SCRA Compliance

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Find John Doe

Compliance, Compliance, Compliance

2012 set the stage for 2013, and while everything is important in successfully running your business, nothing is more important than staying on top of compliance in our industry. We saw the CFPB start to come in to our industry in 2012, and it has definitely set the tone for what all skip, repo and forwarding companies need to prioritize in 2013. It's also sent a shiver down the spine of the nations largest lenders, as not all their vendors are as compliant as they can be, or as the lenders need them to be. For this reason we've seen lenders closely auditing their vendors, and we've seen some lenders actually cutting off some "productive" vendors, and some lenders have brought previously outsourced work back in house in fear of what their vendors could be doing. They're also recognizing the difficulty they have in staying on top of what their vendors are actually doing with their accounts. When we started Skipbusters in 1988, we didn't need to have any policy or security manuals. When we sold the company in 1999, we had company handbooks for HR, and procedural manuals to insure we were in observance of all relevant laws regarding skip tracing. When we started FJD in 2007, we had a company handbook covering all HR related issues, a detailed business plan, security, and network security diagrams to insure the protection of our employees, our clients and their information, and our clients customers and their information. We also developed detailed manuals and training and testing in regard to how we operated in relation to the state and federal laws surrounding skip tracing and compliance management. I was never audited by a client at Skipbusters, and we're now audited about once a month at FJD. We went through a six hour, in house, detailed audit with one of the largest Credit Unions in the US this past week. In addition to that, we had dozens of hours of answering hundreds of questions and providing documentation in advance of the auditors arrival. We now have a full time compliance and a full time security person who keeps us up to date, and in compliance in all areas. We have everything from Physical Security detailed plans to Pandemic Emergency plans and documented testing plans to prove we are covered in the case of a Pandemic emergency. Seriously. Last year, we were not only audited by at least a dozen large lenders, but we also were audited on our software side by all three credit bureau's and several of the largest data providers in the country. The good news is we passed every one of these. The challenge is operating a profitable business under this type of compliance and regulatory scrutiny. The other challenge is not everyone understands the skip tracing industry as we're not repossessing, we have no field employees and we are not collecting debts. With that said, we still train and test our staff to follow most FDCPA type laws as they just fall under what best practices we should be following anyway, i.e.: 1. Don't repeatedly call people 2. Don't disclose personal information to 3rd parties 3. Don't use threats, profanity, don't be rude, etc. and the list goes on and on... In the end, its a good thing as I am a consumer just like you, and I hate it when I am bothered or harassed by someone on the phone, or in person. As a knowledgeable person regarding the laws surrounding contact management and collection, skip tracing and repossession, I do my best to insure that our staff understands the policies and procedures we train them on. In the end we are all human, and mistakes can happen, but what everyone wants to avoid are intentional mistakes, or downright flagrant violations of laws. If a mistake is made, find out what happened and correct it so the same mistake doesn't happen again. When you run a skip company, etc. you will occasionally have an employee who makes a mistake, and when that happens, make sure it was not intentional and if it was, act quickly and terminate them, and use that as a message and lesson to your other staff members. If you are a client, insure your vendors are honest, reputable, stable, and most importantly, that they understand your needs in the eyes of the CFPB and other regulatory agencies, as we are now operating in an arena where all lenders are 100% responsible for their vendors actions.

