*NAAS Home Page*
cc: NAAS Subscribers and Users
Bcc: Domestic and International Affiliates
Proposed Federal Law: Making membership directories available to the public
NEWS, Commentary & Analysis
The National Association of Student Financial Aid Administrators (a/k/a/ NASFAA), and an alphabet-related group called National Association for College Admission Counseling (a/k/a/ NACAC) boast what is believed to be the largest collective membership of teachers, financial-aid counselors, financial-aid admissions' counselors, universities, colleges, student-loan providers, student-loan underwriters, and student-loan originaters in the financial-aid industry. In a nutshell, both of these groups represent persons and institutions that have significant influence as to what is marketed to students and parents, and they both have numerous affiliations with for-profit corporations. Collectively, they have each been granted tax-exempt status by the Internal Revenue Service of the U.S. This tax exempt-status has not stopped either organization from engaging in controversial conduct.
NASFAA is a non-profit association of institutions, colleges, universities, and individuals, agencies, and students who, according to literature produced by NASFAA, are "interested in promoting the effective administration of student financial aid." Virtually every college and university, and post-secondary institution, in the United States of America is a member of or some how associated with NASFAA.
NACAC is an alphabet-related organization that fosters cooperation with NASFAA on many endeavors. The National Association for College Admission Counseling works primarily with counseling and enrollment professionals at the high-school level. The group claims to help all students realize their full educational potential, with particular emphasis on the transition to postsecondary education. NACAC was founded in 1937. It is an organization of more than 10,000 professionals, many of which are high-school guidance counselors who work with college-level financial-aid professionals.
With respect to federal legislative action, both NACAC and NASFAA represents the interests of its respective members. It is not unusual for NASFAA and NACAC to seek legislation favorabel to financial-aid administrators, college counselors, teachers, and student loan providers, during the legislative process, and to compile reports to its membership on actions taken by Congress. A substantial amount of revenue for NASFAA is generated by annual fees paid by its members, revenue generated by advertisements and sponsorship fees paid by affluent members such as Sallie Mae, Nellie Mae, and various companies involved in student loans, and financial-aid.
Despite established facts, and what some may believe suggestions to the contrary, NACAC claims "it is committed to promoting high professional standards that foster ethical and social responsibility." This statement is a joke.
NACAC Officer quoted in N.Y. Times story by reporter with ties to N.Y. Underworld figure
There are many ways to judge the integrity and character of a person. One way is to ascertain who he or she associates with. Other than perhaps his wife, who else knew how perverted and disgusting New York Governor Eliot Spitzer really was?? After-all, despite his sexual attraction to diseased prostutitutes, she maintained her marraige to this creep. Apparently, she approves and accepts his character.
Although Spitzer kept his conduct private, there is yet still another way to analyze the character and integrity of person. Simply analyze what he or she says in public, and what he/she is willing to conceal from the public. In spitzer case, he concealed talk of certain issues, and certainly did not share with the public his fetish for tramps, hookers, whores, and bimbos. By analyzing a persons's public statements, we can infer and ascertain the extent to which he/she is willing to prostitute themselves and for what price.
Consider the bizarre conduct of Mr. David Hawkins. He is a long-time officer and employee of NACAC. He has been employed at the non-profit group for so long that one wonders whether or not he can get a job anywhere else. Despite being employed by a non-profit organization, and despite claims by his employer that it "is committed to promoting high professional standards that foster ethical and social responsibility...", this creep did not shy away from a chance to be quoted in a one-sided article that demeaned and insulted National Academy of American Scholars.
Mr. Hawkins did not make a good faith attempt to first contact NAAS directly to express his alleged concerns or opinions about the viability, integrity, and business practices of National Academy of American Scholars. Instead, he chimed in his cheap two cents worth of empty-headed comments like a drunken sailor in Asia. Then again, the sorry Mr. Hawkins also did not publicly disclose the fact that many NACAC members were engaging in massive student-loan fraud and/or unethical conduct soon to be announced by the New York Attorney General. Nor did Mr. Hawkins offer commentary about a pending investigation by the Associated Press about the massive number of teacher abuse cases that regularly occur in American schools. Neither did Mr. Hawkisn comment upon why NACAC has heretofore not chronicled and publicly listed the many cases of student-rapes-by-teachers, student molestations by teachers, and financial-aid crimes committed by members of NACAC on its public website like its does purported scholarship fraud. Why the silence on such important issues Mr. Hawkins?
