It is in the report, sir. It is the amount both by the number of loans and the dollar amount that they loan.
What is your standard? When does a bank do right? What percentage, how many loans? What are your standards?
It really depends on the peer group as an industry. You certainly can expect less, and should expect less, from a very small bank, and expect more from a very large bank. That, we do.
Or read it into the record. I understand you have them available. Why don't you do that. Let us hear what we tell banks we expect of them.
This report is about 200 pages. How far do you want me to read?
Read the part that you think makes the point you just made.
Any banks that fails to provide a fair share of housing loans in low and moderate income neighborhoods can and should be denied city banking business and deposits. That's as clear a statement as we can make.
What is a fair share? Give us numbers or percentages. What is a fair share?
As long as the total 305 BILL 980003 growth is going up, and there is not an economic reason for it to go down, that is, as an industry, a good indicator of effort.
So if you go from percent to percent of your loans in low income areas, the bank is doing well, even though it is an insignificant amount of the bank's assets?
Those numbers are much higher than that, Councilman. It is going to take me a minute to pull it, but those numbers are bogus.
Yes. You are engaged in a harangue. What you need to do now is put upon the record a fair example of what you think bears out the point you are making. To say to read the report is a snippy response, and is not a response to the Councilman's question. If you have an example, if you can have an example in your report that says sanctions 306 BILL 980003 will be invoked when this standard is not met, tell us what the standard is.
That's going to be too vague to be useful. Give us an example of dollars and tell us when you have invoked the sanction, if ever.
Yes, we have. I am trying to get the bank to do better. As I said, I would rather not mention who they are.
It ought to be clear to you by now that that is not an acceptable answer. You are not going to be able to cloak somebody and shield them from the effects of their acts or their failure to act. So you are going to have to put somebody on the record for falling below some reasonable standard, or you are going to have 307 BILL 980003 to take the weight for being unwilling or unable to answer the question.
I am not sure what question you want me to answer, Councilwoman.
I think that's been what the problem was, that you are not answering because you don't understand the question. Mr. Cohen's question, it seems to me, is, at what point does a bank fall below an acceptable level of a social responsibility? And when that has happened, what sanctions will you apply? And when, if ever, have you applied that sanction? That seems to me a very clear question.
When given the size of the bank and the need, the posity of numbers in low and moderate income areas, that we believe that they could and should do better. That has happened.
Do you think that's going to be acceptable to me or Cohen?
Don't you think that's what you have been saying for the last 4 minutes? 5
Don't you think 7 now we need to say a number below which they will 8 not be accepted? Don't you think we are looking for 9 the name? We even are going to ask you when you 10 invoke this sanction. 11 So you are not going to be able to 12 protect whoever it is you think you are protecting. 13
And we are going 16 to make you say it on a public record. You are not 17 going to be able to send us a report. 18 So either there is no sanction, that 19 there is a little sweetheart deal going on, or there 20 is a sanction and you have applied it, and somebody has been required to pay some dues for it. I mean, it is going to have to break down like that. I know you understand the question. Do you? 309 BILL 980003
Let me back up for just a moment, Councilwoman, and just talk a second about the unfairness of what's taking place here. We wouldn't do this if our goals weren't the same as yours. We wouldn't take the effort to write this report, circulate it to the banks. This is something we initiated. It is a very recent event. It is only four years old. So it is annoying -- and I apologize if I am snippy -- it is very annoying to have your motives challenged when you are doing exactly what you would have us do. That's terribly unfair.
I don't question your motives. I give you an opportunity to show what you are doing. Not to infer, not to hint; to show specifically what you got. I have tried to ask this question as clearly as I can. Do you consider the question unfair?
I am reluctant to name the bank that we did this to, yes. 310 BILL 980003
Then give me a hypothetical. But you can't talk about when somebody falls below some acceptable level. You know we are not going to accept that. Banks don't compute interest on some acceptable level. This is a very concrete set of transactions.
It is not. Because the size of the bank also determines what you can expect of them. Of the four largest banks in the city, those that are remaining, they have increased their lending over time since we have been doing this.
Have all of them been at the exact same rate, or have some been better than others?
Some have been better because you expect more from banks that have larger assets.
All right. Of those who have been given much and of whom much is required, are some taking the much and doing too little?
So every bank with which we do business is way above what we would require of them, had we the right and the will to require it?
I believe that the larger bank, that's the case. I think of the smaller banks, we have reason for concern.
