, embargoes, sanctions, or other factors, such as a beneficiary of a partner in the Hedge Fund. Additional variables can include statements relating to Net Asset Value (NAV) that may be issued monthly or quarterly. The RMC system 106 may track statements of the NAV for a fund and highlight anomalies or trends, or sudden increases or decreases in value. It may also be useful to ascertain how heavily leveraged a Hedge Fund may be, as well as whether an amount of leverage is typical for particular Hedge Fund or shows a trend of increasing leverage or decreasing leverage. Typically, a Hedge Fund can require a substantial time commitment for funds invested in the fund, such as from 1 to 5 years, this type of commitment can be conducive to a static partnership which in turn can facilitate efforts to gather information related to the fund.
Hedge funds are inherently private investment vehicles and therefore it is sometimes difficult to obtain information on a level of detail that is equivalent to the amount of information that is available relating to traditional institutions. However, if it is available, other information that may be important relating to risk associated with a Hedge Fund can include the types of investments made by the Hedge Fund, as well as whether there is a change in the types of investments made by the Hedge Fund.
For example, a Hedge Fund may be involved in portfolio pumping which can include the practice of increasing a fund's stake in portfolio securities at the end of a financial period solely for the purpose of fraudulently driving up the NAV of the fund. An investment manager may, for example, manipulate the value of common stocks of an over the counter bulletin board company in which the Hedge Fund held an interest at the end of each month for a period of time. The investment manager can cause fund redemptions to be made at inflated values for the manager's benefit and to the detriment of a Hedge Fund's other investors.
Another practice that a RMC system 106 can attempt to provide information on can include "window dressing". With window dressing, a fund manager or advisor can buy or sell portfolio securities at the end of a reporting period for the purpose of misleading investors as to the securities held by an associated Hedge Fund, and/or the strategies engaged in by the advisers or the source of the fund's performance. For example, an advisor may cause a Hedge Fund to hold significant positions in securities that are not permitted under the Hedge Fund's disclosed investment objectives. As a reporting period draws near, the adviser liquidates these positions to come into compliance with its stated objectives. Investors can be misled if they are told that the find is investing consistent with prospectus disclosure when it is not.
Window dressing may also occur when an adviser replaces investments in otherwise permissible securities with investments in high performers just before the end of a reporting period to make it appear as thought the adviser had a winning hand.
Some embodiments can include a RMC system 106 performing a certification that a risk inquiry has been conducted relating to all known related parties and other risk factors. Inquiry criteria can be listed for the perusal and records of a subscriber interested. A certification can include transmitting to a subscriber any related informational data, informational artifacts or other materials discovered as a result of the inquiry. Embodiments can also include transmitting informational data and artifacts relating to a Hedge Fund risk inquiry without associating the informational data or artifacts with a risk quotient or any other value judgment or other rating. As such, still other embodiments can include a risk quotient, value judgement or other rating to provide a subjective quantification of the amount of risk involved in dealing with a subject Hedge Fund.
In some embodiments, and for example, if permissible under prevailing law, a subscriber can input or otherwise provide to an RMC system 106 information relating to a Hedge Fund. Provider supplied information can include information gathered according to normal course of dealings with a particular hedger fund or discovered via investigation. In addition, in accordance with prevailing law, a financial institution may discover or suspect that a person or entity related to a Hedge Fund is involved in some fraudulent or otherwise illegal activity and report this information to the RMC system 106, as well as an appropriate authority.
A decision by a financial institution concerning whether to pursue a transaction involving a Hedge Fund can be dependent upon many risk variables. A multitude and diversity of risks related to the variables may need to be identified and evaluated. In addition, the weight and commercial implications of each variable and associated Risks can be interrelated.
Information gathered from the diversity of data sources can be aggregated into a searchable data storage structure 108. A source of information can also be received and stored. In some instances a subscriber 111 may wish to receive information regarding the source of information received. Gathering data into an aggregate data structure 108, such as a data warehouse allows a RMC system 106 to have the data 108 readily available for processing a risk management search associated with a risk subject. Aggregated data 108 can also be scrubbed or otherwise enhanced.
In some embodiments involving enhancing data, data scrubbing can be utilized to implement a data warehouse comprising the aggregate data structure 108. Data scrubbing can take information from multiple databases or other sources and store it in a manner that provides efficient access to key portions. Scrubbing can facilitate expedient access to accurate data commensurate with the critical business decisions that will be based upon the risk management assessment provided.
Various data scrubbing routines can be utilized to facilitate aggregation of risk variable related information. The routines can include programs capable of correcting a specific type of mistake, such as an incomprehensible address, or clean up a full spectrum of commonly found database flaws, such as field alignment that can pick up misplaced data and move it to a correct field or removing inconsistencies and inaccuracies from like data. Other scrubbing routines can be directed directly towards specific legal issues, such as money laundering or terrorist tracking activities.
For example, a scrubbing routine can be used to facilitate various different spellings of a word or phrase. In particular, spelling of names can be important when names have been translated from a foreign language into English. For example, some languages and alphabets, such as Arabic, may have no vowels. Translations from Arabic to English can be very important for financial institutions seeking to be in compliance with lists supplied by the U.S. government that relate to terrorist activity and/or money laundering. A data scrubbing routine can facilitate risk variable searching for multiple spellings of an equivalent name or other important information. Such a routine can enhance the value of aggregate data gathered and also help correct database flaws. Scrubbing routines can improve and expand data quality more efficiently than manual mending and also allow a subscriber 111 to quantify best practices for regulatory purposes.
Retrieving information related to risk variables from aggregated data is an operation with the goal to fulfill a given a request. In order to process a request against a large document set of aggregated risk data with a response time acceptable to the user, it may be necessary to utilize an index based approach to facilitate acceptable response times. A direct string comparison based search may be unsuitable for the task.
An index file for a collection of documents can therefore be built upon receipt of the new data and prior to a query or other request. The index file can include a pointer to a document and also include important information contained in documents the index points to. At query time, the RMC system 106 can match the query against a representation of the documents, instead of the documents themselves. The RMC system 106 can retrieve the documents referenced by the indexes that satisfy the request if the subscriber submits such a request. However it may not be necessary to retrieve the full document as index records may also contain the relevant information gleaned from the documents they point to. Efficiency can be increased as the user is allowed to extract information of interest without having to read the source document.
At least two exemplary retrieval models can be utilized in fulfilling a search request. One retrieval model can include Boolean retrieval in which a document set is partitioned in two disjoint parts with one fulfilling a query and one not fulfilling it. A second retrieval model can include relevance ranking in which all the documents are considered relevant to a certain degree. Boolean logic models use exact matching, while relevance ranking models use fuzzy logic, vector space techniques, such as a technique wherein documents and the query are considered vectors in a multidimensional space, a shorter distance between a document vector and the query vector indicates increased relevance for the document, neural networks, and probabilistic schema.
Augmenting data can include data mining techniques that use software to analyze and sift through the aggregated data stored in the warehouse utilizing techniques such as mathematical modeling, statistical analysis, pattern recognition, rule based trends or other data analysis tools. In contrast to traditional systems that may have gathered and stored information in a flat file and regurgitated the stored information when requested, such as in a defined report related to a specific risk subject or other ad hoc access concerned with a particular query at hand, the present invention can provide risk related searching that adds a discovery dimension by returning results that human operator would find very labor and cognitively intense.
