Andrea Psoras – M&A Resume

Andrea M. Psoras

201 W117th Str #2B  NY, NY 10026 ; (212) 666-2569;


  • Financial Analyst/Financial Sector with strong strategic thought leadership skills: experience consulting to, analyzing predominantly depository and financial institutions. Strong skills in: Financial analysis, research, quantitative analysis with strong commercial intuition and reasoning/problem solving, abilities and experience for M&A-investment banking (combinations/divestitures), credit/counter-party risk, stock or Private equity portfolio investments (industry/macro, credit analysis) using 10Q, 10K, Y9-C, “Call”, TFR, Focus; FR Y-14/“Stress Tests: DFAST, CCAR; Dodd Frank (Resolution Plan) related, consulting business development.
  • Member: NYSSA since 1990 (in process-2016). Passed CFA I. 
  • International Bank Credit Trained – formal credit training; 24 credits specific to Accounting. Jul’14 NYC Exam for Staff Analyst Trainee: 78%; Jun15 NYC Civil Service exams score 76% for Analyst, 80% for Assoc Staff Analyst
  • Strong software skills including (spreadsheet) forecasts, strong modeling, building models: MS Office: Excel, Word, Access, Powerpoint, MS Project; Lotus  123, Amipro; FoxPro; dBase; WordPerfect; Bloomberg API spreadsheet building; FactSet product use; QuickBooks; STATA; Sybase; WordPress-website development; some SAS JMP; data mining, data analysis; transactions-projects with multiple stakeholder collaboration
    • EMPLOYMENT/CONSULTING: (see also Transactions/Projects/ Activities List )
    • PLLC Family office/Independent Consulting (“PLLC”) Analyst            (8/08 — Pres)
    • QED International Associates, Inc. (“QEDI”)  Senior Vice President (10/05 – 8/08)
    • Strategic Advisory (“SA”)  Principal/Analyst                                              (6/95 – 9/05)
    • KPMG Peat Marwick, LLP (“KPMG”)                               Senior Banking Analyst 
    • Ryan Beck (now part of Stifel Nicolas); Consulting (“IC”)   AVP; Consultant; Contractor
    • Lyons, Zomback & Ostrowski (Advest Group) (“LZO”)       Associate/M&A consulting

EMPLOYMENT INCLUDING CONSULTING HISTORY (see also Transactions/Projects/Activities List)

PLLC Family office/ Independent Consulting ( PLLC). NY, NY (2008-present): Financial services/related consulting for client and ad hoc projects using Financial Reports: 10Q, 10K, A/R, Y9-C, Call, TFR, Focus and related to these. Public Due Process Comments Letters to FASB, SEC, Fed/BoG, FDIC, OCC, CFTC, USDA, Amicus letters

Capital Markets Advisors, LLC. NY, NY (CMA), Senior Manager (5/12-7/13): Financial services, related consulting, business development.

  • Co-authoring service contracts-agreements with banks,
  • Co-authoring/writing CMA’s business, operating plans, presentations in PowerPoint,
  • Resolution Plans Consulting- foundation/ organized/developed presentation, website, website materials for Resolution Plans consulting

QED International Associates, Inc. NY (QEDI) Senior Vice President (2005 – 2008): Quantitative consulting

  • Design and developed strategies of: Indexes, quantitative, fundamental analysis; Exchange Traded Funds; trading, investment strategy consulting to asset management, investment, pension, and related communities, Risk/Credit/Portfolio Management product development.
  • Co-authored white papers. Co-authored with Herbert Blank: “When Vice is Nice”, Financial Advisor,” When Sin is Superior”, April 2006 Co-Authored with Michael Carty and Ed Matluck, PhD, “Does the Steel Industry Perform Differently than the Basic Materials Sector?” for Van Eck

Strategic Advisory (SA)- Principal. NY, NY Provided strategy consulting to clients, affiliations. Also see following-client engagements (Transactions-Projects List)

KPMG Peat Marwick, LLP, (KPMG) Senior Banking (M&A and related; execution side) Analyst, NY, NY. For the Global Capital/Capital Strategies Group promoted in less than a year from Senior Research Analyst. Co-authored ABA Banking Journal White Paper- “Mergers & Acquisitions: Current Issues and Trends Affecting the Banking Sector”.

Lyons, Zomback & Ostrowski ((LZO).part of Advest Group), NY, NY. Associate. Fulfilling M&A, strategic advice (execution side) roles. Please see below: “Professional Experience and Skills” for skills, experience; “Transactions List

Prior Professional Experience in the Maritime sector: Norton Lilly Intl, Maersk Line/Moller Steamship

EXPERIENCE: Financial Sector, Related (Also see Transactions-List

M&A and Related Consulting (mostly “Execution” side):

  • LZO, KPMG, SA I co-authored M&A, recap, strategy/strategic plans-strategic planning, business-capital plans (these were predecessors to ‘Resolutions’ Plans) for regulator, client purposes.
  • LZO, KPMG, SA I created, constructed, developed complex, scenario driven interactive Excel, Lotus spreadsheet models with stress testing/scenarios, pro-forma forecasts for business combinations, divestitures, capital planning,/capital adequacy/recapitalizations, private placements, financial and/or credit analysis; modeled mostly retail, (some) commercial, industrial, SNC/‘participations’ loan portfolios – to accompany co-authored materials.
  • LZO, KPMG, SA For execution side of transactions/projects: I engaged in strategic planning consulting, strategic economic and financial analysis collaborating between external, internal stakeholders: senior partners/investment bankers, analysts, clients and/or external parties such as the regulators; “turn-around” work. I also was involved in some business development.
  • LZO, KPMG, QEDI, IC While laws, regulations have been designed to diminish the number of ‘mouths’ feeding at the table of the US economy, for stakeholders – clients, regulators (external) and MDs (internal) I researched/surveyed/co-authored: industry trends, economic/demographic trends, sub-sectors; fairness opinions, regulatory assisted transactions/FDIC resolutions-Resolution plans, Open Bank Assistance Requests/Applications; D’Oenche Doctrine. I also analyzed deposit franchise/branch networks, market/trade areas, calculated Herfindahl (deposit concentration, anti-competition/anti-competitive) analysis; associated scenario driven spread complex interactive sheet models.
  • LZO, KPMG, SA, PLLC Used/analyzed, dealt with definitions, data changes in “TRF”, “Call” reports, UBPRs, BHCPRs (“RAP”) including Examiners/Exam Reports, and GAAP data on North American based financial institutions, other public and private enterprises – understanding, comfortable with data and those definitions that role up into these reports
  • LZO, KPMG Worked on structured pricing/bids, strategies for acquiring, selling branches; also for failing/failed financial institutions.
  • LZO For clients, internal use I worked on the development of the LZO Bank & Thrift Directory, and from regulator data in dBase form I built, I contributed to developing a credit scoring model that quality-rated banks and thrifts as a proxy for rating their CDs

Financial Analyst – Credit Analysis/Counter-party Credit Risk (and project-contract-temporary, etc):

  • Used/analyzed GAAP; RAP data: “Call”, Y9-C reports, Focus Reports for broker/dealers, North American based financial institutions, credit card banks, financial service cos, broker/dealers, ETNs, also analyzing US subsidiaries (“subs”) and foreign subs in Europe, Asia of US based financial institutions (some translating from French, Spanish)
  • Reviewed Y2K, operations/IT compliance, some editing of Counterparty ISDA docs used for adjusting global exposures to credit counterparties
  • Provided credit analysis using internal credit utility software on Global 1000 cos. at a global bank for Senior Management
  • For Treasury, Controller, determined profits and losses from trading: derivatives – options, swaps, hedges; forward rate agreements, FX; A/L gap analysis in Sybase, G/L work for CFO of large European bank US sub
  • For dealing with, solving systems issues and reporting differences in at a global bank’s Global Asset Management, I reconciled portfolio performance of large private wealth clients’ portfolios to Custody’s reports
  • Medium Term Notes: Transactions and Collateral Due Diligence, coordination with Traders/Trading Banks

Other Related Experience­ Full CV, Transactions List)

  • Financial Services consulting: Dodd Frank Resolution Plan/PMO business development, related consulting
  • Financial analysis, transactions, and product development on other sectors: CFTC public due process comment on Event driven commodity contracts; “Stress” Tests public due process comment
  • Analysis of Accounting/Financial Reporting; Risk Management, Regulation and Legislation
  • Basel III Public due process comment; Basel II macro/micro (some policy) Analysis
  • Analysis of mortgage products, mortgage equity products and associated companies

EDUCATION and OTHER: ATTRIBUTES, ACTIVITIES; (Transactions , References List Provided Upon Request)

Franklin & Marshall College, Lancaster, PA, Degree: B. A.  Major/minor: Business Management/Economics, “Finance”. Advanced research in Money & Banking: “Capital Adequacy in Commercial Banking”; Accounting: “Barter revenue as a component in Revenue Recognition”; Additional 24 credits in Accounting and Economics/Econometrics (F&M) 2004/Feb-May; Econometric/quantitative review of Gramm Leach Bliley mandated study of the profitability of lending under the Community Reinvestment Act, in process. Extracurricular activities: varsity field hockey& lacrosse (de facto regionally, nationally ranked).