Let's talk about those who are failing to meet our reasonable expectation. Are some banks suggesting themselves to you by name in the definition I just gave, banks which fail to meet our reasonable expectation of socially responsible?
Of the larger banks, I don't believe that's the case. 312 BILL 980003
Whatever their size, Mr. Hayllar. Whatever their size. If we are doing business with a bank that is failing to be socially responsible -- are there any such?
I think there are banks that can do better, and I want them to do better.
Did you not understand my question, or are you simply refusing to use my language?
Then let me help you with it. Are there banks with whom the City of Philadelphia does banking business, those banks which fail to meet our reasonable expectations of socially responsible? Are there such?
So every bank 313 BILL 980003 with whom the City of Philadelphia does business meets our minimum standard of socially responsible?
That's a yes/no 7 question, Mr. Hayllar. That's a yes/no question.
By the virtue of we do business with them, the answer is yes.
So everybody with whom we do business meets our reasonable responsibility, our reasonable level of social responsibility?
Yes. It may not be what you agree with, but I believe the answer is yes.
Because much of it is a subjective answer. We look at the size of the bank, what it purports to do in the marketplace, we look at what its lending is.
This is now like Charlie Brown's teacher, whacka, whacka, whacka. We 314 BILL 980003 are not getting anywhere with this. But I think you understand what I am saying, and I understand that you stonewalled me. I am going to give the record back.
Yes. I yielded to Councilwoman Clark. Two things that trouble me. It seems to me the City of Philadelphia has enormously low expectations from banks. Because if anybody says that the banks today in Philadelphia, including all the major ones, are doing a good job by giving a fair share of their loans to moderate and low income areas, they are living in a different world than I am living in. Go to any neighborhood in the City of Philadelphia, and any public meeting raise that question, and you will find total condemnation of banks from every point of view. So if the government of the city 315 BILL 980003 feels the banks are doing a good job, they have no 3 relationship whatever with the citizens. Secondly, the question I raised of you on the voting, what did that have to do with your answer about a fiduciary relationship? I raise the question of the Mayor's vote on the merger that's coming up later this month, I think February 27. There is a stockholder's meeting. The Pension Board owns 15,000 shares of stock in CoreStates. Is that 15,000 shares of stock going to be voted in favor of firing thousands of Philadelphians, or is it going to be voted against firing them? The issue is that simple, yet there seems to be great hesitation at the city Administration's level, at the Mayor's level, of what to do in that situation, with the leaning and the direction of voting to support CoreStates. Tell me, if that happens, what's the message going to be to the people of Philadelphia as to the attitude of the city government toward them?
We are still addressing the issue of how the Pension Fund is going to vote. 316 BILL 980003 We have not made a decision.
Well, when are you going to make a decision? Shouldn't you be busy now rallying support for a no vote from the state Pension Fund, from every labor union Pension Fund that exists, from every source? Instead, the leader of the America's Mayor is sitting quietly by and letting CoreStates and First Union make the decision that will give a couple hundred million dollars to the President of CoreStates, that will give him annual salaries of a million or more, while thousands of Philadelphians are thrown out of work? What's the problem going out in front and saying it is bad, Philadelphia, we are against it, and we are urging all workers' Pension Funds and all other Pension Funds to vote in support of jobs and against the layoffs that this merger will induce? Why aren't we out in front on that?
We have to make a decision as to what is in the best interest of the Fund, and that is the decision we are currently grappling with. 317 BILL 980003
But in the meantime you are totally ineffective in rallying support. The Mayor has been down in Washington rallying for support in a number of changes in federal policy. And that's good and that's helpful to the city, that's helpful to all cities. Why isn't he doing it now? Is it because there is a business involved? And is the answer in Philadelphia that if you are a business, it is open season, do whatever you want, the government will support you, even if it means cutting down on city revenue, even if it means taking jobs away from Philadelphians? I think the people of Philadelphia are entitled to an answer from the Mayor with respect to that.
Well, I believe the stockholders' meetings for First Union and CoreStates are on the 27th of the month.
Tell me, First Union, from what's been reported in the press, would they be doing a fair job, would you say, in the loan policy? 318 BILL 980003
I haven't gotten First Union's numbers. I have First Fidelity's numbers.
