U.S. CUSTOMS SERVICE

Budget Authorization

Issues

Statement of Norman J. Rabkin

Director, Administration of Justice Issues

General Government Division

United States General Accounting Office

GAO Testimony

Before the Subcommittee on Trade

Committee on Ways and Means

House of Representatives

For Release on Delivery

Expected at

11:00 a.m. EDT

on Tuesday

April 13, 1999

GAO/T-GGD-99-79

Statement

U.S. Customs Service: Budget Authorization

Issues

Page 1 GAO/T-GGD-99-79

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today at this Customs oversight hearing to discuss

work we have done, mostly for this Subcommittee, addressing Customs’

efforts to interdict drugs, combat corruption, and comply with the Results

Act.1

 For the most part, our testimony is based on products we have issued

on each of these subjects since 1997. You also asked us to discuss the basis

for the $163 million access fee to be charged to nongovernment

organizations for the use of Customs’ automation systems as included in

the President’s fiscal year 2000 budget. Our discussion of the user fee is

based on interviews with the Office of Management and Budget (OMB),

the Department of the Treasury, and Customs officials and a review of

sections of the President’s fiscal year 2000 budget.

Created in 1789, the U.S. Customs Service is one of the federal

government’s oldest agencies. Customs is responsible for collecting

revenue from imports and enforcing customs and related laws. Customs

collects revenues of about $22 billion annually while processing an

estimated 15 million import entries and 450 million people who enter the

country. A major goal of Customs is to prevent the smuggling of drugs into

the country by creating an effective drug interdiction, intelligence, and

investigation capability to disrupt and dismantle smuggling organizations.

Customs’ workforce totals almost 20,000 employees at its headquarters, 20

Customs Management Centers, 20 Special Agent-in-Charge (SAC) offices,

and 301 ports of entry around the country.

Our work on Customs’ efforts to interdict drugs has focused on four

distinct areas: (1) internal controls over Customs’ low-risk cargo entry

programs; (2) the missions, resources, and performance measures for

Customs’ aviation program; (3) the development of a specific technology

for detecting drugs; and (4) Customs drug intelligence capabilities.

In July 1998, at the request of Senator Dianne Feinstein, we reported on

Customs’ drug-enforcement operations along the Southwest border of the

United States.2

 Our review focused on low-risk, cargo entry programs in

use at three ports—Otay Mesa, California; Laredo, Texas; and Nogales,

Arizona. To balance the facilitation of trade through ports and the

interdiction of illegal drugs being smuggled into the United States,

Customs initiated and encouraged its ports to use several programs to

 1

 Government Performance and Results Act of 1993, P.L. 103-62.

2

 Customs Service Drug Interdiction: Internal Control Weaknesses and Other Concerns With Low-Risk

Cargo Entry Programs (GAO/GGD-98-175, July 31, 1998).

Drug Interdiction

Low-Risk Cargo Entry

Programs
Statement

U.S. Customs Service: Budget Authorization Issues

Page 2 GAO/T-GGD-99-79

identify and separate low-risk shipments from those with apparently

higher smuggling risk. The Line Release Program was designed to expedite

cargo shipments that Customs determined to be repetitive, high volume,

and low risk for narcotics smuggling. In 1996, Customs implemented the

Land Border Carrier Initiative Program, which required that the Line

Release shipments across the Southwest border be transported by

Customs-approved carriers and driven by Customs-approved drivers. After

the Carrier Initiative Program was implemented, the number of Southwest

Border Line Release shipments dropped significantly. We identified

internal control weaknesses in one or more of the processes used at each

of the three ports we visited to screen Line Release applicants for entry

into the program. These weaknesses included (1) an absence of specific

criteria for determining applicant eligibility at two of the three ports, (2)

incomplete documentation of the screening and review of applicants at

two of the three ports, and (3) lack of documentation of supervisory

review and approval of decisions. During our review, Customs

representatives from northern and southern land-border cargo ports

approved draft Line Release volume and compliance eligibility criteria for

program applicants and draft recertification standards for program

participants.

