Author: Alexis Long

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Helpful Articles Tax

The Tax Advantages of Including Debt in a C Corporation Capital Structure

Let’s say you plan to use a C corporation to operate a newly acquired business or you have an existing C corporation that needs more capital. You should know that the federal tax code treats corporate debt more favorably than corporate equity. So, for shareholders of closely held C corporations, it can be a tax-smart move to include in the corporation’s capital structure:

  • Some third-party debt (owed to outside lenders), and/or
  • Some owner debt.

Tax rate considerations

Let’s review some basics. The top individual federal income tax rate is currently 37%. The top individual federal rate on net long-term capital gains and qualified dividends is currently 20%. On top of this, higher-income individuals may also owe the 3.8% net investment income tax on all or part of their investment income, which includes capital gains, dividends and interest.

On the corporate side, the Tax Cuts and Jobs Act (TCJA) established a flat 21% federal income tax rate on taxable income recognized by C corporations.

Third-party debt

The non-tax advantage of using third-party debt financing for a C corporation acquisition or to supply additional capital is that shareholders don’t need to commit as much of their own money.

Even when shareholders can afford to cover the entire cost with their own money, tax considerations may make doing so inadvisable. That’s because a shareholder generally can’t withdraw all or part of a corporate equity investment without worrying about the threat of double taxation. This occurs when the corporation pays tax on its profits and the shareholders pay tax again when the profits are distributed as dividends.

When third-party debt is used in a corporation’s capital structure, it becomes less likely that shareholders will need to be paid taxable dividends because they’ll have less money tied up in the business. The corporate cash flow can be used to pay off the corporate debt, at which point the shareholders will own 100% of the corporation with a smaller investment on their part.

Owner debt

If your entire interest in a successful C corporation is in the form of equity, double taxation can arise if you want to withdraw some of your investment. But if you include owner debt (money you loan to the corporation) in the capital structure, you have a built-in mechanism for withdrawing that part of your investment tax-free. That’s because the loan principal repayments made to you are tax-free. Of course, you must include the interest payments in your taxable income. But the corporation will get an offsetting interest expense deduction — unless an interest expense limitation rule applies, which is unlikely for a small to medium-sized company.

An unfavorable TCJA change imposed a limit on interest deductions for affected businesses. However, for 2024, a corporation with average annual gross receipts of $30 million or less for the three previous tax years is exempt from the limit.

An example to illustrate

Let’s say you plan to use your solely owned C corporation to buy the assets of an existing business. You plan to fund the entire $5 million cost with your own money — in a $2 million contribution to the corporation’s capital (a stock investment), plus a $3 million loan to the corporation.

This capital structure allows you to recover $3 million of your investment as tax-free repayments of corporate debt principal. The interest payments allow you to receive additional cash from the corporation. The interest is taxable to you but can be deducted by the corporation, as long as the limitation explained earlier doesn’t apply.

This illustrates the potential federal income tax advantages of including debt in the capital structure of a C corporation. Contact us to explain the relevant details and project the tax savings. © 2024

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General

Tax Tips When Buying the Assets of A Business

After experiencing a downturn in 2023, merger and acquisition activity in several sectors is rebounding in 2024. If you’re buying a business, you want the best results possible after taxes. You can potentially structure the purchase in two ways: Buy the assets of the business, or Buy the seller’s entity ownership interest if the target business is operated as a corporation, partnership, or LLC. In this article, we’re going to focus on buying assets.

Asset purchase tax basics

You must allocate the total purchase price to the specific assets acquired. The amount allocated to each asset becomes the initial tax basis of that asset. For depreciable and amortizable assets (such as furniture, fixtures, equipment, buildings, software, and intangibles such as customer lists and goodwill), the initial tax basis determines the post-acquisition depreciation and amortization deductions. When you eventually sell a purchased asset, you’ll have a taxable gain if the sale price exceeds the asset’s tax basis (initial purchase price allocation, plus any post-acquisition improvements, minus any post-acquisition depreciation or amortization).

Asset purchase results with a pass-through entity

Let’s say you operate the newly acquired business as a sole proprietorship, a single-member LLC treated as a sole proprietorship for tax purposes, a partnership, a multi-member LLC treated as a partnership for tax purposes or an S corporation. In those cases, post-acquisition gains, losses, and income are passed through to you and reported on your personal tax return. Various federal income tax rates can apply to income and gains, depending on the type of asset and how long it’s held before being sold.

