FARM CREDIT ADMINISTRATION

Freedom of Information Act Annual Report

FY 2019

I. BASIC INFORMATION REGARDING REPORT 

1. Name, title, address, and telephone number of person(s) to be contacted with questions about the Report: 

Jane M. Virga, Assistant General Counsel, Chief FOIA Officer

Farm Credit Administration

Office of General Counsel 

1501 Farm Credit Drive

McLean, Virginia 22102-5090

703-883-4071

Autumn R. Agans, FOIA Officer

Farm Credit Administration

Office of General Counsel 

1501 Farm Credit Drive

McLean, Virginia 22101-5090

703-883-4082

2. Electronic address for the Report on the World Wide Web:

http://www.fca.gov/home/freedom_info.html

3. How to obtain a copy of the Report in paper form: 

Contact Jane Virga or Autumn Agans, at the above address. 

II. MAKING A FOIA REQUEST
1. FOIA requests to FCA must be made by mail, facsimile, or email at the following addresses:

Freedom of Information Act Officer

1501 Farm Credit Drive 

McLean, VA 22102-5090

703-883-4431

Fax: 703-790-0052

foiaofficer@fca.gov

Note: the FCA does not have any individual agency components. 

2. The FOIA is a law that gives the public access to Federal agency records unless they are exempt or excluded from being 

subject to the FOIA. Under the various FOIA exemptions, the FCA withholds confidential financial and commercial 

information, personal information, deliberative materials, attorney work product, legal advice, and bank examination 

materials. Examples of these kinds of records are: Reports of Examination and workpapers, memoranda containing 

advice and recommendations, legal opinions, personal notes, and some personnel records. The FCA typically releases 

the following records: Bookletters, Informational memoranda, newsletters, news releases, the telephone directory, 

salary information, the Policy and Procedure Manual, and transcripts of public testimony.

With respect to exclusions, Congress excluded three discrete categories of law enforcement and national security 

records from FOIA’s requirements. See 5 U.S.C. § 552(c) (2006 & Supp. IV (2010)). Thus, FCA limits its responses to 

those records that are subject to the FOIA’s requirements. FCA provides a notice to this effect on its webpage and in 

every FOIA response and thus requesters should not take such notices as an indication that excluded records do, or do 

not, exist. 

3. How to access the Agency FOIA regulations: 

https://www.fca.gov/home/freedom_info.html

FCA’s FOIA Fee Schedule:
https://www.fca.gov/required-notices/submitting-a-foia-request

III. ACRONYMS, DEFINITIONS, AND EXEMPTIONS 

1. Agency-specific acronyms or other terms. 

 Farm Credit Administration (FCA or Agency) 

1. Definitions of terms used in this Report:

a. Administrative Appeal – a request to a federal agency asking that it review at a higher administrative level a FOIA 

determination made by the agency at the initial request level.

b. Average Number – the number obtained by dividing the sum of a group of numbers by the quantity of numbers in the 

group. For example, of 3, 7, and 14, the average number is 8. 

c. Backlog – the number of requests or administrative appeals that are pending at an agency at the end of the fiscal year that 

are beyond the statutory time period for a response. 

d. Component – for agencies that process requests on a decentralized basis, a “component” is an entity, also sometimes 

referred to as an Office, Division, Bureau, Center, or Directorate, within the agency that processes FOIA requests. The 

FOIA now requires that agencies include in their Annual FOIA Report data for both the agency overall and for each 

principal component of the agency.

e. Consultation -- the procedure whereby the agency responding to a FOIA request first forwards a record to another agency 

for its review because that other agency has an interest in the document. Once the agency in receipt of the consultation 

finishes its review of the record, it responds back to the agency that forwarded it. That agency, in turn, will then respond to 

the FOIA requester.

f. Exemption 3 Statute – a federal statute that exempts information from disclosure and which the agency relies on to 

withhold information under subsection (b)(3) of the FOIA.
g. FOIA Request – a FOIA request is generally a request to a federal agency for access to records concerning another person 

(i.e., a “third-party” request), or concerning an organization, or a particular topic of interest. FOIA requests also include 

requests made by requesters seeking records concerning themselves (i.e., “first-party” requests) when those requesters are 

not subject to the Privacy Act, such as non-U.S. citizens. Moreover, because all first-party requesters should be afforded 

the benefit of both the access provisions of the FOIA as well as those of the Privacy Act, FOIA requests also include any 

first-party requests where an agency determines that it must search beyond its Privacy Act “systems of records” or where a 

Privacy Act exemption applies, and the agency looks to FOIA to afford the greatest possible access. All requests which 

require the agency to utilize the FOIA in responding to the requester are included in this Report. 

