text:
Title 7 Part 1484
Title 7 → Subtitle B → Chapter XIV → Subchapter C → Part 1484
Electronic Code of Federal Regulations e-CFR
Title 7 Part 1484
e-CFR data is current as of December 5, 2019
Title 7 → Subtitle B → Chapter XIV → Subchapter C → Part 1484
Title 7: Agriculture
§1484.11 Has the Office of Management and Budget reviewed the paperwork and record keeping requirements contained in this part?
§1484.12 What is the Cooperator program?
§1484.13 What special definitions apply to the Cooperator program?
§1484.14 Is my organization eligible to participate in the Cooperator program?
§1484.31 Who acts on behalf of each Cooperator?
§1484.32 Must Cooperators follow specific employment practices?
§1484.33 Must Cooperators follow certain financial management guidelines?
§1484.34 Must Cooperators adhere to specific standards of ethical conduct?
§1484.35 Must Cooperators follow specific contracting procedures?
§1484.36 How do Cooperators dispose of disposable property?
§1484.37 Must Cooperators adhere to Federal Travel Regulations?
§1484.38 Can a Cooperator keep proceeds generated from an activity?
Subpart D—Contributions and Reimbursements§1484.50 What cost share contributions are eligible?
§1484.51 What are ineligible contributions?
§1484.52 What are the guidelines for computing the value of non-cash contributions?
§1484.53 What are the requirements for documenting and reporting contributions?
§1484.54 What expenditures may FAS reimburse under the Cooperator program?
§1484.55 What expenditures may not be reimbursed under the Cooperator program?
§1484.56 How are Cooperators reimbursed?
§1484.57 Will FAS make advance payments to a Cooperator?
Subpart E—Reporting, Evaluation, and Compliance§1484.70 Must Cooperators report to FAS?
§1484.71 Are Cooperator documents subject to the provisions of the Freedom of Information Act?
§1484.72 How is program effectiveness measured?
§1484.73 Are Cooperators penalized for failing to make required contributions?
§1484.74 How is Cooperator program compliance monitored?
§1484.75 How does a Cooperator respond to a compliance report?
§1484.76 Can a Cooperator appeal the determinations of the Deputy Administrator?
Authority: 15 U.S.C. 714c(f).
Source: 64 FR 52630, Sept. 30, 1999, unless otherwise noted. Redesignated at 65 FR 9995, Feb. 25, 2000.
Subpart A—General Information
§1484.10 What is the effective date of this part?
This part applies to activities that are conducted in accordance with the Cooperators' FY 2000 and subsequent marketing plan years. The Cooperator Program is administered by personnel of the Foreign Agricultural Service.
[64 FR 52630, Sept. 30, 1999. Redesignated and amended at 65 FR 9995, Feb. 25, 2000]
§1484.11 Has the Office of Management and Budget reviewed the paperwork and record keeping requirements contained in this part?
The paperwork and record keeping requirements imposed by this part have been submitted to the Office of Management and Budget (OMB) for emergency review and reinstatement under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). OMB has previously assigned control number 0551-0026 for this information collection.
§1484.12 What is the Cooperator program?
(a) Under the Foreign Market Development Cooperator (Cooperator) Program, FAS enters into project agreements with eligible nonprofit U.S. trade organizations to share the costs of certain overseas marketing and promotion activities that are intended to create, expand, or maintain foreign markets for U.S. agricultural commodities and products. FAS does not provide brand promotion assistance to Cooperators under this program.
(b) FAS enters into project agreements with those eligible nonprofit U.S. trade organizations that have the broadest possible producer representation of the commodity being promoted and gives priority to those organizations that are nationwide in membership and scope. Project agreements involve the promotion of agricultural commodities on a generic basis. Project agreements do not involve activities targeted directly toward consumers purchasing as individuals. Activities must contribute to the maintenance or growth of demand for the agricultural commodities and generally address long-term foreign import constraints and export growth opportunities by focusing on matters such as reducing infra-structural or historical market impediments; improving processing capabilities; modifying codes and standards; and identifying new markets or new applications or uses for the agricultural commodity or product in the foreign market.
(c) The Cooperator program generally operates on a reimbursement basis.
(d) FAS policy is to ensure that benefits generated by Cooperator agreements are broadly available throughout the relevant agricultural sector and no one entity gains an undue advantage or sole benefit from program activities.
§1484.13 What special definitions apply to the Cooperator program?
For purposes of this part the following definitions apply:
Activity—a specific market development effort undertaken by a Cooperator to address a constraint or opportunity.
Administrator—the Vice President, CCC, who also serves as Administrator, FAS, USDA, or designee.
Agricultural commodity—an agricultural commodity, food, feed, fiber, wood, livestock or insect, and any product thereof; and fish harvested from a U.S. aquaculture farm, or harvested by a vessel as defined in title 46, United States Code, in waters that are not waters (including the territorial sea) of a foreign country.
Attache/Counselor—the FAS employee representing USDA interests in the foreign country in which promotional activities are conducted.
Commodity Division—the office within the Foreign Agricultural Service responsible for the commodity covered by the project agreement.
Compliance Review Staff—the office within the Foreign Agricultural Service responsible for performing periodic reviews of Cooperators to ensure compliance with this part.
Constraint—a condition in a particular country or region which needs to be addressed in order to develop, expand, or maintain exports of a specific U.S. agricultural commodity.
Consumer promotion—activities that are designed to directly influence consumers by changing attitudes or purchasing behaviors towards U.S. agricultural products.
Contribution—the cost-share expenditure made by a Cooperator or the U.S. industry in support of an activity; e.g., money, personnel, materials, services, facilities, or supplies.
Cooperator or U.S. Cooperator—a nonprofit U.S. agricultural trade organization which has entered into a foreign market development agreement with FAS.
Cooperator Program—the Foreign Market Development Cooperator Program.
Deputy Administrator—the Deputy Administrator, Commodity and Marketing Programs, FAS, USDA, or designee.
Division Director—the director of a commodity division, Commodity and Marketing Programs, FAS, USDA.
Eligible commodity—an agricultural commodity that is comprised of at least 50 percent U.S. origin content by weight, exclusive of added water.
Eligible trade organization—a United States trade organization that promotes the exports of one or more United States agricultural commodities or products and does not have a business interest in or receive remuneration from specific sales of agricultural commodities or products.
Expenditure—transfer of funds.
FAS—Foreign Agricultural Service, USDA.
Foreign third party—a foreign entity that assists, in accordance with this part, in promoting the export of a U.S. agricultural commodity.
Generic promotion—a promotion that does not involve the exclusive or predominant use of a single company name or logo(s) or brand name(s) of a single company.
Market—a country or region in which an activity is conducted.
Marketing plan year—the program year beginning on October 1 and ending on September 30, during which Cooperators can undertake activities, consistent with this part and their agreements with FAS, and seek reimbursement. For example, marketing plan year 2000 begins on October 1, 1999, and ends on September 30, 2000.
Project agreement—a contract between FAS and a Cooperator in which the basic working relationship is described including the program and financial obligations of each.
Project funds—the funds made available to a Cooperator under a project agreement, and authorized for expenditure in accordance with this part.
Property—furniture or equipment having a useful life of over one year and an acquisition cost of $500 or more.
STRE—sales and trade relations expenditures.
Trade team—a group of individuals engaged in an activity intended to promote the interests of an entire agricultural sector rather than to result in specific sales by any of its members.
USDA—the United States Department of Agriculture.
[64 FR 52630, Sept. 30, 1999. Redesignated and amended at 65 FR 9995, Feb. 25, 2000]
§1484.14 Is my organization eligible to participate in the Cooperator program?
(a) To participate in the Cooperator program, an entity must be a nonprofit U.S. agricultural trade organization and contribute at least 50 percent of the value of resources provided by FAS for activities conducted under the project agreement.
(b) FAS may require that a project agreement include a contribution level greater than that specified in paragraph (a) of this section. In requiring a higher contribution level, FAS will take into account such factors as past Cooperator contributions, previous Cooperator program funding levels, the length of time an entity participates in the program, and the entity's ability to increase its contribution.
(c) FAS will enter into Cooperator agreements only for the promotion of eligible commodities.
Subpart B—Application and Fund Allocation
§1484.20 How can my organization apply to the Cooperator program?
FAS will publish a Notice in the Federal Register that it is accepting applications for participation in the Cooperator program for a specified marketing plan year. Applications shall be submitted in accordance with the terms and requirements specified in the Notice. An application shall contain basic information about the applicant and the proposed program, a strategic plan, and performance measures. FAS may request any additional information which it deems necessary to evaluate a Cooperator program application.
(a) Basic applicant and program information. All Cooperator program applications shall contain:
(1) The name and address of the applicant;
(2) The name of the Chief Executive Officer (or designee);
(3) The name and telephone number of the applicant's primary contact person;
(4) A description of management and administrative capability;
(5) The name(s) of the person(s) responsible for managing the program;
(6) A description of prior export promotion experience;
(7) A description of the organization, its membership, and membership criteria;
(8) A list of affiliated organizations;
(9) The applicant's Federal Tax Identification Number;
(10) The dollar amount of FAS resources requested under the Cooperator program;
(11) The value of the applicant's contribution, stated in dollars or as a percentage of paragraph (a)(10) of this section;
(12) The value of contributions from other sources, stated in dollars or as a percentage of paragraph (a)(10) of this section;
(13) A description of the eligible commodity(s); the associated commodity aggregate code(s), obtained from FAS; and the percentage of U.S. origin content by weight, exclusive of added water; and
(14) A certification statement, and, if requested by the Deputy Administrator, a written explanation supporting the certification, that any funds received will supplement, but not supplant, any private or industry funds or other contributions to program activities. The written explanation, if necessary, shall indicate why the Cooperator is unlikely to carry out the activities without Federal financial assistance. The certification shall also state that information contained in the application is true and accurate and that all records supporting the claim that project funds do not supplant other funds will be made available to authorized officials of the U.S. Government.