The Three Tier Targeting Program—a method of targeting high-risk

shipments for narcotics inspection—was used at the three Southwest

border ports that we visited. According to officials at the three ports, the

Three Tier program had two operational problems that contributed to their

loss of confidence in the program’s ability to distinguish high- from lowrisk shipments. First, there was little information available in any database

for researching foreign manufacturers. Second, local officials doubted the

reliability of the designations. They cited examples of narcotics seizures

from shipments designated as “low-risk” and the lack of a significant

number of seizures from shipments designated as “high-risk.” Customs

suspended this program until more reliable information is developed for

classifying low-risk importations.

One low-risk entry program—the Automated Targeting System—was being

pilot tested at Laredo. It was designed to enable port officials to identify

and direct inspectional attention to high-risk shipments. The Automated

Targeting System is designed to assess shipment entry information for

known smuggling indicators and thus enable inspectors to target high-risk

shipments more efficiently. Customs is evaluating the Automated

Targeting System for expansion to other land-border cargo ports.
Statement

U.S. Customs Service: Budget Authorization Issues

Page 3 GAO/T-GGD-99-79

In September 1998, we reported on Customs’ aviation program missions,

resources, and performance measures.3

 Since the establishment of the

Customs Aviation Program in 1969, its basic mandate to use air assets to

counter the drug smuggling threat has not changed. Originally, the

program had two principle missions:

• border interdiction of drugs being smuggled by plane into the United

States and

• law enforcement support to other Customs offices as well as other federal,

state, and local law enforcement agencies.

In 1993, the administration instituted a new policy to control drugs coming

from South and Central America. Because Customs aircraft were to be

used to help carry out this policy, foreign counterdrug operations became

a third principal mission for the aviation program. Since then, the program

has devoted about 25 percent of its resources to the border interdiction

mission, 25 percent to foreign counterdrug operations, and 50 percent to

other law enforcement support.

Customs Aviation Program funding decreased from about $195 million in

fiscal year 1992, to about $135 million in fiscal year 1997—that is, about 31

percent in constant or inflation-adjusted dollars. While available funds

decreased, operations and maintenance costs per aircraft flight hour

increased. Customs Aviation Program officials said that this increase in

costs was one of the reasons they were flying fewer hours each year. From

fiscal year 1993 to fiscal year 1997, the total number of flight hours for all

missions decreased by over one-third, from about 45,000 hours to about

29,000 hours.

The size of Customs’ fleet dropped in fiscal year 1994, when Customs took

19 surveillance aircraft out of service because of funding reductions. The

fleet has remained at about 115 since then.4

 The number of Customs

Aviation Program onboard personnel dropped steadily, from a high of 956

in fiscal year 1992 to 745 by the end of fiscal year 1997.5

 

3

 Customs Service: Aviation Program Missions, Resources, and Performance Measures (GAO/GGD-98-

186, Sept. 9, 1998).

4

 Customs’ fleet will increase because additional aircraft were funded in the Fiscal Year 1999 Omnibus

Consolidated and Emergency Supplemental Appropriations Act, P.L. 105-277, 112 Stat 2681-553, 2681-

583.

5

 Staffing for the Aviation program is expected to grow to 817 in fiscal year 2000, according to Customs’

latest budget justification.

Aviation Program
Statement

U.S. Customs Service: Budget Authorization Issues

Page 4 GAO/T-GGD-99-79

Customs has been using traditional law enforcement measures to evaluate

the aviation program (e.g., number of seizures, weight of drugs seized,

number of arrests). These measures, however, are used to track activity,

not measure results or effectiveness. Until 1997, Customs also used an air

threat index as an indicator of its effectiveness in detecting illegal air

traffic.6

 However, Customs has discontinued use of this indicator, as well

as selected other performance measures, because Customs determined

that they were not good measures of results and effectiveness. Having

recognized that these measures were not providing adequate insights into

whether the program was producing desired results, Customs says it is

developing new performance measures in order to better measure results.

However, its budget submission for fiscal year 2000 contained no new

performance measures.

The pulsed fast neutron analysis (PFNA) inspection system is designed to

directly and automatically detect and measure the presence of specific

materials (e.g., cocaine) by exposing their constituent chemical elements

to short bursts of subatomic particles called neutrons. Customs and other

federal agencies are considering whether to continue to invest in the

development and fielding of this technology.