Additionally, a FOIA request includes records referred to the agency for processing and direct response to the requester. It 

does not, however, include records for which the agency has received a consultation from another agency. (Consultations 

are reported separately in Section XII of this Report.)

h. Full Grant -- an agency decision to disclose all records in full in response to a FOIA request. 

i. Full Denial – an agency decision not to release any records in response to a FOIA request because the records are exempt 

in their entireties under one or more of the FOIA exemptions, or because of a procedural reason, such as when no records 

could be located. 

j. Median Number – the middle, not average, number. For example, of 3, 7, and 14, the median number is 7.

k. Multi-Track Processing – a system in which simple requests requiring relatively minimal review are placed in one 

processing track and more voluminous and complex requests are placed in one or more other tracks. Requests granted 

expedited processing are placed in yet another track. Requests in each track are processed on a first in/first out basis. 

i. Expedited Processing – an agency will process a FOIA request on an expedited basis when a requester satisfies 

the requirements for expedited processing as set forth in the statute and in agency regulations. 

ii. Simple Request – a FOIA request that an agency using multi-track processing places in its fastest (nonexpedited) track based on the low volume and/or simplicity of the records requested. 
iii. Complex Request – a FOIA request that an agency using multi-track processing places in a slower track based 

on the high volume and/or complexity of the records requested. 

l. Partial Grant/Partial Denial – in response to a FOIA request, an agency decision to disclose portions of the records and to 

withhold other portions that are exempt under the FOIA, or to otherwise deny or otherwise deny a portion of the request for a

procedural reason. 

m. Pending Request or Pending Administrative Appeal – a request or administrative appeal for which an agency has not 

taken final action in all respects. 

n. Perfected Request – a request for records which reasonably describes such records and is made in accordance with published 

rules stating the time, place, fees (if any) and procedures to be followed. 

o. Processed Request or Processed Administrative Appeal – a request or administrative appeal for which an agency has 

taken final action in all respects. 

p. Range in Number of Days – the lowest and highest number of days to process requests or administrative appeals. 

q. Time Limits – the time period in the statute for an agency to respond to a FOIA request (ordinarily twenty working days 

from receipt of a perfected FOIA request). 

2. Concise descriptions of the nine FOIA exemptions:

a. Exemption 1: classified national defense and foreign relations information

b. Exemption 2: internal agency rules and practices

c. Exemption 3: information that is prohibited from disclosure by another federal law

d. Exemption 4: trade secrets and other confidential business information

e. Exemption 5: inter-agency or intra-agency communications that are protected by legal privileges
f. Exemption 6: information involving matters of personal privacy

g. Exemption 7: records or information compiled for law enforcement purposes, to the extent that the production of those 

records (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to 

a fair trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal 

privacy, (D) could reasonably be expected to disclose the identity of a confidential source, (E) would disclose techniques and 

procedures for law enforcement investigations or prosecutions, or would disclose guidelines for law enforcement 

investigations or prosecutions, or (F) could reasonably be expected to endanger the life or physical safety of any individual

h. Exemption 8: information relating to the supervision of financial institutions

i. Exemption 9: geological information on wells
3. Agency Component Abbreviations

