2018 national contract management association boston workshop · page 4 2018 national contract...
Post on 28-Jul-2018
214 Views
Preview:
TRANSCRIPT
2018 National ContractManagement AssociationBoston WorkshopHot topics
March 7, 2018
Page 1 2018 National Contract Management Association Boston Workshop
36
34
Agenda
DCAA/DCMA update
DCAA accounting system pilot
Purchasing system
2018 National Defense Authorization Acts
DCAA rights to data and records
Relevant legal cases
DoD IG report
Contract closeout
DFARS Case 2016-D006: Procurement of commercial items
02
10
13
23
28
32
43
Page 2 2018 National Contract Management Association Boston Workshop
DCAA/DCMA update
Page 3 2018 National Contract Management Association Boston Workshop
DCAA FY 2018 priorities
Meeting customers’ needs on requested audits, including meeting agreed-upondates
Completing incurred cost audits in a timely manner
Performing high risk post award Audits (Truth in Negotiations Act (TINA)/Truthfulcost or pricing data)
Performing high risk business system audits
Completing termination audits in a timely manner
Performing real-time testing of labor and materials
Source: Hlavin, Jacqueline. "DCAA Update." 8 November 2017, PowerPoint file.
Page 4 2018 National Contract Management Association Boston Workshop
DCAA incurred cost strategy
► Since Better Buying Power 2.0 (2013), it has been a DefenseContract Audit Agency (DCAA) goal to eliminate the incurred costbacklog
► DCAA approach► Developed a multipronged approach to working down backlog
in an effective manner► Dedicated audit teams► Multiyear audit techniques► Increased staffing dedicated to incurred cost► Implementing a low-risk sampling approach to performing
incurred cost audits
Source: Hlavin, Jacqueline. "DCAA Update." 8 November 2017, PowerPoint file.
Page 5 2018 National Contract Management Association Boston Workshop
DCAA/DCMA forward pricing strategy
► Defense Contract Management Agency (DCMA)/Defense ContractAudit Agency (DCAA) Joint Communication Plan► Early coordination► Responsive to the buying commands► Eliminate duplication
► Tailoring audits to meet the customer’s needs► Timely completion of audits
Page 6 2018 National Contract Management Association Boston Workshop
DCAA trendsNumber of days to complete audits government fiscal years (GFY) 2012–2016
Source: DCAA Report to Congress on FY 2016 Activities, 31 March 2017. Graphical data prepared by EY’s Government Contract Services.
Audit Report Type GFY 2011 GFY 2012 GFY 2013 GFY 2014 GFY 2015 GFY 2016 GFY 2011 GFY 2012 GFY 2013 GFY 2014 GFY 2015 GFY 2016Forward Pricing 120 110 97 95 85 86 N/A -8% -12% -2% -11% 1%Special Audits 184 217 184 165 159 133 N/A 18% -15% -10% -4% -16%Incurred Cost 965 1,184 1,090 1,006 883 885 N/A 23% -8% -8% -12% 0%Other Audits 283 384 309 461 333 268 N/A 36% -20% 49% -28% -20%
Average Elapsed Days to Complete Audit Year-Over-Year Change
Page 7 2018 National Contract Management Association Boston Workshop
DCAA trendsCompleted DCAA audits GFYs 2004–2016
Number of completed DCAA audits
Type of audits FY04 FY05 FY06 FY07 FY08 FY09 FY10 FY11 FY12 FY13 FY14 FY15 FY16
Incurred costs and special audits 26,480 26,360 23,697 22,519 19,956 12,826 5,166 3,886 4,189 4,187 3,796 3,214 3,085
Price proposals 10,299 9,673 9,015 8,182 8,113 7,004 5,590 2,599 1,811 1,316 1,089 883 873
Cost accounting standards 2,340 2,426 2,413 2,648 1,927 1,292 916 874 680 725 779 423 276
Defective pricing 586 562 485 452 356 154 59 31 37 31 24 26 35
Total audits 39,705 39,021 35,610 33,801 30,352 21,276 11,731 7,390 6,717 6,259 5,688 4,546 4,269
1 From Department of Defense Office of Inspector General (DoD IG) Semiannual Reports to Congress
Prepared by EY – Government Contract Services
0
5,000
10,000
15,00020,000
25,000
30,00035,00040,000
45,000
FY04 FY06 FY08 FY10 FY12 FY14 FY16
Number of completed DCAA audits1
Incurred costs andspecial audits
Price proposals
Cost accountingstandards
Defective pricing
Total audits0
500
1,000
1,500
2,000
2,500
FY04 FY06 FY08 FY10 FY12 FY14 FY16
Number of DCAA audits unresolved by DCMA1
Total open
Page 8 2018 National Contract Management Association Boston Workshop
DCAA trendsQuestioned costs GFYs 2004–2016