NARS 2012

I attended NARS this past week and found it to be very informative, and a great opportunity to meet old and new friends, to do some business, and to stay informed about our industry. I'll be better prepared next year so I can attend more of the discussions as the one's I saw were well organized and informative. Great job by Les and the ARA and the article below by Kevin Armstrong really says it all. See you at NARS 2013! http://blog.cucollector.com/hot-topics/nars-2012-a-huge-success/?utm_source=CU+Collector.com+Subscriber+List&utm_campaign=a0ec5dbbc1-3_30_12_Newsletter&utm_medium=email NARS 2012 A Huge Success! Las Colinas, TX – March 27, 2012 – If you weren’t at this years North American Repossessors Summit (NARS) held at the Omni Mandalay in Dallas, you missed without a doubt, the most important meeting regarding the future of the repossessions industry that’s been held to date. With over 500 Repossession company owners, employees and vendors, this was probably the largest meeting in the industries history. This massive attendance can be largely attributed to the tumultuous times the industry has been going through and this years NARS delivered with some lively and timely debate and conversations from industry leaders addressing many of the important issues facing the industry today. The two day seminar was highlighted by two separate sessions with a panel of industry leaders. Representing their respective associations were Mary Jane Hogan (ARA), George Badeen (AFA), Patrick Altes (TFA), Ed Marcum (RSIG) and Jennifer McDaniels (NFA). They appeared before an energetic audience armed with some pointed questions. The session was moderated by Auto Sales Trade Association leader Jack Tracy, with an open question and answer period on the topics of “Acting on the Challenges of Our Industry – From Talk to Action” on Friday and “What Should You Expect from An Association or Industry Organization?” which was conducted on Saturday. Starting Friday afternoon, after introductions, was the “Technology Innovations and Opportunities” panel that focused on ALPR and remarketing, which featured Zach Hollowell, Business Line Director of OPENLANE, Rick O’Connor, Director of Remarketing of Sales of SMARTAUCTION, Kyle Kolsky, VP Marketing and Brand Management of LEAP Auto Loans, Inc. and Chris Metaxas, CEO of DRN. Each explained their market edge and shared some conflicting views on several points. Zach Hollowell of OPENLANE and Rick O’Connor of SMARTAUCTION disagreed on whether or not online auctions have truly gained acceptance in the industry, while Scott Jackson of MVTRAC spoke of the virtues lenders expanding of ALPR on portfolios before assignment for repossession. Some of the attendees laughed out loud when Chris Metaxas, CEO of DRN apologetically stated “I don’t think we’ve done a very good communicating with our affiliates.” Ed Marcum of RSIG followed by Joe Taylor, VP and Stamatis Ferarolis, President of RISC spoke of the critical contributions their respective companies play in compliance and education play in the industry in their session “RISC/RSIG: Why it’s Critical to Your Business”. There was a private meeting for DRN Members held before finally breaking out for the evenings cocktail party hosted by DRN and finishing for the day. Did you go to NARS? If so, please take this survey If not, Why? Please take this survey On Saturday morning, Keynote speaker Mike Goins, Head of Deficiency Recovery for TD Auto Finance made a presentation to the industry called “Déjà vu, is this the Future?” and presenting “Direct Forwarding and Facilitation Models; Know, Understand. Educate and Adapt” was a panel consisting of Steve Norwood, President & CEO of Consolidated Asset Recovery Systems, Inc.; Scott Jackson, CEO of MVRECOVERY and Debra Durham, owner of Midwest Adjusters, Inc. who discussed the many issues both good and bad about the forwarding industry. A panel of industry professionals like Michael Eusebio, Owner of Digital Dog Auto Recovery and Premier Recovery Service and (CA), Clark Thomas, PHD of Texas Hide and Seek Recovery (TX), Dave Kennedy, owner and CEO of First Credit Resources, Inc. and John Lewis, founder of MasterQueue and Find John Doe provided their views on survivability and profitability in these profit thin times called “Additional Revenue Opportunities”. Each spoke of cross selling opportunities existing in additional services as well as the importance of understanding exactly what it costs to repo a car for agency owners. After a great lunch hosted by OPENLANE, Attorney Michael Dougherty presented, what I felt was one of the more illuminating sessions of the seminar regarding the industries future expectations of the Consumer Financial Protection Bureau called, “The Consumer Financial Protection Bureau (CFPB) – Is It a Legal Minefield.” With the rumor of clandestine attendance of one or more persons from this Federal Bureau, it highlighted the important role that this bureau may play in shaping the future of the repossession industry. While largely feared the industry might be regulated or licensed by the bureau, Mr. Dougherty reported that a source close to the CFPB advised him that the focus would be on education, certification and compliance from the industry, which would be enforced through more stringent due diligence requirements placed on the lenders creating a need for the industry to follow suit. Aside from the superior speakers and information provided, the networking and catching up with friends old and new was worth the trip to Texas alone. The 2012 NARS transcended being an association event, it was a true gathering of the industry. While not everyone agrees with each other on exactly how to accomplish it, industry unity is alive and growing. Every year the event gets bigger and every year it continues to improve. If you’ve never been to NARS or had once before, be sure not to miss the NARS 2013. Whether you are a lender, collector or repossession industry professional, you owe it to yourself to participate.

