The Ease of Finding Pandemic Disaster Loan Cheaters

In 2021, the SBA Inspector General suggested that nearly $80 billion of funding may have been fraudulent and the number is getting larger. However, while many criminal cases include complex investigations, finding EIDL or PPP fraud on the surface is quite easy. This article highlights how easy it really is to find those who may have committed COVID-19 Relief fraud and several techniques that the government can and probably is using to find those who committed fraud from the pandemic funding programs.

By Thomas Tramaglini, Managing Director at BRP Onesta
info@BRPOnesta.com
www.backofficedepot.com
www.thomastramaglini.com
About Thomas Tramaglini

Since the onset of COVID-19 Relief offered small businesses during the pandemic, fraud has been reported as rampant. Considerable action has been taken to underscore the importance of oversight as well. Since President Biden vowed to ramp up oversight of the Pandemic Programs passed by Congress during the Trump Administration and after as well, the Department of Justice has prosecuted many small business owners and legislation has been passed that make oversight a long-term reality.

However, finding pandemic fraud is not hard. Video evidence is not needed. The proof is in the data and the trail of data which applications can be tied to.

Pandemic fraud was easy.

Many small business owners (and some were not small business owners) used a host of different tactics to defraud the US Government’s PPP and EIDL programs from March 2020 through August 2021. Some of these tactics include bank and wire fraud, identity fraud, as well as the submission of false documents such as quarterly tax reports and taxes.

In our industry, we have seen fraud for many years. Commonly, we see fraudulent bank statements regularly, as well as other fake documents such as false payroll data, tax forms, etc. However, when the Trump Administration rolled out pandemic relief in good faith, many small business owners did not return

the favor. They saw “free money” and clearly did whatever it would take to get funded.

We have written extensively about many of the fraud cases and background of cases that continue to pop up in the news, as well as new indictments and convictions in the following articles:

Small Business owners are accountable for what they attested to when submitting their pandemic relief applications

When small business owners filed applications for PPP and for EIDL, they attested that the information they were submitting was true. For instance, in the standard PPP application, the small business owner had to “certify that the information provided in this application and the information provided in all supporting documents and forms is true and accurate in all material respects. I understand that knowingly making a false statement to obtain a guaranteed loan from SBA is punishable under the law, including under 18 USC 1001 and 3571 by imprisonment of not more than five years and/or a fine of up to $250,000; under 15 USC 645 by imprisonment of not more than two years and/or a fine of not more than $5,000; and, if submitted to a federally insured institution, under 18 USC 1014 by imprisonment of not more than thirty years and/or a fine of not more than $1,000,000.”

Therefore, small business owners who knowingly filed requests for disaster relief funding knew in advance of accountability, and they hedged that they would never be held accountable for submitting false (or verifiable) information.

Evidence is Easy to Be Found

Unlike many criminal cases that are cloak and dagger and require massive, complex investigations to uncover hidden evidence, investigating COVID-19 fraud is relatively easy because there are verifiable data and a paper trail leading the way to who done it.

Anyone Can Mine EIDL and PPP Data

The SBA has released a host of PPP and EIDL data which can be found here:

BackOffice Depot Data for Download

Feel free to download all public data as because the data are public data under the Freedom of Information Act (FOIA).

Cross-Checking Data is Not Hard

In many cases, people believe that the government is not very smart.

However, what is needed to find fraud is not hard and the government does not have to be smart to outsmart stupid. Anyone who has access to data can find those who possibly committed fraud with a simple V Lookup or the use of a Pivot Table using Microsoft Excel. Here are a few simple ways that the government is using data to find those who may have committed fraud.

Were the companies who submitted applications, operating?

During review and underwriting their EIDL or PPP loans, the SBA and many lenders did not ask for articles of organization or incorporation or even back up that the company was operating. For instance, anyone can download any of the spreadsheets that we have on our website (see above) to pull the data for themselves. We have easily accessible datasets listing have every pandemic relief loan given from March 2020 through October 2021.

One can go through the list of businesses and just Google the businesses. It is easy to find businesses who are operating and who are not. Websites report scores of data on businesses including number of employees, how many trucks are in operation, and more.