Columbia University, NY, NY. Public Economics with research: ‘Shadow Pricing of Foreign Exchange”; Spanish.

Baruch College: Accounting Certificate, Budgeting and QuickBooks, Audit.


Present: New York Society of Security Analysts “NYSSA” Committees: –Financial Reporting and Analysis, Corporate Governance/Shareholder Rights; Sustainable Investing.

Former: Professional Risk Managers’ Investment Association “PRMIA”; Quantitative Work Alliance For Applied Finance Economics and Wisdom “QWAFAFEW”. New York State Society of Certified Public Accountants; Foreign Policy Assn.; American Assn for the Advancement of Science (AAAS).

Community/Civic/Social memberships, endeavors have included:: The Penn Club of New York; Greenwich Field Hockey Club VP-88/90; 93 Empire State Games gold medal winning field hockey team. Whitehall Club; Downtown A/C-Audit Committee, Instructor w/Sons & Daughters Program; Computer instructor at Fountain House.

President’s Council on Physical Fitness Award, 2 years.

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201 W. 117th Street #2B  NY, NY 10026 (212) 666-2569



Public Due Process Comment Letter – FDIC Notice and Request for Comment: Guidelines for Appeals of Material Supervisory Determinations: Federal Register Vol 81, No. 150 (Aug 4, 2016, pps 51441-6.) in process.

Policy-Legal Analysis of New York Bankers Association v. The Cty of New York , et al.  Analysis of and comment to the New York City Banking Commission regarding the 2105 law suit by New York Bankers (Trade ) Assocation against New York City Counci’s  2012 “Responsible Banking Act” and associated programs administrated by the Community Investment Advisory Board.

Public Due Process Comment Letter  (letter #01) FDIC:  Company-Run Annual Stress Test Reporting Template and Documentation for Covered Institutions with Total Consolidated Assets of $50 Billion or More under the Dodd-Frank Wall Street Reform and Consumer Protection Act OMB Control Number 3064–0189 / 75152-75155 Federal Register / Vol. 79, No. 242 / Wednesday, Dec 17, 2014–0189.html 2014-stress_test_reporting_dodd-frank_3064–0189-c_01.pdf

Public Due Process Comment Letter (letter #29) FDIC: Single Point of Entry / 77614-76624 Federal Register / Vol. 78, No. 243 / Wednesday, Dec 18, 2013

Public Due Process Comment Letter (letter#40): FASB Project: 2012-260 Financial Instruments—Credit Losses (Subtopic 825-15) comment letter for Public Due Process. 2 May 2013

Public Due Process Comment Letter: Fed, FDIC, OCC, SEC Comment regarding opposition to Basel III adoption, analysis, in narrative style

Director on Board: Occupy Financial (OWS’ financial company established to do financial services, payment cards). Worked on organization’s development-establishment, business plan, financial (interactive spreadsheet) model.

Public Due Process Comment Letter (letter#167): FASB Project: 2011-230- Revenue Recognition (Topic 605): Revenue from Contracts with Customers Updated Exposure Draft comment letter for Public Due Process. 13 March 2012

Public Due Process Comment Letter: US Department of Agriculture –Comment letter against deregulating Dow Agri Group GMO 2,4-D (dioxin) tolerant soy, and supporting banning GMO in the US food supply and agriculture; Amicus Letter: OSGATA v Monsanto- Friend of the Court Letter on behalf of Organic Seed companies and Organic Farmers Trade Association in anti-competitiveness/corporate abuse lawsuit against Monsanto.!documentDetail;D=APHIS-2010-0103-4699

Public Due Process Comment Letter: Fed, FDIC, OCC, SEC: Comment for public due process regarding “Restrictions on Proprietary Trading and Certain Interests in, and Relationships with, Hedge Funds and Private Equity Funds”  et al, aka “Volcker Rule”;

Comment Letters and Analysis: Financial Crisis Inquiry Commission: Attended and analyzed hearings/testimonies while FCIC conducted its Due Process on Capitol Hill, 2010 and 2011


Financial Crisis and Financial Crisis Inquiry Commission: Forensics/post-mortem on root with associated prospered causes of the financial ‘crisis’ from late 2005 through the present and regular input to the Financial Crisis Inquiry Commission related to its hearings and analyses. (1/2010-1/2011)

Public Due Process Comment Letter (#440 10-22-10): FASB – Revenue Recognition (Topic 605): Revenue from Contracts with Customers  Letter #440. 10/2010

Bank/financial sector small cap Stock Indexes– Selected a universe (27 names; bench of 71 names) of under-covered smaller (market) cap financial companies including banks, thrifts. Produced an index of their stock market returns from 2005 -2010. Back-tested/compared portfolio return in top 10% against 41 ETFs, CEFs, indexes used for comparison. (10/09-5/10)

FASB “Blue-Ribbon” Panel convened on “fair value” impact in Financial Crisis“ Impact of use of Fair Value as the basis if measure in US financial reporting model, ie, US GAAP. Reviewed and attended US hearings, without public comment letter to FASB – 2010

Public Due Process Comment Letter (#81): FASB – Project: Fair Value Measurements and Disclosures (Topic 820) Reference Number: 1830 100 Amendments for Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRS 10/09

Public Due Process Comment Letter to the Securities and Exchange Commission (‘SEC”): Roadmap for the Potential Use of Financial Statements Prepared in Accordance with International Financial Reporting Standards by U.S. Issuers [Release No. 33-8982; File No. s7-27-08] aka opposition of “Adoption of IFRS” (2009)

Capital Link Inc Maritime Indexes: Developed/constructed Capital Link Maritime Index for the Capital Link website tracking its maritime clients’ stock movement, with oversight by expert, former co-worker Herb Blank.

Board of Governors of the Federal Reserve System Comment on data robustness/improvement for data used in revenue reported in Y-9C, 1/12/09 and to FFIEC and FDIC regarding data improvements desired in the Y-9C, ‘Call” Reports.


2008 Presidential Campaign – Vice President on the Independent Ticket with Jeffrey Boss for President

FDIC Comment Letter on Capital Adequacy

 Public Due Process Comment Letters on 8May 08 RE Commodity Futures Trading Commission: Agricultural Forum, April 22, 2008: comment; 5May08 related to Agri-commodities “CFTC Requests Public Input on Possible Regulation of “Event Contracts”ETFs, ETNs, ETCs  tracking commodities and associated indexes – public opposition to these equity market tradable vehicles submitted the Commodities Futures Trading Commission and Securities and Exchange Commission on May 8-9, 2008 towards its public comment on the recent problems in the agricultural commodities.

HedgeMetrics, Haugen Custom Financial Systems Sales of these QEDI clients’ products; engaged in portfolio management business development sales on behalf of both clients

XShares Advisors, Index Administrators for 19 Healthshares Indexes and associated Exchange Traded Funds “ETFs” Monitoring index members and selecting new bio/health members for index representation.

Enterprise Development Partners, LLC “PLASMARC”: Project development, capital infusion, merger/acquisition, site strategy $500MM-$1.5Billion (on-going); capital search for $250K-$25MM.

DiscoverScreenS: Capital infusion and strategic roll-up$3MM to $10MM.

OREnterprise: Risk Management company providing software for Sarbanes Oxley Sections 404, 302 Compliance; capital search $5MM

Van Eck Global, “Does the Steel Industry Perform Differently Than the Basic Materials Sector” Co –author with C. Michael Carty and Ed Matluck, PhD.

Rapid Ratings™: Sales and Consulting. Rapid Ratings™ screens portfolios for banks, lenders, large creditors and insurance companies to identify counterparty risk exposures to high vs low-risk credits investigate the creditworthiness of potential new credits; monitors creditworthiness trends of existing credits; also for compliance with BASEL II requirements.

Blue Ridge Motion Pictures  Capital Search, real estate sale of properties, $10MM – $20MM.


Rapid Ratings™: Sales and Consulting. Rapid Ratings™ screens portfolios for banks, lenders, large creditors and insurance companies to identify counterparty risk exposures to high vs low-risk credits investigate the creditworthiness of potential new credits; monitors creditworthiness trends of existing credits; also for compliance with BASEL II requirements.

Strategic Shareholder effort – Shareholder/corporate governance opposition to regulatory filings of the Sovereign Bancorp for acquisition of Independence Bancorp combined with opposition of regulatory filings by Banco Santander Application acquisition/change in control for Sovereign Bancorp; for regulatory submission, legal battle, amicus brief submission on behalf of shareholders; Relational Investors, I reviewed Santander application with Federal Reserve Bank of New York, New York State Department of Banking and Sovereign Bancorp application with the Office of Thrift Supervision for Independence.

Co-Author Blank, Herb, and Andrea Psoras. “When Sin Is Superior”, Financial Advisor, April 2006. Co-author on a white paper analyzing period from 1985 through 3Q2005 the divestiture and use of shunned ‘vice’ sectors to tweak investment portfolios ( ). The SPADE Index refers to this research.


Rapid Ratings™: Sales and Consulting while at QED International. Rapid Ratings™ screens portfolios for banks, lenders, large creditors and insurance companies to identify counterparty risk exposures to high vs low-risk credits investigate the creditworthiness of potential new credits; monitor the creditworthiness trends of existing credits; and comply with BASEL II requirements.

