€¦ · Web viewBroadcasting live from the Pro Business Channel studios in Atlanta, Georgia, it's time for Capital Club Radio brought to you by FLOCK Specialty Finance

michael_bernstein_founder_meb_finance_interviewed_on_capital_club_radio

11/03/17 Page 2 of 14

Broadcasting live from the Pro Business Channel studios in Atlanta, Georgia, it's time for Capital Club Radio brought to you by FLOCK Specialty Finance. Please welcome your host Chairman and CEO, Michael Flock.

00:25 Michael Flock: Good afternoon and welcome to Capital Club Radio. We are absolutely delighted today to have a special guest who has almost two decades of experience in the debtbuying industry. Michael Bernstein is the founder emeritus and former CEO of CMAX. He foundedCMAX as a debt buyer in 2001 and became one of the leading debt buyers by 2005 when his company generated $60 million of revenue. Following the crash in 2008, however, he decided toexit the debt buying business and transformed CMAX into a lender to small and middle market debt buyers. He then sold the majority of his interest in 2010 to JH Capital and Metropolitan Equity Partners in order to increase his capital base and infrastructure.

01:18 MF: In 2017, he sold the remaining interest in CMAX to JH Capital. During his leadership at CMAX, he processed more than $350 million in loan volume. And he recently formed his... new company, his own company, MEB Financial solutions, and signed an exclusive distribution agreement with FLOCK Specialty Finance, our company. And we're excited about our future together and having one of the industry's leading financial experts and deal makers. So Michael, how did you get into debt buying? I know when you graduated from Georgetown you got into the mortgage industry and I think you had a small business there that was very successful.

02:04 Michael Bernstein: That's correct. I graduated from Georgetown in 1995 and in the mid to late '90s I acquired several mortgage companies as part of a rollup strategy. We acquired both the servicing assets, as well as, the origination platforms of these companies. We typically would sell off the origination platform and focus more on the servicing assets. The concept there was to... On the servicing side, it was to build a servicing, mortgage servicing portfolio, mostly Fannie Mae, Ginnie Mae, Freddie Mac portfolio, but we would sell off... Once we acquired these servicing assets, we would then stratify them, sell off the assets that had a higher market value than intrinsic value, reap some profit on those trades and then we were left with assets that had stronger cash flow than market value. So, we were left with those mortgage assets at little to no cost basis.

03:07 MB: So, built up a couple of billion dollar portfolios in the late 1990s, early 2000s, and then sold that off to one of the major mortgage servicing companies. As part of the... One of the acquisitions in the mortgage space, we acquired a company that specialized in defaulted second mortgages and that was really my introduction into the charge off or defaulted consumer debt market. And so, we... As part of that second mortgage operation, we then acquired some other defaulted second mortgage portfolios. We did very well in terms of the recoveries relative to the purchase price we paid. So that's really my entry into the charged off debt industry.

03:56 MF: So it's defaulted second mortgages that was the bridge to debt buying?


11/03/17 Page 3 of 14

04:00 MB: It was a bridge to debt buying, that's correct.

04:02 MF: Charged off consumer debt portfolios?

04:03 MB: That's correct. And then from there we realized that there were other asset classes within the charged off space such as credit card, which was the primary focus of Credit Max when it was a debt buyer. So, in 2001, myself and my former business partner, we developed a businessmodel to acquire charged off credit card debt at the time direct from issuer. And the business modelwas to outsource the collections to a network of collection agencies rather than build an internal infrastructure. So, we built out the collection network and then part of the model was after a certain period of time we would recall the accounts that did not perform and then we would place them on an online trading platform that we built.

04:53 MB: So, the model, I think, worked very well, it was very unique I think to the market place because part of the collection model is we looked at... It was more of an incentive based model in that, even though the collectors that were collecting these accounts were not employees of Credit Max, they were employees of the agencies that we contracted with, we would provide bonuses to those specific collectors. We would identify which accounts would be placed with each collector based on the debtor attributes as well as the collector attributes, we'd try to match up as best as we could.

05:30 MB: And then we would also... So, we would then provide the collector with specific bonus programs where they could make significant bonuses from us, and this was from Credit Max at that time. This was over and above their normal compensation from the agency. So, what happened is we would attract the best performing collectors at those agencies, and even though our collection expense may have been higher than our competitors, our liquidation rates were maturely higher.