Common sense would indicate that most students and parents are more interested in real issues that directly relate to their security and welfare than rather or not a private organization is charging $1 or $5 in scholarship processing fees? Apparently, these fees compete with the SAT/ACT tests, and the fees charged by the National Scholarship Provider's Association (N.S.P.A.), a creation of NASFAA and NACAC members.
The fact that Mr. Hawkins agreed to be quoted in the article is certainly not surprising given the unsavory persons that have been allowed to be members of NACAC. Several of their members and/or business associates have been the subject of law enforcement and ethical probes for financial-aid fraud, abuse allegations, cheating, perversity, immorality, etc. Furthermore, it should be noted that is is quite common for NACAC members to quote verbatim the Socialist rhetoric of the same corrupt federal informant that NASFAA aligned itself with in 1996.
Core principals of democracy and capitalism are commonly attacked in NACAC e-list serves. Reading an NACAC e-list serve is not entirely dissimilar from reading a manisfesto on Communism. Many NACAC members avoid discussion of the rampant incidents of teachers abusing students, teachers involved in fraud, student-loan fraud, and other issues that are not relevant to the purses of their respective members and business associates. Instead, their number one and most repeated rallying cry is the Marxist, anti-Capitalistis rhetoric of the federal informant they discreetly support: "Do not pay money, to get money."
After being quoted by parrot Hawkins, another enterprising gentleman based out of Arlington, VA coincidentally and strategically appeared as if on cue. A purported and highly suspicious "ethics" website run by Jack Marshall essentially parroted the same article as the N.Y. based reporter. As if lacking a brain for originality, Mr. Marshall essentially repeated the same discredited theories that first originated by the same Socialist federal informant linked to NASFAA, and the same federal informant often quoted by NACAC members. This tactic is a common pattern amongst persons and affiliates of NACAC, and NASFAA. The idea was first invented by the Nazis. It is called Revolving Mis-information. (a/k/a/ RMI)
In reviewing electronic evidence, foot-prints, and other damning evidence associated with certain suspect visitors to National Academy of American Scholar's websites, the fact that the dumb Mr. Marshall put his foot in his mouth was to be expected. His electronic trail is a public post-card. After all, his business is headquartered in Arlington, VA. That fact is certainly no surprise. Arlington, VA, coincidentally, is location of the headquarters to a number of subjects previously published about by this Publisher. The Council of Better Business Bureaus is headquartered there. NACAC is headquartered there. Convicted spy Robert Phillip Hanssen had a home in the region, and it was common for him to meet his Russian handlers in parks in the area. Magistrate files indicate that Mr. Hanssen shared the same philosophy as the federal informant connected to NASFAA.
Certainly, it is not unreasonable to speculate whether or not Mr. Hawkins was a legitimate impartial observer or was he really a planted pigeon by the reporter whose job was to further impugn or cast aspersions about the integrity of NAAS?
Exactly what is the extent of the relationship between Hawkins, Marshall, the federal informant, the N.Y. Underworld figure helped by the reporter, is unclear. What is clear, hoewever, is that many may perceive the public principles posted by NACAC on its website, and the conduct of Hawkins and many NACAC members to be contradictory.
The student-loan industry, according to the New York Attorney General, is an $85 billion dollar industry. Thousands of students across America have been fleeced by members and business associates of NACAC and NASFAA to the tune of thousands of dollars each. Yet, it is quite common for NACAC & NASFAA members to hypocritely bash any scholarship sponsor for simply having the audacity to charge a $1 dollar handling fee for postage and handling of scholarship literature.
Many students and parents have been deprived and censored of pure merit-based scholarship literature by corrupt and criminal members of NACAC and NASFAA who have falsely represented themselves as being prudent obversers of the student's best interests but who are really gatekeepers of the student loan industry and SAT industry. Comments by the N.Y. Attorney General casting doubts about the integrity of NASFAA President Dallas Martin simply confirm what is already known by many outside the student-loan industry.
Have you read or seen any articles of NACAC and/or NASFAA terminating the membership privileges of organizations and persons investigated by the N.Y. Attorney General and other law enforcement agencies that were found to have defrauded students and parents? I certainly haven't and I doubt if you have either.