This discovery dimension supplied by the RMC system 106 can be accomplished through the application of augmenting techniques, such as data mining applied to the risk related data that has been aggregated. Data mining can include the extraction of implicit, previously unknown and potentially useful information from the aggregated data. This type of extraction can include unlooked for correlations, patterns or trends. Other techniques that can be applied can include fuzzy logic and/or inductive reasoning tools.
For example, augmenting routines can include enhancing available data with routines designed to reveal hidden data. Revealing hidden data or adding data fields derived from existing data can be very useful to risk management. For example, supplied data may not include an address for a person involved in a Hedge Fund; however a known telephone number is available. Augmented data can include associating the telephone number with a geographic area. The geographic area may be a political boundary, or coordinates, such as longitude and latitude coordinates, or global positioning coordinates. The geographic area identified can then be related to high risk or low risk areas.
An additional example of augmented data derived from a telephone number can include associating the given telephone number with a high risk entity, such as a person listed on an OFAC list.
In some embodiments, a subscriber 111 can access the RMC system 106 via a computerized system as discussed more fully below. The subscriber can input a description of a Hedge Fund, or other inquiry, such as the name of a party associated with a Hedge Fund. In some instances, and in accordance with applicable laws, other identifying information can also be input, such as a date of birth, a place of birth, a social security number or other identifying number, or any other descriptive information. The RMC system 106 can receive the identifying information and perform a risk related inquiry or search on the aggregated data, including, if it is available, any scrubbed data.
In other embodiments, a subscriber 111 can utilize a computerized proprietary risk management (PRM) system 112. The PRM system 112 can receive an electronic feed from a RMC system 106 with updated data, including, if it is available, any scrubbed data. In addition, data mining results can also be transmitted to the PRM system 112 or performed by the PRM system 112 for integration into the risk management practices provided by in-house by the subscriber.
Information entered by a subscriber into a PRM system 112 may be information gathered according to normal course of dealings with a particular entity or as a result of a concerted investigation. In addition, since the PRM system 112 is proprietary and a subscriber responsible for the information contained therein can control access to the information contained therein, the PRM system 112 can include information that is public or proprietary. If desired, information entered into the PRM system 112 can be shared with a RMC system 106. Informational data can be shared, for example via an electronic transmission or transfer of electronic media. However, RMC system data 108 may be subject to applicable local or national law and safeguards should be adhered to in order to avoid violation of such law through data sharing practices. In the event that a subscriber, or other interested party, discovers or suspects that a person or entity is involved in a fraudulent or otherwise illegal activity, the system can report related information to an appropriate authority.
Generally, the functionality of a PRM 112 is equivalent to functionality provided by an RMC system 106, except that data stored in the PRM 112 and access to the RPm 112 can be kept proprietary. For the remainder of this document, any reference to an RMC 106 can be considered to also include a PRM 112 unless otherwise specified.
The RMC system 106 can allow a Financial Institution, or other subscriber, to screen Hedge Fund related entities with various due diligence checks on an efficient basis. An inquiry can be utilized to identify Hedge Funds by principals involved, by investment style, performance, domicile or other criteria. It can also be useful in determining if a Hedge Fund is for U.S. and non-U.S. investors; whether a Hedge Fund is a single manager fund or a fund of funds; details relating to management style and underlying investments; or research details of a fund. Details can also be included relating to fund risk and performance analytics.
A log or other stored history can be created by the RMC system 106 and/or a PRM system 112, such that utilization of the system can mitigate adverse effects relating to a problematic account. Mitigation can be accomplished by demonstrating to regulatory bodies, shareholders, news media and other interested parties that corporate governance is being addressed through tangible risk management processes.
One or more reports can also be generated which are related to one or more risk variables searched by the RMC 106. In various embodiments, the reports can include informational data returned by a risk query, any related informational artifacts, descriptions of informational artifacts, risk quotients or other evaluations or summaries of information resulting from any related RMC searches.
An inquiry can also be automatically generated from monitoring transactions being conducted by a subscriber 111, or taking place with systems under control of a subscriber. For example, an information system can electronically scan transaction data for key words, entity names, geographic locales, or other pertinent data relating to Hedge Funds. Programmable software can be utilized to formulate an inquiry according to a Hedge Fund name, partner name, sponsor name, manager name, beneficiary name or other pertinent data and run the inquiry against a database maintained by the RMC server 210 or in a PRM server 211. Other methods can include voice inquiries via a telephone or other voice line, such as voice over internet, fax, electronic messaging, or other means of communication. An inquiry can also include direct input into a RMC system 106, such as through a graphical user interface (GUI) with input areas or prompts.
An inquiry can also be generated by filling in data in a GUI with fields or prompts. Prompts or other questions proffered by the RMC system 106 can be according to predetermined data fields, or depend from previous information received. Information generally received, or received in response to the questions, can be input into the RMC system 106 from which it can be utilized for real time risk assessment and generation of a risk valuation, such as a risk quotient.
An alert list containing names and/or terms related to a Hedge Fund can also be supplied to the RMC system 106 by a subscriber 111 or other source. Each alert list can be customized and specific to a subscriber 111. The RMC system 106 can continually monitor data in its database via an alert inquiry with key word, fuzzy logic or other search algorithms and transmit related informational data to the interested party. In this manner, ongoing diligence can be conducted. In the event that new information is uncovered by the alert inquiry, the subscriber 111 can be notified. Appropriate action can be taken according to the information uncovered.
The RMC system 106 can quantify risk due diligence by capturing and storing a record of information received which can include, for example, informational data, copies of or a description of any artifacts and a description of any actions taken relating to a Hedge Fund. Once quantified, the due diligence data can be utilized for presentation, as appropriate, to regulatory bodies, shareholders, news media and/or other interested parties, such presentation may be useful to mitigate adverse effects relating to a problematic transaction. The data can demonstrate that corporate governance is being addressed through tangible risk management processes.
In some embodiments, a RMC database 108 can contain only information collected from publicly-available sources relevant for the detection and prevention of money laundering, fraud, corrupt practices, organized crime, activities subject to governmental sanctions or embargoes, or other similar activities that are the subject of national and/or global regulation. A subscriber 111 can use the database to identify the possibility that a risk subject associated with a Hedge Fund may be involved in illegal activities.
A subscriber 111 to the RMC system 106 can access the database electronically and to receive relevant information electronically and, in specific circumstances, hard copy format. If requested, a RMC system 106 provider can alert a subscriber 111 upon its receipt of new RMC system 106 entries concerning a previously screened individual. A subscriber 111 will be permitted to access information in the RMC system 106 in various ways, including, for example: system to system inquires involving single or batch screening requests, individual inquiries (submitted electronically, by facsimile, or by phone) for smaller screening requests, or through a web-based interface supporting an individual look-up service. Generally, employees and vendors will not be permitted to use or share to information about subscriber requests unless such access is necessary to provide a requested product or service or to fulfill legal obligations under prevailing law.