The easiest data to find discrepancies are with the larger EIDL and PPP loans that were taken by small businesses. For instance, I was able to download all loans for PPP over $150K and then sort the column with loan amounts. I was easily able to then choose 10 loan recipients at random. Just in my cursory review I was able to find 1 trucking company that received $700,000+ but they only had listed on the USDOT site that they had 2 trucks. The same business also showed on the EIDL website that they had listed 4 employees. Given the PPP rules for how much salary was able to be delivered in funding, something there seems fishy. The other company I found listed in the 10 companies I reviewed also received $700K+. The company seemed to not have a website, business in good standing, did not file an annual report for more than 6 years, or have any notable information which demonstrated a legitimate business. I even Googled the business address, and the business address was a vacant home sold more than 2 years ago.

Matching tax data with PPP/EIDL Applications

Tax data. It is that simple.

Simply put, the IRS has a record of every tax return and report of quarterly payroll data.

One can easily take the PPP dataset, combined with the data from the IRS (which the Department of Justice or Inspector General for the SBA) should be able to cross-reference using a V Lookup or Pivot Table and find matching and non-matching numbers. Those who submitted quarterly payroll data (940/941) which does not match the IRS records should immediately be investigated.

I am going to guess (however, I cannot give the government that much credit) that the IRS and SBA have begun cross-checking these data and found many fraudulent applications.

The same governmental agencies should also be able to cross-check income from 1040s or 1120 (or other forms) to see if what was submitted was really what was submitted. That is, many people or small businesses do not file taxes. However, when submitting their applications everyone did. It wasn’t until much later on during the pandemic that the SBA began asking for tax transcripts. One can only think of the millions of loans that were approved without any check of tax forms or the infamous 3506T review.

Were some people really that stupid?

The answer is yes.

As aforementioned above, we have written extensively on the subject, as far as ranking the most dubious losers who defrauded the government.

Congress recently passed legislation that extends the statute of limitations out to 10 years for pandemic fraud. It is likely that those who cheated, will be called on it.

Dr. Thomas Tramaglini is the Managing Director for BRP Onesta, a company that supports small businesses. By offering a host of important and affordable services that small

Where to Get Free Money for Your Small Businesses: Small Business Grant Portal

Without a doubt, small business owners want access to capital so they can run and grow their businesses. However, many small business owners who we speak with do not know where to start. So, to help small business owners access these free programs we have built a list of small business grants on our portal which we keep current weekly.

In this article, we provide an overview of current grant programs, highlight one current grant program, and list others that are available (scroll down)

By Thomas Tramaglini, Managing Director at BRP Onesta
info@BRPOnesta.com
www.backofficedepot.com
www.thomastramaglini.com
About Thomas Tramaglini

Is my business eligible for grant funding?

This is always a loaded question. However, most small businesses do qualify for some type of grant funding.

There are always different methods for how to find the right grant. We suggest that any small business owner looks based on:

  • Goals of grant (usually grants carry a greater mission to solve problems – for instance, grants that lead to job creation)
  • Industry – search for grants specific to your industry
  • Grants tend to address places of higher poverty

The key of looking for a grant is to not focus on just getting money. Instead, focus on how organizations that provide grants want you to spend the funds. Then, you can organize your application around how to match your business to what the organization is looking for grantees to accomplish.

Certifications – Where Grants Have Prevalence.

Does your business have a certification? Does the small business owner have a certification? Many grants are put aside for businesses that have a certification. Some of the certifications are:

  • Woman-owned small business
  • Minority-owned small business
  • Disadvantaged business enterprise
  • Veteran-owned small business

For more information on the certifications, and how to get your certification and others, click here.

7 Things Every Small Business Owner Should Be Ready for When Applying for A Grant

Grants represent a great way to access capital for a business, however there are several things which small business owners should be aware of before applying. In preparation for writing a grant, we have built an extensive, yet helpful list of important things which will help any small business owner in their pursuit of a small business grant.

This list of what to expect can be found here: Click Here.

Highlighted Grant Database: Grants.gov

For the month of May, we are highlighting the Grants.gov website.

Grants.gov warehouses thousands of different grants provided by the Federal government. Small business owners can search available grants at https://grants.gov/web/grants/search-grants.html. On the database you can look at grants by industry, funding instrument, agency, and opportunity status.

What Small Business Grants are Currently Available?