$- $1.00 $2.00 $3.00 $4.00 $5.00 $6.00 $7.00 $8.00 $9.00
$10.00
Mar
-04
Sep-
04M
ar-0
5Se
p-05
Mar
-06
Sep-
06M
ar-0
7Se
p-07
Mar
-08
Sep-
08M
ar-0
9Se
p-09
Mar
-10
Sep-
10M
ar-1
1Se
p-11
Mar
-12
Sep-
12M
ar-1
3Se
p-13
Mar
-14
Sep-
14M
ar-1
5Se
pt-1
5M
ar-1
6Se
pt-1
6
Questioned Cost per Audit(In Millions)1
Questioned Cost per Audit ($ millions)
0%10%20%30%40%50%60%70%80%
Mar
-04
Sep-
04M
ar-0
5Se
p-05
Mar
-06
Sep-
06M
ar-0
7Se
p-07
Mar
-08
Sep-
08M
ar-0
9Se
p-09
Mar
-10
Sep-
10M
ar-1
1Se
p-11
Mar
-12
Sep-
12M
ar-1
3Se
p-13
Mar
-14
Sep-
14M
ar-1
5Se
pt-1
5M
ar-1
6Se
pt-1
6
Percentage of Questions Cost Sustained1
Percent Sustained Linear (Percent Sustained)
1 From DoD IG Semiannual Reports to Congress
Prepared by EY – Government Contract Services
Page 9 2018 National Contract Management Association Boston Workshop
DCAA future approach
► Moving forward – increasing the Agency audit effort in:► Business systems audits► Post award audits► Real-time Labor and Material audits
► Eliminating the Incurred Cost backlog► Creating an Incurred Cost Proposal portal► Increased use of joint audit efforts with willing contractors, DCAA
and contractor Internal Audit
Source: Hlavin, Jacqueline. "DCAA Update." 8 November 2017, PowerPoint file.
Page 10 2018 National Contract Management Association Boston Workshop
DCAA accounting system pilot
Page 11 2018 National Contract Management Association Boston Workshop
Background
► DCAA initiated pilot accounting system audits at multiple largedefense contractors
► It removed the accounting system audit program from its website.► DCAA is using a draft audit program that is significantly modified
from prior audit programs► Pilot audit program appears to be consistent among contractors► Additional contractors are receiving notifications of accounting
system audits
Page 12 2018 National Contract Management Association Boston Workshop
Key considerations
Requestcopies of any audit
program
Be prepared for extensivewalk-throughs and
demonstrations
Assessbilling and
labor controls prior toDCAA audit
Develop strategies forinternal audit requests and
compensation reviews
Identify resources andsystem access controls
needed for IT auditprocedures
Page 13 2018 National Contract Management Association Boston Workshop
Purchasing system
Page 14 2018 National Contract Management Association Boston Workshop
Regulations, guidance and applicability
Business system Contractor purchasing systemDFARS contract clause guidance DFARS 252.244-7001
Threshold level and attributes Awards expected to exceed $25m over the next 12-monthperiod include those represented by prime contracts,subcontracts under government prime contracts andmodifications.Notes:(1) contractor purchasing system review is not performed for aspecific contract; (2) the head of the agency responsible forcontract administration may raise or lower the $25m reviewlevel if considered to be in the government's best interest.
Exemptions Firm-fixed-price contracts awarded on a competitive basis;competitively awarded fixed-price contracts with economicprice adjustment; and FAR Part 12 qualifying sales orcommercial items
Cognizant audit/review authority DCMA
Note: Contractor Purchasing System Review (CPSR) guidebook, published October 2, 2017, establishes the CPSRthreshold at $50m in annual sales (an increase over the $25m threshold established in Federal AcquisitionRegulation (FAR) 44.302).
Page 15 2018 National Contract Management Association Boston Workshop
Purchasing system criteria
► 24 criteria* under the DFARS clause, in summary:► Defined segregation of duties for subcontracting functions► Periodic formalized training, focusing on public laws and
regulations, prohibited practices and importance ofsegregation of duties
► Source selection adequately documented, including solesource justification
► Purchasing file maintenance and documentation retained► Pricing and negotiation with subcontractors documented► Clause flow-down
► Although there are 24 DFARS criteria, there are 29appendices within the CPSR guidebook that dictate theDCMA audit process
*See full text for criteria DFARS 252.244-7001, Contractor Purchasing System Administration.