Component 

Abbreviation Component Name

FCA Farm Credit Administration

IV. Exemption 3 Statutes

Statute

Type of 

Information

Withheld

Case Citation Agency / 

Component

Number of 

Times

Relied 

upon

by Agency / 

Component

Total 

Number 

of

Times 

Relied 

upon

by 

Agency 

Overall

N/A N/A N/A FCA 0 0

V.A. FOIA REQUESTS -- RECEIVED, PROCESSED AND PENDING FOIA REQUESTS

Agency / Component

Number of 

Requests

Pending as of 

Start

of Fiscal Year

Number of

Requests 

Received

in Fiscal Year

Number of

Requests 

Processed

in Fiscal Year

Number of 

Requests

Pending as of 

End

of Fiscal Year

FCA 2 21 21 2

AGENCY OVERALL 2 21 21 2
V.B.(1). DISPOSITION OF FOIA REQUESTS -- ALL PROCESSED REQUESTS

Agency / 

Component

Number 

of Full 

Grants

Number 

of 

Partial 

Grants / 

Partial 

Denials

Number of 

Full Denials 

Based on 

Exemptions

Number of Full Denials Based on Reasons Other than Exemptions

No 

Records

All Records 

Referred to 

Another 

Component 

or Agency

Request 

Withdrawn

FeeRelated 

Reason

Records 

not 

Reasonably 

Described

Improper 

FOIA 

Request 

for Other 

Reason

Not 

Agency 

Record

Duplicate 

Request

Other 

*Explain 

in Chart 

Below

TOTAL

FCA 7 5 0 6 0 3 0 0 0 0 0 0 21

AGENCY 

OVERALL 7 5 0 6 0 3 0 0 0 0 0 0 21

V.B.(2). DISPOSITION OF FOIA REQUESTS -- "OTHER" REASONS FOR "FULL DENIALS BASED ON REASONS OTHER THAN EXEMPTIONS"

Agency / 

Component

Description of "Other" Reasons for Denials from 

Chart B(1)

Number 

of Times 

"Other" 

Reason 

Was 

Relied 

Upon

TOTAL

FCA N/A 0 0

AGENCY 

OVERALL 0
V.B.(3). DISPOSITION OF FOIA REQUESTS -- NUMBER OF TIMES EXEMPTIONS APPLIED

Agency / 

Component

Ex. 

1

Ex. 

2

Ex. 

3

Ex. 

4

Ex. 

5

Ex. 

6

Ex. 

7(A)

Ex. 

7(B)

Ex. 

7(C)

Ex. 

7(D)

Ex. 

7(E)

Ex. 

7(F)

Ex. 

8

Ex. 

9

FCA 0 0 0 0 3 0 0 0 0 0 0 0 2 0

AGENCY 

OVERALL 0 0 0 0 3 0 0 0 0 0 0 0 2 0

VI.A. ADMINISTRATIVE APPEALS OF INITIAL DETERMINATIONS OF FOIA REQUESTS -- RECEIVED, PROCESSED, AND PENDING ADMINISTRATIVE 

APPEALS

Agency / 

Component

Number of 

Appeals

Pending as of 

Start

of Fiscal Year

Number of

Appeals 

Received

in Fiscal Year

Number of

Appeals 

Processed

in Fiscal Year

Number of 

Appeals

Pending as of 

End

of Fiscal Year

FCA 0 0 0 0

AGENCY 

OVERALL 0 0 0 0

VI.B. DISPOSITION OF ADMINISTRATIVE APPEALS -- ALL PROCESSED APPEALS
Agency / 

Component

Number 

Affirmed on 

Appeal

Number Partially 

Affirmed & Partially 

Reversed/Remanded 

on Appeal

Number Completely 

Reversed/Remanded 

on Appeal

Number of 

Appeals 

Closed for 

Other 

Reasons

TOTAL

FCA 0 0 0 0 0

AGENCY 

OVERALL 0 0 0 0 0

VI.C.(1). REASONS FOR DENIAL ON APPEAL -- NUMBER OF TIMES EXEMPTIONS APPLIED

Agency / 

Component

Ex. 

1

Ex. 

2

Ex. 

3

Ex. 

4

Ex. 

5

Ex. 

6

Ex. 

7(A)

Ex. 

7(B)

Ex. 

7(C)

Ex. 

7(D)

Ex. 

7(E)

Ex. 

7(F)

Ex. 

8

Ex. 