The FEDS laid down the gauntlet

The FEDS have laid down the gauntlet, and its about time. Owning a skip company can be risky business if you don't insure your employees are in compliance at all times. This means not only the obvious things, like...no pretexting, no breaking phone numbers, no threatening people, no harassment, no profanity, etc. This also means the things that have not been as obvious, and things I've never seen a client audit, but given the statement below, the lenders will likely start rethinking If you don't have software that monitors compliance, specifically the compliance of your employees and your vendors as it relates to how they communicate with the public, you will likely squirm a bit, or a lot, when the FED walks in your office and asks you to open up your Kimono. Many software's claim to monitor compliance, but if that software is not also your workflow software, how can it tell you when a call was placed to a person who the law says cant be called, how do you know what your people are doing when you let them go to Facebook, how do you really know what your vendor is doing if you cant fully audit their actions as you are not familiar with the software they work in so you have to take them at face value when they deny they did what your customer has accused them of doing. masterQueue addresses these areas and many more, and given what the Chief said yesterday, if my employees or my vendors were operating out of compliance, I'd be looking for a solution in a pro active manner instead of waiting for the FED to walk through my front door. Consumer Financial Protection Bureau Chief Richard Codray stated yesterday: "Through our supervision team, we examine non bank providers of consumer financial products and services, many of them for the first time at the federal level. The enforcement team that I helped build can commence actions against market players who cheat consumers – and their competitors – by not following federal consumer financial laws. GOOD- and he did this last year by filing the largest suits against illegal debt collection activity in the history of the FED - and they got multi-million dollar judgments in every case. "Those who follow the law are placed at a competitive disadvantage in contrast to those who do not, and their reputations are harmed when they are lumped in with their competitors who engage in illegal activities. OMG- this is like when the State of Calif started licensing repossession activity, eventually putting an end to large scale illegal repossession activity. It's tough to compete when you know your competitors are not playing by the rules, but you dont want to rat them out as you'll sound like a whiner, but when you fire people for breaking the rules, or worse breaking the law, and they all end up at your competitors shop, you know they likely haven't changed their bad habits, but you wonder why doesn't the client seem to care? We'll maybe the client doesn't care, but now the FED seems to care. Good for the FED. Codray continues..."Our goal is to help the honest debt collectors do their jobs responsibly and see that the rest are either rehabilitated or run out of business once and for all. When this proposed rule becomes final, our supervision authority will then allow us to go on-site with debt collectors, examine their operations from the inside, and determine whether a collector is complying with the law. We will set forth our expectations through public examination procedures, encourage robust compliance programs, communicate expectations confidentially to the entity throughout the examination and rating process, and ensure appropriate corrective action where necessary. These supervisory efforts would cover more than 60 percent of market activities. By comprehensively assessing large collectors, as well as many of the bank creditors who originate the debt, supervision would allow us to understand and address the systemic problems posing risks to consumers. By proactive coordination among federal and state law enforcement, we can help Americans dig themselves out of the residue of this financial crisis, without being plagued by the indignity of illegal debt collection tactics." Good job to whomever set this agency up.