Page 16 2018 National Contract Management Association Boston Workshop
CPSR trends – Process
► DCMA has standardized its processes► Revised DCMA CPSR guidebook two times in 2017► More detailed data requested pre-CPSR► More communications with contractors pre- and post-CPSR► Reports and initial determinations completed in a timely manner► Less files and more depth► Notice up to six months prior to CPSR► Sixty days or so to complete► Number of questions have increased over previous year► Very standardized► Enterprise-wide data required
See full text for criteria DFARS 252.244-7001, Contractor Purchasing System Administration.
Page 17 2018 National Contract Management Association Boston Workshop
CPSR trendsData calls and determinations
► Data calls are requesting more data.► Sixty days to write and internally vet reports.► Administrative Contracting Officer (ACO) has 10–15 days to issue
initial determination to contractors.► DCMA CPSR Team Lead can issue Level 2 Corrective Action
Requests (CARs).► Initial determination letter addresses all Level 3 (and above)
CARs.► Contractor needs to address Level 2 CARs directly with CPSR
Team and Level 3s directly with ACO.► DCMA CPSR Team can review contractor acquired property.► ACO can conduct surveillance reviews.
See full text for criteria DFARS 252.244-7001, Contractor Purchasing System Administration.
Page 18 2018 National Contract Management Association Boston Workshop
CPSR trendsAreas of focus
► Policy and procedure manual► Commercial item acquisitions► Protecting the Government’s interest when subcontracting with
contractors debarred, suspended or proposed for debarment► Limitation on use of appropriated funds to influence certain federal
contracting and financial transactions (anti-lobbying)► Defense priorities and allocation system (DPAS) rating► Cost and price analysis► Flow-downs► Terms and conditions► Reporting of executive compensation
See full text for criteria DFARS 252.244-7001, Contractor Purchasing System Administration.
Page 19 2018 National Contract Management Association Boston Workshop
Historical CPSR findings
Summary information of CPSR findings from FY16 which could result incorrective actions, inadequate determinations and disapproval:Finding Material Nonmaterial No findingDebarred suppliers 66 15 45
Anti-lobbying FAR 52.203-12 48 78
Price analysis 43 17 66
DPAS 34 92
FFATA 31 95
Sole Source justifications 27 18 81
Policies and procedures 20 74 32
Commercial Item determinations 15 111
Documentation 12 52 62
TINA 12 114
Flow-downs 31 95
Training 25 101
Internal review/audits 24 102
Purchase reqs. 20 106
Negotiation evidence 18 108Source: Obermeyer, Andrew. "Preparing for a CPSR (Contract Purchasing System Review) - Hot Topics." The 36th Annual Government Contract Management Symposium,5 December 2017, Hyatt Regency Crystal City, Arlington, VA, Conference Presentation
Page 20 2018 National Contract Management Association Boston Workshop
Leading practices in CPSR preparation
► Minimum six-month preparation prior toexpected on-site CPSR activity
► CPSR readiness team to perform acomprehensive review of key CPSR topics
► Risk assessment of purchase orders andsubcontracts, including an assessment ofaward type, dollar value, volume and priorrelated DCAA/DCMA findings
► An initial detailed analysis of a sample ofprocurement files by parties external to thepurchasing function (e.g., governmentcompliance, third-party consultants,internal audit)
► Detailed analysis of current purchasingpolicies, procedures and practices againstrecent DCMA guidance
► Analysis and remediation of procurement files► Based on initial assessments, may be a
broad scrutiny of files or focused oncertain aspects (e.g., cost/price analysis,certifications, file organization)
► Often choose to analyze all files in scopefor the CPSR
► Development of a detailed audit supportstrategy, including:► Participation by executive management► Communication strategies► Plans for system and process walk-
throughs highlighting controls► Plans to address known risk areas that
could generate findings
Our experience has shown that most contractors that successfullynavigate a CSPR typically share the following traits:
Page 21 2018 National Contract Management Association Boston Workshop
FY18 focus areas
► Recent comments from DCMA leadership discussed the following areas asbeing important for FY18 CPSRs► Renewed emphasis on commercial items
► Documenting market research► Conducting robust price analysis► Reviewing commerciality assertions
► Counterfeit parts► Only applies to cost accounting standards covered contractors► Inadequate system can trigger disapproval of purchasing system and withholds► Clause must be included in subcontracts, including commercial item contracts for
