Law Office of Linda Dozier, PLLC 

1629	K	Street,	NW,	Suite	300

Washington,	DC		20006

(571)	766-6406

July 21, 2015

Filed electronically at e-ORI@dol.gov

Office of Regulations and Interpretations

Employee Benefits Security Administration

Attn: Conflict of Interest Rule

Room N-5655

U.S. Department of Labor

200 Constitution Avenue, NW

Washington, D.C. 20210

Re: Definition of “Fiduciary,” RIN 1210-AB32

Dear Sir or Madam:

The purpose of these comments is to reemphasize the enforcement-related 

reasons for revising the definition of “fiduciary” as it relates to the rendering of

investment advice and to examine and evaluate the practical implications of 

enforcing the proposed regulation.

1 As explained in these comments, a final

regulation that includes clear and consistent EBSA enforcement standards and 

procedures will best protect plans, participants, and plan fiduciaries, and ensure

that consultants and advisers are afforded fair and efficient methods of complying 

with the regulation.

2

I. ENFORCEMENT ISSUES UNDER THE 1975 REGULATION

Revising the definition of “fiduciary” as it relates to giving investment advice is 

important to address EBSA’s long-standing enforcement issues with the existing 5-

part test. The preamble to the proposed regulation notes that plan fiduciaries often 

hire consultants and advisers to assist them in performing their investment duties. 

																																																							 1 The opinions expressed in this letter are my own and do not reflect the opinions 

of any other person, organization, or agency. Although I submit these comments 

as a private practitioner, I spent more than 22 years as a professional in the 

Employee Benefits Security Administration’s (EBSA’s) Office of Enforcement.

2 I do not address how this regulation may affect Individual Retirement Accounts 

(IRAs) because EBSA does not have enforcement jurisdiction over IRAs.
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Under the current 5-part test, if those consultants and advisers have conflicts of 

interest and the plan experiences a loss or engages in a prohibited transaction 

resulting from the plan fiduciary’s reliance on the consultant or adviser’s conflicted 

advice, the fiduciary may bear the full burden of liability for that loss. The 

consultant or adviser can avoid being cited as a fiduciary because one or more of 

the elements of the 5-part test are not satisfied and the consultant/adviser is not 

otherwise a fiduciary. The plan fiduciary then is in the unfair position of having 

relied on expert advice in order to more prudently perform its fiduciary duties, but 

nevertheless bears the liability that results from the adviser’s conflicted interests.

EBSA investigators work diligently to compile the evidence necessary to identify 

the person or entity responsible for a fiduciary breach. However, in order to cite an 

investment adviser for a fiduciary breach under ERISA in cases where fiduciary 

status cannot otherwise be established, an investigator must establish a factual 

record that supports each element of the 5-part test. Specifically, the 5-part 

test requires that, to be found a fiduciary, the adviser must have: 

(1) Rendered advice as to the value of specific securities or other property, 

or made recommendations as to the advisability of investing in, purchasing, 

or selling securities or other property, (2) on a regular basis (3) under a 

mutual agreement, arrangement, or understanding with the plan or plan 

fiduciary (4) that the advice would serve as a primary basis for investment 

decisions with respect to plan assets, and (5) that the advice would be 

individualized based on the particular needs of the plan. 

The most problematic elements are the requirements that the advice have been 

rendered on a regular basis and that there have been a mutual agreement or 

understanding that the advice would be a primary basis for the plan fiduciary’s 

specific investment decision. As noted in the preamble, the regular basis 

requirement is an artifact of the 1970’s that needs to be eliminated because expert 

advice today is routinely furnished on a one-time basis. 

The “mutual agreement, arrangement or understanding” requirement presents a 

more difficult question. On the one hand, consultants and advisers often take 

advantage of this requirement and effectively avoid fiduciary liability by merely 

including disclaimers in their service contracts with plans. Such disclaimers 

explicitly deny that any mutual agreement exists regarding the fiduciary’s ability to 

rely on the investment advice as a primary basis for making an investment 
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decision. On the other hand, consultants and advisers nevertheless proceed to 

offer the investment advice on which the plan fiduciary relies.