(2005-September from 11 September 2001) Whistle-blower years – over time period while the major financial players were using the financial ‘engineering’ aka ‘financial innovation’ to pump fees through the income statement and structure off-balance sheet securitizations to hide non-performing assets), I was a Financial sector analyst who went to the New York Fed, SEC on another investment banker engaging in corporate espionage and fraud.

Forming a new unit/repositioning of Strategic Advisory to Strategic Well-Being, to provide well-being and ‘retail’ financial advice to groups and individuals, adjusting business plan, preparing to Incorporate, building website, taking advocacy role against medtech/big pharma self-dealing – Spring/Summer 2005

Freelance writing and analyses of (Spring, Summer 2005): 1. The Google auction IPO; 2. Reporting Intangibles and the Knowledge Economy; 3. The ‘Catch-up’ Provision in 401(K) Plan Sponsor, Participant Adoption, discussing Vanguard experience as of 2004; 4. “Free” Trade = FRAUD TRADE, “Free” Trade: The British Crown Colonial Form of Commerce

Grass roots campaign for candidate for Manhattan Borough President, Summer 2005.


Stock Market related research on a trading model in targeted industries, Fall 2004

Re-matriculated Franklin & Marshall College – Accounting and Economics with ‘cutting edge’ research/ analysis on Revenue Recognition writing about/analyzing Barter Revenue in the Income Statement , and beginning an Econometric review of the Board of Governors study of Community Reinvestment Act lending. Spring 2004

Reviewed, opposed merger proposal between Bank of America and Fleet Boston on Concentrations of Power issues. Testified before the Committee at the Federal Reserve Bank of Boston with written statement introduced as support, however not read in entirety at the hearing: Public Hearing Regarding Bank of America Corporation, and FleetBoston Financial Corporation – Held on Wednesday, Jan 14, 2004, at the Federal Reserve Bank of Boston: Unedited Transcript. Vol I, Pgs 1 – 423, line . 0263 beginning 23

Reviewed provided feedback on Senate, House drafts on ‘Economic Stimulus’ and other Congressional/legislative efforts

New York Society of Security Analysts – Corporate Governance Handbook – research/analysis – drafts on Transparency, Management and Board Quality, and Independence; for the Corporate Governance/ Shareholder Rights Committee and used by the New York Society of Security Analysts, then by the CFA Institute for its own Corporate Governance Handbook.

Baruch College-Accounting Program/Accounting Certificate, 2003.


Reviewed provided feedback on Senate, House drafts on ‘Economic Stimulus’ and other Congressional/ legislative efforts

Client: Joint Equity Development Corp (“JEDCO”) a mortgage product startup founded in Connecticut/search for $5mm private equity. Advisor role: first became acquainted with the founder while at KPMG, where my role for this transaction began as Senior Analyst along with the transaction management/execution efforts.

Client: Julie Research Labs (NY) Strategic Advisor to Trident Project ($2.5B non-nuclear naval rocketry). Project impacted by policies of US nuclear arms strategy. Private equity search for firm while it was/is involved in lobbying for change in nuclear arms policy.

Client: Sageworks, Inc. and (CT/NC)– Strategic advisor/marketing for founder, Brian Hamilton on behalf of SageWorks, Inc. – an Internet based artificial intelligence tool/product that advises and provides an analytical model for ‘small’ business and other entrepreneurs to improve their business decisions, business performance.

Client: Alternative Power (NY) In negotiations to provide Advisor/Manager/Analyst to find strategic partners and with private equity, client development for this green energy/alternative energy, photo voltaic company – the September 11 catastrophe derailed the engagement (contract size difficult to estimate- $500k to $mm+).

Client: Enterprise Development Partners (NY) corporate strategy change for “green” steel/”green” power from waste.   Private Equity/Advisor role for this enterprise with operating strategies including scrap steel refining, waste pyrolsis and with strategies for profitable ‘community’ economic development (private equity $25mm-to open end project size).

Client engagement: UBS For 5 months in 1999 and again in 2001, I worked for UBS Warburg as a Counter-party credit risk analyst in its North American Financial Institutions department. Not an officer who could approve enlarging credit line exposures and approving trades that exceeded credit limits, I analyzed financial condition and relationships with UBS North American counter-parties. This group included: SunTrust, BBT (Branch Bank & Trust), Wachovia, National City (OH), Fifth Third, Citibank’s subs in Spain (whose financial statements were in Spanish), the Bahamas, its Credit Card Banks in UT and SD, its Asset Management Bank in Japan, BAC’s Institutional/Investment bank units in Canada and Chicago, Pacific Century Bankshares (BOH), Morgan Stanley’s Paris Broker/Dealer, whose financial statements were in French, Providian, The Dime (NY), Wilmington Trust Company, Fiduciary Trust Company, Shelby Collum Davis, Legg Mason, Spear Leeds Kellogg, Archipelago ECN, Jeffries, Raymond James, Advest, the Canadian banks, the US Farm Credit System, the FHLB, the Federal Reserve Bank of New York.

2000 Client engagement/subcontractor –

BLAYLOCK & PARTNERS- Combinations, financial modeling, strategic consulting for and with its endeavors including:

UPS (Transport/Fulfillment Sector) activities – Modeling and Buy-side M&A search for freight forwarders/customs house brokers; other types of fulfillment related companies and other potentially appealing companies to UPS. Transactions totaled approximately $100mm, and role was largely as analyst, but included some advisory and transaction management.

ChevronTexaco (CA) petroleum/consumer finance – Gas Credit Card specialty purpose entity/vehicle engagement on which I was among the group of advisors reviewing this investment/Joint Venture for Blaylock ($15mm) private equity opportunity.

TIAA-CREF (Fixed income investment organization)- $300mm-$500mm Collateralized Debt Obligations structured finance transaction on which I was an advisor, manager, analyst.

Southern Cos. (power/utilities) – business development/Private Equity opportunities to present Southern with suitable partners, targets.

Williams Family Investments Real estate/commerce on St. Thomas – Private Equity, M&A ‘services’ where I acted as Advisor/Manager as well as Analyst for insurance underwriting and brokerage.

Verizon Wireless (Telecom) $10B Initial Public Offering where I was included on a (syndicate company) Management/analyst team.

1995-2000* STRATEGIC ADVISORY (Overlapping in 2000 with Blaylock & Partners) Private Equity Activity log:

Client: SAGEWORKS   Strategic Advisor including Research for and Sale of the $10mm-$15mm company, a web-based small business artificial intelligence analytical tool

Client: The Archivum (NY/CA) – $3mm Advisor/manager/research engagement for this startup media content company.

Client: Julie Research Laboratories – $1.5mm Advisor role for this operating defense sub-contractor company


Client: Enterprise Development Partners/in conjunction with PLASMARC:          MTN and Medium Term Debentures financings – research, Habib Tariq, Developing market banks, investments in Latin/South America, Asia, former Soviet Block and Warsaw pact countries (while providing research/Due diligence efforts I conducted due diligence, encountered foreign paper, the complex global financial ‘grid’, “3rd World Debt, tax evasion, money laundering, and correspondent banking complexities)

1996 Client: Wit Capital now ETrade (NY/CA) $6mm private equity search for this on-line broker/dealer startup

1995 Client: Depthograpy  (NY) $3mm-$5mm Advisor/Manager/Research for this operating depth lenticular photography company

1994 + Client: JEDCO, LLC

1994-95 KPMG PEAT MARWICK LLP Capital Strategies/Global Capital Group a department created to compete directly with the major investment banks for financial services M&A transactions.

1994-95 General Electric Capital Corp (CT)Strategic Financial Advisor/manager for bid for $12B ITT Consumer leasing/lending division; Advisor/manager search for buyer of $3.5B ITT thrift, AND other Buy side engagements for its activities on which I was manager/analyst for these $multi-million transactions.

1994-95 Joint Equity Development Corp “JEDCO” (CT) Advisor/manager/analyst for $5mm Venture capital/private equity search activity as well as senior strategic analyst for unique mortgage equity product enterprise.

1994-95 Union Savings Bank of Danbury (CT) – Strategic Financial Advisor/manager/analyst for Merger/acquisition strategy to buy branch network, bank or thrift – estimated $80mm.

1995 First Fidelity National Bank (OK) – Strategic Financial Advisor/manager/analyst on growth/acquisition strategy and bank/thrift acquisition targets in its market area estimated net worth $25mm.

1994-95 Fingerhut (MN) Strategic Advisor/manager/analyst for M&A buy side target search thrift/consumer finance sub estimated net worth would be $100 mm.

1994-95 RMBI (NY)- Strategic Financial Advisor/manager on this mortgage bank’s estimated $15mm sale to Roslyn Savings Bank (NY)

1994-95 Pooled Asset Auction (NY) partnership to acquire an sell Real Estate Assets owned by CalFed – $350mm on which I was among the Advisor/manager team.

1994 KPMG – Development of its Derivatives Initiative with KPMG national lead partner for financial services practice Group Analyst consulting/business development.

1994 KPMG European Rating Project Survey and Initiative (NY) analyst for intelligence related to survey and dialogue with European/French banks/bankers after these began to be rated by US rating agencies.