The Chairman and the Ranking Minority Member of the Subcommittee on

Treasury and General Government, Senate Committee on Appropriations,

asked us to provide information about (1) the status of plans for field

testing a PFNA system and (2) federal agency and vendor views on the

operational viability of such a system. We are issuing our report on that

work today.7

Customs, the Department of Defense (DOD), the Federal Aviation

Administration (FAA), and Ancore Corporation—the inspection system

inventor—recently began planning to field test PFNA. Because they are in

the early stage of planning, they do not expect the actual field test to begin

until mid to late 1999 at the earliest. Generally speaking, agency and

vendor officials estimated that a field test covering Customs’ and DOD’s

requirements will cost at least $5 million and that the cost could reach $8

million if FAA’s requirements are included in the joint test. Customs

officials told us that they are working closely with the appropriate

applicable congressional committees and subcommittees to decide

 

6

 The air threat index used various indicators, such as the number of stolen and/or seized aircraft, to

determine the potential threat of air drug smuggling.

7

 Terrorism and Drug Trafficking: Testing Status And Views on Operational Viability of Pulsed Fast

Neutron Analysis Technology (GAO/GGD-99-54, Apr. 13, 1999).

Pulsed Fast Neutron

Analysis Inspection System
Statement

U.S. Customs Service: Budget Authorization Issues

Page 5 GAO/T-GGD-99-79

whether Customs can help fund the field test, particularly given the nofederal-cost language of Senate Report 105-251.8

 In general, a complete

field test would include (1) preparing a test site and constructing an

appropriate facility; (2) making any needed modifications to the only

existing PFNA system and its components;9

 (3) disassembling, shipping,

and reassembling the system at the test site; and (4) conducting an

operational test for about 4 months. According to agency and Ancore

officials, the test site candidates are two seaports in California (Long

Beach and Oakland) and two land ports in El Paso, Texas.

Federal agency and vendor views on the operational viability of PFNA

vary. While Customs, DOD, and FAA officials acknowledge that laboratory

testing has proven the technical feasibility of PFNA, they told us that the

current Ancore inspection system would not meet their operational

requirements. Among their other concerns, Customs, DOD, and FAA

officials said that a PFNA system not only is too expensive (about $10

million to acquire per system), but also is too large for operational use in

most ports of entry or other sites. Accordingly, these agencies question the

value of further testing. Ancore disputes these arguments, believes it can

produce an operationally cost-effective system, and is proposing that a

PFNA system be tested at a port of entry. The Office of National Drug

Control Policy has characterized neutron interrogation as an “emerging” or

future technology that has shown promise in laboratory testing and thus

warrants field testing to provide a more informed basis for deciding

whether PFNA has operational merit.

At the request of the Subcommittee on National Security, International

Affairs, and Criminal Justice, House Committee on Government Reform

and Oversight,10 in June 1998 we identified the organizations that collect

and/or produce counterdrug intelligence, the role of these organizations,

the federal funding they receive, and the number of personnel that support

this function.11 We noted that more than 20 federal or federally funded

organizations, including Customs, spread across 5 cabinet-level

departments and 2 cabinet-level organizations, have a principal role in

 8

 Senate Report 105-251 (July 1998) on the fiscal year 1999 Treasury and General Government

Appropriations bill directs the Commissioner of Customs to enter into negotiations with the private

sector to conduct a field test of the PFNA technology at no cost to the federal government.

9

 The existing (prototype) PFNA system is located at the vendor’s plant in Santa Clara, CA.

10 This is now the Subcommittee on National Security, Veterans’ Affairs, and International Relations of

the House Committee on Government Reform.

11 Drug Control: An Overview of U.S. Counterdrug Intelligence Activities (GAO/NSIAD-98-142, June 25,

1998).

Federal Counterdrug

Intelligence Coordination

Efforts
Statement

U.S. Customs Service: Budget Authorization Issues

Page 6 GAO/T-GGD-99-79

collecting or producing counterdrug intelligence. Together, these

organizations collect domestic and foreign counterdrug intelligence

information using human, electronic, photographic, and other technical

means.

Unclassified information reported to us by counterdrug intelligence

organizations shows that over $295 million was spent for counterdrug

intelligence activities during fiscal year 1997 and that more than 1,400

federal personnel were engaged in these activities. The Departments of

Justice, the Treasury, and Defense accounted for over 90 percent of the

money spent and personnel involved.