The disclaimer practice is the most egregious when plan fiduciaries seek advice 

from consultants or other experts to assist them in their fiduciary duties, proceed to 

rely on the advice, and only learn later that the adviser’s conflicts or other 

operational failures made the advice unreliable. In addition, because of their 

reliance (despite the disclaimer), plan fiduciaries may fail to ask questions aimed at 

identifying and evaluating the adviser’s conflicts of interest. In this respect, the 

Department correctly seeks to eliminate the abusive practices by which consultants 

and advisers act to induce plan fiduciaries to rely on their services while 

disclaiming responsibility. Nevertheless, the Department must exercise care to 

avoid inappropriately imposing fiduciary liability on consultants and advisers who 

actually do not expect or intend that their professional services will be relied upon 

by plan fiduciaries in making investment decisions.

Once an investigator finds that the 5-part test cannot be used to establish fiduciary 

status, the investigation may instead focus on whether the consultant or adviser 

can be deemed to have acted as a de facto fiduciary under a functional analysis. 

That is, the investigator must determine whether fiduciary status was conferred by 

virtue of the fact that the consultant or adviser actually exercised discretionary 

authority or control over the investment of the plan’s assets. Typically, consultants 

and advisers are careful not to step over the line whereby they would either have 

control and authority over a plan fiduciary’s investment decision or directly over the 

plan’s assets. Thus, depending on the facts and circumstances of a particular 

investigation, establishing the factual record to demonstrate fiduciary status of a 

consultant or adviser in such cases is extremely complex, time-consuming, and 

expensive both for the Government and the person or entity that is the subject of 

the investigation.3 

While the1975 regulation has presented enforcement challenges to the 

Department for many years, the issue came to a head nearly ten years ago when, 

in 2005, the U.S. Securities and Exchange Commission issued its “Staff Report 

																																																							 3 The preamble to the first proposal published in the Federal Register in 2010 (See 

U.S. Department of Labor, Employee Benefits Security Administration, 75 Fed. 

Reg. 65263 (proposed October 22, 2010) (referred to herein as the “2010 

Proposal) discussed many of the enforcement concerns arising from the 5-part 

test. In the current 2015 proposal these concerns are not included in the 

preamble.
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Concerning Examinations of Select Pension Consultants, May 16, 2005” (the “SEC 

Report”). 4 In preparing the report, the SEC’s Office of Compliance Inspections 

and Examinations (OCIE) examined 24 large pension consultants. OCIE found, 

among other things, that more than half (13) of the pension consultants or their 

affiliates had ongoing relationships with both pension plans and money managers 

and that, for some of these consultants, the compensation received from the 

money managers comprised a significant part of their annual revenue. Further, 

while OCIE could not definitively conclude that consultants skewed their 

recommendations to investments handled by specific money managers with whom 

they had relationships, it did find that most of the pension consultants provided 

their plan clients with little or no disclosure of their relationships with or services 

provided to the money managers.5

As explained in the SEC Report, under the securities laws, 

an adviser owes its clients a duty of “utmost good faith, and full and fair 

disclosure of all material facts” as well as an affirmative obligation “to 

employ reasonable care to avoid misleading clients.” Thus, the Advisers Act 

in recognition of the adviser’s fiduciary duty [under the securities laws], 

requires advisers to provide disinterested advice, and to ensure this,

requires advisers to disclose material facts. Whether an adviser’s 

relationships with other parties create a material conflict of interest depends 

on the facts and circumstances.6 

In contrast to the securities law standard that mandates disinterested advice and 

disclosure, ERISA requires fiduciaries to act in accordance with the higher 

standards of conduct derived from trust law principles. In particular, ERISA 

requires that fiduciaries discharge their duties to the plan “solely in the interest of 

the participants and beneficiaries” and for the “exclusive purpose” of providing 

benefits and defraying reasonable expenses.7 Furthermore, ERISA fiduciaries 

must act in accordance with the prudent man standard that requires the fiduciary to 

discharge his duties with the “care, skill, prudence, and diligence under the 

circumstances then prevailing that a prudent man acting in a like capacity and 

familiar with such matters would use in the conduct of an enterprise of a like 

																																																							 4 https://www.sec.gov/news/studies/pensionexamstudy.pdf (the SEC Report)

5 Id., pp. 5-6.

6 Id., pp. 1-2.

7 29 U.S.C. section 1104(a)(1)(A)
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character and with like aims.”8 In addition to these overarching trust law 

principles, ERISA fiduciaries are also charged with avoiding prohibited transactions 

unless a statutory or administrative exemption applies. 