In some embodiments, a RMC system 106 can take any necessary steps so as not to be regulated as a consumer reporting agency. Such steps may include not collecting or permitting others to use information from the RMC database 108 to establish an individual's eligibility for consumer credit or insurance, other business transactions, or for employment or other Fair Credit Reporting Act (FCRA) covered purposes such as eligibility for a government benefit or license.
To satisfy the requirements of embodiments prohibiting use of the RMC 106 for FCRA covered purposes, a subscription agreement can be established between the RMC system 106 provider and a subscriber 111 which will create enforceable contractual provisions prohibiting the use of data from the RMC database 108 for such purposes. The operations of the RMC system 106 can be structured to minimize the risk that the RMC database will be used to furnish consumer reports and therefore become subject to the FCRA.
Some embodiments can therefore include establishment of additional policies and practices to avoid FCRA implications, such as, for example: the information in the RMC database can be collected only from reputable, publicly available sources and not contain information from consumer reports; the RMC system 106 can collect and permit others to use the information only for the purpose of complying with regulatory and legal obligations associated with the detection and prevention of money laundering, fraud, corrupt practices, organized crime, activities subject to governmental sanctions or embargoes, or other illegal activities that are the subject of national and/or global regulation.
The RMC system 106 can forego collection of and refuse to permit others to use information from the database to establish an individual's eligibility for consumer credit or insurance, for employment or for any other use contrary to any other restrictions FCRA may establish. Subscribers can be required to execute a licensing agreement that will limit their use of the data to specified purposes, including, for example, specifically that the subscriber 111 will not use the information to determine a consumer's eligibility for any credit, insurance, other business transaction or for employment or other FCRA-covered purposes. Accordingly, some embodiments can require each subscriber 111 to certify that the subscriber 111 will use the data only for such specified purposes, and to certify annually that the subscriber 111 remains in compliance with its certification that the information is not being used for any of the proscribed purposes.
A licensing agreement that can be utilized with some embodiments can also require that subscribers 111 separately secure information from non-RMC system 106 sources to satisfy any need the subscriber has for information to be used in connection with the subscriber's determination regarding a consumer's eligibility for credit, insurance, other business transactions, or employment or for other FCRA-covered purposes.
In another aspect, in some embodiments of a RMC system 106, a provider can utilize the RMC system 106 to provide services exclusively to other Financial Institutions or business entities, such that the RMC system 106 provider will have neither "customers" nor "consumers" as those terms are defined in the Gramm-Leach-Bliley Act (GLBA) and therefore may have no notice or disclosure obligations under the GLBA. In addition, a subscriber's disclosure of the name of its customer to a RMC system 106 may be permitted for institutional risk control and other purposes under the GLBA. An RMC system 106 provider can be contractually obligated to use customer names received from a subscriber only for the purpose of fulfilling that subscriber's request for information or for another purpose permitted by the GLBA, ensuring that the Act's limits on re-use and re-disclosure are met.
In another embodiment, a RMC system 106 may allow dissemination of database information for purposes including: the prevention or detection of crime; the apprehension or prosecution of offenders; or the assessment or collection of any tax or duty.
In still another aspect, a RMC system 106 can be structured to take advantage of the immunity from liability for libel and slander granted by the Communications Decency Act ("CDA") to providers of interactive computer services. Where its operations are not protected by the CDA, a RMC system 106 may be able to reduce its risk of liability for defamation substantially by relying only upon information and artifacts provided by official government sources and other reputable sources, and taking particular care with defamatory information from unofficial sources. In addition the RMC system 106 provider can take reasonable steps to assure itself of the information's accuracy, including insuring that the source of the information is reputable.
The RMC system 106 can operate an interactive computer service as that term is defined in the CDA. The clearinghouse can therefore provide an information service and/or access software that enables computer access by multiple users to a computer server. In some embodiments, if desired, a RMC system 106 provider can limit its employees or agents from creating or developing any of the content in the RMC database 108. Content be maintained unchanged except that the RMC system 106 can remove information from the database that it determines to be inaccurate or irrelevant.
Still other embodiments can incorporate a transmission of information from the RMC database 108 that will be carefully structured such that the RMC system 106 will not provide "consumer reports" regulated by the FCRA. As such, the data may be limited by not relating to consumers, but rather to corporate entities. Data on consumers can be prevented from identifying them definitively, inasmuch as the individual named in a public record may or may not be the individual who is the subject of a RMC search. Moreover, the RMC system 106 can forego collecting information in order to provide consumer reports, and also not use or have a reasonable basis to expect that subscribers will use, any RMC data 108 for FCRA covered purposes.
For example, in some embodiments, the RMC system 106 can limit collection of data to that information that will be relevant for the detection and prevention of money laundering, fraud, corrupt practices, organized crime, activities subject to governmental sanctions or embargoes, or other similar activity that is the subject of national and/or global regulation. The RMC system 106 can be limited to collecting information for the RMC database 108 solely from publicly-available sources, principally information from news media and information released to the public by government agencies, such as regulatory enforcement action notice and embargo, sanction and criminal-wanted lists.
If desired, in order to help avoid implications with the FCRA, an embodiment can prevent data from including identifiers that would assure the subscriber that the subject of the data is the same person as the subject of the subscriber's inquiry. For example, while the data will typically identify the subject by name, they often will not include a social security number, photograph, postal address, or similar comparatively definitive identification. As many people share identical names, a subscriber often will be unsure whether any or all of the data received relate to the person inquired about.
Referring now to
In addition, a PRMC server 211 can access the RMC server 210 via the network 201 or via a direct link 209, such as a T1 line or other high speed pipe. The RMC server 210 can in turn be accessed by a Subscriber 111 via a system access device 204-207 and a distributed network 201, such as a local area network, or other private network, or even the Internet, if desired. A Subscriber 111 can also be situated to access the RMC server 210 directly, or any other system architecture conducive to a particular need or situation. In some embodiments, a remote Subscriber 111 can access the RMC server 210 via a system access device 204-207 also used to access other services, such as resources available on the Internet.
A computerized system or system access device 204-207 used to access the RMC server 210 or the PRM server 211 can include a processor, memory and a Subscriber 111 input device, such as a keyboard and/or mouse, and a Subscriber 111 output device, such as a display screen and/or printer. The system access devices 204-207 can communicate with the RMC server 210 or the PRM server 211 to access data and programs stored at the respective servers 210-211. The system access device 204-207 may interact with one or more servers 210-211 as if the servers 210-211 were a single entity in the network 200. However, the servers 210-211 may include multiple processing and database sub-systems, such as cooperative or redundant processing and/or database servers that can be geographically dispersed throughout the network 200.
The PRM server 211 and the RMC server 210 include one or more databases 202-203 storing data relating to proprietary risk management. The PRM server 211 and the RMC server 210 may interact with and/or gather data from an operator of a system access device 204-207 or other source. Data received may be structured according to risk variables and utilized to calculate a risk quotient.
Typically a Subscriber 111, will access the PRM server 211 or RMC server 210 using client software executed at a system access device 204-207. The client software may include a generic hypertext markup language (HTML) browser, such as Netscape Navigator or Microsoft Internet Explorer, (a "WEB browser"). The client software may also be a proprietary browser, and/or other host access software. In some cases, an executable program, such as a Java™ program, may be downloaded from a server 210-211 to the client computer and executed at the system access device or computer as part of the RMC risk management software. Other implementations include proprietary software installed from a computer readable medium, such as a CD ROM. The invention may therefore be implemented in digital electronic circuitry, computer hardware, firmware, software, or in combinations of the above. Apparatus of the invention may be implemented in a computer program product tangibly embodied in a machine-readable storage device for execution by a programmable processor; and method steps of the invention may be performed by a programmable processor executing a program of instructions to perform functions of the invention by operating on input data and generating output.