Among its many missions, Customs is the lead agency for interdicting

drugs being smuggled into the United States and its territories by land, sea,

or air. Customs’ primary counterdrug intelligence mission is to support its

own drug enforcement elements (i.e., inspectors and investigators) in their

interdiction and investigation efforts. Customs is responsible for producing

tactical, operational, and strategic intelligence concerning drug-smuggling

individuals, organizations, transportation networks, and patterns and

trends. In addition to providing these products to its own drug

enforcement elements, Customs is to provide this information to other

agencies with drug enforcement or intelligence responsibilities. Customs is

also responsible for analyzing the intelligence community’s reports and

integrating them with its own intelligence. Customs’ in-house collection

capability is heavily weighted toward human intelligence, which comes

largely from inspectors and investigators who obtain information during

their normal interdiction and investigation activities.

On March 30, 1999, we issued a report to the Chairman of the Senate

Caucus on International Narcotics Control on the efforts of Customs and

the Immigration and Naturalization Service to address employee

corruption on the Southwest border.12 We said that both agencies could do

more to prevent drug-related employee corruption. The following reflects

our findings and recommendations relative to Customs and Customs’

response to our report.

Customs has policies and procedures designed to ensure the integrity of its

employees. These policies and procedures consist mainly of mandatory

background investigations for new staff and 5-year reinvestigations of

employees, as well as basic integrity training. As required, Customs

 

12 Drug Control: INS and Customs Can Do More to Prevent Drug-Related Employee Corruption

(GAO/GGD-99-31, Mar. 30, 1999).

Corruption
Statement

U.S. Customs Service: Budget Authorization Issues

Page 7 GAO/T-GGD-99-79

generally had completed background investigations for new hires by the

end of their first year on the job. However, reinvestigations were typically

overdue, in some instances by as many as 3 years. Customs officials said

that the basic training that new employees are to receive includes integrity

training. Agency records for 88 of 100 randomly selected Customs

employees on the Southwest border showed that they received several

hours of integrity training as part of their basic training. According to

Customs officials, the remaining employees likely received basic training,

but it was not documented in their records.

However, Customs was not taking full advantage of these policies and

procedures, as well as the lessons it should have learned from closed

corruption cases, to address fully the increased threat of employee

corruption on the Southwest border. Some Customs employees on the

Southwest border have engaged in a variety of illegal drug-related

activities, including waving drug loads through ports of entry, coordinating

the movement of drugs across the Southwest border, transporting drugs

past Border Patrol checkpoints, selling drugs, and disclosing drug

intelligence information. Customs’ Office of Internal Affairs is required to

formally report internal control weaknesses identified from closed

corruption cases, but has not done so. Our review of nine cases involving

Customs employees assigned to the Southwest border who were convicted

of drug-related crimes between fiscal years 1992 and 1997, revealed

internal control weaknesses that were not formally reported and/or

corrected.13 These weaknesses included instances where

• drug smugglers chose the inspection lane at a port of entry,

• employees did not recuse themselves from inspecting individuals with

whom they had close personal relationships, and

• employees disclosed drug intelligence information.

Also, Customs had not formally evaluated its integrity procedures to

determine their effectiveness. For example, we determined that financial

information required for background investigations and reinvestigations

was not fully reviewed.14

 

13 If employees entered guilty pleas, we considered them to have been convicted of the crime.

14 The Department of the Treasury’s Office of Professional Responsibility published a report on

corruption with findings that are consistent with ours. See An Assessment of Vulnerabilities to

Corruption and Effectiveness of the Office of Internal Affairs, U.S. Customs Service (Feb. 1999).
Statement

U.S. Customs Service: Budget Authorization Issues

Page 8 GAO/T-GGD-99-79

We recommended that Customs

• evaluate the effectiveness of integrity assurance efforts, including training,

background investigations, and reinvestigations;

• comply with policies that require employment reinvestigations to be

completed when they are due;

• document that policies and procedures were reviewed to identify internal

control weaknesses in cases where an employee is determined to have

engaged in drug-related criminal activities;

• strengthen internal controls at Southwest border ports of entry; and

• fully review financial disclosure statements to identify financial issues,

such as cases in which employees appear to be living beyond their means.