It was funny watching a worm like Hawkins exposing his apparent stupidity. You see, neither myself or the N.Y. Attorney General, and I suspect, many other persons, have a lot of respect for NASFAA, NACAC, and their assortment of money-hungry members. David Hawkins is no saint. He is not even close.
Origins of Student-loan Schemes
Many wonder when and how the student-loan scandal begin. Who coordinated the scandal? Who set in motion what parts of the pie the chef would pass out?
In or about July of 1996, various members and professionals of NASFAA and NACAC, and the student-loan industry used the Interent and conference meetings to develop a strategy to get more business for the student-loan industry.
Looking for a scapegoat and diversion, many persons associated with NASFAA and NACAC began to flirt with the ideas being floated about by a student with ties to a burgeoning financial-aid business, which would late be bought by a subsidiary of Monster, Inc. The computer-science student was enrolled at Carnegie Mellon University and used a clever scheme to drum up business for the financial-aid business website that he ran, as well as the student-loan providers that were featured on his website. He created a list of phony, unofficial, and unverified "criteria" that he personally labeled as scams for businesses that he thought were competitors for monies against the sponsors or featured companies of his website, or that competing for money from students.
With assistance from NASFAA and NACAC members, student-loan providers, and corrupt reporters with ties to the student-loan industry, the sneering Carnegie Mellon University student took on the label of "financial-aid expert" although he publicly posted resume did not indicate any past or pending experience that would qualify him for such a lofty label. An airhead employee of Carnegie Mellon University, Barbara B. Lazarus, even endorsed a sloppy, inept, and clumsily-written financial-aid book that the CMU student had written. At the time, Barbara B. Lazarus was apparently the Associate Provost for Academic Projects of CMU. A circus of other old and menopause-age female NACAC and NASFAA members also jumped at the opportunity to ride the coat-tails of young Socialist.
The NASFAA-backed CMU student used his education, charm, and intellect, to cleverly manufacture unsubstantiated statistics, and scary propaganda of purported "massive scholarship fraud occuring in the financial-aid industry." Naturally, he kept his lid closed and avoided any discussion of student-loan fraud, unethical business arrangements between NASFAA members and univerity employees, since this was the very fraud that he apparently sought to protect and conceal in the first place.
NASFAA, under Dallas Martin, jumber on board and became the "exclusive sponser" of the website ran by the financially ambitious CMU student. To augment his contrived authenticity, he became a federal informant for the U.S. Justice Department, the FTC, and the U.S. Postal Inspection Service, amongst many other federal agencies. Who did he inform upon? Competitors to the student-loan industry, and companies that he perceived as competitors to his own profitable financial-aid websites.
Soon the CMU student, turned businessman, and unlikely federal informant, appeared at news conferences hosted by the FTC. His self-serving rhetoric was parroted by NACAC members. He was applauded by various persons connected to NASFAA, and his rhetoric appeared in many financial-aid books at the suggestion of federal agencies and persons connected to NASFAA, and NACAC.
Law Diverts Attention Away from Student-loan Scam Artists connected to NASFAA and NACAC members
Eventually, federal legislation called The College Scholarship Fraud Prevention Act was passed into law in 2000. As designed by members of NASFAA, the Act did not address the sort of conduct currently being investigated by the N.Y. Attorney General against numerous members of NASFAA. The Act deliberately omitted a Code of Conduct for Student loan providers, and made no criminal provisions for NASFAA or NACAC members who cheat and steal from students.
The impetus to pass this new law was largely based on the self-serving and abstract theories that originated from the enterprising CMU student connected to NASFAA. Not only were none of his statements ever proven, but many were deliberate embellishments, and falsehoods, deceptions, and meant to protect the money-pie associated with the student-loan and SAT industry, and the ongoing unethical conduct of persons who were members of the organizations that sponsored him.
Consider these facts:
The Act certainly did not address these facts and issues:
What The College Scholarship Fraud Prevention Act did do, however, was provide a new lease on life for the massive student-loan scheme that was being perpetrated on students and parents. While NASFAA and NACAC members were exhorting students and parents to "Never pay money to a scholarship sponsor who charged an application or handling fee...", many of the same members were pocketing under-the-table fees and secret commissions from student-loan providers for re-directing these students to a "preferred lender's list."