electronics or anything containing electronic parts► DFARS 252.246-7008 Sources of Electronic Parts creates new notification requirements
► Buy American is a new CPSR report element► Not a flow-down but prime must verify that the requirements are met► Applies to all purchases above the micro-purchase threshold except commercial off-the-
shelf items
Page 22 2018 National Contract Management Association Boston Workshop
CPSR trendsReminders
► Plan plenty of time to complete both the risk assessment and thepre-CPSR data request
► Establish a relationship with DCMA► Conduct pre-CPSR self-assessment► Prepare a corrective action plan, if required,
in a timely manner
Page 23 2018 National Contract Management Association Boston Workshop
2018 National Defense Authorization Acts
Page 24 2018 National Contract Management Association Boston Workshop
Sec. 803Performance of incurred cost audits
► DCAA must notify contractors within 60 days whether thesubmission is adequate
► Audit findings shall be issued for an incurred cost audit no laterthan one year after the date of receipt of adequate submission► If audit findings are not issued within one year after receipt of
adequate submission, the audit shall be considered to becomplete
► DCAA Issued a memorandum for regional directors onJanuary 29, 2018 – Issued to confirm that agency policy will berevised to require incurred cost submissions to be reviewed foradequacy within 60 days of receipt► Agency will be providing guidance for complying with the
National Defense Authorization Act (NDAA) one-yearrequirement
Page 25 2018 National Contract Management Association Boston Workshop
Sec. 803Performance of incurred cost audits
► DoD is required to use a qualified private auditor to perform asufficient number of incurred cost audits to confirm:► Incurred cost audits are completed no later than one year after
the receipt of a qualified incurred cost submission► DCAA is able to devote ample resources to high priority audits► Qualified private auditors are used to perform a substantial
number of incurred cost audits on an ongoing basis to improvethe efficiency and effectiveness of incurred cost audits
► Establishes numeric materiality standards► Requires the DoD to coordinate with the private auditor and 809
panel when establishing the standards► Requires peer review be performed by an external party on
unqualified (clean) DCAA opinions
Source: NDAA for FY2018.
Page 26 2018 National Contract Management Association Boston Workshop
Sec. 803Performance of incurred cost audits
Timeline for selection of qualified private auditors:► By October 1, 2018, DoD must provide the House Armed Services
Committee and Senate Armed Services Committee copies of itsacquisition plan, including:► Description of the incurred cost audits DoD determines are
appropriate to be conducted by qualified private auditors► Estimate of the number and dollar value of incurred costs
audits to be conducted by qualified private auditors for eachyear of FY19–25
► By April 1, 2019, DoD must award an indefinite delivery/indefinitequantity contract to two or more qualified private auditors toperform incurred cost audits► DCMA or other “authorized entity outside of DoD” is then
authorized to issue task orders to perform incurred cost auditswhen needed
Source: NDAA for FY2018.
Page 27 2018 National Contract Management Association Boston Workshop
Other highlights
Section 804 disallows contractors to select incurred cost submission (ICS) auditprovider
Section 805 increased the simplified acquisition threshold to $250k
Section 806 increased the micro purchase threshold to $10k
Section 811 increased the cost or pricing data threshold to $2m
Section 822 limits uses of lowest price technically acceptable
Source: H.R.2810 — National Defense Authorization Act for Fiscal Year 2018, 115th Congress (2017–2018).
Page 28 2018 National Contract Management Association Boston Workshop
DCAA rights to data and records
Page 29 2018 National Contract Management Association Boston Workshop
DCAA rights to data and records
► Access to records controlled under FAR 52.215-2, Audit and Recordscontract clause► The government “… shall have the right to examine and audit all records and other
evidence sufficient to reflect properly all costs claimed to have been incurred oranticipated to be incurred directly or indirectly in performance of this contract.”
► “… right of examination shall include inspection at all reasonable times of thecontractor’s plants, or parts of them, engaged in performing the contract.”
► “The contracting officer (or authorized representative) has the right to examine andaudit all of the records (including computations and projections) in order to evaluatethe accuracy, completeness, and currency.”