Small business grants are free money for small businesses which are provided by government, non-public, and for-profit entities. Most small business grants provide business owners an avenue to apply for a bigger goal. For instance, the US Department of Labor has hosted grants to small businesses in places of high poverty for the development of careers and creation of new jobs.

While it takes time and effort to research and apply for grants, the end game can be worth it as small business grants are funds which do not need to be paid back.

To help you get started, we always keep and refresh small business grants which are available to small business owners (https://www.backofficedepot.com/smallbusinessgrants).

Dr. Thomas Tramaglini is the Managing Director for BRP Onesta, a company that supports small businesses. By offering a host of important and affordable services that small business owners tend to not have time to do themselves, the team at BRP Onesta can help small businesses grow infinitely. Although located in on the famous Jersey shore, BRP Onesta serves clients in all 50 states, Puerto Rico, Mexico, and Canada.

8 Affordable Small Business Financing Options for The Post Pandemic Era

While the Economic Injury Disaster Loan (EIDL) and the Payroll Protection Programs (PPP) were beneficial for small business owners, as they say, “all good things must come to an end.” What it does not mean is that there are not great options out there for small business owners to take advantage of. We know that traditional bank loans and lines of credit are rarely out there but that does not mean access to financing has to be hard or expensive.

In this article, we will share a list of 8 different financing products which are easy to attain, and in some cases will cost you nothing.

By Thomas W. Tramaglini, Managing Director at BRP Onesta
info@BRPOnesta.com
www.backofficedepot.com
www.thomastramaglini.com
About Thomas Tramaglini

What’s out there for small business owners?

In the post EIDL/PPP era, what is out there for small businesses? We get that question a lot from clients to we put together a list of 8 options for small business owners. Also, you can apply through our platform as we do not charge clients broker fees or add on extra origination charges, ultimately making the product more affordable than going through loan brokers or directly through a website for business funding.

Small Business Grants

Small business grants are free money for small businesses which are provided by government, non-public, and for-profit entities. Most small business grants provide business owners an avenue to apply for a bigger goal. For instance, the US Department of Labor has hosted grants to small businesses in places of high poverty for the development of careers and creation of new jobs.

While it takes time and effort to research and apply for grants, the end game can be worth it as small business grants are funds which do not need to be paid back.

To help you get started, we always keep and refresh small business grants which are available to small business owners (https://www.backofficedepot.com/smallbusinessgrants).

Term loans

Term loans are easy to apply for and usually provide small business owners terms from 1 year out to 5 years. Approvals are based on underwriting guidelines specific to the industry, amount of loan, monthly revenue, credit score, business credit score, and time in business.

Small business term loans usually have set fixed interest rates and payments can be daily,

weekly, bi-weekly, or even monthly. For most term loans under $150K the only documentation needed tends to be an application, business bank statements, as well as proof of business. Some lenders ask for taxes if your funding request is for more than $150,000 or on a case-by-case basis.

Average Range for Borrowing: $1,500 to $550,000

Rate(s): 7% – 38% APR

Credit Score Requirement: 600

To apply for pre-qualification (no credit pull) for a Small Business Term Loan Click Here.

Equipment Term Loans with Rebate

Some equipment loans carry rebates which can be advantageous for small business owners. That is, a lender will lease to the small business a piece of equipment and provide a rebate at an amount which is parallel to the costs of the equipment loan. For instance, if it is determined that the equipment loan is for $25,000, the equipment is then amortized with interest over 60 monthly payments, without origination or fees. Then, upon receipt of equipment, a rebate is provided for the business owner for the equipment at the amount the equipment costs.

What is beneficial about the loan is that to an extent, equipment is tax deductible under Chapter 179 of the IRS Tax Code so what you are paying back is tax deductible. Also beneficial is that this loan is not one that counts as an MCA position and having a longer term make the payments more affordable than traditional term loans.

Average Range for Borrowing: $20,000 to $100,000

Rate(s): 15% – 20% APR

Term(s): 5 years

Credit Score Requirement: 680

Business Credit Score: Paydex Score of 80

To apply for pre-qualification (no credit pull) for a 5 Year loan click here.

Line of Credit

Lines of credit have the most flexibility. For instance, the beauty of a line of credit is that you only draw what you need when you need to. Applications for lines of credit are fast and have

flexible terms.

Range for Borrowing: $1,500 to $250,000

Rate(s): 7% – 28% APR

Term(s): Variable

Credit Score Requirement: 680

To apply for pre-qualification (no credit pull) for a line of credit, click here.