Asset purchase results with a C corporation

If you operate the newly acquired business as a C corporation, the corporation pays the tax bills from post-acquisition operations and asset sales. All types of taxable income and gains recognized by a C corporation are taxed at the same federal income tax rate, which is currently 21%.

A tax-smart purchase price allocation

With an asset purchase deal, the most important tax opportunity revolves around how you allocate the purchase price to the assets acquired. To the extent allowed, you want to allocate more of the price to: Assets that generate higher-taxed ordinary income when converted into cash (such as inventory and receivables), Assets that can be depreciated relatively quickly (such as furniture and equipment), and Intangible assets (such as customer lists and goodwill) that can be amortized over 15 years. You want to allocate less to assets that must be depreciated over long periods (such as buildings) and to land, which can’t be depreciated. You’ll probably want to get appraised fair market values for the purchased assets to allocate the total purchase price to specific assets. As stated above, you’ll generally want to allocate more of the price to certain assets and less to others to get the best tax results. Because the appraisal process is more of an art than a science, there can potentially be several legitimate appraisals for the same group of assets. The tax results from one appraisal may be better for you than the tax results from another. Nothing in the tax rules prevents buyers and sellers from agreeing to use legitimate appraisals that result in acceptable tax outcomes for both parties. Settling on appraised values becomes part of the purchase/sale negotiation process. That said, the appraisal that’s finally agreed to must be reasonable.

Plan ahead

Remember, when buying the assets of a business, the total purchase price must be allocated to the acquired assets. The allocation process can lead to better or worse post-acquisition tax results. We can help you get the former instead of the latter. So get your advisor involved early, preferably during the negotiation phase. Contact us. © 2024

Categories
News

Pay Attention to the Tax Rules if you Turn a Hobby into a Business 

Many people dream of turning a hobby into a regular business. Perhaps you enjoy boating and would like to open a charter fishing business. Or maybe you’d like to turn your sewing or photography skills into an income-producing business. You probably won’t have any tax headaches if your new business is profitable over a certain period of time. But what if the new enterprise consistently generates losses (your deductions exceed income) and you claim them on your tax return?

You can generally deduct losses for expenses incurred in a bona fide business. However, the IRS may step in and say the venture is a hobby — an activity not engaged in for profit — rather than a business. Then you’ll be unable to deduct losses. By contrast, if the new enterprise isn’t affected by the hobby loss rules, all otherwise allowable expenses are deductible, generally on Schedule C, even if they exceed income from the enterprise. Important: Before 2018, deductible hobby expenses could be claimed as miscellaneous itemized deductions subject to a 2%-of-AGI “floor.” However, because miscellaneous deductions aren’t allowed from 2018 through 2025, deductible hobby expenses are effectively wiped out from 2018 through 2025.

How to NOT be deemed a hobby:

There are two ways to avoid the hobby loss rules: Show a profit in at least three out of five consecutive years (two out of seven years for breeding, training, showing or racing horses). Run the venture in such a way as to show that you intend to turn it into a profit maker rather than a mere hobby. The IRS regs themselves say that the hobby loss rules won’t apply if the facts and circumstances show that you have a profit-making objective. How can you prove you have a profit-making objective? You should operate the venture in a businesslike manner.

The IRS and the courts will look at the following factors: How you run the activity, Your expertise in the area (and your advisors’ expertise), The time and effort you expend in the enterprise, Whether there’s an expectation that the assets used in the activity will rise in value, your success in carrying on other activities, your history of income or loss in the activity, the amount of any occasional profits earned, your financial status, and whether the activity involves elements of personal pleasure or recreation. Case illustrates the issues in one court case, partners operated a farm that bought, sold, bred and raced standardbred horses. It didn’t qualify as an activity engaged in for profit, according to a U.S. Appeals Court. The court noted that the partnership had a substantial loss history and paid for personal expenses. Also, the taxpayers kept inaccurate records, had no business plan, earned significant income from other sources and derived personal pleasure from the activity. (Skolnick, CA 3, 3/8/23)

Contact us for more details on whether a venture of yours may be affected by the hobby loss rules, and what you should do to avoid tax problems. © 2024

Categories
News

When Partners Pay Expenses Related to the Business 

It’s not unusual for a partner to incur expenses related to the partnership’s business. This is especially likely to occur in service partnerships such as an architecture or law firm. For example, partners in service partnerships may incur business expenses in developing new client relationships. They may also incur expenses for: transportation to get to and from client meetings, professional publications, continuing education and home office.