► FAR 31.201-2 Determining allowability► “A contractor is responsible for accounting for costs appropriately and for
maintaining records, including supporting documentation, adequate to demonstratethat costs claimed have been incurred, are allocable to the contract, and complywith applicable cost principles in this subpart and agency supplements. Thecontracting officer may disallow all or part of a claimed cost that is inadequatelysupported.”
Page 30 2018 National Contract Management Association Boston Workshop
DCAA rights to data and records
► Request can be verbal or in writing► Time to retrieve or produce requested records needs to be
“reasonable,” although DCAA’s standard of late is that recordsshould be “readily available”
► Request should clearly state what support is needed and when itshould be provided
► Request needs to be clearly defined for time periods, contractscovered, specific items … unambiguous and not open ended
► Access does not mean uncontrolled access► Electronic records are suitable as are paper copies► Communicate with government representative(s) if clarification
needed► Don’t delay or ignore in responding to a formal request► Avoid “Denial of Access to Records” determination
Page 31 2018 National Contract Management Association Boston Workshop
What if DCAA is overreaching?
► Communicate and clarify the nature and timing of the requesteddata
► Determine the relevance and availability of records requested –consider offering alternatives
► If records are lost, destroyed or stolen, or otherwise compromised,notify the DCAA and the ACO as well as internal legal counsel
► Request the DCAA auditor’s supervisor be engaged in theconversation if a resolution cannot be achieved
► If the issue still cannot be resolved, elevate the issue, in writing, tothe DCAA Field Audit Manager and engage with the DCAARegional Audit Manager
► Finally, if mutual understanding still cannot be reached, the issueshould be elevated, in writing, to a Senior Executive Serviceofficial at the cognizant DCAA Regional Office or DCAA HQ
Page 32 2018 National Contract Management Association Boston Workshop
Relevant legal cases
Page 33 2018 National Contract Management Association Boston Workshop
RaytheonUnallowable cost penalties
► The Board addressed penalties related to unallowable costs.► It found that costs previously determined to be unallowable were
not subject to level 1 penalties because they were not expresslyunallowable – did not address level 2 penalties.
► It found directly associated costs of lobbying were subject to level1 penalties, despite not being expressly unallowable.
► The Board found testimony and other evidence can be used todemonstrate allowability of professional services/consultant costsabsent any other contemporaneous documentation.
► This demonstrates the importance of having established policiesand personnel training to provide assurance that unallowablecosts subject to penalties are precluded from being claimed.
► “Title 10 U.S.C. § 2324(b) provides for penalties when a contractorincludes in its proposal a cost that is [expressly unallowable undera cost principle …”].
Source: Armed Services Board of Contract Appeals Nos. 57576, 57743, 57798 and 58280.
Page 34 2018 National Contract Management Association Boston Workshop
DoD IG report
Page 35 2018 National Contract Management Association Boston Workshop
DoD IG report
► External peer review on DCAA System performed 11/17/17► Summary
► “Pass with Deficiencies” audit opinion► Of the 67 audits sampled, 5 deficiencies were noted (7%)
# Deficiency Audits cited DCAA response1 Did Not Obtain Sufficient Evidence 27% Disagree
2 Did Not Report on PertinentInformation or Scope Restrictions 12% Disagree
3 Did Not Adequately Document theProcedures Performed 13% Agree
4 Did Not Perform AdequateSupervisory Reviews 9% Disagree
5 Did Not Exercise ProfessionalJudgment in Some Instances 6% Agree
Page 36 2018 National Contract Management Association Boston Workshop
Contract closeout
Page 37 2018 National Contract Management Association Boston Workshop
Contract closeout overviewWhat is contract closeout?