HEADLINE RISK 2012

As we enter 2012, it still amazes me that companies are not moving faster to mitigate HEADLINE RISK. HEADLINE RISK? It’s the risk that a major event or story will spread throughout various media publications, and will negatively impact a company’s stock. The risk is due to the harmful nature of the story, even if the news is not justifiable. • CEO OF XXX Bank resigns after vendor loses laptop with two million customers social security numbers. “I take full responsibility” says John Doe of XXX Bank. I should have: 1. Paid more attention to my Risk and Security teams 2. Hired better people to manage my Risk and Security teams 3. Asked tougher questions so our customers identities were always protected to the best of our ability 4. Hired better vendor managers to audit our vendors. They made the audit trips, but in hindsight, (after seeing the pictures of them golfing and partying on Facebook) I may need auditors to audit my auditors in 2012. When I started Find John Doe in 2007, I spent Ten Grand to have Fulbright & Jaworski give me a legal opinion in writing on what I could and couldn’t do when it came to skip tracing. I started the first skip company in 1998, and ten years later, I knew the rules had changed, and so had the www dot playing field dot com, so I figured I’d lawyer up and get an opinion. As we enter 2012, it amazes me the now obvious things I was told then that I couldn’t do are still common occurrences by companies that range from Large First Party Lenders, to their Servicers, and mostly, by the vendors whom the large, medium and small lenders hire. Why don’t the lenders pay more attention to the HEADLINE RISK they face? • No “PHONE BREAKS”, as now the person requesting it is just as liable as the person providing the info, thanks to Private Investigators hired in 2006 by Hewlett Packard leaking details to the media about how they allegedly were hired by the Chairwoman of the Board of HP to access the phone records of the other Board members and Nine Analysts who covered the company. After Congressional Hearings and President Bush Signing the Telephone Records and Privacy Protection Act of 2006, hiring companies to break phone numbers is just as illegal for the person doing the “break” as it is for the collector, or his boss, who authorized it; wink…wink. • No “UTILITY BREAKS”. Yes Mister CEO, your collectors still do request this information brokers who illegally access the utility records of public and private utility companies to see if your customer still lives at the last known address. This should make every CEO, VP of Operations, Risk Manager and anyone accountable for the protection of their company to ask and INSURE their company, or the companies they hire are not doing this, or THEY might be the one the DA goes after and puts in jail, and it’s a ten year sentence, BTW. This leads to the obvious question…Is your Collection Supervisor or those accountable really on top of Privacy, Risk and Security when it comes to how you manage risk and how you work your higher risk accounts? As we hit 2012, those still breaking phone numbers have significant issues, but ladies and gentlemen, the bar has been lowered, and if you are not in the fire yet, get ready, because it’s scary, and it should be as there are bad people out there and they will mess with you, AND YOUR CUSTOMERS, if you give them the opportunity. Ask yourself, and your staff some questions, but don’t take the answers at face value. Do some in depth auditing and find out the real answers, and make sure your auditor is craftier than the skip tracers, repossessors, collectors, collection supervisors, risk managers, operations managers etc. are, or better yet, promote your best skip tracer to the Risk audit team. Some other questions to ask within your organization are : Do you still access public records data on your customers via web-based sites? YES,…Oops. That’s Old school….and a huge RISK. Do you have printers, or worse, can these documents be stored and downloaded en mass on a zip drive, or emailed, and if they are emailed, do you even know what your new employee is emailing from their CPU? These reports are accessed through the data providers web site and they come in the form of a .pdf report that can be fifty pages long. It’s a challenge to read a fifty-page document on a 15” screen, so many times I see these reports printed and sitting on people’s desks, or in a “file” in their drawer. A file is a large envelope that is used to hold papers, its what people used to use in business back before there were paperless requirements put in place by the companies who avoid headline risk like the plague. Walk on your collection floor and if you see papers, you have issues. Are you tracking everything your staff is doing during the collection process? Are you auditing your vendors who do collections, skip tracing and repossession? Oh Really, good for you. How often do you visit them? Quarterly, Annually, Semi-Annually? Is it dinner and drinks, or an actual audit? How in depth is the audit? Is it a surprise, or planned with a list of what they want so it’s “easy on everyone”? I hear one of my competitors down the street knows when the audit is coming and they hire temps to make them look like a bigger company than they are to help convince the large lender they can handle their business. Would your auditors catch that? Apparently not, as they keep growing. How detailed is the audit? How do you dig to find out what they really do? Do you use vendor managers or auditors, or should you use a skip tracer or at least bring one along? What web sites do they visit? Oh, you let them access Facebook, cool. That’s a great site to get info from people who don’t protect their privacy. What about the people who mark their Facebook pages private. Do you let your employees or Vendors “Friend” people? Of course not ! Really, how do you know? Well… How do you REALLY know? Ok, let me be frank….if your people have access to Facebook and if you have no record of what they’re doing, you have …. MAJOR HEADLINE RISK. Google “Facebook Collection Agency Lawsuit” to see what I mean, lots of HEADLINE RISK opportunities here. You may still subscribe to the “old school theory” of what goes in the TOP SLOT and comes out the BOTTOM SLOT is OK, as long as “I don’t know what happened in between”. OLD SCHOOL. The Telephone Records and Privacy Protection Act says you are not only responsible to know what is happening, you also can spend TEN YEARS in the slammer if you are accountable, but if I’m a CEO of XXX Bank, I can care less about the Three Years my Ops Mgr got in the pokey, because I just lost my job because I didn’t know what was going on. How do they “Friend” people on Facebook? They log in with an account they created that is only used for finding people. Oh, you didn’t think they would do that cause you told them they might get fired? Are you giving them a bonus if they find more people? Are you in a city where there are more jobs for collectors than there are collectors? If you fire them will your HR department tell the company calling for a reference that they got you in a class action lawsuit over Friending hundreds of people on Facebook and then repossessing their cars, hammering them for payments, posting on their walls and embarrassing them? If they’re looking for a guy, your collector will have a site with a hot chick’s picture, and if it’s a chick they’re looking for, it’s a photo of some dude with a six pack; abs not beer, well, maybe beer. Chances are there are a lot of “friends” on each page who have already been repossessed, or know someone who got repossessed. Class Action. In my next blog I’ll talk about Repossession and the HEADLINE RISKS here as this is even worse as the stakes go up, and so do the lawsuit settlement amounts and HEADLINE RISK potential as people get killed, customers and repossessors.