Although the SEC addressed certain conflicts of interest through its 2005 

examination project and subsequent enforcement efforts, the SEC Report’s 

findings prompted EBSA to institute its own investigative review to determine 

whether conflicts of interest had resulted in losses to the plans that might be 

addressed under ERISA’s more demanding fiduciary rules. Accordingly, following 

the issuance of the SEC Report, EBSA’s Office of Enforcement commenced a 

national enforcement project styled the “Consultant and Adviser Project (CAP).” 

The CAP was intended to determine whether there were conflict of interest issues 

that should be addressed under ERISA and whether plans had, as a consequence, 

incurred losses that could be recovered. 

EBSA’s National Office worked closely with its Regional Offices to identify 

appropriate investigative targets, plan investigations to address issues, analyze the 

resultant evidence, cite violations, and obtain corrections. A major challenge that 

the CAP presented was the fact that it was very difficult and resource intensive to 

determine whether the pension consultants and advisers were fiduciaries under the 

5-part test. The disclaimer provisions in the service contracts and other similar 

issues often made it difficult to establish fiduciary status under the 5-part test. 

Thus, despite dedicating valuable investigative resources to address potentially 

serious conflicts of interest, EBSA was unable to pursue potential violations, at 

least in part, because of the 5-part test.9

Despite enforcement results that were limited by the 1975 regulation, the CAP 

provided compelling evidence that the Department needed to take concrete steps 

to eliminate the 5-part test and structure a new standard that defines fiduciary 

investment advice in a manner more consistent with the statutory language. The 

language of the statute states simply that “ . . . a person is a fiduciary with respect 

to a plan to the extent . . . he renders investment advice for a fee or other 

compensation, direct or indirect, with respect to any moneys or other property of 

such plan, or has any authority or responsibility to do so.” 10

																																																							 8 29 U.S.C. section 1104(a)(1)(B)

9 See the 2010 Proposal at pp. 65271-2. 10 29 U.S.C. section 1002(21)(A)(ii)
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Accordingly, the revised definition of fiduciary should define investment advice in a 

manner that is consistent with the law itself but also recognizes the practical 

implications that any such revision will have (1) for the adviser industry that seeks

to comply in good faith with the regulation, and (2) for the Government when it 

seeks to fairly and effectively enforce the regulation. 

II. DEFINITION OF “RECOMMENDATION” IN THE PROPOSED 

REGULATION

Under the proposed regulation defining “fiduciary” in connection with rendering 

investment advice, the term “investment advice” includes, among other things, (1) 

“a recommendation as to the advisability of acquiring, holding, disposing or 

exchanging securities or other property . . .” and (2) “a recommendation as to the 

management of securities or other property. “11 Thus, the definition of the term 

“recommendation” is critical to determining whether a communication by a 

consultant or adviser to a plan, plan fiduciary, or plan participant rises to the level 

of being a “recommendation” that could result in the adviser being deemed a 

fiduciary under ERISA. The proposed regulation defines a “recommendation” as 

being “a communication that, based on its content, context, and presentation, 

would reasonably be viewed as a suggestion that the advice recipient engage in or 

refrain from taking a particular course of action” [emphasis added]. 12 The 

preamble indicates that the language of this definition has been taken from the 

Financial Industry Regulatory Authority (“FINRA”) guidance relating to its suitability 

rule.13 The Department specifically requests comments on whether it should adopt 

some or all of the standards developed by FINRA in defining the term 

“recommendation.” 

Setting clear and consistent guidelines for EBSA enforcement actions requires 

adopting a final regulation that defines what constitutes a “recommendation” with a 

																																																							 11 75 Fed. Reg. 21956 (proposed April 20, 2015)

12 Id., 21960

13 FINRA Rule 2111 is the suitability rule which states that firms and their 

associated persons “must have a reasonable basis to believe” that a transaction or 

investment strategy involving security that they recommend is suitable for the 

customer. This reasonable belief must be based on the information obtained 

through the reasonable diligence of the firm or associated person to ascertain the 

customer’s investment profile. http://www.finra.org/investors/suitability-whatinvestors-need-know
Definition of “Fiduciary,” RIN 1210-AB32

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level of certainty comparable to the one that EBSA investigators currently use in 

determining de facto fiduciary status. The proposed definition does not satisfy this 

standard. A reasonable level of certainty for determining what constitutes a 

“recommendation” that confers fiduciary status is essential, not only because 

consultants and advisers need to know when they are fiduciaries and must 

therefore comply with ERISA’s many rules and requirements, but also because 

such certainty is necessary for effective, efficient EBSA enforcement. 