I am not referring to your report. I am referring to what's appeared in the press recently, with the fact that First Union turns down the vast majority of applications it gets for loans from minority communities, while by a 3-to-1 ratio it supports the loan requests made by communities that are totally white, or overwhelmingly white. You saw that. It was in the newspaper within the last week or ten days.
I am saying I don't know if it is true. That's what we want to know.
Doesn't that concern you, with at least a number of us, and I think the vast majority of us feel in Council, is a 319 BILL 980003 very inadequate record by the banks in making loans, wouldn't it concern you that this merger involves a company from outside of Philadelphia, which has a notoriously bad, maybe the worst record of any bank in the country, with respect to loans in low-income neighborhoods? Wouldn't that concern you?
Especially when the bank, I think you rated CoreStates very highly along all other Philadelphia banks.
Then tell me, what's the reason of the concern or the delay, and what does this have to do with a fiduciary relationship of any kind?
We have to evaluate financially what the merger means to the participants in terms of the value of the fund, and that is what we are doing.
And it isn't enough to you that thousands of Philadelphians are going to be laid off? 320 BILL 980003
Of course it is. But as a fiduciary, we have to look at how it affects the fund itself.
Tell me, how could it affect the fund adversely in any significant way? You know, I don't mind your making these speeches for the record. But we have a fund that's worth over $3 billion right now. We have 15,000 shares of stock. An infinitesimal percentage of it would be point 000, maybe 10 or 15 or 20 zeros, before you would even get to a 1 at the end. How could whatever we did have any impact?
That is part of the deliberations. You are correct, that is a factor.
Madam Chair, it just makes no sense whatever. Thank you, Madam Chair.
You are welcome. The Chair recognizes Councilman Rizzo.
Thank you, Madam 321 BILL 980003 Chair. Mr. Hayllar, I would like to go back to the space consolidation. Can you hear me okay? When you came to us and discussed the purchase of One Parkway, there was very little conversation at that time that you would need additional office space to house 619 additional employees. When you anticipated a move to One Parkway, didn't you tell us that that would accommodate all of the employees?
I certainly hope not. From the beginning, it had always been our plan that we would have a group of employees and quasi employees, agencies that are not necessarily branches of government, but nonprofits for which we work very closely, for example, that we would want to find rental space for them. So that was always part of the plan. We never said -- at least I hope we never said -- that we would put all the remaining employees in One Parkway, because we knew we couldn't.
The employees that 322 BILL 980003 are moving into One Parkway, many of them are coming from leased space?
All of them. Now, we are moving to the Land Title Building, hopefully, that's your goal.
To move 350 employees in the 100 South Broad Street. This building, City Hall, it is pretty quiet. This is a big building. Why do we need to lease space? Do we know the available space in this building, before we start moving people to rental space?
I know where you are going. And they are, I think, very appropriate questions. But the future use of City Hall is not something that I understand has been determined, nor was it in the purview of our group. The space in this building, a lot of it is very special use, it was designed for 323 BILL 980003 courtrooms. It was my understanding that the Civil Division was moving back, that there would be some offices moving into this building. But in terms of the functions that are moving, say, into One Parkway, consolidation, efficiency of the space, we felt required -- and Council ultimately agreed -- a separate building.
When we leave these other leases to move into One Parkway, are we paying for any unused time on those leases? Have we looked carefully --
-- that we are not moving to the Land Title Building, when we are paying rent for an empty office someplace else?
I am more concerned that the other side is true, that the lease expires. Most of these offices come out of 1600 Arch, and that lease expires in November of this year. I am more concerned that we are able to get out in time, as opposed to having any vacancy and paying for empty space. 324 BILL 980003 There might be a minimal amount of that. But the moves are calculated to start in the spring of this year, consolidating offices -- it would be the first time, for example, the Law Department is consolidated. The remaining offices will move over. We have recommended 100 South Broad, Land Title Building. And that shift needs to be done by November of this year. If there is a payment of a month or so where we are out of the building, that may happen, but it is minimal.
I believe Fleet Management is going to move to Land Title Building?
Has that been carefully, to move to Broad Street, no parking, problem that we have with the parking -- and, by the way, I understand that the parking lot underneath MSB, its lease with the contractor is about to end. And I would hope that someone would look at that to see if that space may be available for some of the parking problems that we have around here, with all the space that we take up on the streets, and constantly hear people complain about 325 BILL 980003 the reserved parking around this area. But it seems to me, to move to Broad Street, with no parking, for departments that have lots of vehicles associated with their operation, doesn't seem to make a lot of sense.