Referring now to
In addition to the information itself, a source of risk variable data can also be received 311 by the RMC server. For example, a source of risk variable data may include a private investigator, a government agency, an investigation firm, public records, news reports, publications issued by Treasury's Financial Crimes Enforcement Network ("FinCEN"), the State Department, the CIA, the General Accounting Office, Congress, the Financial Action Task Force ("FATF"), various international financial institutions (such as the World Bank and the International Monetary Fund), the United Nations, other government and non-government organizations, internet websites, news feeds, commercial databases, or other information sources.
The PRM server 211 or RMC server 210 can aggregate the data received according to risk variables 312 or according to another data structure which is conducive to fielding risk related to Hedge Funds.
A RMC server 210 can be accessed in real time, or on a transaction by transaction basis. In a real time embodiment, any changes to the RMC data 108 may be automatically forwarded to a system access device 204-207 or an in-house PRM system 112. On a transaction by transaction basis, the PRM system 112 can be queried for specific data that relates to variables associated with a particular transaction.
All data received can be combined and aggregated 312 according to risk variables to create an aggregate source of data which can be accessed to perform risk management activities. Combining data can be accomplished by any known data manipulation method. For example, the data can be maintained in separate tables and linked with relational linkages, or the data can be gathered into on comprehensive table or other data structure. In addition, if desired, information received can be associated with one or more variables including a position held by a sponsor or Hedge Fund partner, a country in which the fund is domiciled, how long a find has been operating, the amount of leverage on the Hedge Fund's assets, the veracity of previous dealings with persons associated with the Hedge Fund, the propensity of people associated with the Hedge Fund to execute unlawful or unethical transactions, a type of transaction that will involve the Hedge Fund, or other criteria.
In some embodiments, a certification package can be created relating to a particular Hedge Fund 313. A certification package can include a list of parameters for which an inquiry was executed. For example, parameters can include all principals involved in a Hedge Fund. The parameters can be researched and the results included in a certification package. In addition, research into any suspect practices or associations can also be conducted. A certification package can be standardized or subjective to a particular fund. The list of subjects researched can serve as an indicator of how comprehensive the research is that is being performed.
If desired, different levels of certification can also be made available. For example a Level A certification may include high level research and Levels B, C, and D may include increasingly more detailed research and a more comprehensive list of researched parameters. Other examples of Hedge Fund related parameters that can be part of one or another certification level can include: a sponsor of a Hedge Fund, a partner of a Hedge Fund, a domicile of a Hedge Fund, an investment of a Hedge Fund or investors in a Hedge Fund where applicable.
Still other embodiments can include generating a risk quotient for a Hedge Fund based upon the certification research and weighted risk variables 314. Generation of a risk quotient may have legal implications pertaining to the FCRA or statutes regarding the sharing of information. Accordingly, a Hedge Fund risk quotient may be more suitably generated on an in-house PRM system 112. However, a RDC system 106 can be made capable of generating such a rating which can provide a ready Risk reference for a subscriber 111.
The RMC server 210 or PRM server 211 can receive an inquiry relating to a Hedge Fund 315. The inquiry from a subscriber 111, or other authorized entity, can cause the respective servers 210-211 to search the aggregated data and associate related portions of aggregated data with Hedge Fund 316. The associated portions of aggregated data can be transmitted 317 to a destination designated by the inquiry requester, such as a system access device 204-207 or a PRM system 112, a fax machine or a voice line.
The RMC server 210 may also receive a request for the source of any associated portions of aggregated data transmitted 318, in which case, the RMC server 210 can transmit the source of the associated portions of aggregated data 319. The source may be useful in adding credibility to the data, or to follow up with a request for additional information.
The RMC server 210 can also store in memory, or otherwise archive risk management related data and proceedings 320. Archived risk management related data and proceedings can be useful to quantify corporate governance and diligent efforts to address high risk situations. Accordingly, reports quantifying RMC risk management risk management procedures, executed due diligence, corporate governance or other matters can be generated 321.
Referring now to
An inquiry can be performed against the aggregated and enhanced data 415. In addition, an augmented search that incorporates data mining techniques 416 can also be included to further expand the depth of knowledge retrieved by the inquiry. If desired, a new inquiry can be formed as a result of the augmented search. This process can continue until the inquiry and augmentation ceases to add any additional meaningful value.
As discussed above, any searching and augmentation can be archived 417 and reports generated to quantify the due diligence efforts 418.
Referring now to
Access can be accomplished, for example, by opening a dialogue with a RMC system 211 with a network access device, 204-207, 204-207. Typically, the dialogue would be opened by presenting a GUI to a network access device accessible by a person or an electronic feed that will enter information relating to the transactor. The GUI will be capable of accepting data input via a network access device. An example of a GUI would include a series of questions relating to a transaction. Alternatively, information can be received directly into fields of a database, such as from a commercial data source. Questions can be fielded during a transaction, or at any other opportunity to gather information.
In some embodiments, automated monitoring software can run in the background of a normal transaction program and screen data traversing an application. The screened data can be processed to determine key words wherein the key words can in turn be presented to the RMC server 210 as risk subjects or risk variables. The RMC server 210 will process the key words to identify entities or other risk variables. Monitoring software can also be installed to screen data traversing a network or communications link.
The Subscriber 111 will receive back information relating to risk associated with conducting a transaction involving the submitted subject 512. The information can include enhanced data, such as scrubbed data. In some embodiments, a Subscriber 111 can receive ongoing monitoring of key words, identified entities, a geographic location, or other subject, or list of subjects. Any updated information or change of status detected via an ongoing monitoring can result in an alarm or other alert being sent to one or more appropriate Subscriber 111s.
The Subscriber 111 can also receive augmented information 513, such as data that has been processed through data mining techniques discussed above.
In addition to receiving augmented information 513, a Subscriber 111 can request an identifier, such as a link to a source of information relating to a Hedge Fund 514. Receipt of a link pertaining to a source of information 515 may be useful to pursue more details relating to the information, or may be utilized to help determine the credibility of the information received.
A Subscriber 111 can also cause an archive to be created relating to Hedge Fund related risk management 516. An archive may include, for example, information received relating to risk associated with a Hedge Fund, inquiries made concerning the Hedge Fund and any results received relating to an inquiry. In addition, the Subscriber 111 can cause a RMC server 210 to generate reports to quantify the archived information and otherwise document diligent actions taken relating to risk management 517.
A number of embodiments of the present invention have been described. Nevertheless, it will be understood that various modifications may be made without departing from the spirit and scope of the invention. For example, a Hedge Fund can voluntarily provide information to a RMC 106 in order to establish credentials that can be passed along to any subscriber placing an inquiry related to the Hedge Fund. In addition, an investigation firm, auditing firm or other information provider can also voluntarily provide information to a RMC 106 which can bolster the image of the information provider and also aid the subscriber 111. Accordingly, other embodiments are within the scope of the following claims.
Patent Citations
Non-Patent Citations
Referenced by
Legal Events
Original Image


