BEFORE
THE
IOWA
INSURANCE
COMMISSIONER
Division
Case
No.
105524
IN
THE
MATTER
OF
ADAM
HOCKING,
NPN:
9839832,
DOB:
09/I3/XXXX,
ORDER
AND
CONSENT
TO
ORDER
and
ADAM
HOCKING
&
ASSOCIATES
II
INC.,
NPN:
16933283,
BEP:
1002210035,
Respondents.
NOW
THEREFORE,
upon
motion
of
the
Iowa
Insurance
Division
(“Division”)
and
by
the
consent
of
Respondents
Adam
Hocking
and
Adam
Hocking
&
Associates
II
Inc.,
and
pursuant
to
the
provisions
of
Iowa
Code
chapter
507B—Insurance
Trade
Practices,
Iowa
Code
chapter
522B—Licensing
of
Insurance
Producers,
and
Iowa
Administrative
Code
chapter
15
Unfair
Trade
Practices,
the
Commissioner
enters
the
following
Order
and
Consent
to
Order
(“Consent
Order”):
I.
PARTIES
AND
JURISDICTION
The
Commissioner
of
Insurance,
Douglas
Ommen,
directly
and
through
his
designees.
1.
administers
and
enforces
Iowa
Code
chapter
507B—Insurance
Trade
Practices,
Iowa
Code
chapter
522B—Licensing
of
Insurance
Producers,
and
Iowa
Administrative
Code
chapter
15
Unfair
Trade
Practices
pursuant
to
Iowa
Code
§
505.8.
Adam
Hocking
(“Hocking”)
is
an
individual
with
a
last-known
residence
address
of
4631
2.
Timberline
Dr.,
West
Des
Moines,
Iowa
50265.
Hocking
is
the
sole
owner
and
operator
of
Adam
1
October 9, 2020
Hocking
&
Associates
II
Inc.,
(“AHA”)
with
a
last-known
business
address
of
1239
73rd
Street,
STE
A,
Windsor
Heights,
Iowa
50324.
Hocking
is
and
has
been
licensed
in
the
state
of
Iowa
as
a
resident
insurance
producer
3.
since
November
1,
2007.
He
is
licensed
under
National
Producer
Number
9839832.
AHA
has
been
a
licensed
business
entity
insurance
producer
since
April
9,
2013.
AHA
is
4.
licensed
under
National
Producer
Number
16933283
and
BEP
number
1002210035.
Pursuant
to
Iowa
Code
§
505.28,
Hocking
and
AHA
(hereinafter
“Respondents”)
have
5.
consented
to
the
jurisdiction
of
the
Commissioner
of
Insurance
by
committing
acts
governed
by
chapters
507B
and
522B.
Respondents
knowingly
and
voluntarily
enter
into
this
Order.
Respondents
agree
to
be
6.
bound
by
the
terms
this
Order.
Respondents
neither
admit
nor
deny
paragraphs
37,
40,
41,
52-55,
58,
and
59.
II.
FINDINGS
OF
FACTS
Hocking
applied
for
resident
insurance
producer
licenses
with
the
Division
by
submitting
7.
through
the
Iowa
Uniform
Application
for
Individual
License
(“Uniform
Application”).
In
submitting
the
Unifomi
Application.
Respondents
designated
the
Commissioner
as
an
agent
for
service
of
process.
AHA
applied
for
a
business
entity
producer
license
with
the
Division
by
submitting
a
8.
Uniform
Application
for
Business
Entity
Producer
License
(“Uniform
Application”)
through
the
National
Insurance
Producer
Registiy.
In
submitting
the
Uniform
Application,
AHA
designated
the
Commissioner
as
an
agent
for
service
of
process.
Hocking
is
and
has
been
the
only
licensed
insurance
producer
for
AHA
since
it
was
9.
incorporated.
2
10.
Hocking
is
bilingual
and
speaks
both
English
and
Spanish
fluently.
Hocking
represents
multiple
businesses
and
individuals
within
the
local
Latin
American
11.
community.
12.
Consumers
H.G.
and
A.S.
are
a
Latin
American
couple
who
operate
business
entity
NTM,
a
used
car
dealership
they
purchased
in
July
of
2016.
Consumers
H.G.
and
A.S.’
primary
language
is
Spanish.