For the following reasons, I urge the Department to amend the proposed definition 

of “recommendation” because it is too vague to ensure fair, effective, and 

consistent enforcement. 

As an initial matter, FINRA’s broad language defining the term “recommendation” 

is not appropriate in the ERISA context. FINRA uses this general definition to 

evaluate unsuitable recommendations but, importantly, investment advisers and 

their representatives already know by virtue of registration when they are subject to 

FINRA’s rules. In contrast, ERISA investment advice fiduciary status is not 

determined through registration, but instead is determined through application of 

the definition in the regulation implementing the statute. Accordingly, a specific 

definition or standard is essential to ensure that an adviser knows and understands 

the extent of his applicable fiduciary responsibilities and potential liabilities.

The dangers of adopting too vague a definition are twofold: consultants and 

advisers will not necessarily know when they are acting as fiduciaries, but also 

EBSA investigators will encounter uncertainty when determining which consultants 

and advisers are subject to ERISA’s fiduciary requirements. In this regard, 

investigators may be reluctant to cite a consultant or adviser for an ERISA violation 

when the person appears to have acted in good faith and was genuinely unaware 

of having acted as a fiduciary in committing a breach. Such uncertainty would 

have many serious consequences such as increased and unnecessary costs to 

those investigated, increased delays in completing investigations while seeking 

interpretive guidance, increased litigation, and a greater likelihood that 

enforcement resources will focus largely on the more “obvious” cases. Only by 

revising the proposed regulation to provide greater clarity for the meaning of 

“recommendation” can the Department avoid wasting valuable investigative 

resources and avoid substantially increasing costs to the consultants and advisers 

subject to EBSA investigations while possibly allowing more egregious violations to 

go unaddressed. 
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III. SUGGESTED REVISIONS TO THE PROPOSED DEFINITION OF 

“RECOMMENDATION”

In the interests of ensuring compliance and fair and effective enforcement, the 

definition of “recommendation” should be revised so that it is consistent with 

ERISA’s statutory scheme. Specifically, the definition of “recommendation” 

contained in the final regulation should reflect the ERISA elements of discretionary 

control and authority when evaluating whether the content and context of a 

communication rises to the level of a “recommendation.” Doing so would replace 

the subjectivity of the proposed definition with objective standards and help 

improve the ability of consultants and advisers to comply with ERISA’s fiduciary 

requirements. The following are presented as criteria that could be applied to 

specific circumstances when determining whether a communication is a 

recommendation: 

• CONTEXT-RELATED FACTORS:

o Communication Responds to Fiduciary Request for Advice. Did the 

adviser provide the communication in response to a plan fiduciary’s 

request for advice or assistance relating to a specific investmentrelated decision? Having responded to a request from a plan 

fiduciary for substantive guidance on a specific investment decision 

would establish the context in which the plan fiduciary would 

reasonably expect to rely on the adviser’s response and the adviser 

could expect to be deemed a fiduciary. 

o Communication Is Expected to Convey Judgment and/or Expert 

Knowledge On Which Fiduciary May Reasonably Rely. Regardless 

of whether the adviser disclaimed having made a recommendation, 

did the adviser provide a judgment or conclusion based on special 

knowledge or expertise that the adviser knew, or should have known, 

the plan fiduciary lacked and would reasonably rely on in making the 

investment decision? 
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• CONTENT-RELATED FACTORS:

o Discretion Used in Producing the Communication. To what extent 

did the adviser exercise discretion in deciding the content and 

conclusion presented to the plan fiduciary? Did the adviser merely 

follow an established formula in developing the content or one 

dictated by the fiduciary, or instead did the adviser affirmatively 

choose what content to include and/or exclude? Was the 

selection/exclusion of the content a key factor in supporting the 

conclusion that was subsequently presented to the plan fiduciary?

o Communication Substantively Argues for a Specific Outcome. 