text:
Gear Review
High Roller 60a
super gnarly tires. the higher rolling resistance is not noticeable.
they grip like no other and handle very well on wet/snow packed trails. this will be my second season using these tires.
i would definitely recommend.
View More Details on Maxxis High Roller UST Mountain Bike Tire - 26in

subset: commoncrawl


text:
9 Cool Items For Golfers At CES
The International Consumer Electronics Show in Las Vegas is billed as the largest such show in the world, featuring more than 3,200 exhibitors and an estimated 20,000 new products, ranging from wearables to ultra high-definition TVs to connected cars.
While the conference doesn't include a dedicated golf zone, the week-long event did showcase at least a few intriguing finds for golfer who look to gadgets to improve their game or to make a round more enjoyable.
Here are some products that stood out amid a sea of recently released or forthcoming gadgets at the annual tech confab.
What could make those marathon Saturday rounds in the dead of summer more bearable? Solar Cool Technologies might have the answer with its solar-powered cooler, essentially a portable mini-fridge that gives you quick and easy access to those cold ones. If you use battery-draining GPS golf app, the cooler also includes a USB port to keep smartphones juiced up. As long as there's sunlight, the cooler won't run out of power. It's not for the budget-minded, though, with a hefty $1,200 price tag. Of course, it's also an excellent accessory for camping, tailgating and other outdoor activities, making the cost slightly more palatable. The cooler will be available in June. Solarcooltech.com
- Keywords:
- golf,
- equipment,
- gadgets,
- International Consumer Electronics Show,
- Andy Vuong


text:
Kiwanis gathers items for food ministry
The Sevierville Kiwanis Club set up shop outside Food City on Saturday, collecting cans and other food items to help the Sevier County Food Ministries replenish supplies.
"We've teamed up with Food City today and we're handing out brochures that list some of the basic things all families need, hoping to build up their supplies a little," said Kiwanis Club member Leslie Atchley.
Atchley, along with Kiwanis President Terrye McAnally, greeted customers walking into the grocery store. Emily-Grace McCarter and Tyler Jeffers of the Sevier County High School Key Club also helped pass out the yellow brochures displaying foods they were looking for.
"We're also taking cash donations, because with cash they can buy more food per dollar than what we can, but the visualization of people seeing what they need, and that there is a need, is important," Atchley said.
Atchley said the food ministry's shelves are bare right now. One of the Kiwanis members also volunteers at the food ministry, and Atchley said he's been keeping the club informed on the status of the ministry's shelves.
In just a couple hours at Food City, the club had collected about 14 crates of food. They had boxes of macaroni and cheese, cans of soup, fruits and vegetables, as well as jars of peanut butter.
"There's no goal, just whatever we can get," Atchley said. "Every can helps."
The tactic was to hand out the brochure to every person walking into the store, then wait. No pleading, heckling or harassing.
"Somebody may bring us one can and the next person may bring us three bags full," Atchley said. "It just depends on where their heart and conscious is at the moment."
After 5 p.m., the club gathered all the items they collected since 8 a.m. and drove them over to the food ministry.


text:
"The time has come," the Walrus said,
"To talk of many things:
Of shoes--and ships--and sealing-wax--
Of cabbages--and kings--
And why the sea is boiling hot--
And whether pigs have wings."
The Walrus and The Carpenter
On March 21st, 2013 the Repository was taken offline. It was a good run, but it has been a solid year since I last stepped foot into EQ. The game has moved on, the guide was becoming more and more outdated with each passing day, so I turn my attentions to
other pursuits
. A hearty thank you to all that helped collect information, and to those that donated over the years, know the money was used well. In addition to covering my EQ related costs, it helped pay for someone get their college transcipts sent in on time to start school, it kept a person in North Dakota from losing their heat one winter, it paid for another person's dog to go to the vet and live another 4 years, it provided a single mother a little something to buy gifts for her kids for Christmas. A great number of lives have been touched by your generosity.
- Rasper the Helpdesk (aka Tony)
For those of you still doing old content, do not be afraid, the guide lives on at


text:
From her drama on Love & Hip Hop Atlanta to her beef with Tamar Braxton, K. Michelle isn't one to keep her opinions to herself. Today the singer took to Twitter to express her frustration at Iggy Azalea's Memphis-style of rapping. Gossip blogger Perez Hilton was there at the ready though to defend the Australian and K. Michelle laid into him, telling him to use his platform for more important issues than her taste in music. Check our gallery to track the whole Twitter feud.
Do you think K. was in the right? Or do you think Perez had a point coming for the Love & Hip Hop-per?


text:
The ideal
way to earn a degree in art at UNI is to enter as a freshman, and to complete all requirements at a single school. That is the most efficient means, and, in the long run, it is usually the most cost effective. Nevertheless, we make every effort to do what we can to accommodate
Student work
(top of page, left to right) © Bounnak Thammavong, Tyler Speicher and Jensen Barnes.


text:
August Busch IV to Leave AB Board
|August A. Busch IV will be leaving the board of the company he used to run.
We read the news over at our favorite gossip site, Punching Kitty; they apparently got it from Bloomberg News.
Bloomberg's source is apparently the newly released agenda for beer conglomerate AB's April shareholders meeting. It shows two new members will be voted onto the board of the Belgium-based company -- which apparently means the writing's on the wall for St. Louis' very own bad beer baron.
Busch's girlfriend, Adrienne Martin, was found dead in his bedroom December 19. The coroner's report showed that Martin had used oxycodone and cocaine prior to her death; Busch refused to cooperate with the investigation, and St. Louis County Prosecutor Bob McCulloch closed the case without filing charges.
Busch was previously linked to the death of a young woman in Tucson; he did not face charges in that incident, either.
The Post-Dispatch previously reported that Busch earned $93,000 for serving on the AB board in 2010, yet only attended one of nine board meetings.
Sponsor Content


text:
Overall Record: 0-2 Last Week:
No Team Scores
Scoreboard: No Team Scores at Valentine Invitational, Boston, Mass, 2/13
Schedule: Friday-Sunday, Feb. 19-21, at Patriot League Indoor Championship, West Point, N.Y.
- The Holy Cross men's track and field team will kick off the indoor championship season at the Patriot League Indoor Championship in West Point, N.Y. on Feb. 19-21. Holy Cross is looking to improve on its eighth place performance a year ago.
- At last year's indoor championship, the distance medley relay team qualified for the IC4A Indoor Championship with a seventh place finish and time of 10:18.27. Seniors Kyle Rougeot's (Torrington, Conn.) and Timothy Richard (Attleboro, Mass.) ran on the relay team.
- In a tune up for the Patriot League Indoor Championship, multiple members of the track and field team hit season-best marks at the Valentine Invitational on Saturday, Feb. 13. Richard clocked a season-best and personal-best time of 8:33.38 in the 3,000. In the 1,000, senior Brendan Medeiros (Fall River, Mass.) ran a team-best and season-best time of 2:33.15, while freshman Kyle Shepard (White Plains, N.Y.) finished with a personal-best time of 2:35.47. Senior A.J. Malloy (Dunbarton, N.H.) finished with a season-best time of 23.45 seconds in the 200 and senior Chase Kennedy (Marblehead, Mass.) ran a season-best time of 51.41 seconds in the 400.