(b) Strategic plan and performance measures. All Cooperator program applications shall also contain:
(1) A description of the U.S. and world market situation for the eligible commodity;
(2) Data summarizing historical and projected U.S. production, U.S. exports to the world, world trade, and U.S. market share;
(3) A summary of proposed activity budgets by country or region;
(4) A summary of proposed administrative budgets by country or region;
(5) A list of all countries that define any designated region;
(6) For each country or region for which activities are proposed:
(i) A market assessment, including the constraint(s) impeding U.S. exports, the export growth opportunities, the performance of competing suppliers, expected changes in demand, etc.;
(ii) The long-term strategy that will be used to counteract the constraints and achieve additional U.S. exports;
(iii) Previous activities, performance, and evaluation results;
(iv) Projected export goals and U.S. market share; and
(v) Performance indicators against which future success in addressing the constraint(s) or opportunities may be measured;
(7) A description of all proposed activities, including the requested FAS resources and the specific goals and benchmarks to be used to measure the effectiveness of each activity;
(8) A justification for any new overseas office, including a list of job titles, corresponding position descriptions, salary ranges, and any request for approval of salaries above the Foreign Service National (FSN) salary plan. To request approval of a salary above the FSN salary plan, the Cooperator shall include a detailed description of both the duties and responsibilities of the position, and of the qualifications and background of the individual concerned. The Cooperator shall also justify, based on a verifiable local salary survey or other documented local salary information, why the highest FSN salary level is inappropriate.
§1484.21 How does FAS determine which Cooperator program applications are approved?
(a) General. FAS allocates funds in a manner that effectively supports the strategic decision-making initiatives of the Government Performance and Results Act (GPRA) of 1993. In deciding whether a proposed project will contribute to the effective creation, expansion, or maintenance of foreign markets, FAS seeks to identify those projects that would demonstrate a clear, long-term agricultural trade strategy by market or product and a program effectiveness time line against which results can be measured at specific intervals using quantifiable product or country or region goals. These performance indicators are part of FAS' resource allocation strategy to fund applicants which can demonstrate performance based on a long-term strategic plan and address the performance measurement objectives of the GPRA.
(b) Approval criteria. FAS will consider a number of factors when reviewing proposed projects, including:
(1) The ability of the organization to provide an experienced U.S.-based staff with technical and international trade expertise to ensure adequate development, supervision, and execution of the proposed project;
(2) The organization's willingness to contribute resources, including cash and goods and services of the U.S. industry and foreign third parties;
(3) The conditions or constraints affecting the level of U.S. exports and market share for the agricultural commodities and products;
(4) The degree to which the proposed project is likely to contribute to the creation, expansion, or maintenance of foreign markets;
(5) The degree to which the strategic plan is coordinated with other private or U.S. government-funded market development projects;
(6) Past program results and evaluations, if applicable; and
(7) Previous Cooperator program funding.
§1484.22 How are Cooperator program funds allocated?
After determining which applications to recommend for approval, the Commodity Divisions recommend funding levels for the approved applicants within their respective divisions. Applications then compete for funds on the basis of the following allocation criteria (the number in parentheses represents a percentage weight factor). Data used in the calculations for contribution levels, past export performance and past demand expansion performance will cover not more than a 6-year period, to the extent such data is available. The method for applying the following criteria will be described in the Cooperator program announcement in the Federal Register:
(a) Contribution Level (40%).
(b) Past Export Performance (20%).
(c) Past Demand Expansion Performance (20%).
(d) Future Demand Expansion Goals (10%).
(e) Accuracy of Past Demand Expansion Projections (10%).
Subpart C—Program Operations
§1484.30 How does FAS formalize its working relationship with approved Cooperators?
FAS will notify each applicant in writing of the final disposition of its application. FAS will send a program agreement, allocation approval letter, and a signature card to each approved applicant. The allocation approval letter will specify any special terms and conditions applicable to a Cooperator's program, including the required level of Cooperator contribution. An applicant that accepts the terms and conditions contained in the program agreement and allocation approval letter should so indicate by having its Chief Executive Officer sign the program agreement and submit the signed agreement to the Director, Marketing Operations Staff, FAS, USDA. Final agreement shall occur when the Administrator signs the agreement on behalf of FAS. The application, the program agreement, the allocation approval letter, and this part shall establish the terms and conditions of a Cooperator agreement between FAS and the approved applicant.
§1484.31 Who acts on behalf of each Cooperator?
The Cooperator shall designate at least two individuals in its organization to sign program agreements, reimbursement claims, and requests. The Cooperator shall submit the signature card signed by those designated individuals and by the Cooperator's Chief Executive Officer to the Director, Marketing Operations Staff, FAS, USDA, prior to the start of the marketing plan year. The Cooperator shall immediately notify the Director of any changes in signatories (e.g., removal or addition of individuals, name changes, etc.), and shall submit a revised signature card accordingly.
§1484.32 Must Cooperators follow specific employment practices?
(a) A Cooperator shall enter into written contracts with all overseas employees and shall ensure that all terms, conditions, and related formalities of such contracts conform to governing local law.
(b) A Cooperator shall, in its overseas offices, conform its office hours, work week, and holidays to local law and to the custom generally observed by U.S. commercial entities in the local business community.
(c) A Cooperator may pay salaries or fees in any currency (U.S. or foreign) in conformance with contract specifications. Cooperators are cautioned to consult local laws regarding currency restrictions.
§1484.33 Must Cooperators follow certain financial management guidelines?
(a) A Cooperator shall implement and maintain a financial management system that conforms to generally accepted accounting principles.
(b) A Cooperator shall institute internal controls and provide written guidance to commercial entities participating in its activities to ensure their compliance with these provisions. Each Cooperator shall maintain all original records and documents relating to program activities for 5 calendar years following the end of the applicable marketing plan year and shall make such records and documents available upon request to authorized officials of the U.S. Government. A Cooperator shall also maintain all documents related to employment, such as employment applications, contracts, position descriptions, leave records, and salary changes; and all records pertaining to contractors. A Cooperator shall also maintain adequate documentation related to the proper disposition of all property purchased by the Cooperator and for which the Cooperator is reimbursed with program funds.
(c) A Cooperator shall maintain its records of expenditures and contributions in a manner that allows it to provide information by marketing plan year, country or region, activity number, and cost category. Such records shall include:
(1) Receipts for all STRE (actual vendor invoices or restaurant checks, rather than credit card receipts);
(2) Original receipts for any other program related expenditure in excess of $25.00;
(3) The exchange rate used to calculate the dollar equivalent of each expenditure made in a foreign currency and the basis for such calculation;
(4) Copies of reimbursement claims;
(5) An itemized list of claims charged to the Cooperator's FMD account;
(6) Documentation with accompanying English translation supporting each reimbursement claim, including original evidence to support the financial transactions, such as canceled checks, receipted paid bills, contracts or purchase orders, per diem calculations, and travel vouchers; and
(7) Documentation supporting contributions including: the date(s), purpose, and location(s) of each activity for which cash, goods, or services were claimed as a contribution; who conducted the activity; the participating groups or individuals; and the method of computing the claimed contributions. Cooperators must retain, and make available for audit, documentation related to claimed contributions.
(d) Upon request, a Cooperator shall provide to FAS the original documents which support the Cooperator's reimbursement claims. FAS may deny a claim for reimbursement if the claim is not supported by adequate documentation.
§1484.34 Must Cooperators adhere to specific standards of ethical conduct?
(a) A Cooperator shall conduct its business in accordance with the laws and regulations of the country(s) in which each activity is carried out.
(b) Neither a Cooperator nor its affiliates shall make export sales of agricultural commodities covered under the terms of a project agreement. Neither a Cooperator nor its affiliates shall charge a fee for facilitating an export sale. For the purposes of this paragraph, "affiliate" means any partnership, association, company, corporation, trust, or any other such party in which the Cooperator has an investment, other than a mutual fund. A Cooperator may collect check-off funds and membership fees that are required for membership in the Cooperator's organization.
(c) The Cooperator shall not use program activities or program funds to promote private self interests or conduct private business, except as members of sales teams.
(d) A Cooperator shall select U.S. agricultural industry representatives to participate in activities such as trade teams or trade fairs based on criteria that ensure participation on an equitable basis by a broad cross section of the U.S. industry. If requested, a Cooperator shall submit such selection criteria to FAS for approval.
(e) All Cooperators should endeavor to ensure fair and accurate fact-based advertising. Deceptive or misleading promotions may result in cancellation or termination of a project agreement.
(f) The Cooperator must report any actions or circumstances that have a bearing on the propriety of program activities to the Attache/Counselor and the Cooperator's U.S. office shall report such actions in writing to the appropriate Division Director.
§1484.35 Must Cooperators follow specific contracting procedures?
(a) Cooperators have full and sole responsibility for the legal sufficiency of all contracts and assume financial liability for any costs or claims resulting from suits, challenges, or other disputes based on contracts entered into by the Cooperator. Neither FAS nor any other agency of the United States Government or any official or employee of FAS or the United States Government has any obligation or responsibility with respect to Cooperator contracts with third parties.
(b) Cooperators are responsible for ensuring to the extent possible that the terms, conditions, and costs of contracts constitute the most economical and effective use of project funds.
(c) All fees for professional and consulting services paid in any part with project funds must be covered by written contracts.
(d) A Cooperator shall:
(1) Ensure that all expenditures for goods and services in excess of $25.00, which are reimbursed with project funds, are documented by a purchase order, invoice, or contract;
(2) Ensure that no employee or officer participates in the selection or award of a contract in which such employee or officer, or the employee's or officer's family or partners has a financial interest;
(3) Conduct all contracting in an open manner. Individuals who develop or draft specifications, requirements, statements of work, invitations for bids, or requests for proposals for procurement of any goods or services shall be excluded from competition for such procurement;
(4) Base each solicitation for professional or consulting services on a clear and accurate description of the requirements for the services to be procured;
(5) Perform some form of price or cost analysis, such as a comparison of price quotations to market prices or other price indicia, to determine the reasonableness of the offered prices; and
(6) Document the decision-making process.