What’s the tax treatment of such expenses?

Here are the answers. Reimbursable or not as long as the expenses are the type a partner is expected to pay without reimbursement under the partnership agreement or firm policy (written or unwritten), the partner can deduct the expenses on Schedule E of Form 1040. Conversely, a partner can’t deduct expenses if the partnership would have honored a request for reimbursement. A partner’s unreimbursed partnership business expenses should also generally be included as deductions in arriving at the partner’s net income from self-employment on Schedule SE.

For example, let’s say you’re a partner in a local architecture firm. Under the firm’s partnership agreement, partners are expected to bear the costs of soliciting potential new business except in unusual cases where attracting a large potential new client is deemed to be a firm-wide goal. In attempting to attract new clients this year, you spend $4,500 of your own money on meal expenses. You receive no reimbursement from the firm. On your Schedule E, you should report a deductible item of $2,250 (50% of $4,500). You should also include the $2,250 as a deduction in calculating your net self-employment income on Schedule SE. So far, so good, but here’s the issue: a partner can’t deduct expenses if they could have been reimbursed by the firm. In other words, no deduction is allowed for “voluntary” out-of-pocket expenses.

The best way to eliminate any doubt about the proper tax treatment of unreimbursed partnership expenses is to install a written firm policy that clearly states what will and won’t be reimbursed. That way, the partners can deduct their unreimbursed firm-related business expenses without any problems from the IRS. Office in a partner’s home subject to the normal deduction limits under the home office rules, a partner can deduct expenses allocable to the regular and exclusive use of a home office for partnership business. The partner’s deductible home office expenses should be reported on Schedule E in the same fashion as other unreimbursed partnership expenses.

If a partner has a deductible home office, the Schedule E home office deduction can deliver multiple tax-saving benefits because it’s effectively deducted for both federal income tax and self-employment tax purposes. In addition, if the partner’s deductible home office qualifies as a principal place of business, commuting mileage from the home office to partnership business temporary work locations (such as client sites) and partnership permanent work locations (such as the partnership’s official office) count as business mileage.

The principal place of business test can be passed in two ways:

First, the partner can conduct most of partnership income-earning activities in the home office. Second, the partner can pass the principal place of business test if he or she: Uses the home office to conduct partnership administrative and management tasks and doesn’t make substantial use of any other fixed location (such as the partnership’s official office) for such administrative and management tasks.

To sum up when a partner can be reimbursed for business expenses under a partnership agreement or standard operating procedures, the partner should turn them in. Otherwise, the partner can’t deduct the expenses. On the partnership side of the deal, the business should set forth a written firm policy that clearly states what will and won’t be reimbursed, including home office expenses if applicable. This applies equally to members of LLCs that are treated as partnerships for federal tax purposes because those members count as partners under tax law. © 2024

Categories
General

7 Common Payroll Risks for Small to Midsize Businesses

If your company has been in business for a while, you may not pay much attention to your payroll system so long as it’s running smoothly. But don’t get too complacent. Major payroll errors can pop up unexpectedly — creating huge disruptions costing time and money to fix, and, perhaps worst of all, compromising the trust of your employees. For these reasons, businesses are well-advised to conduct payroll audits at least once annually to guard against the many risks inherent to payroll management. Here are seven such risks to be aware of:

1. Inaccurate recordkeeping. If you don’t keep detailed and accurate records, it will probably come back to haunt you. For example, the Fair Labor Standards Act (FLSA) requires businesses to maintain records of employees’ earnings for at least three years. Violations of the FLSA can trigger severe penalties. Be sure you and your staff know what records to keep and have sound policies and procedures in place for keeping them.

2. Employee misclassification. Given the widespread use of “gig workers” in today’s economy, companies are at high risk for employee misclassification. This occurs when a business engages independent contractors but, in the view of federal authorities, the company treats them like employees. Violating the applicable rules can leave you owing back taxes and penalties, plus you may have to restore expensive fringe benefits.