Short Term Loan

Short term loans are those which go from 6 months to 5 years. Most short-term loans have

weekly payments and little underwriting requirements. Further, credit is less important and while rates tend to be higher for small business owners, there is minimal paperwork needed and funds can be disbursed in as fast as 1 hour.

Average Range for Borrowing: $2,500 to $500,000

Rate(s): 8.99% – 34% APR

Credit Score Requirement: 450

To apply for pre-qualification (no credit pull) for a line of credit, click here.

Consolidation Loan

Consolidation loans present a host of different options for small business owners who already have debt or would like to combine working capital already taken. There are

different consolidation programs available which small business owners can use to ensure that they have the maximum economic performance they can have.

For originators, loan consolidation is an art. There are virtually dozens of ways to consolidate loans which can be helpful. Once you apply, our team will craft an option which provides you a simple, affordable road map for consolidation and beyond.

Average Range for Borrowing: $25,000 to $500,000

Rate(s): 9.0% – 39% APR

Term(s): Up to 3 years

Credit Score Requirement: 500 and up

To apply for pre-qualification (no credit pull) for a consolidation loan, click here.

Equipment or Vehicle Loans

Perhaps one of the best loans small business owners can take is for equipment or vehicles. With relatively low rates, equipment or vehicle loans can be efficient and lower in cost than working capital loans or merchant cash advances. Plus, the benefits are that the loan does not usually go on the business owner’s personal credit and has a longer term, up to 6 years.

Further, many lenders do not count an equipment loan towards working capital loans or merchant cash advances, so small business owners may be able to acquire more capital. Some equipment and vehicle lenders may also provide additional working capital as well.

Average Range for Borrowing: $25,000 to $150,000

Rate(s): 6.0% – 21% APR

Term(s): Up to 6 Years

Credit Score Requirement: 600

To apply for pre-qualification (no credit pull) for an equipment or vehicle financing, click here.

Asset-Based Loans

Asset-based loans are loans that are collateralized with either equipment or real estate. Loans that have collateral attached to it are usually cheaper than regular term loans and less risks for lenders to provide funds.

Asset-based loans for small business owners can be a great way to access lower-cost working

capital and the terms can be beneficial as well. Also, asset-based loans usually carry simple monthly interest, which means you pay interest by the month, not the term. If the borrower pays the loan back earlier, they can save on the interest as they do not pay the months that they do not have the loan. This is a similar loan product to a line of credit.

Average Range for Borrowing: $10,000 to $500,000

Rate(s): Simple Monthly Interest (starting at 1.5% per month)

Term(s): Up to 5 Years

Credit Score Requirement: None

To apply for pre-qualification (no credit pull) for an asset-based loan, click here.

Dr. Thomas Tramaglini is the Managing Director for BRP Onesta, a company that supports small businesses. By offering a host of important and affordable services that small business owners tend to not have time to do themselves, the team at BRP Onesta can help small businesses grow infinitely. Although located in on the famous Jersey shore, BRP Onesta serves clients in all 50 states, Puerto Rico, Mexico and Canada.

What Do Small Business Owners Need to Know About Filing Their Taxes for 2021?

Did you receive EIDL or PPP proceeds in 2021 and you do not know how that is handled with regards to your taxes? What are the new requirements for the submission of taxes for small businesses in 2021? Indeed, for Small Business Owners Tax season brings on a layer of anxiety and additional work. While some small business owners use accountants, many small business owners file their taxes on their own. In this article, we provide an overview of some of the changes which small business owners should be aware of when preparing to submit their taxes either through an accountant or on their own.

By Thomas Tramaglini, Managing Director at BRP Onesta
info@BRPOnesta.com
www.backofficedepot.com
www.thomastramaglini.com
About Thomas Tramaglini

Introduction

Tax season is in full swing. In most cases, corporate taxes are due to the Internal Revenue Service on April 15th. If you have an S-Corporation, your corporate taxes were due on March

15th (unless your fiscal year is not operating on a calendar year). There have been some changes that have been made by government changes or additions to legislation (much in COVID Relief legislation), so here is a short recap of some of the changes.