9

FCA 0 0 0 0 0 0 0 0 0 0 0 0 0 0

AGENCY 

OVERALL 0 0 0 0 0 0 0 0 0 0 0 0 0 0

VI.C.(2). REASONS FOR DENIAL ON APPEAL -- REASONS OTHER THAN EXEMPTIONS
Agency / 

Component

No 

Records

Records 

Referred 

at Initial 

Request 

Level

Request 

Withdrawn

FeeRelated 

Reason

Records 

not 

Reasonably 

Described

Improper 

Request 

for Other 

Reasons

Not 

Agency 

Record

Duplicate 

Request 

or 

Appeal

Request 

in 

Litigation

Appeal 

Based 

Solely on 

Denial of 

Request 

for 

Expedited 

Processing

Other 

*Explain 

in chart 

below

FCA 0 0 0 0 0 0 0 0 0 0 0

AGENCY 

OVERALL 0 0 0 0 0 0 0 0 0 0 0

VI.C.(3). REASONS FOR DENIAL ON APPEAL -- "OTHER" REASONS

Agency / 

Component

Description of "Other" Reasons for Denial on 

Appeal from Chart C(2)

Number of 

Times 

"Other" 

Reason 

Was Relied 

Upon

TOTAL

FCA N/A 0 0

AGENCY 

OVERALL 0
VI.C.(4). RESPONSE TIME FOR ADMINISTRATIVE APPEALS

Agency / 

Component

Median Number 

of Days

Average 

Number of Days

Lowest Number 

of Days

Highest Number 

of Days

FCA 0 0 0 0

AGENCY 

OVERALL 0 0 0 0

VI.C.(5). TEN OLDEST PENDING ADMINISTRATIVE APPEALS

Agency / 

Component

10th 

Oldest 

Appeal

9th 8th 7th 6th 5th 4th 3rd 2nd Oldest 

Appeal

FCA

Date of 

Appeal N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Number 

of Days 

Pending 0 0 0 0 0 0 0 0 0 0

AGENCY 

OVERALL

Date of 

Appeal N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Number 

of Days 

Pending 0 0 0 0 0 0 0 0 0 0
VII.A. FOIA REQUESTS -- RESPONSE TIME FOR ALL PROCESSED PERFECTED REQUESTS

Agency / 

Component

SIMPLE COMPLEX EXPEDITED PROCESSING

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

FCA 5 8.7 <1 36 N/A N/A N/A N/A N/A N/A N/A N/A

AGENCY 

OVERALL 5 8.7 <1 36 N/A N/A N/A N/A N/A N/A N/A N/A

VII.B. PROCESSED REQUESTS -- RESPONSE TIME FOR PERFECTED REQUESTS IN WHICH INFORMATION WAS GRANTED

Agency / 

Component

SIMPLE COMPLEX EXPEDITED PROCESSING

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

FCA 10.5 11.83 <1 36 N/A N/A N/A N/A N/A N/A N/A N/A

AGENCY 

OVERALL 10.5 11.83 <1 36 N/A N/A N/A N/A N/A N/A N/A N/A
VII.C. PROCESSED SIMPLE REQUESTS -- RESPONSE TIME IN DAY INCREMENTS

Agency / 

Component

<1-

20

Days

21-

40

Days

41-

60

Days

61-

80

Days

81-

100 

Days

101-

120 

Days

121-

140 

Days

141-

160 

Days

161-

180 

Days

181-

200 

Days

201-

300 

Days

301-

400 

Days

401+

Days TOTAL

FCA 19 2 0 0 0 0 0 0 0 0 0 0 0 21

AGENCY 

OVERALL 19 2 0 0 0 0 0 0 0 0 0 0 0 21

The two FOIA requests that were processed in 21-40 day range were pending during the 

government-wide furlough, and we could not obtain permission from other agencies to 

release information that was generated in their offices of Inspector General.