[64 FR 52630, Sept. 30, 1999. Redesignated and amended at 65 FR 9995, Feb. 25, 2000]
§1484.36 How do Cooperators dispose of disposable property?
(a) Property purchased by the Cooperator, and for which the Cooperator is reimbursed with project funds, that is unusable, unserviceable, or no longer needed for project purposes shall be disposed of in one of the following ways. The Cooperator may:
(1) Exchange or sell the property, provided that it applies any exchange allowance, insurance proceeds, or sales proceeds toward the purchase of other property needed in the project;
(2) With FAS approval, transfer the goods to other Cooperators for their activities, or to a foreign third party; or
(3) Upon Attache/Counselor approval, donate the goods to a local charity, or convey the goods to the Attache/Counselor, along with an itemized inventory list and any documents of title.
(b) A Cooperator shall maintain an inventory of all property valued at $500 or more which was acquired in furtherance of program activities. The inventory shall list and number each item and include the date of purchase or acquisition, cost of purchase, replacement value, serial number, make, model, and electrical requirements.
(c) The Cooperator shall insure all property which was acquired with program funds and safeguard such property against theft, damage, and unauthorized use. The Cooperator shall promptly report any loss, theft, or damage of such property to the insurance company.
(d) The Cooperator is responsible for reimbursing FAS for the value of any uninsured property at the time of the loss or theft of the property.
[64 FR 52630, Sept. 30, 1999. Redesignated and amended at 65 FR 9995, 9996, Feb. 25, 2000]
§1484.37 Must Cooperators adhere to Federal Travel Regulations?
Travel shall conform to the U.S. Federal Travel Regulation (41 CFR Chapters 300 through 304) and air travel shall conform to the requirements of the "Fly America Act" (49 U.S.C. 1517). The Cooperator shall notify the Attache/Counselor in the destination countries in writing in advance of any proposed travel. The timing of such notice should be far enough in advance to enable the Attache/Counselor to schedule appointments, make preparations, or otherwise provide any assistance being requested. Failure to provide advance notification of travel may result in disallowance of the expenses related to the travel.
§1484.38 Can a Cooperator keep proceeds generated from an activity?
Any income or refunds generated from an activity, i.e., participation fees, proceeds of sales, refunds of value added taxes (VAT), the expenditures for which have been wholly or partially reimbursed, shall be repaid by submitting a check payable to Commodity Credit Corporation or by offsetting the Cooperator's next reimbursement claim.
[64 FR 52630, Sept. 30, 1999. Redesignated and amended at 65 FR 9995, 9996, Feb. 25, 2000]
Subpart D—Contributions and Reimbursements
§1484.50 What cost share contributions are eligible?
(a) The Cooperator shall pay all costs necessary for the operation of the Cooperator's U.S. office.
(b) In calculating the amount of contributions that it will make, and the contributions it will receive from a U.S. industry or a State agency, a Cooperator program applicant may include the costs (or such prorated costs) listed under paragraph (c) of this section if:
(1) Expenditures will be made in furtherance of the Cooperator's overall foreign market development program;
(2) The contributor has not been or will not be reimbursed by any other source for such costs; and
(3) The contribution is made during the period covered by the project agreement.
(c) Subject to paragraph (b) of this section, eligible contributions are:
(1) Cash;
(2) Compensation paid to personnel;
(3) The cost of acquiring materials, supplies, or services;
(4) The cost of office space;
(5) A reasonable and justifiable proportion of general administrative costs and overhead;
(6) Payments for indemnity and fidelity bond expenses;
(7) The cost of business cards;
(8) The cost of seasonal greeting cards;
(9) Fees for office parking;
(10) The cost of subscriptions to publications;
(11) The cost of activities conducted overseas;
(12) Credit card fees;
(13) The cost of any independent evaluation or audit that is not required by FAS to ensure compliance with program requirements;
(14) The cost of giveaways, awards, prizes and gifts;
(15) The cost of product samples;
(16) Fees for participating in U.S. government activities;
(17) The cost of air and local travel in the United States related to a foreign market development effort;
(18) Transportation and shipping costs;
(19) The cost of displays and promotional materials;
(20) Advertising costs;
(21) Reasonable travel costs and expenses related to undertaking a foreign market development activity;
(22) Payment of employee's or contractor's share of personal taxes;
(23) The cost associated with trade shows, seminars, entertainment and STRE conducted in the United States;
(24) Product research that is undertaken to benefit an industry and has a specific export application; and
(25) Consumer promotions.
§1484.51 What are ineligible contributions?
(a) The following are not eligible contributions:
(1) Any portion of salary or compensation of an individual who is the target of a promotional activity;
(2) Any land costs other than allowable costs for office space;
(3) Depreciation;
(4) The cost of refreshments and related equipment provided to office staff;
(5) The cost of insuring articles owned by private individuals;
(6) The cost of any arrangement which has the effect of reducing the selling price of an agricultural commodity;
(7) The cost of product development or product modifications;
(8) Slotting fees or similar sales expenditures;
(9) Funds, services, or personnel provided by any U.S. government agency;
(10) Capital investments made by a third party, such as permanent structures, real estate, and the purchase of office equipment and furniture;
(11) The value of any services generated by a Cooperator or third party which involve no expenditure by the Cooperator or third party, e.g., free publicity;
(12) Membership fees in clubs and social organizations; and
(13) costs included as contributions for any other federally-assisted project or program.
(b) The Deputy Administrator shall determine, at the Deputy Administrator's discretion, whether any cost not expressly listed in this section may be included by the Cooperator as an eligible contribution.
§1484.52 What are the guidelines for computing the value of non-cash contributions?
(a) Computing the value of an individual's time. If an individual's salary is known, allocate the individual's salary on the basis of time spent on foreign market development activities. If the individual's salary is unknown, claim up to the equivalent of a step 10, GS-15 for professional personnel and up to the current estimated industry rate at the person's level of employment for nonprofessional personnel.
(b) Computing the value of indirect expenditures. Allocate value on the basis of sound management and accounting procedures when considering indirect expenditures, such as overhead and facilities, which are furnished by the industry.
§1484.53 What are the requirements for documenting and reporting contributions?
(a) Each claimed contribution must be documented by the Cooperator, showing the method of computing non-cash contributions, salaries, and travel expenses.
(b) Each Cooperator must keep records of the methods used to compute the value of non-cash contributions, and
(1) Copies of invoices or receipts for expenses paid by the U.S. industry and not reimbursed by the Cooperator for the joint activity; or
(2) If invoices are not available, an itemized statement from the U.S. industry as to what costs it incurred pursuant to the joint activity; or
(3) If neither of the foregoing is available, a statement from the U.S. industry as to what goods and services it provided; or
(4) If none of the foregoing are available, a memo to the files of the U.S. Cooperator's estimate of what contributions were made by the U.S. industry, item by item, and the method used to assign a value to each.
(c) Each Cooperator must report its contributions as described in §1550.70 (a).
§1484.54 What expenditures may FAS reimburse under the Cooperator program?
(a) A Cooperator may seek reimbursement for an expenditure if:
(1) The expenditure is reasonable and has been made in furtherance of a market development activity; and
(2) The Cooperator has not been or will not be reimbursed for such expenditure by any other source.
(b) Subject to paragraph (a) of this section, FAS will reimburse, in whole or in part, the cost of:
(1) Production and placement of advertising in print or electronic media or on billboards or posters;
(2) Production and distribution of banners, recipe cards, table tents, shelf talkers, and similar point of sale materials;
(3) Direct mail advertising;
(4) Food service promotions, product demonstrations to the trade, and distribution of promotional samples;
(5) Temporary displays and rental of space for temporary displays;
(6) Fees for participation in retail and trade exhibits and shows, and booth construction and transportation of related materials to such exhibits and shows;
(7) Trade seminars, including space rental, equipment rental, and duplication of seminar materials;
(8) Production and distribution of publications;
(9) Part-time contractors, such as interpreters, translators, and receptionists, to help with the implementation of promotional activities, such as trade shows, food service promotions, and trade seminars;
(10) Giveaways, awards, prizes, gifts, and other similar promotional materials, subject to the limitation that FAS will not reimburse more than $1.00 per item;
(11) Compensation and allowances for housing, educational tuition, and cost of living adjustments paid to U.S. citizen employees or U.S. citizen contractors stationed overseas, subject to the limitation that FAS shall not reimburse that portion of:
(i) The total of compensation and allowances that exceed 125 percent of the level of a GS-15, Step 10 salary for U.S. Government employees, and
(ii) Allowances that exceed the rate authorized for U.S. Embassy personnel;
(12) Foreign transfer, temporary lodging, and post hardship differential allowances for U.S. citizen employees;
(13) Approved salaries or compensation for non-U.S. citizens and non-U.S. contractors. Generally, FAS will not reimburse any portion of a non-U.S. citizen employee's compensation that exceeds the compensation prescribed for the most comparable position in the Foreign Service National (FSN) salary plan applicable to the country in which the employee works. However, if the local FSN salary plan is inappropriate, a Cooperator may request a higher level of reimbursement for a non-U.S. citizen in accordance with §1550.20 (b)(8);
(14) A retroactive salary adjustment that conforms to a change in FSN salary plans, effective as of the date of such change;
(15) Accrued annual leave at such time when employment is terminated or when required by local law;
(16) Overtime paid to clerical staff;
(17) Fees for professional and consultant services;
(18) Air travel, plus passports, visas, and inoculations, subject to the limitation that FAS will not reimburse any portion of air travel in excess of the full fare economy rate or when the Cooperator fails to notify the Attaché/Counselor in the destination country in advance of the travel, unless the Deputy Administrator determines it was impractical to provide such notification;
(19) Per diem, subject to the limitation that FAS will not reimburse per diem in excess of the rates allowed under the U.S. Federal Travel Regulation (41 CFR Chapters 300 through 304);
(20) Automobile mileage at the local U.S. Embassy rate, or rental cars while in travel status;
(21) Other allowable expenditures while in travel status as authorized by the U.S. Federal Travel Regulation (41 CFR Chapters 300 through 304);
(22) An overseas office, including rent, utilities, communications originating overseas, office supplies, accident liability insurance premiums, and legal and accounting services;
(23) The purchase, lease, or repair of, or insurance premiums for, property that has an expected useful life of at least one year, such as furniture, equipment, machinery, removable fixtures, floor coverings, and computer hardware and software;
(24) Office decor, such as draperies or blinds;
(25) Premiums for health or accident insurance or other benefits for foreign national employees that the employer is required by law to pay;
(26) Accident liability insurance premiums for facilities used jointly with third party participants for Cooperator program activities, or such insurance premiums for travel of non-Cooperator personnel;
(27) Market research;
(28) Evaluations, if not required by FAS to ensure compliance with program requirements;
(29) Legal fees to obtain advice on the host country's labor laws;
(30) Employment agency fees;
(31) STRE, including breakfast, lunch, dinner, receptions, and refreshments at activities; miscellaneous courtesies such as checkroom fees, taxi fares, and tips; and decorations for a special promotional occasion;
(32) Educational travel of dependent children, visitation travel, rest and recuperation travel, home leave travel, and emergency visitation travel for U.S. overseas employees as allowed under the Foreign Affairs Manual;
(33) Evacuation payments (safe haven), and shipment and storage of household goods and motor vehicles;
(34) Demonstration projects;
(35) Purchase of trade and business periodicals containing material related to market development activities for use by overseas staffs;
(36) Training expenses in the U.S. for FSNs;
(37) Language training for U.S. citizen employees at the foreign post of assignment;
(38) Forward year financial obligations required by local law or custom; such as severance pay, attributable to employment of foreign nationals; or forfeiture of rent or deposits, attributable to the closure of an office;
(39) Fees for storage of necessary program materials;
(40) Shipment of samples or other program materials from the U.S. to foreign countries; and
(41) That portion of airtime for wireless phones that is devoted to program activities and monthly service fees prorated at the proportion of program-related airtime to total airtime.