Small Business Tax Changes for FY 2021

American Rescue Plan

Credits for Paid Leave Because of COVID Vaccines

The American Rescue Plan of 2021 provides guidance on allowing small business owners to claim refundable tax credits for their employees. This is to reimburse them for the cost of providing paid sick and family leave to employees due to COVID-19. This includes leave taken by employees to receive or recover from COVID-19 vaccinations. ARP tax credits are available to eligible employers who paid sick and family leave from April 1, 2021, through September 30, 2021.

Employee Retention Credit: The American Rescue Plan extended the ERC until December 31, 2021.

PPP and EIDL

If you received Economic Injury Disaster Loan proceeds in 2021 the funds do not count as taxable business income for 2021. However, it is important to retain detailed records for an audit that can be ordered by the Small Business Administration (SBA) or Department of Justice.

You can use EIDL funds to pay taxes to lower your accrued liabilities.

Did your small business receive a PPP loan in 2021? Like EIDL, the Paycheck Protection Program (PPP) loan (forgiven or unforgiven) does not count as business income and you are eligible to write off allowable business expenses, even if the PPP loan was used to pay those expenses. Learn more about allowable uses of EIDL and PPP here.

Digital Payment Services (PayPal, Venmo)

If customers pay for services or goods through a digital pay service such as PayPal or Venmo and the amount is above $600 it should be counted as income. Beginning in 2022 those digital services are required to report those metrics to the IRS, and this can be an easy place for an audit.

Sick and Family Leave Credits

Sick and family leave credits: Eligible employers can claim refundable tax credits that reimburse them for the cost of providing qualified sick and family leave wages for employees on leave between April 1, 2021, and September 30, 2021, either for the employee’s own health needs or to care for family members.

401(k) Contributions to One Participant or Solo 401(k)

Business owners with no employees can contribute up to $58,000 in tax year 2021. In 2022, they can contribute up to $61,000 to a one-participant or solo 401(k), with an additional $6,500 catchup if the owner is over 50.

Meals

Do you claim business meals? Business meals at restaurants are 100% deductible for tax years 2021 and 2022 (up from 50%).

Other Tax Stuff

The standard mileage rate for business use of a vehicle is 56 cents per mile for the 2021 tax year. In the 2022 tax year, the rate increases to 58.5 cents per mile.

Charitable Gift Deductions increased: C Corporations are still allowed to raise the limit for cash donations from 10% to 25% for the 2021 tax year.

Get Help if Needed

If you are unsure about your tax needs, need to file taxes from previous years, or just have

questions, please contact our team of advisors today.

Dr. Thomas Tramaglini is the Managing Director for BRP Onesta, a company that supports small businesses. By offering a host of important and affordable services that small business owners tend to not have time to do themselves, the team at BRP Onesta can help small businesses grow infinitely. Although located in on the famous Jersey shore, BRP Onesta serves clients in all 50 states, Puerto Rico, Mexico and Canada.

BRP Onesta is not an accountancy and does not give advice on tax decisions which would be better answered by a CPA or tax professional. In other words, if you have a question, as your accountant.

7 Things Every Small Business Owner Should Be Ready for When Applying for A Grant

Small business grants opportunities are out there! In this post we address some critical things that might serve as a roadblock to a small business owner getting the grant they apply for.

By Thomas W. Tramaglini, Managing Director at BRP Onesta info@BRPOnesta.com www.backofficedepot.com http://www.thomastramaglini.com About Thomas Tramaglini

Grants: They are out there – but are you ready?

Small business owners ask us all the time for grants which they can apply for that will support their new or established business. That is why we always keep an updated list of grants on our website which every small business owner should visit regularly.

Yet, in many cases small business owners are not successful in attaining a grant.

Grants represent a great way to access capital for a business, however there are several things which small business owners should be aware of before applying. Below, we provide a list of some important things which will help any small business owner in their pursuit of a small business grant.

1. Do your research

The people who provide Grants to small businesses are usually from non-profits or the government. In most cases grants have a specific purpose. Many times, small business owners will just “Apply” for a grant without seeing what type of grant is out there. One simple thing to do is to use a grant database to find the right program to apply for.

We have a few grant databases here to conduct your search

Grantors want to give funds to those who help the organization reach its goals. Some of the best examples are grants that support minority small businesses or veterans. If you are neither then don’t apply because you surely will get rejected.