Regardless of whether the adviser specified that the communication 

was merely investment information or education, or otherwise stated

that the communication was not a recommendation, did the 

communication present information in a manner calculated to 

influence the plan fiduciary to take a specific action or seek a specific 

result? For example, even if an adviser stated he is not making a

specific recommendation, if the content of the communication was

persuasively structured to lead to a specific investment outcome, the 

adviser would nevertheless have exercised a degree of “control” or 

“authority” by effectively arguing in favor of (or against) a particular 

course of action. 

o Level of Analysis Supports Plan’s Reliance on Communication. Was 

the level of analysis contained in the communication sufficient that a 

plan fiduciary could reasonably rely on the judgment underlying the

conclusions in the communication when executing his fiduciary 

duties? For example, did the communication include an analysis 

comparing the costs, benefits, or risks of different investment options 

with a level of detail that provided the plan fiduciary with the 

necessary direction to make the investment decision? 

For purposes of this discussion I have not separately addressed the term 

“presentation” that is included in the proposed regulation because it should not be 

a determining factor in whether a communication rises to the level of a 

recommendation. This term should be excluded because the manner of 
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presentation does not affect the content of the communication nor the relevant 

context in which it is rendered and also does not implicate the elements of ERISA 

fiduciary status, namely discretionary control or authority. Instead, the final 

regulation should include broad language making clear that any communication, no 

matter how presented, is subject to analysis as long as it satisfies the context and 

content factors. 

IV. COMPILING EVIDENCE REGARDING FIDUCIARY STATUS 

Because ERISA is an extremely complex statute, gathering evidence and 

analyzing potential violations is often a time-consuming and difficult task, both for 

the Government and the party being investigated. Accordingly, the final regulation 

defining investment advice “fiduciary” should explicitly address the potential 

difficulties in proving or disproving certain elements of the definitions adopted in 

the final regulation. 

For example, assume an investigator interviews a plan fiduciary who states that 

she had a meeting with her pension consultant and he recommended, based on 

the plan’s specific needs, that she invest the plan’s assets in a particular private 

equity fund. The investigator then interviews the consultant who states that, while 

he provided the plan fiduciary with educational information about different 

investment options, he explicitly stated and explained to the plan fiduciary that he 

did not recommend any specific investment product. Because the advice was 

provided verbally, there is no documentary evidence or third party to corroborate

either statement. 

Under these circumstances, an investigator must determine whether the 

communication rises to the level of being a recommendation that would make the 

consultant an investment advice fiduciary. What other proof should the 

investigator look to other than uncorroborated statements by the two parties? As 

indicated above, if the Department adopts a more precise definition of what 

constitutes a recommendation through the application of specific determining 

factors, the investigator likely could compile evidence of the factors related to the 

content and context of the communication that would permit a determination of 

whether a “recommendation” was made. 

For example, the investigator could gather information about the extent to which 

the consultant analyzed the plan’s specific investment needs and the manner in 

which an investment in the private equity fund could meet those needs. Likewise, 
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the investigator could determine whether the plan fiduciary requested a 

recommendation and whether she sought the advice because of the consultant’s 

level of expertise. Having gathered this type of information for all of the applicable 

factors, an investigator would then weigh the facts to determine whether the 

preponderance of the evidence objectively indicated conduct consistent with the 

exercise of fiduciary authority and control by the consultant or adviser regarding 

the content and context of the communication whereby it constituted a 

recommendation for purposes of the regulation. 

To heighten its effectiveness, the final regulation should include specific 

evidentiary guidelines that will provide the foundation for weighing the key factors 

to determine fiduciary status when the evidence, particularly verbal statements, is

not conclusive. For example, if the evidence shows that the fiduciary had 

previously relied on the consultant’s expertise in making a difficult investment 

decision and the consultant was familiar with the needs of the plan, such evidence 

might be used to demonstrate fiduciary status even though there is no 

documentary evidence of the actual rendering of the “recommendation.” Clear 

guidelines for making such inferences must be spelled out in the final regulation, 

however, because inferences based on context where there is no nexus between 

the separate acts might inappropriately lead to a finding of fiduciary status.