§1484.55 What expenditures may not be reimbursed under the Cooperator program?
(a) FAS will not reimburse expenditures made prior to approval of a Cooperator's program, unreasonable expenditures, or any cost of:
(1) Expenses, fines, settlements, or claims resulting from suits, challenges, or disputes emanating from employment terms, conditions, contract provisions, or related formalities;
(2) Product development, product modification, or product research;
(3) Product samples;
(4) Slotting fees or similar sales expenditures;
(5) The purchase, construction, or lease of space for permanent displays, i.e., displays lasting beyond one marketing plan year;
(6) Office parking fees;
(7) Coupon redemption or price discounts;
(8) Refundable deposits or advances;
(9) Giveaways, awards, prizes, gifts, and other similar promotional materials in excess of $1.00 per item;
(10) Alcoholic beverages that are not an integral part of a promotional activity;
(11) The purchase, lease (except for use in authorized travel status), or repair of motor vehicles;
(12) Travel of applicants for employment interviews;
(13) Unused non-refundable airline tickets or associated penalty fees, except where travel is restricted by U.S. government action or advisory;
(14) Any arrangement which has the effect of reducing the selling price of an agricultural commodity;
(15) Goods and services and salaries of third party personnel;
(16) Membership fees in clubs and social organizations;
(17) Indemnity and fidelity bonds;
(18) Fees for participating in U.S. Government sponsored activities, other than trade fairs, shows, and exhibits;
(19) Business cards;
(20) Seasonal greeting cards;
(21) Subscriptions to non-trade related publications;
(22) Credit card fees;
(23) Refreshments, or related equipment, for office staff;
(24) Insurance on household goods and personal effects, including privately-owned automobiles, whether overseas or stored in the U.S., belonging to U.S. citizen employees;
(25) Home office domestic administrative expenses, including communication costs;
(26) Payment of U.S. or foreign employee's or contractor's share of personal taxes, except as legally required in a foreign country;
(27) Wireless phone equipment, equipment repair, insurance, and other related charges;
(28) STRE expenses incurred in the U.S;
(29) Entertainment, e.g., amusements, diversions, cover charges, personal gifts, or tickets to theatrical or sporting events;
(30) Functions (including receptions and meals at Cooperator staff conferences) at which target groups, such as members of the overseas trade, opinion leaders, foreign government officials, and other similar groups, are not present; or
(31) Promotions directed at consumers purchasing in their individual capacity.
(b) The Deputy Administrator may determine, at the Deputy Administrator's discretion, whether any cost not expressly listed in this section will be reimbursed.
(c) FAS will reimburse for expenses incurred up to 30 calendar days beyond the conclusion of the marketing plan year.
§1484.56 How are Cooperators reimbursed?
(a) A format for reimbursement claims is available from the Director, Marketing Operations Staff, FAS, USDA. Claims for reimbursement shall contain at least the following information:
(1) Activity code;
(2) Country code;
(3) Cost category;
(4) Amount to be reimbursed or credited;
(5) If applicable, any reduction in the amount of reimbursement claimed to offset FAS demand for refund of amounts previously reimbursed, and reference to the relevant Compliance Report; and
(6) If applicable, any amount previously claimed that has not been reimbursed.
(b) All claims for reimbursement shall be submitted by the Cooperator's U.S. office to the Director, Marketing Operations Staff, FAS, USDA.
(c) FAS will not reimburse claims submitted later than 6 months after the end of a marketing plan year.
(d) If FAS overpays a reimbursement claim, the Cooperator shall repay FAS within 30 days the amount of the overpayment either by submitting a check payable to FAS or by offsetting its next reimbursement claim.
(e) If a Cooperator receives a reimbursement or offsets an advanced payment which is later disallowed, the Cooperator shall within 30 days of such disallowance repay FAS the amount owed either by submitting a check payable to FAS or by offsetting its next reimbursement claim.
(f) The Cooperator shall report any actions having a bearing on the propriety of any claims for reimbursement to the Attache/Counselor and its U.S. office shall report such actions in writing to the Division Director(s).
§1484.57 Will FAS make advance payments to a Cooperator?
(a) Policy. In general, FAS operates the Cooperator program on a reimbursable basis.
(b) Exception. Upon request, FAS may make two types of advance payments to a Cooperator. The first is a revolving fund operating advance provided by FAS only to Cooperators with foreign offices supported with project funds. The second is a special advance payment used to pay an impending large cost item. FAS will provide this type of advance expense payment in lieu of direct payments by FAS to vendors or other third parties. All Cooperators, with or without project fund-supported foreign offices, are eligible to request special advance payments. Normally, special advance payments received from FAS must be liquidated by the Cooperator within 90 days from the date of receipt. Prior to making an advance, FAS may require the participant to submit security in a form and amount acceptable to FAS to protect FAS' financial interests. FAS will not make any special advance payment to a Cooperator where a special advance is outstanding from a prior marketing plan year. Cooperators shall deposit and maintain advances in insured, interest-bearing accounts, unless such accounts are prohibited by law or custom of a host country.
(c) Refunds due FAS. A participant shall return any unexpended portion of an advance, plus any interest earned, either by submitting a check payable to FAS or by offsetting its next reimbursement claim. All checks shall be mailed to the Director, Marketing Operations Staff, FAS, USDA.
Subpart E—Reporting, Evaluation, and Compliance
§1484.70 Must Cooperators report to FAS?
(a) End-of-year contribution report. Not later than January 31 of the year following the completion of the marketing plan year, a Cooperator shall submit two copies of a report which identifies contributions made by the Cooperator and the U.S. industry during that marketing plan year. A suggested format of a contribution report is available on the FAS home page (http://www.fas.usda.gov/mos/programs/fnotice.html) on the Internet or from the Director, Marketing Operations Staff, FAS, USDA.
(b) Trip reports. Not later than 45 days after completion of travel (other than local travel), a Cooperator shall submit a trip report. The report must include the name(s) of the traveler(s), purpose of travel, itinerary, names and affiliations of contacts, and a brief summary of findings, conclusions, recommendations, or specific accomplishments.
(c) Research reports. Not later than 6 months after the end of its marketing plan year, a Cooperator shall submit a report on any research conducted in accordance with its application.
(d) Submission of reports. A Cooperator shall submit the reports required by this section to the appropriate Division Director. Trip reports and research reports shall also be submitted to the appropriate Attache/Counselor(s). All reports shall be in English and include the Cooperator's agreement number, the countries and period covered, and the date of the report.
(e) Additional reports. FAS may require the submission of additional reports.
(f) Independent audit reports. A Cooperator shall provide to the FAS Compliance Review Staff, upon request, any audit reports by independent public accountants.
§1484.71 Are Cooperator documents subject to the provisions of the Freedom of Information Act?
(a) Documents submitted to FAS by Cooperators are subject to the provisions of the Freedom of Information Act (FOIA), 5 U.S.C. 552, 7 CFR part 1, Subpart A—Official Records, and, specifically, 7 CFR 1.11—Handling Information from a Private Business.
(b) If requested by a person located in the United States, a Cooperator shall provide to such person a copy of any document in its possession or control containing market information developed and produced under the terms of its agreement. The Cooperator may charge a fee not to exceed the costs for assembling, duplicating, and distributing the materials.
(c) The results of any research conducted by a Cooperator under an agreement shall be the property of the U.S. Government.
§1484.72 How is program effectiveness measured?
(a) The Government Performance and Results Act (GPRA) of 1993 (5 U.S.C. 306; 31 U.S.C. 1105, 1115-1119, 3515, 9703-9704) requires performance measurement of Federal programs, including the Cooperator program. Evaluation of the Cooperator program's effectiveness will depend on a clear statement by each Cooperator of the constraints and opportunities facing U.S. exports, goals to be met within a specified time, a schedule of measurable milestones for gauging success, a plan for achievement, and reports of activity results.
(b) Evaluation is an integral element of program planning and implementation, providing the basis for the strategic plan. The evaluation results guide the development and scope of a Cooperator's program, contribute to program accountability, and provide evidence of program effectiveness.