The chain-letter scheme of NASFAA and NACAC members
Like a chain-letter scheme, NASFAA and NACAC members recruited other members as part of a covert campaign to mislead the general public of the alleged extent of certain types of purported financial-aid fraud while conveniently ignoring routine abuses in the $85 billion dollar student-loan industry.
Like the Iraq pre-war rhetoric climaxed to a full-blown war, military invasion, and massive loss of life, the mis-information campaign that NASFAA and NACAC members were and continue to be part of resulted in thousands of students being defrauded by corrupt members of NACAC and NASFAA. A scathing letter by the Attorney General of New York directed to the president of NASFAA, Dallas Martin simply confirms what many members of the public feel towards many members of these suspicious non-profit groups: NASFAA and NACAC members account for bulk of all financial-aid fraud in America. In a nutshell, never trust the financial-aid advice of NASFAA and/or NACAC official.
Unverifiable Claims/Non-Existent NACAC Membership Directory
Unlike the secretive nature of NACAC, NASFAA does publish a single volume, paper-backed, general membership directory that may be purchased by the general public. Exactly what NACAC may be attempting to hide or may be ashamed of with regards to their membership base is not clear. Speculation is that certain members of their membership base have been reported upon in the past by this Publisher, and the disclosure of their membership ties to NACAC, or other organizations, may invite questions of integrity and fair-dealing; one NACAC officer agreed to speak to a New York-based reporter in furtherance of a scheme by representaives of a suspected N.Y. crime family to smear the history, integrity, and superior ethics of National Academy of American Scholars.
Without viewing the collective printed membership roster of NACAC in a single volume, it is virtually impossible to ascertain the membership of certain persons into NACAC, and what groups of persons donate money to NACAC.
Request for NACAC Membership Directory Denied
As recently as thirty days ago, this Publisher called the offices of NACAC and asked for a copy of its printed, single-volume, paper-back membership directory. NACAC claimed the directory was available for purchase only by members. Yet, this organization is tax-exempt by the Internal Revenue Service. How is it possible for an American organization to conceal from the general public a general, all-inclusive, membership directory yet rely upon our tax dollars to subsidize their existence? Why should we, as consumers, be forced to pay a de facto "membership tax", complete a membership application, qualify for membership, wait for approval, merely to the to receive a printed copy of a membership directory?
The purpose of the request by this Publisher for a copy of the NACAC membership was multifold.
- Public documentation produced annually by the U.S. Department of Justice, the Federal Trade Commission, and the U.S. Dept. of Education show that the most common types of financial-aid fraud are committed by persons in-the-know: the guidance counselors; parents; university financial-aid officers; admissions' counselors; and, employees of companies/agencies that have relationships with colleges and universities;
- Persons in-the-know are the primary members of NASFAA and NACAC. These persons are capable of best falsifying transcripts, forging or encouraging fraudulent letters of recommendation, falsifying FAFSA documents, under-reporting of parental income, and steering students to fraudulent loan providers, censoring and steering students away from low cost application-fee merit-based scholarship sponsors and towards high cost crooked loan providers that are members of NASFAA/NACAC, and commingling marketing affairs with corrupt financial-aid officers and executives of student-loan companies;
- The Plague Of Sexual Misconduct In Schools. An independent investigation by the Associated Press has determined that more Than 2,500 Cases Over Five Years Ranging From Bizarre To Sadistic. Sensational cases make headlines, but the scale of sexual misconduct by teachers in America's schools gets little attention, as reported by the Associated Press. The Associated Press report reveals a disturbing national picture.
There are 3 million public school teachers nationwide. Many of these teachers/counselors are members of NACAC. Young people were the victims in at least 1,801 of the cases, and more than 80 percent of those were students, reports the AP. Yet, why aren't these cases profiled on the websites of NACAC, anf why aren't the names of teacher convicts and teacher offenders/rapists/molesters posted on the NACAC as are purported.
Iran, Afghanistan, Russia , Amongst Stated NACAC Member locations
- This Publisher wanted to verify the boasts and claims made by NACAC that it is "an organization of more than 10,000 professionals from around the world."