06:00 MF: And so that offset in the increase in the compensation incentives.

06:02 MB: That's correct.

06:05 MF: Now when you were in the mortgage industry, did you also outsource all the servicing there or did you have your own internal servicing?

06:12 MB: The companies we acquired had their own servicing. We should have probably consolidated some of that, but it was really... They were left as stand-alone initially. And that was initially. And then we actually wound up using a subservicer to service.

06:25 MF: So, it was mixed then?

06:26 MB: It was mixed. But we came to the realization that it made more sense obviously to...

06:33 MF: To outsource?


11/03/17 Page 4 of 14

06:34 MB: To outsource. So, we used a subservicer in New Jersey at the time that serviced all the mortgage loans.

06:39 MF: It made more sense because there was less investment on your part to own directly the servicers, is that why?

06:47 MB: Yes, so basically we would acquire these companies that had these servicing assets and when we took over the portfolios, rather than keep each of the operations open and operating, which obviously would be expensive, we just would... We had one major... One main subservicer that we used that would subservice all the mortgages for us.

07:08 MF: Okay.

07:08 MB: As opposed to having many stand-alone type...

07:11 MF: Right, right, right.

07:12 MB: Companies. So, we just thought it made more economic sense.

07:17 MF: So, then it wasn't really a giant departure from your original business to outsource the collections?

07:24 MB: Correct.

07:24 MF: So, you had some experience doing that, it wasn't...

07:27 MB: That's correct. And we also had looked at... We did an in-depth analysis at the time whether it made more sense to outsource collections versus doing it internally. The problem with internal operations is that you're in a way forced to purchase paper... You may over pay in certain situations for paper in order to feed the operation. So, we just felt that by outsourcing and with this model that we had in place where we would actually incentivize the collectors in a way they... Even though they were not really employees of ours, it was almost like we bought those collectors, or those agencies without really paying for them. Because they were dedicated to our paper, they wanted to be on our paper since we were compensating them more than what other companies would pay.

08:12 MF: So that was your competitive advantage?

08:14 MB: Correct. That's...

08:15 MF: Part of your secret sauce...

08:16 MB: Absolutely.

08:16 MF: Differentiation.


11/03/17 Page 5 of 14

08:18 MB:Yes, it was really... I'd say the two functions, one was obviously that incentive bonus structure with the collectors and secondly, we had this placement model that we would look at the debtor attributes and the collector attributes, as well as, try to pair them up as best as possible. For example, you may find that a Texas male collector, 25 to 32 years old may be able to collect better from a Texas debtor, hypothetically. A male Texas debtor. It's interesting because I remember when we started outsourcing at the time, I must have met with 50 different agencies and we finally used about five to seven agencies. But when we met with the collectors they would tell you... Certain collectors felt more comfortable collecting whether it's certain balances whether it was from a male versus female, whether it was from a certain geographic area.

09:10 MB: So, we said, why are we giving accounts to... again hypothetically, a Texas collector... If a Texas collector is telling us, a specific collector saying, "Well, I'd rather collect balances under$5,000," then give an explanation as to why they collect better on those accounts. And they're reallynot touching or trying to collect the accounts over that, then why place accounts... Normally, what happens in an agency is they randomly assign the accounts. So here, it was more in this placement model, we would identify the strengths of the collector and again try to pair them up with which accounts they felt most comfortable collecting. And they actually did perform much better on.

09:47 MF: So, you really then were then quite... I don't know if it was strategic, but operationally, you aligned resources with specific asset classes that you thought there was some harmony, I guess, between certain skills and certain asset classes. So, it wasn't one size fits all, you were very discriminating in terms of how you did your operational collection planning.

10:11 MB: That's correct, it was... Yes, there was in-depth analysis that went into that placement model. Again, we met with literally 50 different agencies, we would meet with the collectors, they would fill out these collector questionnaire forms, we would track their collections on an account level basis. And over time, the model was fine tuned to whereby we really... It became... I don't want to say statistically valid, but it became more statistically valid, in that we just had a better sense of which account should be placed with which collector based on really the different attributes to liquidation performance. Instead many of these debt... Sorry, collection owners or agency owners, they typically just place accounts randomly. And again, if certain collectors collect certain types of debt better, why place the accounts where there're not really not giving much focus? So overall, the liquidation performance we experienced on that was tremendous, in part, the placement model but in part because of this collector bonus incentive program.