(c) A Cooperator shall conduct periodic evaluations of its program and activities and may contract with an independent evaluator to satisfy this requirement. FAS reserves the right to have direct input and control over design, scope, and methodology of any such evaluation, including direct contact with and provision of guidance to the independent evaluator.
(d) A Cooperator shall complete at least one program evaluation each year. Actual scope and timing of the program evaluation shall be determined by the Cooperator and the Division Director and specified in the Cooperator's application approval letter. A program evaluation shall contain:
(1) The name of the party conducting the evaluation;
(2) The activities covered by the evaluation;
(3) A concise statement of the constraint(s) and opportunities and the goals specified in the application;
(4) A description of the evaluation methodology;
(5) A description of additional export sales achieved, including the ratio of additional export sales in relation to Cooperator program funding received;
(6) A summary of the findings, including an analysis of the strengths and weaknesses of the program(s); and
(7) Recommendations for future programs.
(e) A Cooperator shall submit, via a cover letter to the Division Director, an executive summary which assesses the program evaluation's findings and recommendations and proposes changes in program strategy or design as a result of the evaluation.
§1484.73 Are Cooperators penalized for failing to make required contributions?
A Cooperator's contribution requirement is specified in the Cooperator program allocation letter. If a Cooperator fails to contribute the amount specified in its allocation approval letter, the Cooperator shall pay to Commodity Credit Corporation in U.S. dollars the difference between the amount it has contributed and the amount specified in the allocation approval letter. A Cooperator shall remit such payment by December 31 following the end of the marketing plan year.
[64 FR 52630, Sept. 30, 1999. Redesignated and amended at 65 FR 9995, 9996, Feb. 25, 2000]
§1484.74 How is Cooperator program compliance monitored?
(a) The Compliance Review Staff (CRS), FAS, performs periodic on-site reviews of Cooperators to ensure compliance with this part.
(b) In order to verify that federal funds received by a Cooperator do not supplant private or U.S. industry funds or contributions pursuant to §1550.20(a)(14), FAS will consider the Cooperator's overall marketing budget from year to year, variations in promotional strategies within a country or region, and new markets.
(c) The Director, CRS, will notify a Cooperator through a compliance report when it appears that Commodity Credit Corporation may be entitled to recover funds from that Cooperator. The compliance report will state the basis for this action.
[64 FR 52630, Sept. 30, 1999. Redesignated and amended at 65 FR 9995, 9996, Feb. 25, 2000]
§1484.75 How does a Cooperator respond to a compliance report?
(a) A Cooperator shall, within 60 days of the date of the compliance report, submit a written response to the Director, CRS. This response shall include any money owed to Commodity Credit Corporation if the Cooperator does not wish to contest the compliance report. The Director, CRS, at the Director's discretion, may extend the period for response up to an additional 30 days. If the Cooperator does not respond to the compliance report within the required time period or, if after review of the Cooperator's response, the Director, CRS, determines that Commodity Credit Corporation may be entitled to recover funds from the Cooperator, the Director, CRS, will refer the compliance report to the Deputy Administrator.
(b) If, after review of the compliance report and response, the Deputy Administrator determines that the Cooperator owes money to FAS, the Deputy Administrator will so inform the Cooperator. The Deputy Administrator may initiate action to collect such amount pursuant to 7 CFR Part 1403, Debt Settlement Policies and Procedures. Determinations of the Deputy Administrator will be in writing and in sufficient detail to inform the Cooperator of the basis for the determination. The Cooperator has 30 days from the date of the Deputy Administrator's initial determination to submit any money owed to Commodity Credit Corporation or to request reconsideration.
[64 FR 52630, Sept. 30, 1999. Redesignated and amended at 65 FR 9995, 9996, Feb. 25, 2000]
§1484.76 Can a Cooperator appeal the determinations of the Deputy Administrator?
(a) The Cooperator may appeal the determinations of the Deputy Administrator to the Administrator. An appeal must be in writing and be submitted to the Office of the Administrator within 30 days following the date of the initial determination by the Deputy Administrator or the determination on reconsideration. The Cooperator may request a hearing.
(b) If the Cooperator submits its appeal and requests a hearing, the Administrator, or the Administrator's designee, will set a date and time, generally within 60 days. The hearing will be an informal proceeding. A transcript will not ordinarily be prepared unless the Cooperator bears the cost of a transcript; however, the Administrator may have a transcript prepared at FAS's expense.
(c) The Administrator will base the determination on appeal upon information contained in the administrative record and will endeavor to make a determination within 60 days after submission of the appeal, hearing, or receipt of any transcript, whichever is later. The determination of the Administrator will be the final determination of FAS. The Cooperator must exhaust all administrative remedies contained in this section before pursuing judicial review of a determination by the Administrator.


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by Hope
This is a more personal update versus financial. Please skip if that does not interest you.
Today is the last day of Princess and Gymnast first semester in public school. We made it.
Over the last couple of days, I've sat with each of them individually and had them look back at this semester and asked for their feedback and perspective. I thought I would share their thoughts with you.
I asked each of them:
- How did going to public school differ or meet your expectations?
- Looking back and comparing homeschooling in Virginia and public school here, which would you choose? (I didn't ask them about homeschooling here as the challenges we faced were the main reason I chose to try public school.)
Princess' Perspective
The stereotypes about high school are all wrong. First, I didn't get bullied at all. And second, there is not a lot of homework at all.
Princess, age 14, 10th grade
She has had a really good semester. Gotten straight A's across the board. Made the varsity volleyball team for the fall. Inducted into the Anchor Club. And made several new good friends.
Gymnast Perspective
I don't like getting up, but I like feeling normal. And I'm learning things I hadn't learned before, but maybe I wasn't to that level. But there is not a lot of homework. I am glad I was homeschooled, but now I really like the social aspect.
Gymnast, age 12, 7th grade
He has struggled. Grades, fitting in, been assaulted three times and being so busy with training 4 nights a week. There were kids who told him they couldn't be his friend "because he is brown." But he has also grown and matured, and continued to be true to himself. He is finishing the year with all As and Bs and squeaked through the standardized testing (where they tested for the full year of material and he was only there for a semester.)
He is ranked sixth overall in our eight state region in gymnastics. And has just committed to the next year of training and competition, moving up to Level 8. (Here he is modeling over 100 of the medals he has won over the last six years of competing.)
My Thoughts
I had no doubt that both of them would be successful. They are resilient and smart. I could not be more proud.
I think if we had done this back in Virginia it would have been a completely different experience. They would not have faced so much racism. The education is definitely better there. But then again, we had such a strong homeschool network there, I would never have considered it.
And we would have also had to deal with a great deal more bureaucracy. Whereas, here the schools have really worked with us to accommodate Gymnast' training and competition schedule and Princess' advanced status.
Next Year
There are some things we will change in the Fall. Riding the bus more is definitely one we will try. Getting more involved with volunteering at the schools. I'm going to apply to substitute teach.
But for now, we will continue with public schools…I will always regret that it came to this. But I know that at this time and at this place in our lives, it is the best choice for both of them.
Thank you for being part of our journey.

subset: commoncrawl


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I remember that picture, could I have a more recent one?
It was on Sept. 9 that Sonland says Trump told him he "wanted nothing." Lmbo. Right after the whistleblower report was made known.
The DOW is back over 28,000!!!!! Would I vote to impeach or to reelect? The answer should be so obvious.
Thank you. You may enjoy my recent posts here, and here in the recent Unicorn thread.
Great picture to show critics of the usage of the word "unicorn" in the Bible.
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Here is the Sanguinary Priest and Sanguinary Guard Ancient. I used a few layers of Soulstone Red and chucked in some Lamenter's Yellow Glaze to try and give the chalice contents an interesting finish.
And here is the Chaplain. He's great as a test model for my Death Company as well, but I really try to avoid painting black – tough to edge highlight (I don't even know what to do with my Deathwatch models).
Still, I'm happy with the look of these models and don't want to spend too long on each one.
My goal now is painting up a decent force selection for the Wardens within the next few weeks. That means finishing off the following soon, all of which have base layers of Khorne Red and Leadbelcher:
- 5 Devastators
- 10 Tactical Marines (2 x 5)
- Vindicator & Predator
I'm pleased to break down the larger project into a good-sized chunk, and look forward to having a nice painted group.


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Ted Butlers kommentar om silverpriset i sitt nyhetsbrev från oktober 2014 är mer aktuell än någonsin, läs här:
We are set up for violent price reversals to the upside for silver and for all the COMEX/NYMEX metals. Maybe the setup can get stretched out a little longer, but it looks stretched out enough to me by historical standards. We've gone too low in price on too many important commodities as a result of this stupid and manipulative machine trading. There's a payback and a counter-reaction to the price distortions we've witnessed and it seems to me that the payback is at hand.
I think the technical funds have been lulled into a sense of complacency, particularly in silver, by how easy the commercials have let them off the hook when they held extreme short positions recently. But just because the commercials have let the technical funds buy back shorts at prices close to upside penetrations of important moving averages previously, doesn't mean that will always be the case. Just because the technical funds think they will be able to buy back silver shorts near the $18 mark, that doesn't necessarily make it so. The commercials can demand much higher prices before selling. There will come a day when the commercials won't be nearly as accommodative to the technical funds as they had been previously and that will be a great day for silver investors. That day seems at hand to me. – Silver analyst Ted Butler: 29 October 2014


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Main & Dessert
Make your own menu....choose three to four from the following choices to create your own menu for your guests
LAMB'S LIVER ...with bacon & onion gravy. Served on mash.