1994 Webster Financial (CT) – Firm’s role as Strategic financial advisor. My role would be eventually manager/analyst on acquisition plans/synergy with competitor for a merger of equals estimated $95mm in net worth.

1994 KeyCorp (OH)Strategic Advisor to develop (estimated) $multi-billion “Consumer” Bank

1994 Carteret Savings Bank (NJ)Strategic Financial Advisor/manager/research (M&A) for minority bid strategy for failed $billion thrift while it was in RTC Conservatorship.

1994 Midlantic (NJ)Strategic Advisor (part of team as an analyst) for Problem Asset workout $100s mm

1994 Penn Federal Savings (NJ)  – Analyst/Manager for Buy-side search for acquisition targets with net worth greater than $10mm

1988-93 ADVEST GROUP – LYONS, ZOMBACK & OSTROWSKI, INC (LZO) Acquired 2000 by the MONY Group (Mutual of NY)

1992 Citizens First National Bank (NJ) with net worth greater than $100mm Strategic Advisor (I was an Analyst) to ‘hostile’ large shareholder attempting to gain board seat with their ‘shareholder activist’ efforts

 1989-90 Manufacturers Hanover Trust (NY) estimated assets in multi $Billions- Strategic Advisor (analyst on Advisor team) prior to acquisition by Chemical Bank (NY); performance evaluations/bench marking/peer comparisons while MHT was a retainer client

 1989-90 Republic National Bank New York (estimated Assets of $25+Bs) – Valuation, fairness opinion for tax purposes of its Uruguay Subsidiary (net worth $mms) with significant precious metals, metals trading operation – Analyst for Advisor

1988-93 Peoples Westchester Savings Bank (NY) Assets greater than $4Billions Strategic Financial Advisor to client while it was acquiring healthy and failing local thrifts transactions on which I was Analyst-research and/or Manager.

1990-92 $10+mm to 100+mm Recapitalization-Private Equity/Rights offerings/Open Bank Assistance filings for the following: 1992 Union Savings Bank (Long Island) ‘Good Bank/Bad Bank’ strategy, 1991-92 Bank for Savings (MA),

1992 Sentry Bank (MA), 1991-92 Brooklyn Savings (CT) among others Strategic Financial /Regulatory Advisor for recaps/private placements which included detailed modeling, due diligence, capital plans – Associate- (execution side).

1992 RiverBank America (East River Savings Bank – Assets greater than $3.5Billions) – Strategic Financial Advisor for Branch Sales with Sales Memorandum and Recap forecasts and documents on which I was Manager/Analyst-research.

1992 Howard Savings Bank (NJ) Assets greater than $1.5BillionsReviewed documentation and valued auto leasing portfolio ($100+mms) prior to FDIC resolution the role of which I was Analyst-Research.

1992 Garden State Bank (NJ) with assets greater than $350mm – Branch Acquisition strategy as well as Strategic/Regulatory Advisor while under a Memorandum of Understanding (“MOU”). Analyst and assisted LZO Partner.

1991-92 House Financial Services Committee: Research while at LZO for Congressman LaFalce (D/New York) on which I was analyst-research.

1991? Old Stone (RI) with assets in $Billions Strategic Financial Advisor (I was the Analyst) to seller, valuation of trust operations while this ‘thrift’ was ‘failing’.  The Sale was part of a strategy for capital raising purposes for Old Stone. I worked on this forecast/model.

1991 Peoples Westchester Savings Bank (NY) Strategic Financial/regulatory Advisor on ‘purchase & assumption’ acquisition of Larchmont S&LA, valuation/fairness opinion and models role of which I was Manager/ Analyst -Research – $5mm capital infusion. I built, worked on the forecast/model as well as parts of application.

 1990-91 Brooklyn Savings Bank, Danielson CT. Recap and Request for Open Bank Assistance for $14MM -20MM savings bank with assets of $300MM, with non-performing real estate/development-construction projects.

 1990 State Bank of Long Island (NY) assets greater than $250mm – Strategic Financial Advisor/Analyst-research for Branch bid strategy for failed thrift deposit franchises and Acquisition targets.  I worked on this forecast/model as well as bid strategy for this client.

 1990 Federal Deposit Insurance Corporation – Division of Liquidation; Research Analytical advice, empirical feedback on development of Brown-Epstein Resolution/ “Loss-on-Assets” model for failed bank/thrift resolutions as well as use of the Bovenzi-Merton Resolution/ “Loss-on-Assets” model – on this project I was an Advisor as well as an analyst-research.

1989 Savings Bank of Rockland Country, (NY) – MOU/Business-capital plan advisory role – $250MM sized thrift required to meet regulatory constraints under a FDIC MOU.  I worked on the business/capital plan, the financial-spreadsheet model and with the LZO ‘team’ which interacted with Bank’s board, management, control/audit staff to improve it’s financial condition and operations for release from MOU.

1988-90 TONE (The One Bancorp) Bancorp/The Maine Savings Bank  M&A engagements and later, recap/private equity search for this $billions thrift.  I worked on the memorandum for this series of engagements.

1988 Sag Harbor Savings Bank (NY) assets $350mm- Strategic Advisor/Analyst on its sale to Apple Savings Bk (NY) I worked on Sag Harbor’s forecast for valuation and M&A purposes before its acquisition.

**1993 RB Cenlar (NJ based mortgage bank sub-servicing operation) Strategic Financial Advisor/Manager/analyst- research for recap, branch sales, and capital plan while under MOU with regulators.

**1993 RB Elmwood Federal, Media, PAStrategic Financial Advisor on which I was Manager/Analyst to seller, valuation of company

**1993 RB Central Pennsylvania Savings – Strategic Financial Advisor on which I was Manager/Analyst to seller in its sale to Meridian

Other Sector Activities and Relationships: – Steel Sector (Integrated, Specialty-Niche, Blast Furnace, Pyrolsis/Electric-Arc Furnace Refining, Scrap/Recycling), Precious Metals refining, Waste Conversion/Bio-remediation, Environmental Engineering, green energy, media content, logistics/fulfillment, maritime/ocean transport and related sectors.

Other relationships/share ownership in: Bethlehem Steel, Baldor, Morgan/Chase, Lehman Brothers, ConAgra, Novis/Stratford Acquisition Corp, Philip Services, L-3Com/(Ayden), Schlumberger (EMR – Drill Tools/Missile Guidance), BlackLight Power


* In 1999, again in 2001, I worked for UBS Warburg as a Counter-party credit risk analyst in its North American Financial Institutions unit. I analyzed financial condition and relationships with UBS N. American counter-parties. Group included: SunTrust, Wachovia, National City (OH), Fifth Third, Citibank’s subs in Spain (whose financial statements were in Spanish), the Bahamas, its Credit Card Banks in UT and SD, its Asset Management Bank in Japan, BAC’s Institutional/Investment bank units in Canada and Chicago, Pacific Century Bankshares (BOH), Morgan Stanley’s Paris Broker/Dealer, whose financial statements were in French, Providian, The Dime (NY), Wilmington Trust Company, Fiduciary Trust Company, Shelby Collum Davis, Legg Mason, Spear Leeds Kellogg, Jeffries, Raymond James, Advest, the Federal Reserve Bk of NY.

**Indicates the transactions in which I was involved while an Associate VP for 3 months at Ryan, Beck in West Orange NJ.

Posted in financial sector, Professional: banking, Professional: CV-Resume-Transactions List Details | Leave a comment

Banks: Is a New Glass-Steagall Good News? My comment to Ben Levisohn of Barrons

Hello Ben,

I helped work on Gramm Leach Bliley (beginning when it would have been D’Amato Leach Bliley).

I met Rep Jim Leach at the 2000 Republican National Convention while a NY delegate for Senator John McCain. When I met Rep Leach (and I considered that a privilege), after I introduced myself, I asked why didn’t we allow the mix of commerce and banking in repealing Glass Steagall when we ‘passed’ GLB (I missed meeting Senator Phil Gramm and Senator Jessie Helms by the delay in USPS mailing the invitation to me for that function at that event venue in Philadelphia prior to the Convention’s major reason for convening).

Rep Leach said in effect, that if we’d allowed mixing commerce and banking, that large foreign industrial companies like Daimler would have wanted to buy our largest banks, LIKE THAT, A SNAP OF THE FINGERS. My eyes went wide as … and I felt some sort of shock through my system while I looked at him after what he’d said.

He said he didn’t want it, and I agreed I didn’t want that even though I’d researched and analyzed that matter while reviewing what would have breached the founders’ attempts to stop the abuse of power by limiting concentrations of power…

I thought I had it all figured out about what made Ford’s ownership of First Nationwide a marginal operating strategy, and like that, but as if that was OK. Regardless however, what he said had the appropriate shock effect on me.

It was a while before I’d come into a key understanding about what was a root problem of,  and reason for the matter that he’d mentioned ie,  domestic or large foreign commercial and/or industrial enterprises able to buy our banks.  It isn’t only about concentrations of power by size, including  Too Big to Fail. ALL DISCUSSION, CONTEMPLATION AND PLAN TO EMBRACE THE  PROBLEM OF GOING BACK TO GLASS STEAGALL AND WORTH PUTTING THE TOOTHE PASTE BACK INTO THE TUBE  MUST INCLUDE OUR DETERMINATION TO ADDRESS AND AVOID THE ***ABUSE OF POWER***.