Consumers
H.G.
and
A.S.
fi
rst
became
customers
of
Hocking
in
2015.
H.G.
came
to
13.
Hocking
to
purchase
home
insurance.
In
August
of
2016
Consumers
H.G.
and
A.S.
asked
Hocking
to
help
them
secure
business
14.
insurance
for
NTM.
Hocking
was
appointed
with
broker
Atlas
General
Insurance
Services
(“Atlas”)
in
15.
November
of
2016.
On
November
17,
2016,
Hocking
submitted
to
Atlas
a
Commercial
Insurance
Application
16.
for
NTM
with
a
proposed
coverage
period
beginning
on
December
1,2016.
Atlas
issued
a
policy
for
NTM
underwritten
by
United
Specialty
Insurance
Company
17.
(“USIC”)
a
subsidiary
of
State
National
Companies
(“SNC”),
with
an
effective
date
of
January
1
1,2017
through
Januaiy
1
1,2018.
NTM’s
initial
down
payment
to
Atlas
for
their
policy
was
$1,358.07,
from
which
18.
Hocking
was
to
keep
$685.38
per
his
commission
contract
with
Atlas
and
then
send
Atlas
the
net
amount
of
$672.69.
On
January
10,
2017,
Consumer
H.G.
wrote
and
delivered
a
check
to
Hocking
made
out
19.
to
Atlas
General
Insurance
Services
for
$1,358.07.
The
memo
line
of
the
check
was
fi
lled
in
as:
“Insurance
Adam
Hocking
and
Associates.”
3
The
check
was
then
deposited
by
Hocking
into
AHA
account
9093
on
January
20,
2017.
20.
Atlas
representative
K.A.
emailed
Hocking
on
February
2,
2017,
and
infomied
him
that
21.
Atlas
still
needed
to
receive
the
down
payment
amount
of
$672.69
by
Februaiy
5,
2017,
or
a
notice
of
cancellation
(“NOC”)
would
be
issued
for
the
policy.
On
February
4,
2017,
Hocking
emailed
K.A.
stating
that,
“The
client
dropped
off
the
22.
payment
to
my
office
late
last
night
but
addressed
the
check
to
my
agency.
So
I
am
writing
you
a
check
from
my
agency
sweep
acct
were
[^■/c]
we
will
be
depositing
the
check
I
hope
that’s
ok?
95
K.A.
replied,
““Adam,
that
is
perfect.
We
actually
prefer
that
so
you
can
retain
your
23.
commission
from
the
insured.
55
Hocking
had
actually
received
the
check
from
NTM
on
January
10,
2017.
The
check
had
24.
been
made
out
to
Atlas
and
Hocking
had
deposited
it
into
his
business
account.
On
or
about
February
5,
2017,
Atlas
received
a
check
from
Hocking
in
the
amount
of
25.
$672.69.
The
check
was
written
from
bank
account
2875
in
the
name
of
ACA
Real
Estate
Inc.,
Adam
Hocking,
C.H.
Atlas
was
unable
to
cash
the
check
because
it
was
written
from
a
bank
account
that
was
26.
closed
in
November
of
2016.
On
February
6,
2017
Hocking
sent
another
email
to
K.A.
stating,
“so
will
you
be
27.
processing
the
check
we
sent
you
or
will
you
be
applying
my
commission
to
the
payment?
55
K.A.
informed
Hocking
that
he
was
supposed
to
retain
his
commission
from
the
payment
28.
he
received
from
NTM
and
then
send
the
rest
to
Atlas.
Hocking
replied
to
K.A.
that
he
did
not
know
he
was
supposed
to
do
this
and
that
he
sent
29.
the
money
he
received
from
NTM
directly
to
Atlas
without
retaining
his
commission.
4
Hocking
emailed
back
and
forth
with
K.A.
claiming
multiple
times
that
he
was
owed
a
30.
commission
check
by
Atlas.
31.
On
February
28,
2020
K.A.
emailed
Hocking
informing
him
that
the
check
Hocking
sent
Atlas
was
written
on
a
closed
account.
K.A.
told
Hocking
he
needed
to
send
the
payment
ASAP”
as
the
policy
was
now
past
due.
On
March
10,
2017
K.A.
sent
another
email
stating,
“Adam,
We
still
need
this
32.
replacement
deposit.