For example, take the case of an adviser who provided written advice to a plan 

fiduciary on May 19th recommending investment in the ABC private equity fund but 

claims to have provided investment education information only on the XYZ private 

equity fund one month later on June 20th. At that time the discussion between the

adviser and plan fiduciary occurred over lunch with no other witnesses and no 

written record. In both instances the plan fiduciary claims the adviser provided 

investment advice on which the fiduciary believes he could reasonably rely 

whereas the adviser admits only to having provided investment advice in May but 

not at the June meeting. The question that investigators must answer is whether 

the context in which the communication was given on June 20th includes making a 

contextual inference based on the rendering of written advice one month earlier. 

In this case the evidentiary problem of having an uncorroborated verbal 

communication combined with a contextual inference could lead to a conclusion 

that unfairly characterizes the adviser’s communication as a recommendation that 

occurred on June 20th. Thus, including contextual inferences in the definition of 

“recommendation” would require the Department to define the extent to which 

evidence of such facts may be used and relied upon for enforcement purposes. 
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The limits of using such inferences to establish fiduciary status should be stated 

and explained, preferably with examples, in the final regulation itself. 

Once having established fiduciary status based on contextual inference, the 

closely related question is whether a fiduciary breach was committed with respect 

to a particular transaction. For example, using the example described above, if an 

investigator finds that the adviser rendered fiduciary investment advice on June 

20th based on the “context” of having admitted to rendering advice on May 19th, did 

the adviser commit a fiduciary breach on June 20th? Assuming that the adviser 

performed extensive due diligence in connection with the recommendation on May 

19th, but performed no due diligence in connection with the communication to the 

plan fiduciary on June 20th, is this a breach of the prudence rule and, if so, is it fair 

to cite the adviser for a fiduciary breach in one transaction where fiduciary status 

can only be inferred based on an entirely separate transaction?

Unlike investigations of de facto fiduciaries where evidence of fiduciary status is 

established on a transaction-by-transaction basis and includes concrete evidence 

such as, trust account signature cards, execution orders, and trade confirmations, 

among other things, investigations of fiduciary investment advice are far more 

likely to involve reconciling conflicting verbal statements. Therefore, unless there 

is supporting documentation regarding the rendering of investment advice, 

investigators might proceed to rely on the context in which the advice was 

rendered which could lead to array of problems including litigation. Thus, the 

Department should clarify both the limits of using contextual inferences as 

evidence of fiduciary status, but also precisely explain how such contextual 

evidence will be used in finding and citing fiduciary breaches. 

V. CONCLUSION AND RECOMMENDATIONS

As the Department proceeds to finalize the regulation, it is critical that its terms are 

fairly and effectively enforced. With that goal in mind, the Department should 

further consider the following:

• Because the term “recommendation” is central to a finding of fiduciary status

in rendering investment advice, the term should be precisely defined in the 

context of ERISA’s central themes of discretionary authority and control and 

implemented through the application of both specific content and context 

factors that can be proven through direct and indirect evidence. 
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• The Department should clarify that inferences drawn from the context of the 

communication cannot be applied to other transactions to substantiate a 

substantive violation. 

• The Department should clarify that enforcement actions under the final 

regulation will not rely solely on oral evidence where there is no 

corroboration. In addition, evidence relating to contextual or content factors 

would substantively negate any disclaimer asserted by the adviser. 

• The term “presentation” should be deleted from the definition of 

“recommendation” because the mere fact that recommendations may differ 

in how they are presented should not determine fiduciary status. 

In summary, while advisers and consultants will work to comply with the new 

regulation once it is finalized, the proposed definition of “recommendation” is both 

vague and ambiguous and will make it difficult for consultants and advisers to 

know when they are fiduciaries in specific circumstances. In addition, rather than 

providing a desirable degree of flexibility to EBSA’s enforcement efforts, the 

ambiguity and vagueness of the proposed definition will more likely impede 

effective and efficient enforcement in a manner comparable to the 5-part test. 

Accordingly, the Department should revise the definition of “recommendation” to 

include content and contextual factors, develop evidentiary guidelines for proving 

such factors, and explain the application of the factors and their evidentiary 

limitations through a series of examples in the regulation. By doing these things, 

the Department will better ensure fairness to the advisory industry as well as more 

effective, efficient, and consistent enforcement of ERISA’s fiduciary rules and 

regulations. 

* * * * * * * * * * * * *

Thank you for the opportunity to comment on this very important proposed 

regulation. If you have any questions, please do not hesitate to contact me at 

(571) 766-6406.

Sincerely,

Linda Dozier, Esq.

Law Office of Linda Dozier, PLLC