But there’s more to it; it’s not that simple to repeal Gramm Leach Bliley and Commodity Futures Modernization Act both which were de-legislating while legitimizing combining banking with investment banking, and writing and trading credit swaps, and derivatives contracts (these obtaining the ‘financial innovation’ nick name, even though that originally meant developing and selling Mortgage and Asset Backed Securities) without any regulatory framework or oversight.  Legitimization of writing and trading (making these instruments affected by the levels and direction of the financial markets, and thus enfragilating) credit default swaps (CDS) and derivatives gave balance sheet access to these instruments, as if they were legitimate assets belonging on a bank’s balance sheet, when they are not legitimate assets except that legitimization to trade them gave them access to sleaze into asset class. These as assets on banks’ balance sheets increase fragility on a bank’s balance sheet, while performing loans and other legitimate balance sheet worthy assets (those producing monthly cash flows regardless of the directions of the financial markets) tend to stabilize a bank’s balance sheet.

While I was researching my Public Due Process Comment Letter to the regulators about opposing  Basel III, I began to understand another ROOT CAUSE, not only of our long time problems we’ve had in abuse of power and corporate personhood.  My research brought me to know WHY THIS MAY HAVE BEEN THE CASE of large foreign commercial ‘national champions’ acquiring our largest banks, had Rep Leach and the others in Congress not taken some aggressive steps against mixing commerce and banking in GLB.

***We have to repeal US signatory status to the GHWB G8 Agreement to which that president committed the US to the germans, although other European countries are also signatories, but they sort of don’t matter. ***

This particular multilateralism by and since him over these 25 years, has been most of the root problem (s) we’ve been experiencing. In effect GHWB agreed to throw  the US under the bus to suit german interests to ‘align’ US regulation, and in effect the US corporate pecking orders to suit the germans and the ‘national champions’ in Europe. This is their name for their largest companies that have their cozy interests and power with the countries in which they are domiciled. Like Daimler, or DB. In the case of the Grossbanken, these enjoy huge power over there. Think about DB is doing in Europe, now most of which is under the EU ‘free’ trade/euro currency zone umbrella to advantage Germany over all other sovereigns which have become EU members. This is the design of this multilateral framework.

The way that we could and if we should do a restoration of Glass Steagall is to repeal US signatory status to that which is a root foul of our society, economy and somewhat, our sovereignty. Repealing US signatory status to that G8Agreement gives us some traction against larger foreign companies wanting to buy our banks if we reduce their size, as well as some traction against Germany’s interests to obtain hegemon powers.

This interest and that Agreement are sort of what is a root of the ‘global competition’ concerns by senior management of our largest banks, although I am not certain if they understand what is the reason for why their banks would be vulnerable and also in part why they’ve blown up as well as inflated their balance sheets with these pathetic, gmo of the financial product world, swaps and derivatives.

Rather than go down the rabbit hole on ghwb (scherf) we need to understand what he did in that G8, and which no subsequent president seems to be willing to take on and repeal. That G8Agreement also is why rather than administering our own effective regulation that we had with Prompt Corrective Action from the 1991 FDICIA legislation, we’ve adopted the Basels….I liken basel agreements as in effect what comes out of the research department of the Federal Reserve Bank of NY or the Research division of the Board of Governors of the FRS in DC. BSCS was the research arm of the BIS. see?

On a related matter, another thing to which he agreed in that G8Agreement was to deindustrialize the US so as to not be a ‘trade competitor’ to the germans so that Germany could sort of ‘trade’ itself out of some of the cost of reunification, which he and helmut kohl schemed, and to which Thatcher and Mitterand vigorously opposed. In order to spur management to take production out of the US, it would go into ‘trade liberalization’ ie, with cheap labor, and usually Catholic countries, the US would knock down the Constitution’s Article 1 Section 8 tariff framework against the imports from those countries. This is what is commonly known as ‘free’ trade, but in reality, that is a double speak expression for US self immolation and economic treason.

The swaps and derivatives hide the deleterious impact of the increasingly souring loans/ credits in the weakened developed economies to do loans into scratch dirt/ underdeveloped foreign economies which often were former colonies of our allies. These financial items however and glowingly called ‘financial innovation’ which first was an expression used by people like McKinsey’s Lowell Bryon, to characterized asset backed securities, such as MBS and CLOs, but now is an expression used to pretend these contingent agreements deserve balance sheet access like loans, but not at all with the same properties as loans, which are the banks’ main investment business and are a well worn groove that can be regulated. Meanwhile the derivs and swaps were what were not what should have been legitimized and to TRADE, which Commodity Futures Modernization Act (derivatives) and Gramm Leach Bliley (CDS) both allowed.

These enfragilating items do not belong on the balance sheet and a smoking gun as to a real purpose is found here Ms Fixler said, that in the early 90s, US banks were ‘enlisted’ into finding ways to help Germany deal with the cost of reunification. In knowing that Germany would not be able to obtain direct transfer payments from the US in order to reunify, bush – who had some roots on Wall Street with relatives at Brown Brothers Harriman, and anyway, president that was a part of reuniting a Germany that deserved to have been separated, and should have been left separated, but that the US banks which also operate in Europe as counterparties to large European banks that also would be affected by 1. german reunification and 2, the EU strategy that would be Germany taking over Europe using a ‘free’ trade zone, a same currency and a legal framework that eventually always would advantage Germany, except for the power of the ECB against Germany’s sovereign self interests. Draghi knows this and Germany too, and has to play along with the power of the ECB. Notwithstanding, our banks as counterparties and because from that time, the power of the bushs got the FDIC pushed back while the Fed and ‘financial innovation’ got glorious traction. Those instruments could not trade thank God, except when Ruben, Phil Gramm, Larry Sommers, greenspan and Clinton got the Commodity Futures Modernization Act CFMA2000, against Brooksley Born’s insights and experience – no regulatory framework nor institutional structure existed for these instruments, which were lying off balance sheet, but not in the hundreds of trillions notional they do today.

When that legislation got passed, by 2004, derivs and swaps plumed to more than $400 Trillion notional and without virtually any of the paperwork straightened out. It was while Tim Guithner was NY Fed president that he told banks in that district to get their paper work on those contracts in order. It was because my research on barter, and revenue recognition was somewhat of a spur to bring some attention to this huge looming problem of these contracts, how even when hedged, they’re what’s fragile, because they’re financial market connected, (whereas very little about banks’ balance sheets were financial market connected – before glb there weren’t the ‘margin accounts’ concept that had existed on banks’ balance sheets’ from after FDI Act 1933 to 1998. in 1929, when there were margin accounts on banks’ balance sheets, this was some of the reasons banks failed with the 1929 stock market correction.

This is why CFMA 2000 should be repealed and the part of GLB that legitimized the writing and trading of Credit Default Swaps, that part of GLB should be repealed. Don’t even need a Volcker ‘Act’, rule. Delegitimize instruments which make the balance sheets fragile which until CFMA and GLB weren’t on banks’ balance sheets and didn’t belong there anyway, and this will somewhat help diminish the financial crisis.

The financial crisis isn’t really over. Only because of nearly zero interest rates which has tended to spur action into the institutional financial markets, is there ‘stability’ and an illusion that the pus economy is Ok. Unemployment actually is quite high from deindustrialization and the contraction to which that has contributed. Banks don’t have a healthy economy here or in other developed countries into which to lend. This current admin has been aggressive to heist the ‘numbers’ and manipulate them for disingenuous public dissemination, but it’s in effect to keep eroded the US economy to ‘comply’ with that to which GHWB also agreed – to ‘align’ the US economy with that of in effect Germany, to have no net new job growth probably from when he was in the W/H, and facilitate the ability for foreign ‘national champions’ to have more traction here. that’s why foreign banks could operate in the US without being adequately capitalized, and through the 90s enjoyed a fair amount of Teflon from our regulators.

Repealing Glass Steagall isn’t a bad idea and it is possible to put the tooth paste back into the tube. It is better to repeal CFMA 2000 and unwind the huge books of swaps and derivs when these fragile instruments are delegitimized.

Please feel free to quote me, but do give me attribution.