If
we
do
not
receive
the
replacement
by
10:00
am
PST
on
Monday
we
will
have
to
issue
a
NOC.”
On
March
13,
2017
Atlas
sent
Hocking
an
email
stating,
“Adam,
Please
see
the
attached
33.
NOC
(notice
of
cancelation)
that
will
be
sent
to
the
above
insured
due
to
non-payment
of
premium
of
the
replacement
deposit
effective
3/27/2017.
On
March
27,
2017
Atlas
tenninated
NTM’s
policy.
34.
Hocking
never
replied
to
Atlas’s
emails
regarding
cancellation
of
the
policy.
35.
Hocking
never
sent
a
replacement
payment
to
Atlas
to
keep
the
policy
in
force.
36.
Hocking
never
returned
the
$1,358.07
he
received
from
NTM
in
January
2017.
37.
On
February
22,
2019,
NTM
filled
out
and
signed
an
application
for
Garage
Coverage
38.
and
gave
it
to
Hocking.
Hocking
signed
the
application
on
March
1
1,2019
and
then
on
April
1,
2019,
Hocking
submitted
the
application
to
broker.
Burns
&
Wilcox,
requesting
a
quote.
On
April
10,
2019,
quote
number
9309978
was
generated
by
National
Indemnity
39.
Insurance
(“NIC”)
for
a
prospective
policy
for
NTM.
This
quote
document
was
then
emailed
to
Hocking
by
the
Burns
and
Wilcox
agency.
On
April
25,
2019,
Hocking
provided
NTM
an
altered
version
of
the
quote
document
he
40.
received
from
NIC.
5
Hocking
presented
this
altered
document
to
NTM
as
an
active
insurance
policy
and
not
a
41.
quote.
The
numbers
for
the
coverage
and
premium
amounts
were
changed
and
the
word
“quote’
had
been
removed
from
appearing
anywhere
on
the
altered
document,
and
in
the
upper
left
hand
corner
the
word
“policy”
had
been
handwritten
in
ink.
NTM
wrote
him
a
check
for
$5,549.00,
Hocking
deposited
this
check
in
his
agency
42.
account
9101,
on
April
25,
2019.
The
Division
received
documentation
and
communication
from
NIC
as
part
of
the
43.
Division’s
investigation.
NIC
stated
that
NIC
had
received
two
submissions
for
policy
quotes
from
Hocking
in
2019,
one
in
April
and
another
in
October.
Both
applications
were
submitted
through
Bums
&Wilcox.
Both
applications
were
missing
important
infoimation
so
no
policy
was
ever
bound
for
the
client,
NTM.
NIC
continued
that
the
document
Hocking
provided
to
NTM
was
an
altered
version
of
the
quote
that
NIC
had
provided
to
Hocking.
In
June
and
July
of
2019,
NTM
had
multiple
break-ins
resulting
in
the
theft
of
cars
and
44.
property
damage.
NTM
filed
police
reports
in
these
matters
and
went
to
Hocking
to
fi
le
insurance
claims.
Hocking
assured
them
that
he
would
get
these
claims
taken
eare
of
NTM
tried
to
contact
Hocking
multiple
times
through
text
messages,
emails
and
phone
45.
calls
to
inquire
about
the
status
of
their
claims.
Hocking
made
excuses
and
said
he
needed
more
time
and
more
infonuation
to
get
the
elaims
settled.
In
September
2019,
NTM
purchased
a
car
at
auction
in
Illinois.
On
the
trip
back
to
Iowa
46.
with
the
purchased
car,
NTM’s
employee
was
involved
in
a
serious
car
accident.
The
car
NTM
had
purchased
at
auction
was
badly
damaged.
A
police
report
was
fi
led
and
A.S.
attempted
to
fi
le
an
insurance
claim
with
Hocking.
6
Once
again,
Hocking
said
he
would
take
care
of
the
claim.
Hocking
even
provided
A.S.
47.
with
numbers
he
purported
to
be
NIC
claim
numbers.
However,
A.S.
contacted
NIC
and
was
informed
that
the
numbers
Hocking
provided
to
her
were
quote
numbers
and
not
active
claims
numbers.
Hocking
could
not
provide
an
active
policy
to
NTM
and
instead
filed
a
claim
with
his
E
48.
&
O
provider.
On
March
6,
2020, Hocking
sent
NTM
a
check
in
the
amount
of
$5,549.