11:17 MF: And this alignment of collection capabilities with asset classes, was that similar to what you did in the mortgage?

11:23 MB: Not really. The mortgage space was really, I would say, focused on capitalizing on... Again, so part of... The mortgage model was basically... If you looked at a mortgage portfolio similar to a charged off credit card portfolio, certain assets or certain accounts may have higher market value than intrinsic value. So, in those situations we would actually sell off those accounts and we would retain the accounts where the cash flow or the economic value was greater than the market value.


11/03/17 Page 6 of 14

11:57 MF: Right.

12:00 MB: And it's something that could be done in the charged off space as well. Charged off credit card space where if you looked at a portfolio you could identify certain accounts within a portfolio where there's greater market value than economic value and vice versa. To me in the mortgage side, I was able to... In those situations, I would sell off probably... Again, it depended on the deal but probably anywhere from 60% to 80% of the portfolio be left with that remaining 20% to 40% at little or no cost basis. That's what made it attractive to me is that I wasn't tying up investment dollars in those portfolios. I was basically recouping most if not all of the investment. And it was left with this residual piece that generated nice cash flows, I had no debt against those portfolios.

12:47 MF: Let me step back for a second and I look at the timeline of Michael Bernstein's life. You graduated from Georgetown in '95, if that's right, and then you started the mortgage servicing or the mortgage investment company.

13:02 MB: I actually started before that, I'd say '94 was when I started because I...

13:05 MF: So, you started in Georgetown?

13:06 MB: Yeah. Started at Georgetown, but I'd say mostly acquisitions were actually '95, after Igraduated, through 2000.

13:17 MF: And so, you had that company up until, was it 2001 when you founded CMAX?

13:21 MB: Yeah, 2001 is when it basically transitioned over, again based upon this one company that had a second mortgage default.

13:30 MF: The default? So, Michael did you have this burning passion to have your own business when you were in college?

13:36 MB: Yes.

13:36 MF:Yes, okay. And you knew it was going to be financial?

13:39 MB: Financial, yes. I was a finance major at Georgetown and I wrote my thesis on it.Yes. So, I've always had a finance background.

13:44 MF: What was your thesis about?

13:47 MB: It's interesting, about... I studied the junk bond market in the late '80s, which... It's interesting that somebody...

13:56 MF: Michael Milken?


11/03/17 Page 7 of 14

13:57 MF: Is he one of your heroes?

14:00 MB: Well, I don't know about heroes, but the point is that... But I studied that whole market, it was very interesting to me. And it's interesting how many of these assets over the past five to seven years... These assets to... There are some parallels with certain assets that I've financed relative to some of those sort of junk bond. How they were perceived in the marketplace. What's interesting about that market too is that those were assets. Those were higher yielding assets where the cash flows were more attractive, probably, than the market value.

14:41 MF: So, CMAX was started in 2001. How did you capitalize it? How did you get started? Was it with the capital that you made on the sale of the first company?

14:50 MB: Yes. In part yes. I contributed about 25% of the initial capital. I raised the other 75% mostly through family and friends. But mostly through family. And I also had a partner in that business who was based in California. In 2001 we started it... The model took a few years to develop. We studied... We had access through different relationships to about $25 billion of charged off credit card debt. So as part of the model in 2001, we did some purchasing... From 2001 to 2004, we did some purchasing on a small basis. But it was more to test the model, refine the model. And then in 2004, I'd say is really when we started aggressively purchasing paper, based upon the prior three years history.

15:40 MF: So, part of the model... You already described the operational piece where you were aligning the right kinds of collectors with the right kinds of assets, and you differentiated, I think you said, your servicing by some very creative incentives to specific collectors and specific agencies. What else can you describe about the model that you thought maybe different, unusual, full of competitive advantage? What was different about the model that you developed for the first days of CMAX?

16:11 MB: Sure, sure. The second part of it... We would typically... When we purchased a portfolio we would outsource the collections for about a six month period. At the end of six months wewould recall those accounts that did not perform.

16:24 MF: Okay.

16:25 MB: We built an online trading platform that had 5,000 registered buyers. It was called the NDSE, similar to the NYSE. We wanted to make it the online trading platform to the industry, because what's interesting about this space is the fact that it's large. This market is tremendously large and it's interesting how there's not that much transparency. For example, I've been at conferences where I'll speak to two different groups, a buyer and a seller on a specific trade, they'll tell me... One will tell me they sold the debt at a certain price, the buyer will tell me they bought the debt at a different price. There's really no transparency in this marketplace.