PORKERS 'n' HASH...Tim Lear's homemade sausages, served on corned beef hash with gravy and fried onions
SINGAPORE BEEF...strips of peppered, sweet chilli beef served on a noodle stir fry
JAMBALAYA...A New Orleans's inspired dish of pork, sausage, pepper and spicy rice, topped with chicken and prawns
PAULA'S STEAK 'N' MUSHROOM PIE...with seasonal vegtables
HOME MADE CHICKEN KIEV...with lashings of garlic butter
FRED ASTAIRE...chicken with leeks and cream, served with a puff pastry top hat
CAESAR SALAD...with chicken, bacon, shaved parmesan, pine nuts & garlic dressing..nuts
TANDOORI CHICKEN...served on a vegetable Biryani, with a pompadom and a dollop of minted crème friache
PEKING CRISPY DUCK ...on a cucumber & bean sprout salad, with plum sauce & prawn crackers
TEX MEX BASKET... a tortilla basket filled with mixed leaf salad, avocado and crispy coated spicy prawns
TRADITIONAL FISH CAKES...with homemade tartar sauce
GOUJONS OF COD coated with crispy breadcrumbs, with mushy peas and chips
SEAFOOD RISOTTO....pea risotto topped with salmon, prawns and cod.
FILLET OF COD wrapped in Parma ham, served on crushed potato and pea 'hash'. Served with garlic dressing
MUSHROOMS ...baked in fillo pastry with spinach cream
ASPARAGUS RISOTTO... with a homemade red pesto cream...nuts
BAKED AUBERGINE with a spiced cous cous and roasted vegetable stuffing
ROASTED VEGETABLE STACK with melting mozzarella and a tomato and basil sauce
Followed by a selection of homemade desserts


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|New Publication
|Homeopathy in Intensive Care
and Emergency Medicine
|Homeopathy First Magazine
|Best Vitamin C Drink
Learn More With Caralyn
Coupon SHOPWITHHWC
Creating Waves of Awareness
Please tell me who is more intelligent?
Here is the true story
Last Friday, when I was about to leave my clinic after the…Continue
Added by Dr Muhammed Rafeeque on July 29, 2011 at 7:31am — 12 Comments
A 6-year-old girl, named S, was brought to me by her mother. It was her teacher who referred the case for homeopathic consultation. The girl is poor in communication and school performance. She never mingles with others, but plays normally with her own brother and the kids in the neighborhood. She is often active at home, but becomes silent in public. She often gives answer by nodding the head or even by facial gestures. Her teachers used to get irritated from her poor communication. A…Continue
Added by Dr Muhammed Rafeeque on July 25, 2011 at 8:30am — 4 Comments
Added by DR. Sushil Bahl on July 23, 2011 at 6:30am — 2 Comments
Liver Cancer and
Article out
The Liver: Digestive
Function of the Liver, Circulatory Function of the Liver, Microscopic Structure
of the Liver, Microscopic Structure of the Liver, How Liver Cancer Develops:
Carcinogenesis: Initiation, Promotion, Growth of…
Added by Dr Rajneesh Kumar Sharma MD(Hom) on July 22, 2011 at 11:30pm — 8 Comments
Image courtesy: John C. Holden. (lhup.edu)
What do we often read whenever a patient comes with a lab report? Frankly speaking, due to lack of time, we read the 'Impression' given at the end! Right?
But, before we read the 'impression,' or even the details given above the same, make sure that the report…Continue
Added by Dr Muhammed Rafeeque on July 22, 2011 at 1:30am — 6 Comments
Helianthus Annus - Sunflower
A Homeopathic remedy with few Rare symptoms as :-
MIND - INSECURITY; mental - hiding it; but is
galeoc-c-h. helia. tus-p.
HEAD - PAIN - Temples - pulsating - left side
helia. luf-op.
NOSE - DISCHARGE - crusts, scabs, inside - thick
Added by Dr Dushyant Kamal Dhari on July 21, 2011 at 10:40am — 1 Comment
This is my personal intake form which may be downloaded from Mediafire.
Added by Prof Dr Debasish Kundu on July 19, 2011 at 7:00am — 1 Comment
Does anyone have any Ideas about the incorporation of
Carcinocin in Homeopathic Pharmacopea?
To all homeopaths:
I have a problem importing Carcinocin and sarcodes into India. I would like to know from all of you if it is mentioned in any of the pharmacopea of India, U.K or America? …Continue
Added by Dr.Sharad Shangloo on July 18, 2011 at 2:00am — 3 Comments
A young mail of about 26, with diarrhea for the last ten years, met with me, having been taken 5 remedies of 200 potency daily twice or thrice. His office was in front of mine. I was in early days of homeopathy and was seeing him daily doing the practice of taken remedies. Once I asked that why he had taken these and why in this respect. He replied that a reputed lady homeopathic doctor had prescribed these for his diarrhea problem. I said that this was not the proper way of taken…Continue
Added by Muhammad Amir Naim on July 17, 2011 at 2:40pm — 3 Comments
CALLING A SPADE A SPADE by Dr. M. A. USMANI
Allopathy is a scientific therapeutic of Palliation; and Homeopathy is philosophico-scientific therapeutic of curing diseases. Homeopathy has added advantage also of palliating diseases. When a disease is incurable, the…
Added by Dr. M. A. Usmani on July 15, 2011 at 2:30pm — 2 Comments
Abrus Precatorius (Jequirity).
Our materia medica mentions its use in ophthamology and skin mainly in Epitelioma,Lupus,ulcers and Granular lids.
The symptoms from Poisoning by the seeds are as below
Abrin (and Ricin) cause toxicity by inhibition of protein synthesis.
May possibly cause severe…Continue
Added by Dr Dushyant Kamal Dhari on July 15, 2011 at 3:00am — 4 Comments
When Mr. H. entered hurriedly to my consulting room, I thought it is a case of exopthalmos due to hyperthyroidism, because his facial expression and behavior was almost same! But, I was totally wrong! It was his horrible situation that changed his expression. His both nostrils were completely blocked since almost three to four months due to ethmoidal nasal polyps. He was unable to breath through the nose, and there was no sense of smell since many days.
His voice was also changed due…Continue
Added by Dr Muhammed Rafeeque on July 12, 2011 at 12:30am — 5 Comments
When we accept medical activities as our profession then our responsibilities become much higher comparable to other professions, for the simple reason that it involves human life. The chances for defects should be minimum.
Six sigma quality is close to 99.9997%
Added by DR. Sushil Bahl on July 11, 2011 at 9:00am — No Comments
In my limited 10years of practice, I have cured only 15 cases of gall stones, rest never came to me, LOL, so they preferred to do surgery.
This is what pathology study says,
The presence of intraepithelial neutrophilic aggregates, a histologic finding associated with common bile duct obstruction, was identified in 32 (60.4%) cholecystectomy specimens and was the most common pathologic findings. Changes of acute cholecystitis and chronic…
Added by Dr. Sayed Tahir Hassan on July 8, 2011 at 1:30am — 6 Comments
This is actually a topic for debate. You may not support the use of this chemical in Homeopathy, because Dihydrogenmonoxide kills thousands of people every year! Forgive me for suggesting this vehicle that can be used in homeopathy. There are several vehicles used in homeopathy such as globules, sugar of milk, tablets, etc. But, the best and the cheapest vehicle is dihydrogenmonoxide. I have experienced this on several occasions. It is my humble request you to try this in your practice…Continue
Added by Dr Muhammed Rafeeque on July 5, 2011 at 2:30am — 12 Comments
We often hear on our TV, " my doctor said I've got fibromyalgia," and then lots of stories of some famous medicine underlining all of the drug's side effects.…Continue
Added by Dr. Wequar Ali Khan on July 4, 2011 at 1:30am — 5 Comments
This is from my article on facebook. I invite comments from my learned friends.
I have had an opportunity to cure, not just palliate, but a total cure of psoriasis in few cases, while most have been palliated well without any further medicine.
I am presenting few cases that I recall from my memory and also few documented, although not well documented.
1) This was a case of a man who came to me at my allopathy hospital for treatment of chronic…Continue
Added by Dr. Sayed Tahir Hassan on July 3, 2011 at 9:30am — 9 Comments
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Natural Collection #3 | New Releases
The latest Natural Collection Beauty Box arrived the other week and i was very excited by its contents; for the past two boxes there has been a set theme but this time around the box was filled with some of Natural Collections new releases - their new brow range and their new instant glow range.
First up, their brow range. Brow products are a big thing at the moment and so many brands are jumping onto the bandwagon and releasing their own offering and Natural Collection are one of the latest brands to release a range of brow products.
The Natural Collection Double Ended Brow Pencil* is the one i've used the most so far - i have both medium brown and dark brown shade, the dark brown is better suited to my brows so i'll probably end up using medium brown as an eyeliner or i'll pass it onto someone else. It' dual ended so it has a pencil on one side and a spooly brush on the other. It's such a great brow product, it's quite pigmented but it's also quite light (if that makes sense?) so you can achieve a full and natural brow.
The Natural Collection Brow Kit* comes with a brow powder and a wax; there's not shade on the little palette so i don't know how many shades there are or which one this is classed as but it's a dark brown shade and it suits my brows pretty well. It comes with a adorable tiny spooly brush and a dual ended brow brush both of which are actually pretty decent to use - the powder is great for filling in any sparse areas of the brow and the wax is great to shape and set the brows in place.
They Natural Collection Tinted Brow Gel* are the only products that i'm not too sure about. I have the shades medium brown and dark brown - so far i've only tried the dark brown, the shade matches mine brows just fine but the brush on this is quite big and the first time i used this i ended up with really bold almost scouse brows - it wasn't pretty. I'm going to keep working with it and see if maybe it's just one of those products that take a bit of getting used to.
Secondly, we have theire new range of highlighters - these have been designed to work all together as a blush, bronzer and highlighter. Personally, i wouldn't wear them all togther as they are all shimmery and i feel like i'd end up as a disco ball seperately however, they're pretty damn good.
The Natural Collection Highlighter Stick in Rose Glow* is by far my favourite one and the one i've used the most, it's a gorgeous pink pearlescent highlighter and it looks so pretty on. The shimmer is quite chunky so it does need to blended out, i find a sponge really helps but this gives the skin a really beautiful glow.
The Natural Collection Highlighter Stick in Coral Glow* is the blush and it's really pretty on. It does have shimmer in it but it's so pretty and that shimmer adds a nice glow to the skin. I feel like this would be the perfect summery blush - just a shame the UK doesn't seem to have much of a summer.