3. Manual processes. More than likely, if your business prepares its own payroll, it uses some form of payroll software. That’s good. Today’s products are widely available, relatively inexpensive, and generally easy to use. However, some companies — particularly small ones — may still rely on manual processes to record or input critical data. Be careful about this, as it’s a major source of errors. To the extent feasible, automate as much as you can.

4. Privacy violations. You generally can’t manage payroll without data such as Social Security numbers, home addresses, birth dates, and bank account numbers. Unfortunately, possessing such information puts you squarely in the sights of hackers and those pernicious purveyors of ransomware. Invest thoroughly in proper cybersecurity measures and regularly update these safeguards.

5. Internal fraud. Occupational (or internal) fraud remains a major threat to businesses. Schemes can range from “cheating” on timesheets by rank-and-file workers to embezzlement by those higher on the organizational chart. Among the most fundamental ways to protect your payroll function from fraud is to require segregation of duties. In other words, one employee, no matter how trusted, should never completely control the process. If you don’t have enough employees to segregate duties, consider outsourcing.

6. Legal compliance. As a business owner, you’re probably not an expert on the latest regulatory payroll developments affecting your industry. That’s OK; laws and regulations are constantly evolving. However, failing to comply with the current rules could cost you money and hurt your company’s reputation. So, be sure to have a trustworthy attorney on speed dial that you can turn to for assistance when necessary.

7. Tax compliance. Employers are responsible for calculating tax withholding on employee wages. In addition to deducting federal payroll tax from paychecks, your organization must contribute its own share of payroll tax. If you get it wrong, the IRS could investigate and potentially assess additional tax liability and penalties. That’s where we come in. For help conducting a payroll audit, reviewing your payroll costs, and, of course, managing your tax obligations, contact us.

© 2024

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Press Releases

ATA ANNOUNCES DIRECTOR OF HUMAN RESOURCES

ATA ANNOUNCES DIRECTOR OF HUMAN RESOURCES

ATA welcomes Natasha Pennington to their leadership team as the firm’s Director of Human Resources. Bringing more than 15 years of personnel experience to her role, Natasha will execute human resource strategies in support of the overall business plan and strategic direction of the firm, specifically in the areas of employee relations, compliance, HR administration, recruitment & talent acquisition, compensation, benefits, performance management, and HR technology.

“Natasha is an effective communicator and possesses many great qualities for her role at ATA,” said John Whybrew, managing partner of ATA. “I am confident Natasha will be a tremendous asset to help manage our team and streamline our operations.”

Previously, Natasha was an HR Manager with ATA Employment Solutions, ATA’s human resource management partner. Natasha’s career has provided ample opportunity for learning and development.  She is a member of The Society for Human Resources Management (SHRM) and is a SHRM Certified Professional (SHRM-CP). She is also a member of the West Tennessee SHRM chapter (WTSHRM).

“I am passionate about people and learning what motivates them in their careers,” said Pennington. “I’m excited to be part of ATA to support and further develop its human resource strategies.”

Natasha earned a Master of Science degree in Human Resources as well as a Graduate Certificate in Organizational Leadership and Human Resources Management from Chapman University System. She also received a Bachelor of Science degree in Business Administration with an emphasis in Industry Analysis from the University of Redlands.

Natasha received the Volunteer of the Year award in 2016 for her active involvement with Canine Support Teams and their Pawz for Wounded Veterans program. She previously served on the Obion County Chamber of Commerce board in 2020/2021. She is a graduate of the Class of 2019 Adult Leadership Obion County and currently serves on the board as vice president.

Pennington moved to Tennessee from Southern California in 2017. Natasha said, “My husband and I love Tennessee, and we love living and working in Obion County. Moving to Tennessee is one of the best decisions we have ever made!”

Natasha values her faith and family above all, but in her free time, she enjoys fishing, hiking, kayaking, working on her hobby farm, and doing anything adventurous or outdoors.

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About ATA

ATA is an advisory firm that works with clients on all aspects of their business needs. ATA guides its clients towards success by providing consulting services that are not traditionally associated with the accounting industry. For example, Revolution Partners, ATA’s wealth management entity provides financial planning expertise; ATA Technologies provides trustworthy IT solutions; ATA Digital focuses on growth through the design and development of marketing and digital products as well as offers video, social media, and digital content for small businesses; ATA Capital is an investment banking firm dedicated to providing clients with M&A brokerage services; and lastly, ATA Employment Solutions is a comprehensive human resource management agency.