- This Publisher wanted to verify the list of advertisers in the NACAC membership directory, and determine if those advertisers also appear in the NASFAA membership; and, if so, is the advertising content the same'
- This Publisher wanted to get a printed version of the NACAC membership directory because it is possible to easily change or block the web content of a form-entry single-line membership directory based upon numerous factors;
- This Publisher wanted to get a printed version of the NACAC membership directory to ascertain if NACAC was in compliance with its published Statement of Principles and Good Practice.
- This Publisher wanted to get a printed version of the membership directory to ascertain if NACAC was accepting advertising or membership revenue from groups or persons previously investigated by this Publisher, and whether or not such membership -if it existed -- influenced a NACAC officer to speak to a New York-based reporter regarding NAAS.
- This Publisher wanted to get a printed version of the NACAC membership directory to ascertain if NACAC was accepting advertising or membership revenue from groups or persons identified by U.S. State Department as possible terrorists. Remember, NACAC claims or implies that its membership base is world-wide, and provides ¶public categories of countries that are known to be havens of terrorism.
- Etc., etc.
Locations tied to Terrorism
In reviewing its website, and scrolling down the countries where NACAC members are purportedly based, one gets the impression that NACAC members are indeed based all around the world. After all, the categories of countries for NACAC members are printed neatly in alphabetical order ranging from faraway places like ¶Afghanistan, Aland Islands, Albania
Algeria, American Samoa, Bosnia and Herzegovina(a former republic of the U.S.S.R.), Central African Republic, Chad, Chile, China, Congo, Croatia, El Salvador, Equatorial Guinea,Gabon, Gambia,Ghana,Haiti, Islamic Republic of ¶Iran, ¶Korea, Russian Federation, Russia, Turkey, Turkmenistan, Uganda, Ukraine, Uzbekistan, ¶Venezuela, Viet Nam, ¶Yemen, Zambia.
Many of these countries are havens for drugs, terrorists, and anti-American sentiment.
It is therefore understandable why NACAC would decline general access to or even produce a comprehensive single volume, paper-backed membership directory for purchase by the general public. Nenetheles, it is common knowledge that guidance counselers, admissions counselors, and financial-aid professionals are the bread & butter public members of NACAC, and that sponsors (whomever they may be, and wherever they may reside) provide a greater source of revenue.
The current tacky method for persons to ascertain whether or not arrested, suspicious, or charged persons are members of NACAC is to input the person's first and last name into a Membership section of their website and await for whatever output the web page provides. However, it is possible to alter the code and delete evidence of membership too, and therefore deprive the public of knowing whether or not a particular person was or is a current member.
After criticism of the NASFAA membership directory, and its close ties to the student-loan industry, an attempt to examine the NACAC membership directory was met with evasiness. As expected of any person with suspect motives, NACAC simply took steps to keep its membership directory out of public view. Despite being a non-profit organization that is allowed to apparently solicit donations from the general public, and which receives certain federal tax exemptions at the expense of tax-payers who do pay federal tax, NACAC limits the distribution and sale of its national membersip directory to "only members."
"From my own experience - this could get me in trouble - I think every single school district in the nation has at least one [sexual] perpetrator. At least one," says Mary Jo McGrath, a California lawyer who has spent 30 years investigating misconduct in schools. "It doesn't matter if it's urban or rural or suburban."
One victim wonders why there isn't more outrage. "You're supposed to be able to send your kids to school knowing that they're going to be safe," says Jennah Bramow, a 20-year-old single mom and waitress in Cedar Rapids, Iowa.
How does NACACNASFAA, and its puppet employees respond to documented reports that suggest that many of its members toe the line between respected teachers/guidance counselors to either closet molesters or public perverts?
Innnocent young kids are being molested, groped at, raped, fondled, and abused every day at schools,universities, and public institutions. Many of these schools,universities, and public institutions have ties to either NACAC and/or NASFAA.
What are these two sorry and pathetic organizations doing about it? Looking the other way, providing a forum for a supporter of Marxism, and creating "preferred lender's list" to steer students and parents to corrupt student-loan provders.
It is without question that every non-profit organization in America SHOULD be required by federal law to make a copy of a printed, single volume, paper-backed and/or complete electronic summary of its entire donor and membership list.
NACAC does provide access to an online access point for information about its members. However, their version appears deliberately evasive and too cumbersome to use. Inquiring members of the public are limited to searching for a single member at a time, having the responsibility of knowing the precise spelling and sequence of a purported member's name, supplying the precise name of the person or group they are searching for. Currently, members of the public are unable to use the NACAC system visibly cross-reference members from a single summary volume. The NACAC online access point for its membership directory is clearly ineffective, cheap, inferior, and suggests they are seeking to deprive the public of its assorted business relationships, predatorss, and source of funding.