The Natural Collection Highlighter Stick in Copper Glow* was the one i was most nervous about, a shimmery bronze highlighter to be used as a bronzer - i didn't really know what to expect. I applied a little bit on the cheeks like you would a contour and blended it out with a sponge and it was actually really good - you could really see the contour and the shimmer was actually quite subtle (may have helped that applied a very small amount) but i was so impressed.
All of these products are only £1.99 and i have to say they are pretty good. It's so nice to see a range of highlighters and brow products that are so affordable, not everyone has the means to spend £10+ on a single product, so i think it's great that Natural Collection have now catered to that and it's even better than the products are good quality too.
Have you tried any of the Natural Collection's new releases?
Natalie xx
*This item was either gifted to me or sent for review.
2 comments:
- Anonymous17 August 2016 at 15:38
These all look and sound like such lovely products! Especially those highlighter, blush and bronzer products! XxReplyDelete
I'm really liking them - i think they're really good for the price!Delete
Natalie xx
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Careers In Travel & Tourism
Tourism is a booming industry around the world. As a manager with a travel company, you could be involved in managing a team of people, organising travel plans, making bookings, researching the latest 'hot' travel destinations, promoting your brand in the market, and more.
As per World Travel & Tourism Council, there will be over 29.6 million jobs in the Indian travel & tourism industry, by 2026. With the growing number of tourists every year and the rapid expansion of hotels of international standards, the need for skilled and trained people is also on the rise in the tourism industry, leading to great job opportunities.
On completing our tourism management course, you can build a successful career as:
- Tour leader
- Itinerary planner
- Fares & ticketing officer
- Language interpreter
- Foreign exchange cashier/ consultant
- Operations executive
- Travel company owner


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Download it here. There are a few known issues that will be resolved in the next alpha release, but first I need to make sure the core concepts are solid. So please play the alpha and leave your comments! Your feedback is greatly appreciated! Also check out the shiny new website: lemmagame.com
Note: You might get a malicious file warning. It's because I can't afford a code signing signature at the moment, so the installer has not been signed.
And if you simply can't be arsed to play the alpha OR watch the video, here's some screenshots:


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The Vision Medium Bird Cage #M02 is an wonderful cage for budgies, canaries, lovebirds and finches. The Vision Bird Cage provides your bird with a generous amount of room to move around. The Vision bird cage makes it easy so that you can maintain your bird happy.
The Vision bird cage reduces the mess. Bird movements cause air currents, which go with the flow outwards, and in relation to most standard bird cages these air currents eject waste and seed debris out of doors of the cage and onto the floor. With Vision Cages, the combination of the debris guard, the deep base and the placement of the seed/water cups helps combat air currents to keep the majority of the waste and debris within the cage. This reduces the amount of mess and time-consuming clean ups, leaving you more time to enjoy your pet. The Vision Medium Bird Cage is a brilliant home in your new bird.
Important Specs:
Small wire bird cage for budgies, canaries, lovebirds and finches
Cage detaches from base for fast, easy cleaning
Debris guard helps keep waste inside cage
Double height; Equipped with green perches and food/water dishes
Tall; 24.6 inches long x15.6 inches wide x 34.3 inches high


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Enter ZIP code to see local offers
Starting MSRP
The 2020 Corolla Hybrid also comes with Apple CarPlay2 standard!
Under the hood, our proven hybrid drivetrain produces up to an EPA estimated 53 city mpg.
With ergonomically designed seats, Corolla Hybrid's all-new interior is smart, comfortable and designed with you in mind.
Large, colorful and most importantly, practical, Corolla's available 7-in. MID screen brings safety alerts, vehicle health information and more into your line of sight while you drive.
THE 2020 IS DESIGNED FOR SAFETY AND EQUIPPED WITHToyota Safety Sense™ 2.0 (TSS-2.0)TSSMAIN
Toyota Safety Sense™ 2.0 (TSS 2.0)TSSMAIN is designed to help protect drivers, passengers, people in other vehicles on the road, pedestrians and cyclists from harm. This latest generation of Toyota Safety Sense™ represents Toyota's next milestone in a long history of creating advancements and innovations in safety that help prevent crashes and protect people.
2020 Toyota Safety Sense™ (TSS 2.0)
Pre-Collision SystemTSSPCS with Pedestrian Detection function (PCS w/PD) - Vehicle Detection & Pedestrian DetectionTSSPCSPD
2020 Toyota Safety Sense™ (TSS 2.0)
Lane Departure Alert with Steering Assist and Road Edge Detection (LDA w/SA)TSSLDASA
2020 Toyota Safety Sense™ (TSS 2.0)
Automatic High Beams (AHB)TSSAHB
2020 Toyota Safety Sense™ (TSS 2.0)
Dynamic Radar Cruise Control (DRCC)TSSDRCC
2020 Toyota Safety Sense™ (TSS 2.0)
Road Sign Assist (RSA)TSSRSA
2020 Toyota Safety Sense™ (TSS 2.0)


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Thursday, July 15, 2010
Seafood Pasta...
1/2 lb Pane Pasta (boiled in salted water)
1/2 lb Fresh Large shrimp (Lightly boiled)
1/2 lb Fresh Mussels and Clams (pre steamed or boiled)
1/2 lb shredded melting cheese like Boursin, Brie, Camembert, Colby, Fontina, Havarti or Goudas.
3 fresh tomato
2 cloves of garlic
1 or 2 leaves of fresh basil or just improvise with 1 tsp of Italian seasoning.
4 tbs olive oil
1tbs Butter
2 tbs chopped onions
Salt and black pepper to taste
1/2 cup of water or stuck from the clam, shrimp or mussels
Oven proof plate or baking dish
(Blend tomato, chopped onions and garlic in a blender)
Heat up butter and olive oil in a large saute pan or pot
Add blended tomato, onion and garlic and cook for 3-5 mins at low - medium heat
Add clam, shrimp and mussels
Toss around and let cook for 1-2 mins
Add boiled pasta and gently toss
Adjust seasoning with salt and black pepper
Toss and cook for 3-5 mins at low heat.
Plate desired portion and generously sprinkle shredded cheese on seafood pasta
Melt in the oven or under a got broiler till cheese is melted and nad or lightly grilled.
Serve hot and enjoy with a glass of chardonnay or sauvignon blanc if you drink.
Happy good eats.
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Commercial Services
The ARTEC Group is a full service interior design firm that specializes in creating custom commercial interiors. Our experience, passion for excellence, and ability to execute has given us the reputation as the area's top interior design firm. We provide research, planning, design and procurement solutions across a wide range of commercial settings including workspace, retail and leisure environments.
Our commercial Design experience includes but is not limited to Doctor's Office, Dental Offices, Law Offices, Senior Living Centers, Corporate Offices, and Apartment Complexes. If you need commercial design services for your business in the Dallas- Fort Worth, TX area, nearby community, or beyond, The ARTEC Group can create a design that sets you apart from your competitors. We will take the time to learn about your preferences, and to gain insight as to how you wish to portray your business to clients, associates and visitors.
Our experience and expertise contributes to every phase of your project, ensuring that the final results exceed your expectations.
Below are a few of our Commercial Clients:
- Stewart Tile – The Woodlands, TX
- Coldwell Banker – The Woodlands, TX
- CP & G Company – Houston, TX
- Environmental Performance Inc. – The Woodlands, TX
- Onebane Law Firm Corporate Apartment – Houston, TX
- Advanced Foot Care – The Woodlands, TX
- Weitz & Luxenberg Law Firm – New York, NY
- Aerospace Optics Inc. – Fort Worth, TX
- Doctors in Training – Fort Worth, TX
- Vivsun Aerospace Optics Inc. – Fort Worth, TX
- Waterbury Place Apartments – Arlington, TX
- Stayton at Museum Way-Retirement Community – Fort Worth, TX
- Encompass Health Rehabilitation Hospital of City View – ART Installation – Fort Worth, TX


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Whalehead King and company are travelling far afield without a laptop and with no intention of going online. Destination: Boston's evil twin and antipode: The Crescent City, NOLA, The Big Easy, The City That Care Forgot: New Orleans, Louisiana. Your humble narrator intends to stay out all night in public establishments that are legally open for business and let the good times roll in a round-the-clock metropolis enjoying homegrown cuisine and mixology. Your humble narrator has reluctantly stocked up an overfull store of slumber during the past two years in Boston and it is time to draw down that account.
Regular reportage, such as it is, will resume around August 10. Your Man on the Dot may need a while to recover from the culture shock and predicted katzenjammer. In the meantime we have something like 480 articles to peruse in the archives, tracing back to our humble beginnings in Connecticut's Whaling City, idyllic and romantic New London (apologies for the colored typography issues, this blog used to have a black background and our editor lacks the stamina to reformat everything to straight black and white). You can always look over the Dot-centric merchandise on offer if you are looking for a nice coffee mug or tee shirt to give a co-worker or loved one. And of course, in the meantime, you may want to take the time to follow WK on Twitter. Upon return, Whalehead Enterprises is sure to keep up the habit of broadcasting a daily, pithy aphorism or observation of the state of affairs in Dorchester, Mass. on the website that enabled the Iranian revolution. Our motto, however: "No high hopes. Guaranteed."
Enjoy the next week or so. With a tip of the fedora to our faithful readers who make this endeavor worth continuing. With every bite of muffuletta and every sip of Sazerac , WK will be wishing he was at the Dot Tavern watching the Sox instead of at the Absinthe House.
Cheerio, Hip-Hip, chin-chin, to your health, godspeed,
.....Whalehead King.


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That brings XC Season To A Close
The completion of Nationals brings the XC season to a close. Despite some continuing back problems in a couple competitions, it was an excellent 2016 and I am looking forward to an even better 2017!!
The timing of Nationals was unfortuante as it was following a few weeks of moving back and while I was careful when lifting it was just enough to tweak the back.
The continued focus is strength and positional strength so I can better maintain biomechanically efficient positions while running and skiing and reduce back flare ups.
In terms of race focus over the winter I will be focusing on indoor track on the running side and the upcoming Alberta Cups on the skiing side comulating with Nationals in Canmore.