VII.C. PROCESSED COMPLEX REQUESTS -- RESPONSE TIME IN DAY INCREMENTS

Agency / 

Component

<1-

20

Days

21-

40

Days

41-

60

Days

61-

80

Days

81-

100 

Days

101-

120 

Days

121-

140 

Days

141-

160 

Days

161-

180 

Days

181-

200 

Days

201-

300 

Days

301-

400 

Days

401+

Days TOTAL

FCA 0 0 0 0 0 0 0 0 0 0 0 0 0 0

AGENCY 

OVERALL 0 0 0 0 0 0 0 0 0 0 0 0 0 0

VII.C. PROCESSED REQUESTS GRANTED EXPEDITED PROCESSING -- RESPONSE TIME IN DAY INCREMENTS
Agency / 

Component

<1-

20

Days

21-

40

Days

41-

60

Days

61-

80

Days

81-

100 

Days

101-

120 

Days

121-

140 

Days

141-

160 

Days

161-

180 

Days

181-

200 

Days

201-

300 

Days

301-

400 

Days

401+

Days TOTAL

FCA 0 0 0 0 0 0 0 0 0 0 0 0 0 0

AGENCY 

OVERALL 0 0 0 0 0 0 0 0 0 0 0 0 0 0

VII.D. PENDING REQUESTS -- ALL PENDING PERFECTED REQUESTS

Agency / 

Component

SIMPLE COMPLEX EXPEDITED PROCESSING

Number 

Pending

Median 

Number 

of Days

Average 

Number 

of Days

Number 

Pending

Median 

Number 

of Days

Average 

Number 

of Days

Number 

Pending

Median 

Number 

of Days

Average 

Number 

of Days

FCA 2 9 9 0 N/A N/A 0 N/A N/A

AGENCY 

OVERALL 2 9 9 0 N/A N/A 0 N/A N/A

VII.E. PENDING REQUESTS -- TEN OLDEST PENDING PERFECTED REQUESTS
Agency / 

Component

10th 

Oldest 

Request

9th 8th 7th 6th 5th 4th 3rd 2nd Oldest 

Request

FCA

Date of 

Receipt N/A N/A N/A N/A N/A N/A N/A N/A

2019-

09-24

2019-

09-20

Number 

of Days 

Pending 0 0 0 0 0 0 0 0 5 7

AGENCY 

OVERALL

Date of 

Receipt N/A N/A N/A N/A N/A N/A N/A N/A

2019-

09-24

2019-

09-20

Number 

of Days 

Pending 0 0 0 0 0 0 0 0 5 7

VIII.A. REQUESTS FOR EXPEDITED PROCESSING

Agency / 

Component

Number 

Granted

Number 

Denied

Median 

Number of 

Days to 

Adjudicate

Average 

Number of 

Days to 

Adjudicate

Number 

Adjudicated 

Within Ten 

Calendar 

Days

FCA 0 0 0 0 0

AGENCY 

OVERALL 0 0 0 0 0
VIII.B. Requests for Fee Waiver

Agency / 

Component

Number 

Granted Number Denied

Median Number 

of Days to 

Adjudicate

Average 

Number of Days 

to Adjudicate

FCA 5 0 5 7

AGENCY 

OVERALL 5 0 5 7

IX. FOIA Personnel and Costs

Agency / 

Component

PERSONNEL COSTS

Number of 

"Full-Time 

FOIA 

Employees"

Number of 

"Equivalent 

Full-Time 

FOIA 

Employees"

Total 

Number of 

"Full-Time 

FOIA 

Staff"

Processing 

Costs

LitigationRelated 

Costs

Total Costs

FCA 0 2.00 2.00 32000.00 0.00 32000.00

AGENCY 

OVERALL 0 2.00 2.00 32000.00 0.00 32000.00
X. Fees Collected for Processing Requests