► A process to finish or resolve all contractual requirements for aphysically complete contract
► The objective is to establish the final price and make thefinal payment.► “Closeout is complete when all administrative actions have
been completed, all disputes settled, and final payment hasbeen made.” (DCMA Contract Closeout Guidebook)
Page 38 2018 National Contract Management Association Boston Workshop
► Coordinate closeout actions► Manage funds► Process plant and property
clearance► Negotiate final rates► Approve final invoice
► Submit indirect cost proposal► Settle subcontracts► Submit final invoice/voucher
► Reconcile payments► Pay final invoice
► Perform indirect cost audits► Audit subcontractors► Review final invoice
Contract closeout overviewResponsible personnel (DoD contracts)
Contractor DCMA
DFASDCAA
Page 39 2018 National Contract Management Association Boston Workshop
Contract closeout overviewTiming guidelines
Source: DCMA
Physicalcompletion
Audit finalincurred cost
proposal*
Final invoice due
End contractor FY
Final incurred costproposal due*
Process and payfinal invoice
ClosedDCAA actuals8–12 months DCAA actuals
30days
* Not required for firm fixed price contracts or Contract Line Item Numbers –timeline should be reduced 30 months
0–12 months 6 months 12–24 months Varies 4 months Varies due tocircumstances
Contractor
DCAA
Contract Administration Office
DFAS
Project office
Legend
Review andprocess
final invoice
Settle final rates*
Page 40 2018 National Contract Management Association Boston Workshop
Contract closeoutLeading practices
► Retain detailed contract records► Contract type► Modifications► Currently active contracts► Contracts currently being bid on
► Develop a closeout plan► Assign roles and responsibilities in advance
► Actively manage inventory throughout the contract period ofperformance
► Exercise good record-keeping skills and document control► Track costs and comply with requirements of Limitation of
Cost/Funds Clause► Monitor indirect rates to mitigate payback responsibility
Page 41 2018 National Contract Management Association Boston Workshop
Contract closeoutLeading practices
► Submit all contractor requirements on time► Submit ICP six months after fiscal year-end► True-up all interim vouchers 60 days after rates are settled► Close all subcontracts early► Once overhead rates are settled, prepare final voucher within
120 days► Identify any contracts that may be qualified for quick closeout► Utilize available government guidance and resources
► DoD Contract Closeout Checklist► DCAA Cumulative Allowable Cost Worksheet► DCMA Contract Closeout Guidebook► Defense Finance and Accounting Service Payment History
Data
Page 42 2018 National Contract Management Association Boston Workshop
GAO report – Contract closeout backlog
► Report summary► Contracts generally not closed out within FAR time parameters► ICS Audit backlog contributes to backlog► DoD included in Government Accountability Office (GAO)
review► Findings overview
► No agency tracking/oversight of closeout process► DCAA did not meet goal to eliminate backlog by FY2016► DCAA averaged 885 days from submission -> audit completion
► Agency recommendations► Establish goals and performance measures to close out
contracts► DCAA recommendations
► Assess use and effect of multiyear audits► Develop processes and metrics to reduce audit time frame
Page 43 2018 National Contract Management Association Boston Workshop
DFARS Case 2016-D006Procurement of commercial items
Page 44 2018 National Contract Management Association Boston Workshop
DFARS Case 2016-D006Procurement of commercial items
► The final ruling provides the following:► Additional guidance on making price reasonableness
determinations► Purchase prices paid by both the government and
commercial customers are used for purchase price basis► If contracting officer determines that pricing information
isn’t sufficient to determine price reasonableness,contracting officer can request other relevant info, includingcost data
► Promotes consistency in making commercial itemdeterminations► DoD has establish a cadre of experts within DCMA to
provide advice to Contracting Officers► DCMA is also facilitating collaboration with contractors
through commercial item memorandums of agreement
Page 45 2018 National Contract Management Association Boston Workshop
DFARS Case 2016-D006Procurement of commercial items
► Expands opportunities for nontraditional defense contractors to dobusiness with DoD► 66% of total contracts were to small businesses in FY16► The exception to certified cost or pricing data would benefit
small businesses that meet the definition► Does not remove existing requirements for submission of other
than certified cost or pricing data, but rather provides further detailand a hierarchy of other than certified cost or pricing data thatshould be included in proposals
Page 46 2018 National Contract Management Association Boston Workshop
Questions?
EY | Assurance | Tax | Transactions | Advisory
About EYEY is a global leader in assurance, tax, transaction and advisoryservices. The insights and quality services we deliver help build trustand confidence in the capital markets and in economies the worldover. We develop outstanding leaders who team to deliver on ourpromises to all of our stakeholders. In so doing, we play a critical rolein building a better working world for our people, for our clients andfor our communities.
EY refers to the global organization, and may refer to oneor more, of the member firms of Ernst & Young Global Limited, eachof which is a separate legal entity. Ernst & YoungGlobal Limited, a UK company limited by guarantee, does notprovide services to clients. For more information about ourorganization, please visit ey.com.
Ernst & Young LLP is a client-serving member firm ofErnst & Young Global Limited operating in the US.
© 2018 Ernst & Young LLP.All Rights Reserved.
1802-2585887ED None
This material has been prepared for general informational purposesonly and is not intended to be relied upon as accounting, tax or otherprofessional advice. Please refer to your advisors for specific advice.
ey.com
top related