December 2019
Passionate runner and nordic skier who happens to own a run & ski shop!


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Love wine dinners, so when a friend recommended one recently that paired Spanish sherries with some creative dishes, I was intrigued. Happily, in spite of its very reasonable price, the event exceeded expectations. Susan Dove, general manager and sommelier at Trellis Restaurant, 2426 N. Racine, put on a unique dinner with sherries from Bodegas Hidalgo-La Gitana supplied by Classical Wines from Spain, Ltd.
First course, a generous portion of nicely cooked – happily not chewy – Chilled Octopus & Calamari with a light dressing of preserved lemon and caper berry. It was paired with an exquisitely dry sherry with a hint of burnt aroma called La Gitana Manzanilla.
Next came a plate-sized. nearly paper-thin serving of raw marinated Beef Carpaccio seasoned with dehydrated olives, macron almonds, and anchovy vinaigrette. Moist and tasty, it was served with a small stack of grilled bread and accompanied by Napolean Amontillado. Amontillados are naturally aged versions of the best fino sherries – halfway between fino and oloroso, 6 to 8 years old with a nutty flavor.
And then! We were served a helping of Guinea Hen with seasonal mushroom risotto, aged gruyere, and porcini demi glace. Vaguely reminiscent of your grandmother's cream-of-mushroom-soup rice casserole, it was oh-so-much richer and more complex. The hen meat was meltingly tender and delicious. This was my favorite dish of the whole dinner and went beautifully with the Faraon Oloroso, an intense yet dry, silky-feeling sherry with the elegance, balance and savour I expect from sherry. This was also my favorite sherry of the evening.
Dessert consisted of Cappuccino Pot de Creme, served on a plank with nevaditos cookies (made with shortening and white wine!), sugared almonds, figs, and cabrales cheese (a deeply blue variety). Everything was delicious and paired nicely with two completely different dessert sherries. The winemaker's notes: "Alameda Cream is based on an aged Faraon oloroso with a touch of Triana Pedro Ximenez that gives just the right sweetness for a cream sherry. The Triana Pedro Ximenez that's used to sweeten the Alameda is also bottled on its own in very limited quantities. Satin smooth and intense yet complex."
Trellis has a regular menu of carefully selected small plates (e.g., venison meatballs, prosecco cheese fondue), pizza (e.g., fig jam and bacon, summer squash and goat cheese), sandwiches (e.g., shaved leg of lamb, roast duck) and house specialties. Susan clearly cares very much that you have a positive experience at Trellis. Brunch menu looks very attractive, too.
Come sometime when it's not too crowded as the noise level can get high, but do come. Trellis, part of the Four Corners Tavern Group, is a lovely place with a feeling of elegant European comfort.


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[just wrote this, I'm open to suggestions.]
The police tape outside the rambler didn't conceal much.
Everyone in the neighborhood heard the shots.
When the cameras showed up,
the overweight-middle-aged women were interviewed,
the story was obvious enough.
There were still details floating around,
but with these things details seldom get nailed down,
least not to the satisfaction of col de sac gossip.
The local news anchor was able to piece together
a fairly comprehensive synopsis of the crime.
A murder suicide.
Love had had enough of hope,
his adolescent behavior
refusal to accept reality
or notice her.
Neighbors mentioned that Hope seemed distant in conversation.
He was always occupied with half-finished home improvement projects.
Love hadn't been happy in years.
Seduced by possibilities and fear of being alone,
she married the younger man
months after their meeting him.
The promise of a family went unfulfilled
as the couple struggled with infertility.
Love became increasingly depressed, and Hope paid little attention.
He became unconcerned with his wife's needs and her fight with depression.
In a press conference the Sheriff's office noted
the crime appeared to have been planned ahead of time
it was not a crime of passion.
Friday, August 28, 2009
1 comment:
- graham said...
I like this, but there are a lot of instances of passive voice, or half-sentence here, half-sentence there of explanation that isn't always necessary. I might add one or two lines about the idealistic meeting.
good work overall.
- August 28, 2009 at 7:22 PM
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Friday, April 18, 2008
A Kosher and Joyous Passover To All
Because of the holiday of Passover, the next posting on this site will be Monday night , April 21. Magdeburger Joe wishes peace to all and THIS year in Jerusalem!!
Posted by Magdeburger Joe at Friday, April 18, 2008
Labels: Announcement
1 comment:
- Little Jezebel said...
happy passover to you too! so glad i chanced upon your blog!
- 22 April, 2008
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Is maintaining PCI compliance in the enterprise actually possible?
Manage the ongoing struggle enterprises face in maintaining PCI compliance, weighing practicality with security necessity.
The key finding from the 2011 Verizon Payment Card Industry Compliance report was organizations that meet compliance quickly fall out of compliance. Our company does as well, but in our defense, it seems virtually impossible to remain PCI compliant at all times without making it the chief focus of the entire company, which isn't practical. Is it theoretically impossible to remain PCI compliant continuously?
The finding from Verizon's PCI report that illustrates their instantaneous failure to remain PCI compliant is quite telling, as many companies struggle immensely with the notion of maintaining PCI compliance. To be fair, there are so many policies, procedures and processes that have to be continually changed, updated and assessed in order to truly maintain PCI compliance.
Even amid that reality, companies should strive to commit their best efforts to achieving ongoing compliance with all aspects of the 12 core requirements within the Payment Card Industry Data Security Standards (PCI DSS) initiatives. A risk assessment approach should be taken whereby organizations address and ultimately assess areas that are considered susceptible to breaches of cardholder data; this usually starts with the data at rest. With that said, are sufficient encryption and key management initiatives in place for protecting the cardholder data? It is then safe to move on to many of the other areas that have a high risk of being compromised due to their association with the cardholder data environment (CDE)?
It's arguable that it's theoretically "possible" to stay PCI compliant with a risk assessment model that continually assesses system components within and around the CDE. The best way to be continually PCI compliant is to NOT use a start and stop process for compliance, whereby you implement all necessary requirements, walk away, and revisit the same requirements a year later. Security teams must constantly interact with all system components and personnel responsible for their compliance on a routine basis. It's challenging indeed, but it has to be done. Furthermore, continuous compliance is possible, technically speaking, as organizations commit large resources for short periods of time for meeting annual PCI compliance, via on-site by a QSA or an in-house self-assessment. Unfortunately, if an organization is retested, it's common to uncover many PCI violations even though the enterprise in question was "technically" granted certification previously. Even if it is challenging and daunting, maintaining PCI compliance continuously is achievable and worthwhile.
Next Steps
Take at closer look at PCI compliance in SearchSecurity.com's Eye On series: Eye On: PCI DSS compliance
Dig Deeper on PCI Data Security Standard
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OUTRAGE: Illegal who killed Kate Steinle found NOT guilty
(National Sentinel) Sanctuary City: A jury in San Francisco acquitted the illegal alien who killed Kate Steinle, 32, the woman President Donald J. Trump used as justification for his proposed border wall.
The case also highlighted "sanctuary city" policies like those in Bay Area metropolis in which local police are not permitted to cooperate with federal immigration officials in identifying and removing people in the U.S. illegally.
Jose Ines Garcia Zarate, of Mexico, had been caught and deported from the U.S. multiple times. He had been released from jail under a sanctuary policy when he killed Steinle, even though federal immigration officials were trying to detain him.
The acquittal outraged the president, who took to Twitter Friday morning to express his anger and disappointment at the decision.
"A disgraceful verdict in the Kate Steinle case! No wonder the people of our Country are so angry with Illegal Immigration," he wrote.
"The Kate Steinle killer came back and back over the weakly protected Obama border, always committing crimes and being violent, and yet this info was not used in court. His exoneration is a complete travesty of justice. BUILD THE WALL!"
He added: "The jury was not told the killer of Kate was a 7 time felon. The Schumer/Pelosi Democrats are so weak on Crime that they will pay a big price in the 2018 and 2020 Elections."
Attorney General Jeff Sessions also responded to the verdict by blasting sanctuary city policies.
"San Francisco's decision to protect criminal aliens led to the preventable and heartbreaking death of Kate Steinle," he said.
Local media following the trial seemed as though they expected a guilty verdict, The Washington Post reported.
The CBS station in San Francisco called the verdict "shocking." "Stunning," said the San Francisco Chronicle.
Jim Steinle, Kate's father, who was with her when she was killed, said he was "saddened and shocked," the Chronicle reported. "Justice was rendered, but it was not served."
Matt Gonzalez, the lawyer for Garcia Zarate, defended the ruling and even brought up the Russian collusion investigation of the Trump administration as a deflection.
"For those who might criticize this verdict — there are a number of people who have commented on this case in the last couple of years …. Let me just remind them they are themselves under investigation by a special prosecutor in Washington, D.C. and they may soon avail themselves of the presumption of innocence beyond a reasonable doubt, so I ask that they reflect on that before they comment or disparage the results of this case," Gonzales said.
As for the verdict, the Post reported:
After deliberations that began on Nov. 21, Garcia Zarate, 45, a Mexican citizen, was found not guilty of murder, as well of the lesser charges of involuntary manslaughter and assault with a deadly weapon. He was convicted of being a felon in possession of a firearm, which carries a sentence of up to three years. Federal immigration officials said they would now deport Garcia Zarate.
Garcia Zarate's multiple deportations become a rallying cry for Trump during his campaign last year. As a candidate, Trump pledged to build a wall along the length of the U.S.-Mexico border and to enforce all immigration laws.
Steinle was shot by Garcia Zarate on July 1, 2015, as she walked with her father along the crowded Pier 14 in San Francisco. Jim Steinle testified that they heard a gunshot and that shortly thereafter his daughter fell to the ground.
"Help me, dad," was the last thing she said to him, he testified in court.
The bullet had been fired from a .40 caliber handgun Garcia Zarate had stolen from a nearby car of a ranger with the U.S. Bureau of Land Management.
The bullet pierced Kate Steinle's aorta, and she died hours later at a hospital in San Francisco.
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