2. Think like a grant reviewer

A great way to think about your grant application when you write it is to think like a grant reviewer. That is, if you are going to be the person or team reviewing the grant you are writing what would they be looking for.

Most grants have a list of what they are looking for in the grantee. Take that list and make your own list of grant requirements and use that to guide your application. Even have someone else review your application with the list you provided as a guide. Most grants are graded on a scale or rubric, so this is a helpful technique when writing your application.

3. Keep accurate records of what you are applying for

One common mistake that many small business owners make is that they do not save information regarding what they applied for. Then, when the grant reviewer(s) asks questions, or for supporting documents, the small business owner shows either insincerity or disregard for the grant which leads to q quick decline.

So – Take notes. Keep a file. Do whatever is necessary so that you are ready when the grant reviewer asks questions or for supporting materials.

4. Grants are usually not like EIDL and PPP

Over the past few years, small business owners have had a taste of PPP and EIDL programs. For the most part, there were few guardrails which small business owners had with the pandemic funds being doled. Regardless, there were a bunch of knuckleheads who did not follow the minor rules (Actual Rules Here) and paid the price for it (Fake 940/941s. More Lamborghinis, Rolexes and Real Estate, Oh My).

Grants have technical components that one must usually follow, and nobody is entitled to grant funds. Grant applications should demonstrate that the business owner is worthy of the funds.

5. Make sure that you are writing like you can write

On many occasions I have seen grant applications declined because they are poorly written. I have sat on grant panels myself and seen some awful demonstrations of the English language. Nobody expects a trucker to write like F. Scott Fitzgerald but run on sentences, misspelling, failing to proofread, and just not being to the point is what I have seen kill an application. Even for the worthiest small business owner. So, if you have been writing using slang or short texting words, a word to the wise – do not use those in grant applications.

If you are unsure if you are writing a good piece, send it to me anytime and one of my team members or I will look at what you wrote (info@brponesta.com).

6. Make sure you have the following:

In many cases, grant organizations will ask for the following things. If you need any assistance with any of these things, which are pretty much what every small business should have regardless, contact our team of advisors now.

  • Articles of Organization or Incorporation
  • Corporate Financials (P&L, Balance Sheets)
  • Business Bank Statements
  • Tax Returns
  • Business Plan
  • Operating Agreements
  • Privacy Policy
  • 2 Year Corporate Financial Outlook
  • Website Address
  • Company Overview

7. Use a grant writer

Most small business owners are not grant writers. In fact, most small business owners do not have the time to write grants or are not experienced in writing grants. Therefore, companies like ours (contact our team of advisors as we write grants) exist to help small business owners.

We are well schooled in the grants that are out there, as well as how to effectively write those grants.

If you are a small business owner and you want us to write one or more grants for you, we have a bunch of different grants and grant writers who will help you at an affordable rate. If you are interested contact our team of advisors now.

Sign Up for Our Secret Sauce Newsletter for Small Businesses and receive the link to 1 Tradeline Who Gives Business Credit for Free Click Here

Dr. Thomas W. Tramaglini is the Managing Director for BRP Onesta, a company that supports small businesses. By offering a host of important and affordable services that small business owners tend to not have time to do themselves, the team at BRP Onesta can help small businesses grow infinitely. Although located in on the famous Jersey shore, BRP Onesta serves clients in all 50 states, Puerto Rico, Mexico and Canada.

What Grants Are Available For Small Businesses?

Are you a small business owner and looking for a Small Business Grant? We always keep a running list of current grants available on our website and we just updated it.

By Thomas Tramaglini, Managing Director at BRP Onesta
info@BRPOnesta.com
www.backofficedepot.com
www.thomastramaglini.com
About Thomas Tramaglini

Are you a small business owner and looking for a grant to support your business?

Our team at BRP Onesta continually looks for and list grants that are available for small businesses on our website.

1) Subscribe to our Blog to keep informed and receive updates regularly.

2) Contact our team if you need assistance with your grant application.

Check our list out now.

Dr. Thomas Tramaglini is the Managing Director for BRP Onesta, an organization that that supports small businesses. BRP Onesta offers a host of important and affordable solutions that small business owners tend to not have time to do themselves, the team at BRP Onesta can help small businesses grow infinitely. Although located in on the famous Jersey shore, BRP Onesta serves clients in all 50 states, Puerto Rico, Mexico and Canada.