Don't shoot the Messenger

OK, first off, don't shoot the messenger. In the early 90s, Forwarding wasn't even a word in our industry. Art’s points, and the logic behind starting Relliance are both spot on, in my opinion, but first, let me digress… Manheim Auctions had tried to manage the repossession process in about 1990-91 and after 1-2 years of "getting our lunch handed to us" as an Executive later told me, they had exited the process of trying to manage the repossession process to drive more cars to their auction. To my knowledge, no one else was doing this “Forwarding” practice at the time. A few sharp repo guys may have been doing one off deals with clients who trusted them, but it certainly wasn’t an industry on anyone's radar as is the case today. To understand how it got to where it is today, lets back peddle a minute. In 1988 we had started one of, if not the first skip tracing companies in our industry; Skipbusters. In doing so, we first repo'd our own cars in LA through a repo company I also co-owned called Crown. As we got locates out of our area, we subbed out the work to companies I had known through my prior experience as a Collection Manager at Chrysler Credit. After Skipbusters grew, one of our clients, VW Credit, asked if we could help them manage the nationwide repossession process they were struggling with. Between the time we started Skipbusters and when VW came on, we learned a few valuable lessons. First, you have to find qualified agents and not just the cheapest one’s. They had to be able to understand, sign and stick to the terms of a contract, and they had to be held accountable. You also needed a back up in case something went wrong. You also had to give them a healthy volume of work, they had to be able to make money, and it was a two-way relationship. VW of America in the 70's and 80's didn't have any employees as they hired Chrysler to make and collect loans for them, same as American Motors and Jeep did. Kind of like how Mitsubishi Acceptance (who I worked for later, not sure the exact name of their finance company now) does with a servicer they hire to represent them these days. Anyway, VW decided to start their own finance company after they switched from Chrysler to Deutsch Bank (wonder why they picked a German Bank?) and then realized they were no better with Deutsche than they had been with Chrysler, so then in the early 90s they hired their own employees and created VW credit, their own captive finance company. Through all this transition, Skipbusters was VW's sole skip vendor, and when they kept calling us to ask what repo agency to use in XXX city. We then worked with their Sr management (RIP George, miss ya!) and we created American Recovery Service to manage the repo process for them for a flat $75 per assignment. Before starting ARS, I called Manheim as I knew they had exited the repossession management business, and the guy gave me one word of advise..."RUN". We started ARS in late 1993 and soon after this the sub prime auto finance industry took off, and so did ARS, and Skipbusters. We sold and exited the industry in 1999, just as the word "Forwarding" was becoming a common term in repossession management. The auctions, including Manheim, had jumped back in, as did many other private companies. By the time my non compete expired and I took another look at our industry in 2004, it had changed dramatically. When we started Skipbusters in 1988, not one of the top 20 lenders utilized an outside firm to skip trace their accounts, except for their trusted repo agency whom they were willing to pay a $75 skip fee to. When we built the "Forwarding" model around VW's needs, other lenders who now use forwarders laughed at us, "You want to manage our repossession assignments? That's what we do, and we'd never outsource that responsibility to anyone!!". As lenders consolidated to large call centers, and the national management of repossession vendors and the work they did became more complex than they envisioned, Forwarding took off, as did skip tracing. Now it's almost 2012 and a great deal of large lenders now use Forwarders, and all large lenders use skip companies, so I guess we had a couple good ideas in one sense, but in another, I agree that it has been treated as a commodity and somehow the value of the service has become greatly overlooked, as pointed out in Relliance’s press release. The logic behind the formation of a Forwarding company by Repossession Agencies is a good idea in my opinion, but ONLY if they measure themselves in an agnostic manner against other companies in their service areas. I'm not saying every repo agency deserves a shot at being in Relliance, but if Relliance truly wants to be the best Forwarding company and improve the industry, I believe they, as well as any solid forwarding model, must accept applications from companies who wish to do work for them at a fair price, and the companies who do the best work should earn the