49.
H.G.
first
came
to
Hocking
as
a
client
in
October
2015
to
purchase
personal
home.
50.
Hocking
obtained
H.G.
a
home
owners
policy
(“HA”)
through
State
Auto
Insurance
51.
(“State
Auto”)
beginning
in
October
2015.
H.G.
renewed
this
policy
on
an
annual
basis
until
September
of
2018
when
he
sold
the
house
the
policy
insured.
H.G.’s
premium
payment
was
set
to
be
paid
annually.
H.G.
paid
Hocking
directly
to
52.
cover
his
annual
HA
premium,
expecting
Hocking
to
send
these
funds
to
State
Auto.
Hocking
changed
H.G.’s
billing
cycle
multiple
times
without
H.G.’s
knowledge
or
53.
authorization.
Hocking
received
a
check
annually
from
H.G.
for
the
HA
policy,
but
rather
than
pay
that
54.
amount
to
State
Auto,
Hocking
deposited
the
funds
into
one
of
his
business
accounts
and
then
paid
State
Auto
installment
payments
based
on
the
new
billing
cycles
he
had
requested.
State
Auto
records
indicate
Hocking
was
often
late
or
short
on
his
payments
for
the
HA
55.
policy
and
that
State
Auto
generated
multiple
notices
of
delinquent
balance
and
notice
of
cancellation.
Hocking
eventually
made
the
payments
so
that
the
policy
never
lapsed
or
cancelled.
but
his
actions
were
not
authorized
or
known
by
the
policy
holder,
H.G.
III.
CONCLUSIONS
OF
LAW
7
COUNT
I
Deceptive
Acts
or
Practices
56.
Iowa
Code
§
507B.3
states
that:
A
person
shall
not
engage
in
this
state
in
any
trade
practice
which
is
defined
in
this
chapter
as,
or
determined
pursuant
to
section
507B.6
to
be,
an
unfair
method
of
competition,
or
an
unfair
or
deceptive
act
or
practice
in
the
business
of
insurance.
Iowa
Code
§
507B.4(3)(a)(I)
defines
unfair
methods
of
competition
and
unfair
or
57.
deceptive
acts
or
practices
in
the
business
of
insurance
to
include
the
misrepresentation
of,
“the
benefits,
advantages,
conditions,
or
terms
of
any
insurance
policy.”
Hocking
presented
Attachment
B
to
NTM
as
a
legitimate
enforceable
insurance
policy
58.
when
no
such
policy
actually
existed.
Hocking
collected
money
from
NTM
based
on
his
misrepresentation
as
to
the
tenns,
59.
conditions,
and
benefits
of
the
insurance
doeument
he
presented.
Hocking
and
AHA’s
acts
and
practices
have
been
in
violation
of
Iowa
Code
§
60.
507B.4(3)(a)(l)
subjecting
Hocking
and
AHA
to
suspension
or
revocation
of
their
insurance
producer
licenses,
to
the
imposition
of
a
civil
penalty,
an
order
requiring
Hocking
and
AHA
to
cease
and
desist
from
engaging
in
such
practices,
the
imposition
of
costs
of
the
investigation
and
prosecution
of
the
matter,
and
any
other
corrective
action
the
Commissioner
deems
necessary
and
appropriate
pursuant
to
Iowa
Code
§§
507B.7
and
505.8.
COUNT
II
Using
Fraudulent,
Coercive,
or
Dishonest
Practices
or
Demonstrating
Incompetence
or
Untrustworthiness
Under
Iowa
Code
§
522B.1
l(l)(h),
a
producer
is
prohibited
from
using
fraudulent.
61.
coercive,
or
dishonest
practices
or
demonstrating
untrustworthin
ess
or
incompetence
in
the
conduct
of
insurance
business.
Hocking
used
fraudulent
and
dishonest
practices
when
he
received
a
premium
check
from
62.
NTM
for
$1,358.07
and
cashed
this
check
into
his
AHA
business
account
and
then
wrote
Atlas
a
check
out
of
a
closed
bank
account.
Hocking
never
remitted
the
$672.69
premium
payment
to
Atlas
even
though
NTM
had
63.
given
him
a
check.
Hocking
demonstrated
tlirther
dishonesty
and
untrustworthiness
when
he
told
Atlas
he
64.
had
sent
them
the
check
his
client
had
given
to
him
directly.