17:06 MB: We tried to bring transparency through this online trading platform. We built it in 2004. We built out our infrastructure at the time. We hired about six sales reps and I believe about four business development reps. The sales reps would interface with the buyers, and the business


11/03/17 Page 8 of 14

development reps would interface, at the time, with issuers. Initially when we built this trading platform, we were selling our own debt. At the time, we really just focused actually on the sales side. But we wound up registering about 5,000 buyers. Mostly small to mid-size debt buyers. Many collection law firms. And the concept of that trading platform was to sell to the buyer in whose hands the debt is worth the most.

17:53 MB: That system had the capability to sell debt on an account level, state level, county level, to really fetch the highest price for the seller because... But meanwhile it would still make economic sense for the buyer because if you're, for example, a collection law firm in Florida, let's assume in Dade County, you may not want to purchase... Let's assume you purchase in Palm Beach County, Broward, and Dade County, you may not want to purchase accounts in Northern Florida because there's just different demographics, there's different court systems, you may have to outsource. So, we wanted the capability, through the system, to basically sell whether it was on account level or county level or state level. And again, we had about 5,000 registered buyers, I think of which about 1,500 were collection law firms. And we would wind up putting our accounts on the system andthey would sell out immediately. And so, you then had these national buyers competing with the state buyers, but when it went live on the system we would announce... We'd send out a marketing campaign and we'd say, "Okay, this particular portfolio is going live at 12:00 PM on Monday," and we'd have the sales reps interface with their client base, and once it hit the system it would move very, very quickly.

19:14 MF: So, let's fast forward. In 2008, though, CMAX decided, you decided, to get out of debt buying and into lending. Now, that was the year of the crash, did that have something to do with it?

19:25 MB: In part, yes. One thing I, not just myself, noted, but with the charged off mostly credit card debt, there were cycles that I experienced over an eight-nine year period from 2001 through2009, where it was extremely profitable when prices were relatively low. I remember we werepaying for fresh debt in... Between 2001 and 2005 we were paying I think six or six and a half cents for fresh paper, fresh credit card paper, then in 2000 I think it was six or seven. It skyrocketed to 11 or 12 cents, so all the profit you make when you're buying at six or six and a half, you then wind up giving away a lot of that when it hits 11 or 12 cents. And then when the prices came back down, I think it was 2007 and '08 it was profitable again, but there were signs of it then ratcheting back up. And prices today are astronomical for credit card debt, it's trading in the mid to high teens. So, we thought the finance model just made more sense because if you're advancing roughly 60% to 70%of the purchase price, you're really not that exposed. We did indepth analysis showing that even atthe height of the market back in whenever it was, '06, '07, when it was trading at 11 or 12 cents, that if you advance 60% or 70% against that, it's not nearly as risky as paying...

20:56 MF: So, it's less risky, that's why you decided to do financing as opposed to direct buying?

21:00 MB: Correct, and the yields also I thought were somewhat comparable. Again, it depends. The debt buying market can be very attractive when prices are low, but then again, all the profit you make when it's low can then dissipate when it's...

21:12 MF: Let me ask you the question now, in 2008, did CMAX the debt buyer actually lose money when the market crashed?


11/03/17 Page 9 of 14

21:19 MB: I don't recall in '08 if... I don't recall, to be honest.

21:26 MF: Well, if it was really bad, you would have recalled, so it can't...

21:29 MB: No, I don't think it was. But I do recall that, again, it was very profitable during those years when the pricing was low, and then it was less profitable if not even operating at a slight loss when prices would escalate. So, it was one of those things I felt the financing side could generate very attractive yields, but you're not taking nearly the same risk profile.

21:50 MF: Right. But in '09 the prices really fell...

21:53 MB: They fell.

21:54 MF: A lot. So, part of me thinks it would have been natural for you to jump back in as a debt buyer, but...

22:00 MB:Yes, but then again if you look at where prices have been the last few years, they're back up to... Right now the prices, again, for fresh credit card debt is in the mid to high teens, which I don't... From my perspective...

22:13 MF: Right, it's not attractive.

22:13 MB: We could never sustain that.