lions share of the work from the lenders who hire them. If not, it would just be another association, which does not solve the problems our industry is seeing, from a repo agency and a lenders perspective. For the past five years we have been building a software called masterQueue. Some of you use a limited version of it, some have heard of it, some haven't. This is a collection, skip tracing and repossession assignment management software for Lenders, Forwarders, Skip Companies, Repo companies through interfaces with their Repossession Agency platform, and a variety of other companies associated with our industry. It's a common ground, and one of the most important things it does is show the lenders and Forwarders/Skip Companies who is doing a good job, who is driving ROI to the lenders bottom line, and who isn't, and who is in compliance with the lenders growing list of requirements and who is putting them at risk. It's not a model that's built around charging repo agencies to receive assignments, and we are open to interface with any software, as we have already done with iRepo/RePros and several other platforms, and are starting to do with lenders software platforms. What made us successful at Skipbusters and ARS back when I owned those companies is we were able to leverage technology to improve our client’s business needs. With this in mind, we created masterQueue. I believe the technology in our industry, with a few exceptions, but for the most part, is years behind the times. masterQueue helps bring it up to speed, and it provides lenders a way to see the dollar value that the repo companies who service their accounts can earn them, or cost them when they aren’t doing the job. It also gives them a way to stay compliant to help insure they keep their customers safe, and their names out of the paper, which as we all know is their foremost concern. The reason I bring up masterQueue is without a common software platform, one that really solves all of the needs for Lenders to identify actual performance and compliance, our industry will continue to struggle in my opinion, especially as it relates to working the difficult accounts. masterQueue gives everyone a fair shot at earning business because they are the best at what they do, not because they took someone to the Super Bowl or have a hot looking sales rep. A lender shouldnt care about PRICE, they should worry about COST, which is measured in Full balance skip charge offs, missed opportunities, poor performance and things no software I've seen to date does, except masterQueue.Sorry to sound like a commercial, but you don't see us doing press releases, or even attending many trade shows, but you will see us in forums like this, and hopefully you're hearing about us by word of mouth, from people who understand our industry and whose word you trust. With a little bit of luck and some good code, I think we can help bring Forwarding back to where we envisioned it could be when we first started doing it in the early 90s. Everyone be safe out there, and value your repo agents, the job they do should never be underestimated or treated as anything less than a skilled art, unless you're dealing with some company who doesnt deserve that respect, and if so, your software should be telling you that's an issue before it becomes a problem!

Is it just me?

Has the Auto Finance Skip Tracing business gone the way of the Auto Repo business?

It's brutal out there.

We always relied on Lenders making bad loans and then not doing a very good job on finding their skips, but that's changed. The gravy is gone.

Skip Companies- If you are not working in an environment where you can measure and manage your business every minute of every day, you can fail. If you fail, your clients fail, but I guess that doesn't really matter to you cause you failed.

Are Lenders looking as closely as they can at what Skip companies they hire; I doubt it. Can their Skip Companies go toes up, damn straight they can, and trust me, they will.

Attn Lenders: Please start lending money, and please start taking some risk, and please take a closer look at who you do business with. If your Skip Company has lost four of its five biggest clients in the past few months, there is a problem. If you google your skip companies name followed by the word "LAWSUIT" and there is more than one page of results, you are a sitting duck.

C'mon, there are people out there who need loans and you are all overstaffed and you can handle it. You may need masterQueue to help organize your collection department, but you know your people's Queue sizes are way down, and you have the people to handle the deals, so dont wait for the paper buyers to tell you its coming, force the issue, tell them you can handle it.

Of course, come of those skips will fall through the cracks, but you will make so much off the deals that pay you know that it wont matter, and our industry needs some bread crumbs.

EVERYONE will win.