Hocking
had
sent
Atlas
a
check
from
his
own
closed
bank
account.
Hocking
demonstrated
fraudulent
and
dishonest
practices
when
he
repeatedly
asked
Atlas
65.
when
they
would
send
him
his
commission
check,
knowing
full
well
that
he
had
already
deposited
NTM’s
check
for
$1,358.07.
Due
to
Hocking’s
actions.
Atlas
cancelled
NTM’s
policy
in
March
of
2017.
66.
Hocking
demonstrated
dishonesty
when
he
changed
the
billing
cycle
for
H.G.’s
HA
67.
policy
without
H.G.’s
knowledge
or
authorization.
Hocking
and
AHA’s
acts
and
practices
have
been
in
violation
of
Iowa
Code
§
68.
522B.
1
1(1
)(h)
subjecting
Hocking
and
AHA
to
suspension
or
revocation
of
their
insurance
producer
licenses,
to
the
imposition
of
a
civil
penalty,
an
order
requiring
Hocking
and
AHA
to
cease
and
desist
from
engaging
in
such
practices,
the
imposition
of
costs
of
the
investigation
and
prosecution
of
the
matter,
and
any
other
corrective
action
the
Commissioner
deems
necessary
and
appropriate
pursuant
to
Iowa
Code
§§
522B
and
505.8.
IV.
ORDER
WHEREFORE,
IT
IS
ORDERED
pursuant
to
the
powers
granted
to
the
Commissioner
of
Insurance
by
Iowa
Code
chapters
507B,
and
522B;
9
Adam
Hocking’s
Iowa
resident
insurance
producer
license
is
revoked
for
a
term
of
A.
five-years
from
the
date
of
this
Order,
pursuant
to
Iowa
Code
§§
522B.11
and
522B.17.
AHA’s
business
entity
producer
license
is
revoked
for
a
tenn
of
five-years
from
the
B.
date
of
this
Order,
pursuant
to
Iowa
Code
§§
522B.11
and
522B.17.
Respondents,
pursuant
to
Iowa
Code
§§
507B.7
and
522B,
shall
immediately
cease
C.
and
desist
from
engaging
in
the
business
of
insurance
in
the
state
of
Iowa.
Pursuant
to
Iowa
Code
Iowa
Code
§§
507B.7
and
522B:
D.
Respondents
shall
not
seiwice,
advise
or
handle
any
existing
or
future
a.
insurance
contracts;
b.
Respondents
shall
not
receive,
collect,
or
accept
any
payments
related
to
an
insurance
contract
other
than
any
commissions
payments
that
are
due
Respondents
by
an
insurer
pursuant
to
a
contract
agreement
preceding
the
date
of
this
Order;
c.
Respondents
shall
not
communicate
with
any
of
its
existing
insurance
clients
regarding
the
business
of
insurance
unless
done
so
through
Respondents’
counsel.
Respondents
shall
pay
a
civil
penalty
in
the
amount
of
$3,000.00,
which
shall
be
paid
E.
within
30
days
of
this
Order.
Payment
shall
be
made
payable
to
the
Iowa
Insurance
Division,
to
be
credited
to
the
Iowa
Enforcement
Fund
to
provide
funds
for
insurance
enforcement
and
education
pursuant
to
Iowa
Code
§§
505.8,
507B.7.
Respondents
shall
within
30
days
of
this
Order
pay
$55,000.00
to
the
state
of
Iowa
to
be
distributed
to
A.S.
and
H.G.
as
restitution
pursuant
to
Iowa
Code
§
505.8.
F.
10
G.
These
orders
may
be
enforced
under
Iowa
Code
chapters
502,
507B,
and
522B
including
but
not
limited
to
Iowa
Code
§§
507B.8
and
522B.17(3),
and
additionally,
by
any
collection
remedies
available
to
the
State
of
Iowa
Department
of
Revenue
for
unpaid
penalties
and
other
ordered
monetary
amount.
day
of
,
2020.
SO
ORDERED
on
the
DOUGLAS
M.
OMMEN
Iowa
Insurance
Commissioner
Respectfully
submitted,
/s/Adam
J.
Kenworthy
Adam
J.