text:
Practical Cucumber: Factory Girl steps
This post is part of our Practical Cucumber series.
Did you know that factory_girl comes with some really useful cucumber steps? You're not alone, even though they've been around for a while.
Simply require them in your cucumber
env.rb file:
require "factory_girl/step_definitions"
Then you can begin using them in your features:
Given a user exists with an email of "email@example.com" And the following categories exist: | Name | | Cucumber | | BDD | And the following article exists: | Title | Body | Published at | | Factory Girl cucumber steps | lorem… | 2010-09-10 |
One of my favorite features of the factory_girl steps is that you can also specify associations:
Given the following user exists: | Name | Email | | Brandon | email@example.com | And the following articles exist: | Title | Author | | Article 1 | Name: Brandon | | Article 2 | Name: Daniel |
To make this to work, declare your associations in the factory and the steps will try to find or create by the association attribute.
Factory.define :article do |m| m.sequence(:title) {|i| "Article #{i}" } m.association :author, :factory => :user end
Stop wasting time writing basic steps for creating models and spend your time working on the application.
This post is part of our Practical Cucumber series.
14 Comments
Jeremy D. Frens September 09, 2010 http://www.norecess.org/
In the words of Johnny Carson (through the voice of Dana Carvey), "I… I did not know that." But I'm very happy I do now; that's awesome.
Torey Heinz September 09, 2010 http://ihswebdesign.com
I have been using Machinist lately and didn't find any cucumber steps like these, so right away I hacked together some Machinist steps. http://ihswebdesign.com/blog/machinist-steps/
Might be helpful to someone.
DAvid September 27, 2010
That really good to know. Thanks for this great tip!
Manu October 29, 2010 http://manuraghavan.net
Thank you, I found this useful
Manu October 29, 2010 http://manuraghavan.net
Thank you, I found this useful
neohomerico December 14, 2010
Thanks for sharing
John February 26, 2011
Dorian May 18, 2011
That's very interesting indeed. However i get the following error
Undefined step: "the following user exists:" (Cucumber::Undefined exception)
(i've installed all the required gems and updated the cucumbre env.rb file)
Any hints on how to fix that? Thanks!
Daniel Morrison May 18, 2011 http://collectiveidea.com
Dorian, I know exactly what it is because I got stuck here a couple months ago, even though I've done this tons of times.
Make sure you have a user factory defined. It isn't enough to just have the model, you have to have the factory defined too.
Hope that solves it!
Al March 21, 2012
Is there a way to do this without tables?
Matthew Hassfurder July 02, 2012 http://matthew.hassfurder.com
Alas, it appears these are to be removed in 4.0.
Andrew August 31, 2012 http://www.andrewhavens.com
Ah, yes, these factory_girl steps have been removed. I wondered why I couldn't get it to work. I should also remember check the date of when articles are written. =/
Daniel Morrison August 31, 2012 http://collectiveidea.com
Good point. Time for us to update the post!
Sibu Stephen January 07, 2015
The above steps really seemed to be ,helpful from the point of implementing Factory girl in Cucumber.


text:
Posted at: 04/19/2013 4:25 PM
Updated at: 04/19/2013 5:35 PM
By: HOWARD ULMAN
BOSTON (AP) - The Red Sox and Bruins have postponed their games while authorities search for a suspect in the Boston Marathon bombings.
No makeup date was announced for the opener of the Red Sox three-game series against the Kansas City Royals scheduled for Friday night at Fenway Park. The Bruins game against the Pittsburgh Penguins at TD Garden was rescheduled for Saturday.
(Copyright 2013 The Associated Press. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.)


text:
Strong cast in atmospheric evening of Christie intrigue
Posted: January 31, 2013|
LOVERS of thrillers – particularly the Agatha Christie variety – will be in their element at Derby Theatre this week.
A Murder Is Announced will give mystery fanatics a good fix of bloodshed and mayhem, plus a few well-known names as a bonus.
The atmosphere of murder is fixed from the start, beyond the title of the play, when the hapless and slow-witted Bunny, played convincingly by Claire Fisher, spots an announcement in the paper.
It states that there will be a murder at the house she is in at 6.30pm later that day and so starts a build-up of tension and apprehension.
The large cast is headed by former Dr Who companion and veteran actress Katy Manning, as the formidable Letitia Blacklock, whose life is suddenly in danger, as a consequence of the announcement. She is ably supported by former television stars Dean Gaffney, playing Patrick, and Gemma Bissix, as Julia, who are well-known for their roles in EastEnders as Robbie and Clare respectively.
Stealing the laughs in the show is Julia Main as neurotic home help Mitzi, who suspects her papers and passport are about to be rescinded and she will be sent back to her European homeland – but it is not clear where that is.
Sleuth Miss Marple, played by Geraldine Newman, saves the day as usual and her efforts are much appreciated by the not-so-bumbling Inspector Craddock, played by former 'Allo 'Allo star John D Collins.
The 1950s setting, together with the atmospheric music of the era, make for a predictable but pleasant evening of intrigue at Derby Theatre.
A Murder is Announced continues at Derby Theatre until Saturday.