ATA has 16 office locations in Tennessee, Arkansas, Kentucky and Mississippi. Recognized as an IPA Top 150 regional accounting firm, it provides a wide array of accounting, auditing, tax and consulting services for clients ranging from small family-owned businesses to publicly traded companies and international corporations. ATA is also an alliance member of BDO USA LLP, a top five global accounting firm, which provides additional resources and expertise for clients.

Categories
Tax

Estimated Tax Payments

If you make estimated tax payments, be aware that April 15 isn’t just the 2023 tax filing deadline. It’s also the deadline for the first estimated tax payment for 2024. Estimated tax payments are generally made by self-employed people, retirees, investors, businesses and others that don’t have taxes withheld from their income. The payments are also made by employees who don’t withhold enough tax to pay what’s due.

Taxpayers who don’t make estimated payments (or don’t make sufficient payments) may be subject to failure-to-pay penalties. Exceptions apply to certain taxpayers. The second estimated payment for 2024 will be due June 15. For more information: https://bit.ly/4aFuJuc

Categories
Tax

The tax deadline is almost here: File for an extension if you’re not ready

The April 15 tax filing deadline is right around the corner. However, you might not be ready to file. Sometimes, it’s not possible to gather your tax information by the due date. If you need more time, you should file for an extension on Form 4868. An extension will give you until October 15 to file and allows you to avoid “failure-to-file” penalties. However, it only provides extra time to file, not to pay. Whatever tax you estimate is owed must still be sent by April 15, or you’ll incur penalties — and as you’ll see below, they can be steep. Two different penalties Separate penalties apply for failing to pay and failing to file.

The failure-to-pay penalty runs at 0.5% for each month (or part of a month) the payment is late. For example, if payment is due April 15 and is made May 25, the penalty is 1% (0.5% times 2 months or partial months). The maximum penalty is 25%. The failure-to-pay penalty is based on the amount shown as due on the return (less amounts paid through withholding or estimated payments), even if the actual tax bill turns out to be higher.

On the other hand, if the actual tax bill turns out to be less, the penalty is based on the lower amount. The failure-to-file penalty runs at the more severe rate of 5% per month (or partial month) of lateness to a maximum 25%. If you file for an extension on Form 4868, you’re not filing late unless you miss the extended due date. However, as mentioned earlier, a filing extension doesn’t apply to your responsibility for payment. If the 0.5% failure-to-pay penalty and the failure-to-file penalty both apply, the failure-to-file penalty drops to 4.5% per month (or part) so the combined penalty is 5%. The maximum combined penalty for the first five months is 25%. Thereafter, the failure-to-pay penalty can continue at 0.5% per month for 45 more months (an additional 22.5%).

Thus, the combined penalties can reach a total of 47.5% over time. The failure-to-file penalty is also more severe because it’s based on the amount required to be shown on the return, and not just the amount shown as due. (Credit is given for amounts paid through withholding or estimated payments. If no amount is owed, there’s no penalty for late filing.) For example, if a return is filed three months late showing $5,000 owed (after payment credits), the combined penalties would be 15%, which equals $750. If the actual liability is later determined to be an additional $1,000, the failure-to-file penalty (4.5% × 3 = 13.5%) would also apply to this amount for an additional $135 in penalties. A minimum failure-to-file penalty also applies if a return is filed more than 60 days late. This minimum penalty is the lesser of $485 (for returns due after December 31, 2023) or the amount of tax required to be shown on the return.

Exemption in certain cases Both penalties may be excused by the IRS if lateness is due to “reasonable cause” such as death or serious illness in the immediate family. Interest is assessed at a fluctuating rate announced by the government apart from and in addition to the above penalties. Furthermore, in particularly abusive situations involving a fraudulent failure to file, the late filing penalty can jump to 15% per month, with a 75% maximum.

If you have questions about filing Form 4868 or IRS penalties, contact us. © 2024

Categories
General

Employee or Independent Contractor? A Guide to the New Rule

The U.S. Department of Labor (DOL) published a final rule on January 10, 2024, significantly revising its guidance on the classification of workers under the Fair Labor Standards Act (FLSA) as either employees or independent contractors, which took effect on March 11, 2024. This rule aims to provide clearer analysis for determining a worker’s classification and is designed to be more aligned with long-standing judicial precedents. The objective is to mitigate the risk of misclassifying employees as independent contractors, which can deprive workers of minimum wage, overtime pay, and other FLSA protections, while also offering a consistent framework for businesses engaging individuals who operate independently​​.