22:15 MF: Right. Now, throughout all this time, you say in your bio you processed $350 million or more in loans, and I know we've had a short time together as partners now. I've watched you negotiate, and you are an awesome negotiator, one of the best I've ever seen. Someday I expect you'll write your own "The Art of the Deal" by Michael Bernstein. [chuckle] Can you share with our listeners some of your principles of negotiation? Because you obviously like it, you're very good at it.

22:46 MB: No, I appreciate those, those are very kind words.

22:48 MF: What are your secrets that you're willing to share with the public today?

22:51 MB:Yes, no, I think the most important thing from my perspective, and everyone has a different negotiating style, it's critical to understand the objectives from all parties' perspectives. You want to make sure that the deal works for both sides. I've been in some situations where I thought I... I don't want to use the word "outnegotiated", but the deal needs to work for both sides, and you want to be equitable and fair. And the other thing that's critical is also to listen, because sometimes you just need to understand really... They may not be saying exactly what they mean, and so sometimes it's also just understanding certain things like that. Because sometimes when you're speaking with someone, you may need to pick up on things that they're really not saying. But in terms... Just to me, it's critical to understand their objectives, their needs, and to make a deal fair,


11/03/17 Page 10 of 14

where it works for both sides, because nothing works where...

23:45 MF: So, don't get greedy.

23:46 MB: Don't get greedy, absolutely, because...

23:48 MF: Does this mean you always split the difference or not?

23:50 MB: No, I'm not saying that, but the point is I think, again, it's important, because you don't have a shortsighted mentality with this. My business style is, again, I don't want to be short sighted, I like to look at longstanding relationships, which I've had over the years, and I think again it's treating the individual fairly and just making sure that the deal works for both sides. Because if it doesn't it's just going to be a short lived relationship. And to me there's time and resource that goes into building that relationship and the last thing you want to do is just have a one off type situation where you may have negotiated them on one specific transaction but they feel they've been slighted at that point and then it's difficult to maintain the relationship going forward.

24:40 MF: So, think long term?

24:43 MB: I think so.

24:43 MF: Think beyond the deal?

24:44 MB: Beyond the deal, absolutely. I look at the relationship. I also try to put myself in their position as well. And I was involved in a recent transaction where I wasn't negotiating with this particular individual, but I was trying to explain to them that... They were in negotiation with another lender and I told them, I said, "Look, you don't want them to perceive it that it's a one sidednegotiation." I said, "You should volunteer, basically provide them some trade off so that they viewit that you're being genuine in the negotiation." And he took that to heart and I think that he actually relayed that sort of message and I think hopefully that that deal... It's a transaction, I've been working with this one particular group and I think that that deal should come to fruition. But to me it'salways important to look at all sides and just be fair with it, and I try to put myself in the other person's position as well. And again, the most important thing is look at the overall relationship not just a specific deal.

25:48 MF: That's interesting. So, it's not just the deal, it's not just a transaction. It's a relationship which may generate more transactions in the future because you've maintained a relationship, you haven't burnt your bridge.

26:01 MB: Correct.

26:01 MF: In another words,


11/03/17 Page 11 of 14

26:02 MB: because to establish a relationship it's time, resource... You don't want a situation where the counter party feels that they've been slighted or it's been a one sided negotiation,because...


11/03/17 Page 12 of 14

26:13 MF: You're building trust.


26:14 MF: Right and fairness.


26:17 MF: So, you've built a few companies now in your young life. Obviously, companies don't grow in a straight line you must have had some obstacles along the way, what were some of the obstacles and how did you overcome them?

26:31 MB:Yes, no, there's definitely been obstacles. There's no question about it. Whether it's from funding situations or lack of funding situations to employee matters, to management type matters, it's varied across the board. On the funding side, I've had some situations and you have to be able... It's part of business and you have to be able to manage client expectations. I've been in situations where there has been limited funding and you just have to be transparent with the clients, they understand and I think that they respect that as opposed to not having full disclosure. I think that dealing with the... and again, I'm just using that as example that I've come across. There have been situations where, in the finance business or debt buying business, where there's been some funding crunches. Funding crunches that it can get... It can be difficult because you have got to try to maintain the existing business, but you have to also be transparent with them and explain the situation, and often times... Thankfully we were able to resolve those. They were typically just very short-term issues.