text: About Us Contact Us Policies Login/Register Check Order Status OWN YOUR FITNESSOrder by Phone: 877-734-7227All Products Dip Bar and Dip Station Dip Bar Fitness Station Wall Mount Dip Station All Dip Bars Pull Up Bars Wall Mounted Pull Up Bar Joist Mount Pull Up Bar 26" Doorway Pull Up Bar All Pull Up Bars Workout Gear Indian Clubs - 2lbs Push up Rings Resistance Band Agility Trainer All Workout Gear Package Deals Dynamic Strength Package Kailo Fitness Program Package All Package Deals Current Specials Dip Station and Rings PackageThe Ultimate Pull Up Bar Accessory Push Up Rings Do More Body Weight Moves Wood Gymnastic RingsTake your Fitness to the Next Level See All Specials Dip StationsPull Up BarsWorkout GearPackage DealsSaleWorkoutsBlogHome - Dip Stand - Pull Up Bar Workout System Articles - Dip Bar, Dip Station, Dip Stand, Dip Machine Articles - Dip Station LifestyleDip Station LifestyleA busy lifestyle with a 10 hour work week and other personal commitments does not have to keep you from meeting your health and fitness goals. A recent study found that a dip station strength training workout schedule does not have to be a rigid as you may have previously believed. Even if you have to wake up before dawn and don't get home until way after the sun has set, you can use a pull up bar dip machine workout from Ultimate Body Press to build new strength and muscle all the time. The study compared a group of individuals who performed a resistance training workout all at once to another group who performed the same number of resistance exercises over the course of an entire day. The study found no difference in the amount of muscle gained between the two groups. This means that by using our compact dip stand and pull up products for short mini-workouts throughout the day can be just as effective as one full dip bar workout done in one session.You may consider breaking 3-4 dip machine sets up while you get ready for work. Another strategy would be to take you dip stand to work with you or purchase a second pull up bar to leave at work. This way you can do use the dip bar for a quick super set of dips and inverted rows. This quick pump will help fill your whole body with extra oxygen so you feel more vibrant and alert. Then, when you get home, instead of slipping right onto the couch, step over to your dip machine for another couple sets. You will have accomplished an effective dip stand training routine without sacrificing too much time out of your day. This small change to your workout strategy can have tremendous results.


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Aug. 13, 2007
By Megan Cross
Special to GoHolyCross.com
2006 saw the Crusaders finish with one of their best seasons ever with an overall record of 14-6. The team was 4-1 in conference play and made its 10th straight appearance in the Patriot League Tournament, advancing to the title game for the seventh time in the past 10 years.
Holy Cross had a record breaking season, setting the longest winning streak in school history (10) and tying the all-time record for most goals in a season (59). Nationally, head coach Meg Galligan's group ranked in eight different categories in 2006 including scoring margin (14th), winning percentage (tied 14th), scoring average (15th), goals per game (tied 16th), points per game (17th), assists per game (19th), goals against average (22nd) and shutouts per game (tied 26th).
In the classroom in 2006, the Crusaders had two National Academic Squad selections and five players named to the Patriot League Academic Honor Roll.
Following the great success of recent years, this season's team has high expectations that have become a standard for field hockey at Holy Cross. "The fabric of the 2007 squad will be a blend of eight returning starters and talented youth to help our program continue along its patch of success," said Galligan.
Although the Crusaders lost three of the top four scorers to graduation, Galligan saw players emerge during the spring's developmental season to fill the gap and continue where it left off last fall. The five senior starters will be the core group, packed with experience and familiarity with each other's playing style. The team will lean on the three juniors and the large sophomore class to step up their level of play in order to make a run for the 2007 Patriot League championship.
Galligan went on to say: "The squad went into their summer phase with a commitment to excellence and excitement for the upcoming season that makes me proud to be their head coach."
The frontline will be led by 2006 First Team All-League selection Sara O'Coin who was second on the team in scoring last season (13).
"Sara is extremely fast with great elimination skills to match," said Galligan. "She is a scoring threat while also adept at taking passes away from opposing backs and charging the net. Sara is our `go-to' player when the pressure is on."
Kristin Schulz is a junior who will use the experience she gained from playing in 19 games last fall to be a key role in keeping Holy Cross' historically dangerous frontline intact. "Kristin showed what she can bring to the table this spring in her assertive play and ability to initiate numerous scoring opportunities."
Sophomore Courtney Callahan saw action in 17 games last season with two starts. She will vie for a starting role this season as she is capable of playing on the front and midline. "Courtney has a wealth of potential and continues to improve steadily," said Galligan. "She has a keen sense for spatial awareness and quick stick handling skills."
Sophomore Katie Talbert will add depth to the frontline and will be a contender for a starting position. She shows all the signs of becoming a major scoring threat after coming off the bench in 13 games as a freshman. "Katie has excellent eye-hand coordination and circle play instincts." said Galligan.
Incoming freshmen Kara Gonnerman and Alanna Sikorski are both talented players with a skill set that can offer immediate help as forwards or midfielders.
The midfield will be led by senior starters Lauren Coletta and Katie Rowlenson. A Second Team All-League pick last season, Coletta will be a captain this year and in control at the center position. She will be relied upon for her proven solid defense and ability to move the ball up the field quickly. "Lauren's transition game is superb, offering added support for her teammates in most every play of the game," said Galligan.
Rowlenson is a versatile player who can start anywhere on the midline as well as up front if needed. "Katie is very quick with sound skills to match," said Galligan. "She has become adept at trapping opponents and initiating numerous fast break opportunities for the team."
Co-captain and senior Eli Skovron will anchor the defense unit from the backfield. As a Second Team All-League selection, she can be counted on to shut down opponents with the ball and minimize their scoring opportunities. She recorded 55 interceptions, 47 tackles and two defensive saves last season. "Eli is capable of leading our squad to another top 20 ranking for our defense," said Galligan. "Her calm presence in this pressure packed area of the field will be a positive influence on her teammates."
Senior Kim Powell is a returning starter with a great deal of experience as a back. With her vocal leadership and creative restart skills she will play a key position for the team this season. "Kim's passionate spirit shines through as she is known to perform dynamic plays," said Galligan.
Jessie Cullen is a junior who has been plagued with injuries for two years, but now she is healthy and ready to go. With instincts for the game, she is likely to take a starting role in the midfield or backline. "Jessie is such a good athlete," said Galligan. "We look forward to having her back on the field."
After starting as a freshman last year at left back, Kaitlyn Barnes will round up an experience backline for this upcoming season. With 60 interceptions, 30 tackles and three defensive saves in her rookie season, she proves to have very sound defensive skills and continues to work hard to improve her attacking game. "Kaitlyn is the type of player one can rely upon to get the job done," said Galligan.
Sophomores Katie Aylward and Nora Happny saw action last fall and improved a great deal during the spring season. They will add strength to the group and will fight for a starting position.
Incoming players Brittany Gildea and Breezy Rush have a lot of potential and will offer immediate depth to the team.
"We are fortunate to have two excellent keepers in our program," said Galligan.
2006 Patriot League Co-Goalkeeper of the Year and a First Team All-League selection Erin Singleton had a successful sophomore season as a first-time starting goalkeeper. With her experience, she is capable of helping the defensive unit remain in the top 20. "She offers a commanding presence and sound technique in our cage," said Galligan.
Kelly Casey is a sophomore who saw action as a freshman. "She is full of talent and her abilities and instinct for the game add tremendous depth in this position," said Galligan.