There is parking on Sansom, which is around the corner, on both sides. The one block over, the name of the street escapes me. There is also a parking garage right beside it, which is seldom, if ever, full.
The other comment, before I end, is the fact that hearing Councilman Cohen and Clark talk about banks fleeing the local communities, utility companies have done the same thing. PECO Energy, others have closed their offices and forced people to go to check cashing agencies to pay their utility bills and other places. I think it is about time that we convene a group of people. Because when I worked for PECO, we suggested that the PECO office that was going to close around Broad and Erie take some space that was available at the PGW office on Erie Avenue, 326 BILL 980003 at Broad Street, to allow PECO customers to go to that facility to pay their bills. I think that maybe you should look at encouraging some of the banks to look at some space, public space that we have, rather than put ATM -- by the way, I must have missed that one totally, about ATM machines. Because I think I might even stop by, rather than stop at the one in Chestnut Hill, to get a few bucks out of the ATM machine. I don't know how well publicized that's been. But I think that maybe PGW or another utility could possibly make some rental space available to a bank that would like to set up actual face-to-face customer contact at some of these locations. Because everything seems to be leaving. The utilities are gone, the banks are starting to leave. And to deal with an ATM machine is a cold situation. Thank you, Madam Chair.
Thank you. The Chair recognizes Councilwoman Fernandez. 327 BILL 980003
Thank you, Madam Chair. Three brief questions. First, on of your testimony, you note that for your money management firms, you re-bid the contracts, and noted that you did bid out to two minority firms. Could you provide the Chair with a list of those, who has these contracts for money management?
The amounts tend to vary depending on the time of year, but we certainly will.
Thank you. Secondly, in terms of the tax lien sale, again, I noted earlier how successful that had been. And, again, you need to be thanked, along with a lot of your staff. You did note in your testimony that 30,000 people had made payment agreements to avoid having their properties put into the tax lien sale. 328 BILL 980003 Could you briefly tell us how many of those people have kept their agreements, or could that be forwarded in a report? I think you were going to report periodically to Council; is that correct?
Could you review for the record what happens when those people break their agreement?
We will attempt to get them back on. But, ultimately, they owe the money. We will then discuss with Council whether those liens would be subject to swapping for liens that are in the pool. We need Council's permission to do that, and that's the discussion that needs to take place. A third is a little less than the normal dropout rate that we have been accustom to over the years. So as large as that is, actually, we have done better. It used to be in excess of half of all payment plans were broken. So we are doing a 329 BILL 980003 little bit better. But those liens, that money is owed, and the question is whether we can use those liens to swap for liens we want to take out of the pool that was sold, or we use the traditional collection devices to try to get those people to pay.
Well, from where I sit, I would want you to be very aggressive with these people. Because if others maybe didn't come in, didn't make an agreement, and then can get off, I mean, the people defaulting, I think they ought to be pursued as aggressively as the others who did make an agreement and are now being pursued by the private collection agencies. Because that does, again, represent a lot of money that we need to get into our till. So I think there is a growing, you know, basic anger about people, you know, getting over and not paying, while everyone else, the average, honest citizen pays, just like what Councilwoman Verna was mentioning. And it is even worse when people have contracts with the city. 330 BILL 980003
I was going to add, wait until they see the Section 8 list, because that's rent coming in.
Yes. I believe that will be ready on or before the end of the month.
My last question deals with vendor payment. I know you have done a lot to try to speed up the city's payment to vendors who do business with the city, some of them small businesses, many of them nonprofits. And I think you have made some very important progress. What I was wondering, though, what is your goal for the average payment by the city of bills, like, by July 1 of this year?
We would like to have all the departments that are on the system -- and we will still have some -- we won't have all the departments on the system until December of this year. But once they are on, and once they have been running, we would like to have a 40-day 331 BILL 980003 average payment from the time an invoice has arrived and the check is sent. That's calendar days.
I noticed in your testimony you said an accurate invoice submitted.
Why should it take 40 days if there is an accurate, properly filled out invoice? Why should it take 40 days?
The delay will come in those departments where the invoice is sent to a substation, and it goes to the department's Accounting Bureau, and then from there it goes to the city Accounting Bureau. It may take the paper -- or the transaction it is not paper now -- it may make several stops, and that can cause delay. There are certain departments where it is not a priority, and we have to convince them that this is a priority to get it done. There is no reason we shouldn't be able to make all our payments within 40 days. That's our goal, in answer to you. 332 BILL 980003 There are departments that have problems. We just have to help them work through it.