The final rule applies the following six factors to analyze employee or independent contractor status under the FLSA:

(1) opportunity for profit or loss depending on managerial skill;

(2) investments by the worker and the potential employer;

(3) degree of permanence of the work relationship;

(4) nature and degree of control;

(5) extent to which the work performed is an integral part of the potential employer’s business; and

(6) skill and initiative.

Per the DOL, the final rule provides detailed guidance regarding the application of each of these six factors. No factor or set of factors among this list of six has a predetermined weight, and additional factors may be relevant if such factors in some way indicate whether the worker is in business for themself (i.e., an independent contractor), as opposed to being economically dependent on the employer for work (i.e., an employee under the FLSA).

The background and motivation for this update stem from the original intentions of the FLSA, which was enacted in 1938 to establish critical worker protections. The misclassification of employees as independent contractors has been a persistent challenge, leading to situations where workers might not receive rightful employment benefits, including overtime pay, workers’ compensation insurance, employment taxes, and benefits costs. This misclassification also affects organizational obligations and flexibility in workforce management. The DOL emphasizes that the classification of independent contractors should be narrow under FLSA interpretation to prevent circumvention of employment laws​​.

The introduction of this rule reflects the DOL’s commitment to ensuring that labor laws are appropriately applied to protect workers while also providing clear guidance for employers. By revising the classification guidance, the DOL intends to address and reduce the incidences of misclassification, ensuring that workers are correctly categorized and thereby receive the protections and benefits to which they are entitled under the law​​.

For more detailed information on the new rule and its implications, you can visit the U.S. Department of Labor’s website and other legal analyses provided by labor and employment law experts.

Categories
Financial Institutions and Banking

Bank Wire: BNPL Loans: Managing the Risk

In a recent bulletin, the Office of the Comptroller of the Currency (OCC) offers guidance to community banks on managing the risks associated with buy now, pay later (BNPL) loans. These loans can take many forms, but the bulletin focuses on those that are payable in four or fewer installments and carry no finance charges. Typically, these loans are offered at the point of sale. The lender pays the merchant a discounted price for the good or service and, in exchange, assumes responsibility for granting credit and collecting payments from the borrower. The lender’s primary source of revenue is the difference between the total installment payments and the discounted purchase price, though it may also collect late fees from the borrower.

The bulletin warns banks of various risks associated with BNPL loans. For example, borrowers may overextend themselves or not fully understand their repayment obligations; applicants with limited or no credit history may present underwriting challenges; and the lack of clear, standardized disclosure language may obscure the true nature of the loan, creating a risk of violating prohibitions against unfair, deceptive or abusive acts or practices. The OCC offers tips on designing risk management systems that “capture the unique characteristics and risks of BNPL loans.” You can find the bulletin at https://www.occ.gov/news-issuances/bulletins/2023/bulletin-2023-37.html.

Guidance on venture loans

In another recent bulletin, the OCC offers guidance to banks considering venture lending — that is, commercial lending activities that target high-risk borrowers in the early, expansion, or late stages of development. According to the bulletin, the primary risks associated with venture lending include unproven cash flows, untested business models, difficulty projecting future cash flows, high liquidity needs, high investment spending, and limited refinancing or business exit options.

Typically, these risks are greater for borrowers at an earlier stage of development. The bulletin — which can be found at https://www.occ.treas.gov/news-issuances/bulletins/2023/bulletin-2023-34.html — provides guidance on managing these risks.

CFPB proposal would close overdraft loophole

The Consumer Financial Protection Bureau (CFPB) recently issued a proposed rule designed to rein in excessive overdraft fees charged by large banks. The proposal would end the exemption of overdraft lending services from the Truth in Lending Act and other consumer protection laws.

Banks would be permitted to extend overdraft loans if they comply with the requirements of these laws or, alternatively, charge a fee to recoup their costs at an established benchmark (as low as $3) or at a cost they calculate (provided they show their cost data). The proposed rule would apply only to insured financial institutions with more than $10 billion in assets, but it may be expanded to smaller institutions in the future.

© 2024