27:46 MF: Right.

27:47 MB: But nevertheless, you also have to prepare yourself that if for some reason it has to extend beyond that short period that you have to have sort of a backup or other backup solutions.

28:02 MF: So, you've had multipleorganizations, different types of people: Collectors, sales people, finance people. What are some of the lessons in leadership that you've kind of developed over the years that you could share with us?

28:15 MB:Yes, to me I like to lead by example. I mean to me what is critical is hard work, persistence and I always look for those attributes... There's certain attributes that I try to find whether I'm looking to hire someone or enter into a relationship. There's a lot of smart people in the world and to me what can separate us is hard work, persistence and I know on some of the deals they can take whatever is needed to get a deal done. Sometimes you may have to go the extra mile butit's worth it. Sorry, so back to your question though, is that I think it's important that you view...When I would look for someone to bring on board I would definitely see if there was a way to gauge their work efforts and their, obviously, integrity. That goes without saying, but you just want to make sure that they have the right work ethic... Again, there's a lot of smart people but the fact is if they're hard working that can separate... You don't want someone that just puts in the


11/03/17 Page 13 of 14

minimum and expects to get... It doesn't work.

29:27 MF: Do you need experience in finance to be on your team?

29:31 MB: I'm sorry.

29:31 MF: Do you need experience in finance?

29:33 MB:Yes, I think having some experience of finance has definitely helped. I think that understanding... The collection side is obviously also important. So, understanding... Having a finance background definitely helps, understanding collections. I think my background actually works out quite well for this. The fact that I have a finance degree, but I studied the collection industry for... And was involved in it for nine or 10 years and then before I got into the finance side of the business and so I think the combination has really helped me quite a bit.

30:05 MF: So, what's your vision for the future of MEB Finance Solutions and what's your outlook on the debt buying industry?

30:13 MB:Yes, well, I think times are very exciting right now, that I went through... With macroeconomic crisis in 2009, many of the issuers basically stopped originating to the lower tiered marketplace, so charge offs materially declined in 2010, '11, '12. But then there were many sort of these subprime issuers that filled that void that came about in 2011, '12, '13, '14, so you're seeing a lot of that supply side now come to the market place. There's the online lenders, there's short term installment loans, payday, there's different types of asset classes that have come about to the underbanked consumer as well as to the underbanked retailer. This merchant cash advance business has grown tremendously over the past five years and again that's a segment that I find very interesting because again, it's for the underbanked consumer and underbanked retailer and their needs... There's obviously a strong demand there. With some of the pricing in the marketplace such as credit card debt it's just... Again, it's at prices that are just it's difficult to buy at those levels. But, no, in terms of... The supply side now just seem tremendous with some of these...

31:31 MF: You see it's growing and...

31:32 MB: Growing with some of these other assets...Yes, I was just at this conference two weeks ago, this LEND360 conference and that's really for these consumer type... Consumer lenders...

31:43 MF: Online lenders.

31:44 MB: Online lenders and they have...

31:45 MF: Is that taking over the credit card?

31:47 MB: Yes. It's definitely, yes, there's a market shift in terms of from credit card to again some of these other type lenders, the online lenders whether it's the Lending Clubs, the World, the Prospers and then you obviously have whether it's the short term installment loan providers but


11/03/17 Page 14 of 14

there's definitely a shift in that direction.

32:08 MF: Well we have to wrap it up. I feel like we've only scratched the surface in this half hour. You've got a fascinating career and we appreciate your stories both in mortgage, debt buying and now in debt portfolio financing. Your deals... Your lessons about deals are fascinating and I hope someday we can look forward to seeing your book "The Art of the Deal" by Michael Bernstein.

32:32 MB: No. Thank you very much and I look forward to the continued strategic partnership, which has been very successful too.

32:36 MF: Thank you Michael, we do too. Thank you. Thank you.

32:38 MB: Thanks.

32:41 Thank you for joining Michael Flock and his guests on the Capital Club Radio show. For more information on future interviews, please visit us at flockfinance.com. This program is brought to you by FLOCK Specialty Finance, where clients are provided knowledge and insights to help them grow their business in complex and risky market. FLOCK is more than a transaction.

Documents

€¦ · Web viewBroadcasting live from the Pro Business Channel studios in Atlanta, Georgia, it's time for Capital Club Radio brought to you by FLOCK Specialty Finance