FISCAL YEAR 2022

FREEDOM OF INFORMATION ACT 

ANNUAL REPORT

U.S. Merit Systems Protection Board

February 2023
MSPB FOIA ANNUAL REPORT

FOR

10/01/2021

THROUGH

09/30/2022

The following Annual Freedom of Information Act report covers the 

Period 10/01/2021, through 09/30/2022, as required by 5 U.S.C. 552.

I. BASIC INFORMATION REGARDING REPORT 

1. Name, title, address, and telephone number of person to contact with questions 

about the Report:

William D. Spencer

Chief FOIA Officer

Merit Systems Protection Board

1615 M Street, NW, Suite 500

Washington, DC 20419

(202) 653-7200

 

2. Electronic copies of the report are on the Merit Systems Protection Board’s 

(MSPB) website at https://www.mspb.gov/FOIA/foiareports.htm. 

3. Paper copies of the report may be obtained by writing to the above address.

II. MAKING A FOIA REQUEST

1. Name, address, telephone number, and email of the MSPB office where FOIA 

requests can be filed are found below:

Office of the Clerk of the Board

1615 M Street NW

Suite 500

Washington, DC 20419

(202) 653-7200

FAX (202) 653-7130

Foiahq@mspb.gov

FOIAonline
2. BRIEF DESCRIPTION OF REQUESTS

The MSPB is an independent, quasi-judicial agency in the Executive branch that 

serves as the guardian of Federal merit systems. Many of the FOIA requests 

received by MSPB concern merit cases that have been appealed to the Board. 

The Board’s appellate records are maintained in a system of records subject to 

the Privacy Act of 1974. These records are related to MSPB’s adjudicatory 

process and customarily include all of the parties’ pleadings, allegations, notices, 

orders, and decisions issued by MSPB. Records in those case files often contain 

privacy information which is exempted in accordance with Exemption 6.

3. FOIA REGULATIONS

https://www.govinfo.gov/content/pkg/CFR-2020-title5-vol3/xml/CFR-2020-

title5-vol3-part1204.xml

III. ACRONYMS, DEFINITIONS, AND EXEMPTIONS

Acronym used in this report:

Acronym Definition

MSPB Merit Systems Protection Board

1. Definition 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 or component within the 

same 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 or component within the same 

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 (non-expedited) track based on the 

low volume and/or simplicity of the records requested.

iii. Complex Request – a FOIA request that an agency using multitrack 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 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: information that is related solely to the internal personnel 

rules and practices of an agency

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 these 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

MSPB Headquarters

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 MSPB 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

MSPB 56 138 130 64

AGENCY OVERALL 56 138 130 64
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

MSPB 29 40 7 34 0 3 0 7 6 2 2 0 130

AGENCY 

OVERALL 29 40 7 34 0 3 0 7 6 2 2 0 130

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

MSPB 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

MSPB 0 0 0 0 12 35 1 0 5 1 0 0 0 0

AGENCY 

OVERALL 0 0 0 0 12 35 1 0 5 1 0 0 0 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

MSPB 3 11 12 2

AGENCY 

OVERALL 3 11 12 2

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

MSPB 7 3 1 1 12

AGENCY 

OVERALL 7 3 1 1 12

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

MSPB 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

MSPB 0 0 1 0 0 0 0 0 0 4 0

AGENCY 

OVERALL 0 0 1 0 0 0 0 0 0 4 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

MSPB 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

MSPB 13 26.25 5 135

AGENCY 

OVERALL 13 26.25 5 135
VI.C.(5). TEN OLDEST PENDING ADMINISTRATIVE APPEALS

Agency / 

Component

10th 

Oldest 

Appeal

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

Appeal

MSPB

Date of 

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

2018-

08-21

2018-

08-21

Number 

of Days 

Pending 0 0 0 0 0 0 0 0 1025 1025

AGENCY 

OVERALL

Date of 

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

2018-

08-21

2018-

08-21

Number 

of Days 

Pending 0 0 0 0 0 0 0 0 1025 1025

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

MSPB 3 5.24 <1 31 35 249.38 1 1052 N/A N/A N/A N/A

AGENCY 

OVERALL 3 5.24 <1 31 35 249.38 1 1052 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

MSPB 4 7.13 <1 31 190 354.14 2 1052 N/A N/A N/A N/A

AGENCY 

OVERALL 4 7.13 <1 31 190 354.14 2 1052 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

MSPB 81 6 0 0 0 0 0 0 0 0 0 0 0 87

AGENCY 

OVERALL 81 6 0 0 0 0 0 0 0 0 0 0 0 87

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

MSPB 12 2 0 0 1 2 0 0 0 0 1 0 8 26

AGENCY 

OVERALL 12 2 0 0 1 2 0 0 0 0 1 0 8 26
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

MSPB 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

MSPB 15 56 100.6 48 472.5 542.63 0 N/A N/A

AGENCY 

OVERALL 15 56 100.6 48 472.5 542.63 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

MSPB

Date of 

Receipt 2019-

07-08

2019-

05-10

2019-

04-29

2019-

03-08

2019-

01-02

2018-

07-02

2018-

05-24

2018-

05-24

2017-

05-11

2017-

02-27

Number 

of Days 

Pending

808 847 855 886 937 1060 1085 1085 1346 1399

AGENCY 

OVERALL

Date of 

Receipt 2019-

07-08

2019-

05-10

2019-

04-29

2019-

03-08

2019-

01-02

2018-

07-02

2018-

05-24

2018-

05-24

2017-

05-11

2017-

02-27

Number 

of Days 

Pending

808 847 855 886 937 1060 1085 1085 1346 1399

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

MSPB 0 7 1.0 1.57 7

AGENCY 

OVERALL 0 7 1.0 1.57 7
VIII.B. Requests for Fee Waiver

Agency / 

Component

Number 

Granted Number Denied

Median Number 

of Days to 

Adjudicate

Average 

Number of Days 

to Adjudicate

MSPB 0 0 N/A N/A

AGENCY 

OVERALL 0 0 N/A N/A

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 "FullTime FOIA 

Staff"

Processing 

Costs

LitigationRelated 

Costs

Total Costs

MSPB 1 0.66 1.66 227706.00 0.00 227706.00

AGENCY 

OVERALL 1 0.66 1.66 227706.00 0.00 227706.00

X. Fees Collected for Processing Requests

Agency / 

Component

Total Amount 

of Fees 

Collected

Percentage of 

Total Costs

MSPB 0.00

AGENCY 

OVERALL 0.00
XI.A. Number of Times Subsection (C) Used

Agency / 

Component Number of Times Subsection Used

MSPB 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

MSPB 10 586

AGENCY 

OVERALL 10 586

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

MSPB 62 2

AGENCY 

OVERALL 62 2
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

MSPB 0 3 3 0

AGENCY 

OVERALL 0 3 3 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

MSPB

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

MSPB 172 138 171 130

AGENCY 

OVERALL 172 138 171 130

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 

Previous Annual 

Report

Number of 

Backlogged 

Requests as of 

End of the Fiscal 

Year from Current 

Annual Report

MSPB 48 62

AGENCY 

OVERALL 48 62
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

MSPB 15 11 14 12

AGENCY 

OVERALL 15 11 14 12

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

MSPB 3 2

AGENCY 

OVERALL 3 2