Customs generally concurred with our recommendations and indicated

that it is taking steps to implement them. However, Customs requested

that we reconsider our recommendation that it fully review the financial

disclosure statements provided by employees as part of the background

and reinvestigation process. Customs indicated that implementing this

recommendation may violate the provisions of the Computer Matching

Act.15 Our recommendation expects Customs to make a more thorough

examination of the financial information it collects to determine whether

employees appear to be living beyond their means. We leave it to Customs’

discretion to determine the type of examination to be performed. Since

implementing the recommendation does not require electronically

matching financial disclosure information with other data, the Computer

Matching Act would not apply.

In the past 18 months, we have reported on Customs’ compliance with

provisions of the Government Performance and Results Act. We have also

reported on how it has determined its need for inspectors and how it has

allocated inspectional positions to ports around the country.

Under the Results Act, executive agencies are to develop strategic plans in

which they, among other things, define their missions, establish resultsoriented goals, and identify strategies they plan to use to achieve those

goals. In addition, agencies are to submit annual performance plans

covering the program activities set out in the agencies’ budgets (which

 

15 The Computer Matching and Privacy Protection Act of 1988, P.L. 100-503, generally requires that

agencies engaging in computer matching must do so pursuant to written matching agreements that

state such things as the purpose and legal authority of the match, the justification for the matching

program, its anticipated results, a description of the records to be matched, as well as other

information on the program.

Strategic Planning

Performance Planning
Statement

U.S. Customs Service: Budget Authorization Issues

Page 9 GAO/T-GGD-99-79

began with plans for fiscal year 1999); and the plans are to describe the

results the agencies expect to achieve with the requested resources and

indicate the progress the agency expects to make during the year in

achieving its strategic goals.

The strategic plan developed by the Customs Service addressed the six

requirements of the Results Act. Concerning the elements required, the

mission statement was results oriented and covered Customs’ principal

statutory mission—ensuring that all goods and persons entering and

exiting the United States do so in compliance with all U.S. laws and

regulations. The plan’s goals and objectives covered Customs’ major

functions—processing cargo and passengers entering and cargo leaving

the United States. The plan discussed the strategies by which Customs

hopes to achieve its goals. The strategic plan discussed, in very general

terms, how it related to annual performance plans. The plan discussed

some key factors, external to Customs and beyond its control, that could

significantly affect achievement of the strategic goals, such as the level of

cooperation of other countries in reducing the supply of narcotics.

Customs’ strategic plan also contained a listing of program evaluations

used to prepare the plan and provided a schedule of evaluations to be

conducted in each of the functional areas.

In addition to the required elements, Customs’ plan discussed the

management challenges it was facing in carrying out its core functions,

including information and technology, finance, and human resources

management. However, the plan did not adequately recognize Customs’

need to improve

• financial management and internal control systems,

• controls over seized assets,

• plans to alleviate Year 2000 problems,16 and

• plans to improve computer security.17

We reported that these weaknesses could affect the reliability of Customs’

performance data.

 

16 Customs has established effective Year 2000 program management controls, including structures and

processes for Year 2000 testing, contingency planning, and Year 2000 status reporting. See Year 2000

Computing Crisis: Customs Has Established Effective Year 2000 Program Controls (GAO/AIMD-99-37,

Mar. 29, 1999).

17 See Customs Service: Comments on Strategic Plan and Resource Allocation Process (GAO/T-GGD-98-

15, Oct. 16, 1997) and Results Act: Observations on Treasury’s Fiscal Year 1999 Annual Performance

Plan (GAO/GGD-98-149, June 30, 1998).
Statement

U.S. Customs Service: Budget Authorization Issues

Page 10 GAO/T-GGD-99-79

Further, our initial review of Customs’ fiscal year 2000 performance plan

showed that it is substantially unchanged in format from the one presented

for 1999. Although the plan is a very useful document for decisionmakers,

it still does not recognize Customs’ need to improve its internal control

systems, control over seized assets, or plans to improve computer security.