Andrea Psoras

Posted in asymmetric war, EU, FDIC, financial sector, Germany, Resolutions of 'SIFIs' | Leave a comment

Psoras – Curriculum Vitae/Resume CR 2Q16

Andrea M. Psoras

201 W117th Str #2B NY, NY 10026 ; (212) 666-2569;


  • Financial Analyst/Financial Sector with strong strategic thought leadership skills – experience consulting to, analyzing predominantly depository and financial institutions. Strong skills in: Financial analysis, research, quantitative analysis with strong commercial intuition and reasoning/problem solving, abilities ; team player in transactions-projects with multiple stakeholder collaboration for M&A-investment banking (combinations/divestitures), credit/counter-party risk, stock or Private equity portfolio investments (industry/macro, credit analysis) using 10Q, 10K, Y9-C, “Call”, TFR, Focus, some Basel II, Pillar 3/Market Risk – FFIEC 102; FFIEC 101; FR Y-14/“Stress Tests: DFAST, CCAR – Capital Plans, capital planning and Capital Adequacy research and analysis ; Dodd Frank (Resolution Plan) related, consulting business development. Some Financial Reporting work.
  • International Bank Credit Trained – formal credit training;. 24 credits specific to Accounting.
  • Strong software skills including complex interactive (spreadsheet) forecasts, strong modeling, building models: MS Office: Excel, Word, Access, Powerpoint, MS Project; Lotus 123, Amipro; FoxPro; dBase and programming; WordPerfect; Bloomberg API spreadsheet building; FactSet product use; QuickBooks; STATA; Sybase; WordPress-website development; some SAS JMP/data mining, data analysis; BigDough; Sales Force; MedTracks
  • Member: NYSSA; Jul’14 NYC Exam for Staff Analyst Trainee: 78%; Jun15 NYC exams for Analyst, Assoc Staff Analyst

EMPLOYMENT/CONSULTING (see also Transactions/Projects/Activities List in WordPress)

  • Independent Consulting/PLLC Family office Analyst/Consultant           (8/08-Pres)
  • QED International Associates, Inc. (“QEDI”) Senior Vice President    (10/05–8/08)
  • Strategic Advisory (“SA”) Principal/Analyst                                        
  • KPMG Peat Marwick, LLP (“KPMG”)                         Senior Banking Analyst                                                                        
  • Lyons, Zomback & Ostrowski (Advest Group) (“LZO”) Associate/M&A consulting

EXPERIENCE-Financial Sector, Related (Also see Transactions-List

Financial Analyst – Counter-party Credit Risk (and project-contract-temporary, etc); Financial Reporting:

  • For Financial reporting work by/for Treasury, Control, gap analysis (in Hyperion, Sybase), G/L: I reported to Controller, Treasurer, CFO at large European bank sub in US, for whom I also determined profits and losses from trading: derivatives – options, swaps, hedges; forward rate agreements, FX
  • Used/analyzed GAAP; RAP data: “Call”, Y9-C reports, Focus Reports for broker/dealers, North American based financial institutions, credit card banks, financial service cos, broker/dealers, ETNs, also analyzing US subsidiaries (“subs”) and foreign subs in Europe, Asia of US based financial institutions (some translating from French, Spanish)
  • Reviewed Y2K, operations/IT compliance, some editing of Counterparty ISDA docs used for adjusting global exposures to credit counterparties
  • Provided credit analysis using internal credit utility software on Global 1000 cos. at a global bank for Sr. Mngt
  • For clients (while at LZO), for internal use I worked on the development of the LZO Bank & Thrift Directory a bank rating guide subscription product, and from regulator data in dBase form I built, I co-developed a credit scoring model that quality-rated banks and thrifts as a proxy for rating their CDs

M&A and Related Consulting (mostly “Execution” side):

  • LZO, KPMG, SA I co-authored M&A, recap, strategy, business-capital plans (these were predecessors to ‘Resolutions’ Plans) for regulator, client purposes.
  • LZO, KPMG, SA I created, constructed, developed complex, scenario driven interactive Excel, Lotus spreadsheet models with stress testing/scenarios, pro-forma forecasts for business combinations, divestitures, recapitalizations, private placements, financial and/or credit analysis; modeled mostly retail, (some) commercial, industrial, SNC/‘participations’ loan portfolios – to accompany co-authored materials.
  • LZO, KPMG, SA For execution side of transactions/projects: I engaged in strategic consulting, strategic economic and financial analysis collaborating between external, internal stakeholders: senior partners/investment bankers, analysts, clients and/or external parties such as the regulators; “turn-around” work. I also was involved in some business development.
  • LZO, KPMG, QEDI, IC While laws, regulations have been designed to diminish the number of ‘mouths’ feeding at the table of the US economy, for stakeholders – clients, regulators (external) and MDs (internal) I researched/surveyed/co-authored: industry trends, economic/demographic trends, sub-sectors; fairness opinions, regulatory assisted transactions/FDIC resolutions-Resolution plans, Open Bank Assistance Requests/Applications; D’Oenche Doctrine. I also analyzed deposit franchise/branch networks, market/trade areas, calculated Herfindahl (deposit concentration, anti-competition/anti-competitive) analysis; associated scenario driven spread complex interactive sheet models.
  • LZO, KPMG, SA, IC Used/analyzed, dealt with definitions, data changes in “TRF”, “Call” reports, UBPRs, BHCPRs (“RAP”) including Examiners/Exam Reports, and GAAP data on North American based financial institutions, other public and private enterprises – understanding, comfortable with data and those definitions that role up into these reports
  • LZO, KPMG Worked on structured pricing/bids, strategies for acquiring, selling branches; also for failing/failed financial institutions.

Other Related Experience (Full CV, Transactions/Project List /

  • Financial Services consulting: Dodd Frank Resolution Plan/PMO business development, related consulting
  • Financial Reporting using Financial analysis, transactions, and product development on other sectors: CFTC public due process comment on Event driven commodity contracts; “Stress” Tests public due process comment
  • Analysis of Accounting/Financial Reporting; Risk Management, Regulation and Legislation
  • Basel III Public due process comment; Basel II macro/micro (some policy) Analysis
  • Analysis of mortgage products, mortgage equity products and associated companies
  • Medium Term Notes: Transactions and Collateral Due Diligence, coordination with Traders/Trading Banks

EDUCATION and OTHER: Franklin & Marshall College, B. A. Major/minors: Business Mngt/Economics, Accounting (24 credit hours). Columbia University, NY, NY. Public Economics, research: ‘Shadow Pricing of Foreign Exchange”; Spanish. Baruch College – CUNY : Accounting Certificate. 15 Credit hours (Fall 2003), Budgeting, QuickBooks, Audit. Full CV:

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Psoras, Andrea: Structured, Thermogenic Diet or “The Diet”

Psoras, Andrea: Structured, Thermogenic Diet or “The Diet”

Subject: diet and antioxidants includes list on what to go ORGANIC vrs what not to because of the expense except for the pesticides on those veg/fruit not going organic. ‘Herbal’ list at the ‘end’ of the doc.

Introduction: With or without exercise, it is relatively easy to loose weight and/or enjoy better quality of life with this structured diet which uses a sequencing strategy starting first with liquids then eating food groups especially excluding/AVOIDING any gmo grain product coated with herbicides and animal product having GMO and associated herbicides (mainly Round-up, a high phosphourous herbicide and 2,4D, a dioxin ingredient herbicide). Also this also is a low phosphorus diet (see bot of pg 1, top of pg 2) which attempts to avoid heavily herbicided/insecticided foods although that’s another body of knowledge for another time.

WE NEED to rid our food supply and environment and thus OUR DIETS of GMO and associated herbicides*:!documentDetail;D=APHIS-2010-0103-4699 and live-stock pharma (bio-engineered product and associated herbicides) of any sort in the source animals.

This food and strategy endeavors to achieve this while providing better nutrition, and killing candida albicans – a yeast related, opportunistic and competing organism that lives parasitically in the bodies of most people. The Diet promotes thermogenics. Thermogenics is when the metabolism is increased using foods that leads the body to burning body fat and/or where the food itself needs more energy to burn than the calories the food gives back to the body.

One will find this nutritious diet effective for youthful vigor, weight loss -if one wishes to use it for that purpose as the diet is a modified Fit-for-Life with Atkins**’ higher protein, lower carbohydrate, low phosphorus diet. Atkins however has little fruit and virtually no carbohydrates, while “fit-for-life” suggests eating fruit AT BREAKFAST ONLY before 12pm, but at lunch and dinner eating vegetables while at the same meal avoiding eating proteins with carbohydrates (eat vegs + starch at one meal, while at next meal eating vegs + protein such as meat or fish or poultry or eggs), and suggests to avoid – and thus prohibits eating after 7pm.

Including a faster metabolism and well-being, benefits are improved blood flow to the brain when one avoids eating proteins and carbohydrates at the same meal. The calorie burn also is far better by eating starches at a different meal than meats/proteins, etc and eating vegetables FIRST at both lunch and dinner – before one eats the more complex food such as a carb OR meat.

Again avoid all YEAST, including that in beer. Atkins’ book has an entire chapter on yeast (although Atkins writes about this when cattle became feed-lotted with steroids and pharma-antibiotics, and candida which flares when people eat feed lot cattle with that pharma /antibiotic and steriod contamination and thus the sugar-comfort food cravings) and its negative impact on the body, mind and emotions. Stumbling on both his insights and mine may be liberating for the user of this diet and/or supplements. People became more yeast sensitive with pharma in the feedlot livestock meat. Avoid this and go to grass fed and organic on meat, poultry, milk, eggs etc.

Candida Albicans and its pathology

The yeast family organism by the name of candida albicans causes many health problems often passed off as other problems. Candida Albicans, or “c Albicans” are a bane of the civilized world and contemporary life. While depriving and killing the candida albicans and perhaps parasites and other negative bacteria, the point of this structured food strategy using superior quality calories is optimal nutrition for one’s body and soul, and sense of well being.