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I don't know how many of you have a Winco Foods that you go to (it's only in a few western states), but when I was at Winco last night for the first time in a couple years, we were on the cereal aisle, and I looked over and right above where they have the Power Bars and stuff, there were two lilttle shelves with GLUTEN FREE products!!! I was SO EXCITED!!!
They had about 4 different Gluten-Free Pantry Mixes, some Bob's Red Mill gluten-free, and 4 different shapes of TINKYADA!!!
I almost cried!!!
Winco is one of those really big, really cheap, non-membership grocery stores where you bag your own groceries. When we were first married, there was a time when Winco was all I could afford. I haven't been in so long because my back got so bad that I couldn't bag my own groceries or buy tons of groceries all at once. They don't have a natural food section or anything like that. It's just regular groceries.
So if WINCO has a gluten-free section, no matter how small, we are DEFINITELY getting somewhere.
Started by Nantzie, Jan 27 2006 10:08 AM
1 reply to this topic
Posted 27 January 2006 - 10:08 AM
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The person who says it cannot be done should not interrupt the person who is doing it.
~Chinese Proverb
~Chinese Proverb
Posted 27 January 2006 - 01:31 PM
we have a winco about 45 min away from us. my daughter is going to college in that town----i will have to send her over to see if our winco carries the gluten free stuff. were the gluten free foods any less expensive at winco?
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15 year old twins with celiac, diagnosed dec. 2005
11 year old daughter with celiac diagnosed dec 2005
17 year old son with celiac gene
15 year old twins with celiac, diagnosed dec. 2005
11 year old daughter with celiac diagnosed dec 2005
17 year old son with celiac gene
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Ronna Nirmala & Camelia Pasandaran
A refusal by polling officials to strike fictitious or ineligible voters off the electoral roll for the Jakarta gubernatorial election is threatening to pull the plug on the July 11 poll, an analyst warned on Friday.
Gun Gun Heryanto, a political communications expert at Syarif Hidayatullah State Islamic University (UIN), said that if the Jakarta General Elections Commission (KPUD) did not revise the list, five of the six candidates could boycott the polls in protest. "There's no way an election can be held with just one candidate," he said.
The camps of five candidates running in the election have identified hundreds of thousands of so-called ghost voters and have repeatedly called on the KPUD to revise the list of about seven million voters.
The KPUD has acknowledged the presence of the ineligible voters but has refused to remove them from the list.
Only the incumbent, Governor Fauzi Bowo, has not raised objections to the list. His opponents, including Solo Mayor Joko Widodo and legislator Hidayat Nur Wahid, contend there may be up to 130,000 ghost voters on the electoral roll.
Gun Gun said that if the candidates did boycott the election, it would serve as an important lesson for everyone.
"There's a political lesson to be learned from a failed election as much as from a successful one," he said.
"That's why if the candidates are truly committed to boycotting the poll [over the voter list], they should have the data to back up their claims."
But he added that the odds of the candidates refusing to take part in the election were slim, given that no other local election in the country had ever been called off under similar circumstances.
"All the elections where the voter list has come under question have proceeded in spite of protests," he said.
"But that's because of weak-willed electioneering. That's why the challengers in this election must be really brave. They have to keep putting pressure on the KPUD to be responsible [for the list]."
Gun Gun argued that for the candidates to run in spite of their objections would undermine the legitimacy of the election.
"No matter the outcome, the losing candidates will claim they were disadvantaged by the voter list, and this is going to lead to disputes and even a challenge being mounted at the Constitutional Court," he said.
Some experts, however, contend that the KPUD made the right decision in not revising the list.
Masykurudin Hafidz, supervisory manager of the People's Voter Education Network (JPPR), said changing the list this close to polling day would prove highly disruptive and throw the legitimacy of the election into doubt. "It will also be prone to manipulation by some of the candidates and their camps," he said.
On Thursday, KPUD chairwoman Dahlia Umar said the voter list would stand as announced on June 2, despite the candidates' objections. To prevent ineligible voters from balloting, she said, officials manning polling stations would be told which voters were registered to vote at multiple stations. That way, she said, they could ensure voters were only allowed to vote once.


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Andy Crowe BSc. (Hons) - Disability Advocate -Tetraplegic - TV Actor - Life Explorer
Midday, Saturday 19th October, 1985 my life changed dramatically. As an energetic fifteen year old I was instantaneously paralysed from the neck down. For my sins, I had jumped from an 8ft wall attempting to somersault & land on my back into a skip full of empty cardboard boxes. You guessed it! I landed badly, breaking my neck at the C4/5/6 vertebrae with a complete lesion.
Rushed to Broomfield hospital staying for 1 brief, scary and mentally torturous night I was transferred to the Nation Spinal Injuries Centre, Stoke Mandeville the following day where 9 months were spent in rehabilitation. Early on, I was warned there was unlikey to be a cure in the near future, Medical progress has and will continue to advance towards this aim but is yet to be fully realised over a quarter of a century later. Fortunately, I decided to live with paralysis pretty much from day one and still have the same philosophical viewpoint today. I decided to get on with life, make the most of it and have a mighty fine time in doing so. Maximise the capabilities and opportunities offered!
Over the years I have experienced many wonderful things in my wheelchair that most people would not conceive possible for a person with such a severe level of paralysis. This website is here to inspire people who receive similar injuries or face adversity and barriers in life. Anything is still possible if you put your mind and heart into it!
For the past 7 years I have been employed by ecdp (Essex Coalition of Disabled People) as a "Navigator". I assist people to navigate the Social Care System in Essex and Thurrock giving advice, information and guidance in regards to Direct Payments, personal assistance and care. I am a qualified Disability Equality Practicioner having studied at ARU's Chelmsford Campus.
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The University of Tennessee at Chattanooga's weekly women's basketball television show, Inside Lady Mocs Basketball, is available in the Chattanooga area and throughout the southeast.
Inside Lady Mocs Basketball is hosted by Chris Goforth along with UTC head women's basketball coach Wes Moore. The show features highlights, interviews and an in-depth look at the Lady Mocs' efforts to win their unprecedented 11th straight Southern Conference title.
The show broadcasts throughout the state on various cable channels. For a full listing of air times and channels in the Chattanooga, Knoxville, Memphis and Nashville markets, see the chart below.
The show airs in the southeast region at 4:00 p.m. (ET) on Wednesdays on CSS. CSS (Comcast/Charter Sports Southeast) is a regional sports network that reaches 5.6 million cable subscribers across 12 states.
Inside Lady Mocs Basketball is also available through Comcast On Demand in Chattanooga, Nashville and Knoxville and online via Chattanooga All Access on GoMocs.com.
Inside Lady Mocs Basketball Broadcast Schedule
TuesdayInside Lady Mocs Basketball - 6:30 p.m. - Chattanooga 96 - Previous Week's Show
WednesdayInside Lady Mocs Basketball - 4:00 p.m. - CSS (Regional) - First Airing of the Week Inside Lady Mocs Basketball - 8:30 p.m. - Comcast Chattanooga 96
ThursdayInside Lady Mocs Basketball - 7:30 p.m. - Comcast Knoxville 99Inside Lady Mocs Basketball - 9:00 p.m. - Comcast Memphis 30
FridayInside Lady Mocs Basketball - 6:30 a.m. - CSN 49/CSS (Nashville)Inside Lady Mocs Basketball - 11:00 a.m. - Comcast Chattanooga 96 Inside Lady Mocs Basketball - 7:30 p.m. - CSN 49 (Nashville)
All times are local to host city except the CSS (Regional) airing which is Eastern time.