Regarding Customs’ resource allocation process, in April 1998 we reported

on selected aspects of the Customs Service’s process for determining its

need for inspectional personnel—such as inspectors and canine

enforcement officers—for its commercial cargo or land and sea passengers

at all of its 301 ports.18

Customs officials were not aware of any formal agencywide efforts prior to

1995 to determine the need for additional cargo or passenger inspectional

personnel for its 301 ports. However, in preparation for its fiscal year 1997

budget request and a new drug enforcement operation called Hard Line,19

Customs conducted a formal needs assessment. The needs assessment

considered (1) fully staffing all inspectional booths and (2) balancing

enforcement efforts with the need to move complying cargo and

passengers quickly through the ports. Customs conducted two subsequent

assessments for fiscal years 1998 and 1999. These assessments considered

the number and location of drug seizures and the perceived threat of drug

smuggling, including the use of rail cars to smuggle drugs. However, all

these assessments were

• focused exclusively on the need for additional personnel to implement

Hard Line and similar initiatives,

• limited to land ports along the southwest border and certain sea and air

ports considered to be at risk from drug smuggling,

• conducted each year using generally different assessment factors, and

• conducted with varying degrees of involvement by Customs’ headquarters

and field units.

We concluded that these limitations could prevent Customs from

accurately estimating the need for inspectional personnel and then

 

18 Customs Service: Process for Estimating and Allocating Inspectional Personnel (GAO/GGD-98-107,

Apr. 30, 1998); Customs Service: Inspectional Personnel and Workloads (GAO/GGD-98-170, Aug. 14,

1998); and Customs Service: Inspectional Personnel and Workloads (GAO/T-GGD-98-195, Aug. 14,

1998).

19 Operation Hard Line was Customs’ effort to address border violence and drug smuggling through

intensified inspections, improved facilities, and advances in technology.

Resource Allocation
Statement

U.S. Customs Service: Budget Authorization Issues

Page 11 GAO/T-GGD-99-79

allocating them to ports. We further concluded that, for Customs to

implement the Results Act successfully, it had to determine its needs for

inspectional personnel for all of its operations and ensure that available

personnel are allocated where they are needed most.

We recommended that Customs establish an inspectional personnel needs

assessment and allocation process, and it is in the process of responding to

that April 1998 recommendation. Customs awarded a contract for the

development of a resource allocation model. Customs officials told us that

the model was delivered in March 1999 and that they are in the early stages

of deciding how to use the model and implement a formal needs

assessment system.

Customs plans to spend more than $1 billion over the next few years to

modernize its systems environment for certain core missions, including

facilitating international trade, enforcing laws governing the flow of goods

across the borders, and assessing and collecting about $22 billion annually

on imported merchandise. To pay for the development and implementation

of new automated systems, the President’s budget for fiscal year 2000

proposes a Customs automation systems access fee to be charged to

nongovernment organizations using the system—generally, importers or

their brokers. As currently proposed by the administration, the fee will

amount to $1.80 per 1,000 bytes of information processed by Customs for

commercial users and should generate an estimated $163 million in

revenue per year. Collection of this fee is tentatively scheduled to start in

fiscal year 2000 and to continue for at least the following 4 or 5 years.

You asked us to discuss the basis for the $163 million estimate. According

to Treasury officials, the estimate is based on the following three

assumptions:

• Customs will develop and implement the Automated Commercial

Environment (ACE) over a 4-year period (from fiscal year 2001 to fiscal

year 2004) at a total cost of over $1 billion.20

• Treasury will develop and implement its new International Trade Data

System (ITDS) over the same period at a cost of about $256 million.

• The federal government and the trade community will share the cost of

these systems. Therefore, the $325 million annual cost ($1.3 billion / 4

years, the period to develop and implement the two systems) would be

split—$162.5 million each.

 

20 In 1997, Customs developed a $1.05 billion estimate to develop, operate, and maintain ACE over the

15-year period from 1994 to 2008, and it is still Customs’ current official life cycle cost estimate.

Proposed Automated

Systems User Fee
Statement

U.S. Customs Service: Budget Authorization Issues

Page 12 GAO/T-GGD-99-79

In addition to the $163 million generated by the user fee, additional funds

would be needed from other sources, including direct appropriations, in

each of the four fiscal years beginning in 2001. OMB and Treasury officials

told us that additional appropriated funds already in the budget base will

be directed to the development and implementation of the systems. These

officials also said that current estimates are preliminary and are likely to

change when a contract to develop the systems is awarded.

Customs projected that it will process about 90.5 billion bytes of data

annually for commercial users of its system. Dividing the $163 million

annual cost proposed to be borne by the trade community by the expected

volume yields a charge of $1.80 per 1,000 bytes of information.

Mr. Chairman, this completes my statement. I would be pleased to answer

any questions.
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