I guess it is the 40 days that bothers me. In the private market, people are expected to pay within 30 days. And if you don't, you pay interest. And my sense is that's where the city -- that should be the goal. And I think an original idea had been to have the city start paying interest in cases where you don't meet the payments.
Where we were when we started was somewhere around 68 to 70 days. If I got down to 40, the next step would be to raise the bar to 30. But I want to get a reasonable number. And I think once vendors understand that there is -- that in all probability they will be paid within 40 days after we receive the invoice, that I think that will improve their attitude toward the city and improve their bids. Once we get there, we can certainly want to lower it to 30. But I don't think we are 333 BILL 980003 there yet.
I don't want to say. I would love to. Once we got to 40, it would be investigate easy to come back on the budget cycle for the Year 2000 and say we can make 30.
I think 30 needs to be the goal. If not, I think, then, we should start looking at the city, maybe departments who don't get themselves moving, then the interest would come out of their budgets, or something. But I think we ought to treat our customers just like they would be treated in the private market, if we want the city to be more customer friendly, you know, business-like enterprise. But thank you for all your work to get it down to 46.
Thank you, Councilwoman. Mr. Hayllar, on -76 in your 334 BILL 980003 budget, contribution to the School District, is that wishful thinking? Is that monies that would come to the city if the courts were operated by the state or reimbursed by the state?
This is Dean Kaplan, the city's Budget Director. Councilwoman, the $38 million is one half of the amount which normally would have been appropriated for support of the First Judicial District of Pennsylvania. And as last year, we have diverted that funding equally to the Finance Department and the Commerce Department in hope, I guess, that the state will continue with its progress in making the transition to State Court funding. Should the state go further than it already has, that funding would be available for additional tax cuts for aid to the School District and for economic development purposes.
Is the Finance Department working with the state to determine how much money will be given for the courts? And, if so, when? 335 BILL 980003
Yes. We have, with the Law Department, sent several responses to the Montamuro reports. There have been discussions in Harrisburg about the sequence of events. But we have made our thoughts known to them. And I think in some cases, at least, Judge Bonaviticola has recognized that some of our strongly felt opinions were worthwhile. For example, in the Montamuro report, he did not include rent of court facilities as something the state should assume. Our position was that this is an easy way to balance your budget on the backs of the court facilities, by just giving them cheap and louzy space. It is not in the court's interest to do that, and Judge Bonaviticola has recognized that. So I think we have had some impact on their thinking.
And has there been any determination as yet? Will the state reimburse the city, or will they simply take over?
It could be done either 336 BILL 980003 way. That's something they are working out. There are many, many complicated issues, not the least of which is the pension position of current court employees who are in our system, and our system's benefit level is different from the state system. These are all things they must work out, and they have given themselves a great deal of time within which to do that.
And, of course, if the state takes over, the employees do not come under the City Charter. So you would have probably 2,000 people saying asta lavista.
That is a consideration. I don't know that that is absolutely the case, but I know some people have been concerned about that.
Then there is vacation time and sick time. All of that has to be put into consideration.
Our own view is that you need to transition, so that the people you currently have are treated one way, and that people 337 BILL 980003 that will be hired in the system in the future may become full state employees, or whatever. But there needs to be a well-thought-out transition that is being worked on.
Thank you, Madam Chair. Mr. Hayllar, now about those banks --
I bet you are. Some might say you are done. Let's get back to 990 Spring Garden, though. The employees who are expected to be relocated to that building, or that facility, where are those employees now?
Some of them are at 1600, some of the police may be in facilities down at the end of, I believe it is, Race Street.
Yes, I believe some of them. They are in a variety of locations. The ones on Race are city-owned 338 BILL 980003 buildings, but they are very, very inadequate.
We want to get some of them out of there, because they are really inadequate buildings.
Well, where are the Streets and L & I people coming from?
Do we have Public Utilities up at a facility building up North Broad Street, somewhere up near Broad and Master?
Do we have employees in a building up at Broad and Master?
Are any of those employees going to the 990 Spring Garden?
We think so, but we don't know. That's easy to find out for you. 339 BILL 980003
Well, that's a pretty interesting answer. You think so, but you are not sure. But we have public employees, for whom we are paying rent at a building somewhere in the neighborhood of Broad and Master, but you are saying that you are not sure if any of those people are being relocated to 990 Spring Garden?