What is NACAC afraid of? Do members not want their names to be associated with NACAC? Certainly, Mr. Hawkins has demonstrated how accessible he is for public commentary on issues that do not involve NACAC.
Given the fact that numerous federal laws, and Internal Revenue Codes, require that non-profit organizations make their tax-exempt Form 990 Income statements available for public review, an associated legal question is this: Is there any federal case authority for the I.R.S. to require that non-profit organizations also are required to make their membership lists available to the public for purchase? We believe the answer is yes? Assuming a non-profIt organization has nothing to hide, and can substantiate the cast of characters it associates with, WHY NOT MAKE THE MEMBERSHIP DIRECTORY AVAILABLE????????
Also, by instituting a laborious and error prone software search for members one-by-one, NACAC appears to have set up a convenient obstacle to deprive members of the inquiring public and law enforcement investigators of concrete facts they may need to investigate legitmate concerns.
I REPEAT! Every non-profit organization in America, including NACAC, SHOULD be required by federal law to make a copy of a printed, single volume, paper-backed and/or complete non-editable electronic summary of its entire donor and membership list. If an organization is unwilling to make its membership directory available to the general public in a manner that is not evasive and in a single, paper-back volume instead of an editable software database that uses single-entry queries then the organization should be viewed as a fraud, and stripped of its tax-exempt status.
That's my opinion. What's yours?
..... End of Report....
|A Call for Justice
A public membership directory would certainly help parents and consumer activists pinpoint what many of these non-profit organizations are up to, what percentage of their members are convicted sexual predators, and where many of there members are employed at.|
Publishers note:The information contained herein has been obtained and compiled from sources deemed to be reliable. However, as in the case of all legitimate journalistic reporting, we cannot guarantee the accuracy of the information presented herein nor the credibility of the sources used. Consequently, The Companies, and Publishers, etc., et al., jointly and severally, makes no warranty or representation, express or implied, with respect to the accuracy or completeness of the information herein nor assumes any liability with respect to the use of, or damages resulting from the use of the information contained in this report pursuant to 47 U.S.C. Section 230, subdivision (e), part 3, as well as the First and Fourteenth Amendments to the United States Constitution, as well as Article I, Section 2 of the Constitution of the State of California, as well as other affirmative defenses and doctrines not explicitly mentioned herein. However, to the best of our knowledge and belief, the information cited hereinabove is believed to be factual and accurate, and is offered without recourse to The Companies, etc., et al., the staff, officers, directors, et al. and any affiliates of the same subsequently mentioned in this web presentation. Furthermore, this report is not intended to recommend or deprecate any of the subjects cited or referenced herein and said report is furnished solely to assist the reader in exercising his/her own authoritative discernment. After first publishing this report, or immediately preceding the release of the content hereon, the companies with an asterisk (*) trailing their name are believed to have either ceased operations and/or ceased using a brand name(s) confusingly similar to NAAS. After two years of compliance with NAAS EAS/N2 Rules or after having received written assurances of intended compliance, such companies may be removed from this list. By accessing this report from a general hypertext link, it is the reasonable belief of the Publisher that the statements which form the subject matter of the report are to persons also interested therein and that such persons hereby agree and expressly consent to all applicable NAAS EAS/N2 Rules. Absolutely no part of this report, either partially or in its entirety, may be used in advertising, selling or for commercial purpose or downloaded into any computer system for subsequent storage, personal re-prints, videotaped, or manipulation of any type. Any re-prints or re-broadcasts not authorized by The Companies, or an authorized agent, assignee, or representative of the same, are deemed as non-official representations, and effective forthwith, are immediately disclaimed as being non-representative of Publisher. The captions or subtitles of this report are employed solely for convenience and are not to be used as an aid in interpretation or speculation. Neither this report, nor any reports related thereto, nor any tangential reports, claims to offer legal advice or legal opinions. This report is not a legal opinion. For legal opinions, a person should consult competent legal counsel. Plagerizers and copyright violators are subject to appropriate adjudicative proceedings. All NAAS EAS/N2 Rules apply.