Agency / 

Component

Total Amount 

of Fees 

Collected

Percentage of 

Total Costs

FCA 0.00 0%

AGENCY 

OVERALL 0.00 0.0000

XI.A. Number of Times Subsection (C) Used

Agency / 

Component Number of Times Subsection Used

FCA 0

AGENCY OVERALL 0
XI.B. Number of Subsection (A)(2) Postings

Agency / 

Component

Number of 

Records Posted 

by the FOIA 

Office

Number of 

Records Posted 

by Program 

Offices

FCA 0 10

AGENCY 

OVERALL 0 10

XII.A. Backlogs of FOIA Requests and Administrative Appeals

Agency / 

Component

Number of 

Backlogged 

Requests as of 

End of Fiscal 

Year

Number of 

Backlogged 

Appeals as of 

End of Fiscal 

Year

FCA 0 0

AGENCY 

OVERALL 0 0

XII.B. CONSULTATIONS ON FOIA REQUESTS -- RECEIVED, PROCESSED, AND PENDING CONSULTATIONS
Agency / 

Component

Number of 

Consultations 

Received from 

Other Agencies 

that were 

Pending at the 

Agency as of 

Start

of the Fiscal 

Year

Number of

Consultations 

Received from 

Other Agencies 

During the Fiscal 

Year

Number of 

Consultations 

Received from 

Other Agencies 

that were 

Processed by 

the Agency 

During the Fiscal 

Year

Number of 

Consultations 

Received from 

Other Agencies 

that were 

Pending at the 

Agency as of 

End

of the Fiscal 

Year

FCA 0 0 0 0

AGENCY 

OVERALL 0 0 0 0

XII.C. CONSULTATIONS ON FOIA REQUESTS -- TEN OLDEST CONSULTATIONS RECEIVED FROM OTHER AGENCIES AND PENDING AT THE AGENCY

Agency / 

Component

10th Oldest 

Consultation 9th 8th 7th 6th 5th 4th 3rd 2nd Oldest Consultation

FCA

Date N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Number 

of Days 0 0 0 0 0 0 0 0 0 0

AGENCY 

OVERALL

Date N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Number 

of Days 0 0 0 0 0 0 0 0 0 0
XII.D.(1). COMPARISON OF NUMBERS OF REQUESTS FROM PREVIOUS AND CURRENT ANNUAL REPORT -- REQUESTS RECEIVED AND 

PROCESSED

Agency / 

Component

NUMBER OF REQUESTS RECEIVED NUMBER OF REQUESTS 

PROCESSED

Number 

Received During 

Fiscal Year from 

Last Year's 

Annual Report

Number 

Received During 

Fiscal Year from 

Current Annual 

Report

Number 

Processed 

During Fiscal 

Year from Last 

Year's Annual 

Report

Number 

Processed 

During Fiscal 

Year from 

Current Annual 

Report

FCA 23 21 21 21

AGENCY 

OVERALL 23 21 21 21

XII.D.(2). COMPARISON OF NUMBERS OF REQUESTS FROM PREVIOUS AND CURRENT ANNUAL REPORT -- BACKLOGGED REQUESTS

Agency / 

Component

Number of 

Backlogged 

Requests as of 

End of the Fiscal 

Year from 

Number of 

Backlogged 

Requests as of 

End of the Fiscal 
Previous Annual 

Report

Year from Current 

Annual Report

FCA 0 0

AGENCY 

OVERALL 0 0

XII.E.(1). COMPARISON OF NUMBERS OF ADMINISTRATIVE APPEALS FROM PREVIOUS AND CURRENT ANNUAL REPORT -- APPEALS RECEIVED 

AND PROCESSED

Agency / 

Component

NUMBER OF APPEALS RECEIVED NUMBER OF APPEALS PROCESSED

Number 

Received During 

Fiscal Year from 

Last Year's 

Annual Report

Number 

Received During 

Fiscal Year from 

Current Annual 

Report

Number 

Processed 

During Fiscal 

Year from Last 

Year's Annual 

Report

Number 

Processed 

During Fiscal 

Year from 

Current Annual 

Report

FCA 0 0 0 0

AGENCY 

OVERALL 0 0 0 0

XII.E.(2). COMPARISON OF NUMBERS OF ADMINISTRATIVE APPEALS FROM PREVIOUS AND CURRENT ANNUAL REPORT -- BACKLOGGED 

APPEALS
Agency / 

Component

Number of 

Backlogged 

Appeals as of End 

of the Fiscal Year 

from Previous 

Annual Report

Number of 

Backlogged 

Appeals as of End 

of the Fiscal Year 

from Current 

Annual Report

FCA 0 0

AGENCY 

OVERALL 0 0