Candida is a living organism that will compete with you for the nutrition that you put into your body, while also competing for squatting space in your brain, lungs, stomach, mouth, lower digestive tract – anywhere in your body that is soft, damp dark tissue. It will circulate through your blood and will root in the liver. Rooting in the Liver, candida will cause the liver to produce, thicker, gunkier dirtier blood. Heavy proliferation of candida may be a precursor to liver cirrhosis, lung problems, colon problems, stomach problems. The Candida’s chemistry ie, its ‘pathology’ in people usually are the physiological root of most cravings (as well as perhaps feeling fatigued, sleepy, depressed, depression, irritable and habits such as eating for ‘comfort’ or eating when depressed or nervous, lack of concentration/mental focus, cigarette smoking, craving for alcohol. When detoxing, sometimes I’ve gotten that skin-crawling-listlessness and occasional nausea which passes after up to a few hours, but is quite annoying while enduring it.


Candida organisms cause cravings for, and the desire to ‘taste “Comfort food” such as bread/yeast, dairy, sweets, alcohol*, tobacco, drugs. Some of their chemical blow back signs are depression, PMS and cramps, phlegm, slow colon, sinus headaches and migraines (although regular migraines and bi-polar are from a parasite which has positioned itself on the hypothalamus and imparted its own chemical interference with one’s brain chemistry). (NOTE TO alcoholics – Alcoholics frequently have poor diets and often have severe candida problems. Getting them immediately to optimal, anti-candida nutrition will give you better traction against the alcoholism)

Poor diet with antibiotic polluted dairy and livestock (ie, ‘treated livestock, poultry, eggs, cheese, etc) and red meat from feed lot livestock and/or livestock fed grains, devoid of B-12, excessive amounts of beer and alcohol, and insufficient exercise, sleep, sunshine promote candida proliferation in the body, lungs and brain and mouth.

GMO and herbicides such as dioxin and glyphosate, high phosphorous aggravate-flair the yeast and candida. And the bio-tech of the feed lot growth hormones and associated anti-biotics also spur the candida/yeast problems. Actually going organic significantly lessens the problems of phosphorous blowback, because going organic minimizes the gmo and Roundup (glyphosate, which is high phosphorous) in the body. Foods such as organic poultry or quinoa or kasha/ buckwheat or organic peanuts or nuts are less aggravating and less likely to cause fluid retention. The Round-up and any additional phosphorous load contributes to fluid retention, sciatica, bloat, numb limbs, feet, hands, and other build-up of phosphorous in the capillaries, even sore teeth roots. Cycle out of all foods with gmo ingredients and herbicide contamination and do large doses of dandelion in any form, black raspberry (battery of OPCs), vits E, C, and fish oils and evening primrose oil caps ALL from non gmo origins.

The glyphosate ie, the high phosphorus herbicide by monsanto ie Roundup (and high sweets-comfort food diet) fertilizes the Candida albicans which are ‘opportunistic’ organisms, which means they plume when the body’s run-down condition permits their proliferation. These organisms are negative and dysfunctional in the body, and will reduce one’s vitality when simultaneously competing for proper nutrition against the beneficial bacteria in our bodies. The candida generally will proliferate over the good bacteria in one’s digestive tracts, UNLESS one takes proper nutrition and life style steps, as well as a separate supplement first thing in the morning and before meals, such as a lacto bacillus supplement. Lacto bacillus “LB” products such as All Flora (use if possible one without soy), or Daily Dophilius by Country Life, or Kyodophilous, and Primadophilus bifidum, are effective. LB are important organisms although from foods such as yogurt, beets, carrots, radicchio one can find natural lacto bacillus.

Other Physiological blow back from yeast Remember yeast is a living organism and spore. GMO and herbicides which themselves make gunky blood and harm the liver, but the GMO and herbicides contribute to Yeast gunking up-fouling up the liver with its own root system, interfering with the proper functioning of the liver to cleanse the blood, causing the liver to render dirtier, thicker blood, while causing body odor and the other candida problems, etc. Eliminating GMO/herbicides, yeast and most white refined sugar (especially GMO beet sugar) and/or dirty dairy (antibiotic and stimulant hormone laced, and full of parasites such as shigella and e-coli.

On Children, Babies and their taste buds/desire for ‘sweets’ picky eating and colic:

If you ate sweets, bread and a great deal of dairy and eggs from antibiotic and hormone treated and feedlot/gmo grain fed dairy cows and chickens, and indulged your Candida while you were pregnant, your children usually will be born with Candida Albicans. You can remedy this with cleaning up your diet while breast feeding although babies will be sensitive to the garlic and other quality anti-oxidant Candida killing upgrades in your diet. This will cause them some gas until their Candida are killed.

I am not certain if this takes a day, a week or a month, however avoid giving them formula from soy and other grains from gmo crops, and avoid formula from milk with the dairy from cows treated with stimulant hormones and antibiotics especially if you are avoiding this yourself, avoid also using soy based formulas as well as BigPharma formulas in general. If you are getting proper nutrition and vits/anti-oxidants, that will pass into breast milk. While they are growing, avoid foods with white refined sugar, sodas and other ‘juices’. Clean water and clean milk from non-antibiotic polluted, non-gmo alfalfa fed livestock will be the better beverages for them with limited amounts of quality pure, non sweetened, juices not from concentrates. And if they’ve been given vaccines, make certain they get sufficient B vitamins, using baby vitamins that one can find at the better health food stores.

Or Go to vacuum packed organic such as Parmalat’s vacuum packed milk OR TRADER JOES GALLON ORGANIC MILK- I FREEZE THIS AND IT CAN BE THAWED AND REUSED – AND I BOIL IT) from the diet, generally eliminates body and scalp odor and the ‘garlic on the breath’ after used as a liver cleanse or cold remedy won’t be so bad, but several cloves of chopped garlic in kefir (drinkable yoghurt of dairy from untreated animals – home made kefir from boiled non-pharma milk is best) and taken at night or first thing on an empty stomach is good for the liver and to get rid of colds.

Diet suggestions and tips – avoid all GMO grains and foods with GMO ingredients from those grains that also are polluted with the herbicides*

THERE IS virtually NO PROCESSED FOOD ON THIS STRATEGY by going to a diet that is: yeast free, processed food free, white sugar -free, bleached-bromated white refined flour free strategy, ie eliminating all foods with yeast, and all processed foods. This includes no buillion cubes, no lipton packaged soups. No fruit juices except 100% pure fruit juice so to avoid the gmo sugar beet sugar.

There are Non Yeast breads sold at the better health food stores found in their freezer cases. One needs to read ingredients in any processed carbohydrate as yeast is found in saltines, most crackers and virtually all pretzels, so low fat or low sugar isn’t always the issue, it’s also a yeast issue and what feeds the yeast spores for reasons I explained. Then there are the GMO vegetable oils in many foods. Those also carry the herbicide load and are toxic to health and slow the metabolism.

On this diet there is no yeast bread, or other yeast products, refined white sugar, or things made with white or brown sugar, or in general processed food, except matzo or similar cracker such as Ryevita. Further, eliminating virtually all white refined flour and white refined sugar mitigates cholesterol build-up and plaque in the circulatory system. Bleached and bromated white flour – this and white refined sugar gunk up the liver, and reduce efficiency in proper fat digestion and cholesterol ‘development’/use.

As a result – use breads without yeast, sometimes, although even some slow rise and natural rise are with yeast, however, ask – known as ‘slow rise’ or ‘natural sour’ found in the better health food and sometimes better super markets. I would not recommend this and I have suffered when taking the risk on bakery ‘slow rise’ or natural sour bread except for ‘French Meadows’ brand found in freezer cases of the better, larger health food stores or “Whole Foods” Food Chain markets. Trader Joe’s Sour Dough bread is ok – ingredients were OK.

This Diet recommends dairy and meat from grass ONLY-fed livestock, while avoiding feed lot cattle (most red meat and pork at this point unless labeling states other wise – this generally is the meat found in the supermarket meat section and will not state it is ‘feedlot’ although it may say ‘corn fed’ or grain-fed or even black angus, unless it is labeled ‘grass-fed’. Even “natural is a bogus label which doesn’t mean the meat was from livestock raised eating grass its entire lifetime.

These too have been fed GMO grains, gmo alfalfa, gmo beets and are contaminated with that and dangerous herbicides) processed meats, etc, hot dogs, sausages, and meat w/livestock medicines such as antibiotics or growth hormones and processed/artificial smoked fish, farmed fish, or pharmaceutically treated fish, poultry, livestock, or hogs and all also excluding artificially smoked meats. Avoid ‘pulled’ beef and pork, both which have vinegar and often also are from feedlot livestock and hogs.

Similar to Atkins, The Diet recommends fresh fruits/vegs/ kefir, and organic eggs, and perhaps some occasional whole grains such as buckwheat or river rice, but NOWHERE NEAR THE CARBS AND/OR YEAST CURRENTLY FOUND IN MOST DIETS.

*LIST OF WHAT TO BUY THAT’S ORGANIC in this list: milk, eggs, grass fed meat only, poultry, US cheese.