Kenworthy
Compliance
Attorney
1963
Bell
Avenue,
Suite
100
Des
Moines,
Iowa
50315
515-654-6562
Attorney
for
Iowa
Insurance
Division
Email
Copy
to;
Holly
Logan
Respondent’s
Attorney
11
9th
October
CERTIFICATE
OF
SERVICE
The
undersigned
certifies
that
the
foregoing
instrument
was
served
upon
all
parties
to
the
above
cause,
or
their
attorney,
at
their
respective
addresses
disclosed
on
the
pleadings
on
,
2020.
(
)
Personal
Service
(
)
Restricted
certified
mail,
retiim
receipt
(
)
Email,
by
consent
(
)
Certified
mail,
return
receipt
(
)
By:
( )
First
Class
Mail
Signature:
Hilaiy
Foster
NOTICE
OF
PENALTIES
FOR
WILLFUL
VIOLATION
OF
THIS
ORDER
YOU
ARE
NOTIFIED
that
acting
as
an
insurance
producer,
as
defined
in
Iowa
Code
chapter
522B,
in
violation
of
this
Order,
is
a
felony
under
Iowa
Code
§
507A.
10,
subjecting
you
to
punishment
of
imprisonment,
jail,
fi
nes,
or
any
combination
of
custody
and
fi
nes.
YOU
ARE
ALSO
NOTIFIED
that
if
you
violate
this
Order,
you
may
be
subject
to
administrative
and
civil
penalties
pursuant
to
Iowa
Code
§
522B.17(3).
The
Commissioner
may
petition
the
district
court
to
hold
a
hearing
to
enforce
the
order
as
eertified
by
the
Commissioner.
The
district
court
may
assess
a
civil
penalty
against
you
in
an
amount
not
less
than
three
thousand
dollars
but
not
greater
than
ten
thousand
dollars
for
each
violation,
and
may
issue
further
orders
as
it
deems
appropriate.
NOTICE
OF
FINAL
ORDER
IMPACT
A
fi
nal
order
of
license
revocation
or
a
cease
and
desist
order
may
adversely
affect
other
existing
business
or
professional
licenses
and
may
result
in
license
revocation
or
disciplinaiy
action.
A
fi
nal
order
in
an
administrative
action
does
not
resolve
any
potential
criminal
or
civil
violations
or
causes
of
action
that
might
arise
from
the
same
or
similar
conduct
that
is
the
subject
of
this
this
order.
It
may
result
in
criminal
law
enforcement
authorities,
including
the
fraud
bureau
of
the
Iowa
Insurance
Division,
pursuing
a
criminal
investigation
or
prosecution
of
potential
criminal
law
violations.
12
October 9
X
/s/ Hilary Foster
CONSENT
TO
ORDER
AND
AGREEMENT
I,
Adam
Hocking,
individually
and
as
agent
of
business
entity,
Adam
Hocking
&
Associates
II
Inc.,
have
read,
understood,
and
do
knowingly
consent
to
this
Order
in
its
entirety.
By
executing
this
Consent,
I
understand
that
I
am
waiving
my
rights
to
a
hearing,
to
confront
and
cross-examine
witnesses,
to
produce
evidence,
and
to
judicial
review.
I
further
understand
this
Order
is
considered
a
fi
nal administrative
action
that
will
be
reported
by
the
Division
to
the
National
Association
of
Insurance
Commissioners
and
to
other
regulatory
agencies.
I
also
understand
this
Order
is
a
public
record
under
Iowa
Code
chapter
22
and
information
may
be
shared
with
other
regulatory
authorities
or
governmental
agencies,
pursuant
to
Iowa
Code
§
505.8(8)(d).
I
also
understand
this
Order
will
be
posted
to
the
Division’s
website
and
a
notation
will
be
made
to
the
publicly
available
website
record
that
administrative
action
has
been
taken
against
me.
.
lt>'C
o
Dated:
Adam
Hocldjjg;
Respondent
Adam
Hocking
&
Assoc.
II
Inc.,
Respondent
BY:
TITLE:
Uji
Address
of
Signatory
Subscribed
and
sworn
before
me
by
Adam
Hocking
on
this
day
ofOd-nl^/C
2020.
9
/
m
Notary
Public
fQj/tije
State
of
Iowa
AMBER
S
LESNICK
p
COMMISSION
NUMBER
794358
MYC
OMMISSION
EXPIRES
o
z
/ow^
13