Okay. And if you 17 could also get me some information on all of the 18 other buildings that the particular entity that owns 19 the 990 Spring Garden Street building, where we have 20 other public employees, whether they are in the General Fund, whether they are in the executive branch or the judicial branch of government. I would like to know all of the buildings that this particular owner has or anticipates having public employees in those buildings. 340 BILL 980003
Okay. Let's go to, in a part of the extended exchange either between Councilman Cohen and yourself or Councilwoman Clark and yourself, just for the record, you had indicated that the city's money actually does not sit in banks, you deposit it, I guess, through the Federal Reserve system on Thursday night, I believe, or Thursday afternoon, so that checks are usually dated Friday. Just so the record is clear, if our money is not in banks, and taxpayers' dollars, the various wage tax, property tax, and everything else, if it is not in banks, where is it?
It is in capital professional management, cash management organizations, Smith Barney, CoreStates Capital Assets, which is a sub -- is not a part of the bank, but is affiliated with them. They manage cash. Smith Graham, minority firm out of Houston. Frankie Hughes, minority firm out of 341 BILL 980003 Washington. And the Reserve Funds for debt service is managed by TFM.
So would that be considered a part of the answer to your testimony on , where you talk about the city's $1 billion consolidated cash and capital accounts?
Can you get us, through the Chair, a complete list of all of the firms and dollars under management?
I understand. So in the final analysis, when a bank is a city depository bank, and if we only give them the dollars the day before they are needed by our public employees or vendors, what are the advantages to a bank to be a city depository bank? What do they get out of this?
The four that are able to handle our business, because they have the systems capability to do it, it is a fee business. 342 BILL 980003 And these fees can approach, in the course of a year, they can approach $900,000. So it can be very lucrative. In the smaller banks, in some cases we keep CDs, really, to show support for the bank. We may have some transactions with the bank. For example, it was United Bank that won the bid to put the ATM machines in the police stations.
I know. But that's the type of business they are interested in. There is a niche in there that they can fulfill.
Okay. But you will get us a list of who all the money management firms, the fees that are generated, how much money they have, as pretty much a snapshot, because we recognize that is there is fluctuation. On of your testimony, or your overview, there is a section that reads, "The office, along with the Treasurer's Office, updated the city's written debt policy statement that determines how we obtain and manage our $4.5 million 343 BILL 980003 in long-term debt."
I thought so. "The office also made certain that money managers adhere to the city's investment policies governing how our funds are invested." Now that you have at least clarified the one issue, what is the debt policy?
I can send you a copy of it. It basically -- well, there are two things I believe we are talking about: One is an investment policy and one is a debt policy. Debt policy talks and puts out in certain ratios how much debt we have per capita as a percentage of our Operating Budget, so you have a sense of how much debt we have. So we look at our debt much the same way the rating agencies would. We are concerned about statutory ceilings, sometimes in the first or second decade of the next century. We are concerned about exceeding 344 BILL 980003 those ratios that the rating agencies would think prudent and managing our debt so that we stay on or below them. And that's the notion of the policy. It also explains how we go borrowing, it defines what debt we have out there, what is direct, what is overlapping, and so forth. So it tries to give you a picture inside of 60 pages of what our long-term borrowed debt capacity looks like, how we go about borrowing it.
, the Tax Lien Sale section, I think I heard a piece of the exchange between yourself and Councilwoman Fernandez which may have covered some of the items that I wanted to raise there. I guess you will be back at the table to talk about the pension system. I can save that question for then. And the BAA is coming up on its own. You could, though, help us, I guess, with some perspective. Bureau of Administrative Adjudication is, in your testimony, talking about the burglar alarm systems. I think you may be aware of an 345 BILL 980003 interest and an effort by many members of Council to get rid of the renewal fee. Does the Administration have a particular position on that?
Our concern with that is that because a customer changes the vendor so often, we won't be able to keep track of what particular address has what vendor unless there is an annual renewal process. It is a tool to update the records; that's a principal reason for wanting to have some kind of renewal.
Well, you can have a renewal process. You don't necessarily have to charge for it; right? If your form says, it is time to renew your monitoring with the city, couldn't you have a section on the form that says, "Is this a first time or do you have a previous, have you had a previous vendor," and require the person to put the previous vendors?