NON GMO ARE OK in this group-list: olive oil, VEGS green leafy, avoid iceberg lettuce because of all the insecticides on it. Use escarole, dandelion, green chard; European cheese as long as it is from grass fed livestock and that is difficult to know unless organic, wild fish only.

GMO foods/grains and associated permutations in processed foods: corn, soy, sunflower seeds, alfalfa, rapeseed, canola, sugar beets and sugar beet sugar (papaya, and zucchini and summer yellow squash) as this is used in virtually all juices, candy, and other similar sweeteners. Cane sugar actually is not GMO and is safer than GMO. SAFE NON GMO foods – all the greens, most of the fruit except papaya, avacado and yellow apples, some granny smith. Look for the 4 digit tag or the 5 digit tag starting w/9.

On Cholesterol, and lipid issues such as sciatica

This diet has virtually no white refined sugar or bleached white flour both, nor processed foods with GMO/herbicides all which gunk up the liver and foul with clean cholesterol production that the body needs for itself for nervous system and proper brain nerve/chemistry function. Without what are clean fats and lipids that the body and nerves produces for itself, the body by way of the nerves will ‘electrocute’ itself. Sciatica is an example of this. The nerves in the muscles and brain need the proper cholesterol and clean fats (omega 3,9, vit e, unsaturated fats), so small amount of clean cholesterol one ingests via organic eggs and organic milk given the other foods on this diet deters bad cholesterol buildup.

There also are no triglycerides, no gmo and no associated herbicides in any food on this diet, unless one eats processed food.

The diet includes many fresh fruit and vegetables – grapefruit, including other items for metabolic increase and cruciferous vegetables, fat burners, grass fed livestock while avoiding feed lot, hormone fed dairy and livestock, all which counter any negative effects of clean cholesterol in the diet. REMEMBER this diet avoids all processed food, food with gmo and herbicide ingredients, and triglycerides are found in ALL OF THAT. Chicken and Eggs from poultry raised on organic grains and without antibiotics or other pharma used on poultry on this diet are ok and perhaps the clean milk, which naturally have ‘cholesterol’ but from clean livestock, will be safe for one’s circulatory system.

Avoid food cooked in or cooking in metal pots, pans – unless enamel or ceramic lined. Cook in oven/stove Pyrex or ceramic, or enamel lined cookware – Martha Stewart, corning, Pyrex, a French brand for enamel lined all are very good. AVOID ALUMINUM FOIL OR ALUMINUM OF ANY SORT NONE, NOT EVEN FAST FOOD CONTAINERS…. ASK FOR THE PLASTIC or paper take-out containers on this structured eating plan.

Avoid sweets and products of beet sugar – as this is gmo, (and cane white sugar minimize although cane isn’t gmo), processed food, yeast/bread, items with baking power especially those with include aluminum or phosphates**. If possible avoid leavenings and also IF POSSIBLE, substitute YOGHURT OR MOLASSES FOR THE ACID TO ACTIVATE if one is using baking SODA. I’ve done a great deal of baking however and actually one can avoid any leavening agents except cream of tarter or organic egg whites beaten stiff, unless the recipe doesn’t call for eggs. Most cookies and baked goods however call for leavening which can be eliminated from the recipe with very little negative impact and taste difference. Baking times may be a little longer depending on how dense the batter is.

** DANDELION HELPS ADDRESS THE HIGH PHOSPHOROUS MATTER – DANDELION TEA, GREENS, CAPSULES, ROOT – Note on phosphorus, phosphates and oxalic acid foods foul the circulatory system, liver, kidneys. AVOID or at least LIMIT concentrations of these which one finds in baking powder, oats, fonio (an African grain) Quinoa, buckwheat, soy, peanuts, nuts in general, cheese, poultry, colas but all man and naturally carbonated beverages are bad for oxygen flow in the muscles, spinach (raw is worse than cooked), coffee, chocolate, ‘black’ and ‘green’ tea, chocolate.

The candida love certain chemicals and the “inflammation” – the swelling is their allergic reaction as well as the phosphorus blow-back on the body perhaps acting as fertilizer to the candida. I also get this reaction from nitrates and nitrates in most smoked foods, smoked fish but not from naturally salty foods such as celery. I also suggest higher use of dandelion tea, dandelion herbal capsules, dandelion root and dandelion greens which are effective in mitigating phosphorus concentrations. And go organic, ie free of gmo and herbicides!

This diet will generally fix circulation problems and high blood pressure, with the use of the L-carnitine to deal with fat buildup in the body, perhaps blood vessels. Generally, the diet will also eliminate fluid retention if one avoids the high phosphorous, high phosphate, and refined foods/refined sugars, vinegars, and avoids yeast/bread products generally avoiding what flares the candida albicans, when aggravated will produce fluid retention and stiffness in the joints due to the fluid retention.

Use some sea salt and/or ‘fish’ sauce, an Asian condiment found in Asian food stores. Avoid sodas-carbonated beverages, or coffee/tea as these will impair the proper function of the kidneys. Sometimes I chew bitter cola one can buy sometimes at West African stores but a ginseng supplement is also ok.

Switch to Yerba Mate, a South American beverage found in many of the Latin and South American bodegas in New York and perhaps elsewhere. One also on the web find Yerba Mate and can mail order it. Put yerba mate in a search engine and that should produce sites from which one may order the beverage.

Boil all milk (organic) although most people can handle any negative bacteria in organic dairy. Boil Dairy in stove top capable ceramic, Pyrex, Corningware or enamel lined stainless steel or enamel lined cast iron. Boil or cook all dairy before eating accept yogurt –organic stonyfield is ok – plain is best, however home made kefir is better and easy to make… Switch to ORGANIC (TRADER JOES 1 GALLON CONTAINERS WHICH CAN BE FROZEN) or any other that says it does not use the PbST or the rBST hormone in the milk ie from ‘untreated’, grass fed only cows, or is organic. Typically if farmers are avoiding using stimulant hormones, they also will avoid using/abusing their cows dairy pharma/antibiotics. The dairy antibiotics cause serious problems such as disruption in the gut chemistry, and skin lesions as a result from their impact on the physiology as well as the eventual candida and parasitic build up in the digestive tract that will cause skin lesions and other deleterious conditions in the body, scalp/skin. If they’re using gmo grains however the cows will get sick and will need pharma unless the cows go grass fed and hay only/NON GMO-non gmo alfalfa.

To make ones own kefir (drinkable yoghurt): boil the milk (to kill the bacteria – watch it, however it shouldn’t boil over unless it’s been cut with water) half gallon milk using better names such as organic or vacuum packed Parmalat Organic which does not have to be boiled because it already has the bacteria killed. Neither have the Pbst or rBst Hormone) in an enamel lined pot or boil in ceramic bowl in oven. Let cool to room temperature or refrigerate.

And unless in a half gallon plastic, capable container – already having a previous mixture and one is replenishing, otherwise open 4 lacto bacillus capsules into cooled mixture and cap and shake, or if still in large bowl – stir in and let sit overnight in a warm place to ‘yog’…. It will thicken and will get even thicker when cold. Have this with fruit, alone before in the mornings with the capsules, with other gut cleanse products when mixed with filtered water… or at night with chopped garlic or for tzatziki… It is a loose yogurt and can be used in place of butter milk, kefir! (or replace (clabbered) milk /use baking soda in baked goods and back with either milled dried cane juice, but no white refined sugar, and perhaps turbanado, molasses, honey, maple syrup, rice syrup (rice too now often is gmo), corn syrup – but this isn’t the best thing to use as corn virtually always now is Genetically modified.

Condiments, Vinegar, and Legumes

Avoid these in as much as possible if one is very candida- craves pizza, bread, other similar comfort foods, sweets of any sort even diet sweeteners, diet sodas and obsessions with any of this, habitually indulging in any sort of this, rationalizing it, feeling it is necessary to taste or have SWEET – unless it is a piece of fruit at breakfast or before some sort of fitness, an afternoon lift or after dinner break.

While beginning and on this diet, one is killing the candida and other bad bacteria which actually cause the cravings (and one must eliminate the use of ) for sweet, vinegar, soy sauce, alcohol, etc as candida dwells in one’s body and circulates through the blood stream: ears, nasal cavities, nose, mouth, brain and lungs (for cigarette smoke, which has the sugar from the tobacco leaves, and the brain and lungs crave it and the nicotine). So these negative organisms in their life cycle will die anyway, and as a result their life cycle will crave sweets and the above listed things that promotes their thriving which to you is headaches, sinus problems, depression, foggy mindedness, anxiety, poor circulation, gas and gastrointestinal problems.

This Diet also excludes all SOY in any form. Soy is a legume on which the candida feed. I suggest also avoiding GMO foods such as non-organic corn, soybeans; virtually all corn and soybean product, rice, canola, rapeseed, sunflower seed, beet sugar are from GMO. Moreover, Soy is not native to the ‘western’ diet. And, given its amino acid profile because of its glutamine content beyond that of normal-meat protein, as a protein Soy is inferior to wild fish or meat from grass fed livestock, and or organic poultry, however, if one eats those grains and legumes, go organic.

Avoid vinegar in general as the candida thrive on it. Vinegar gives me three or more days of fluid retention, and gurgling gut. One finds vinegar in most condiments. So avoid those and make your own mayonnaise and mustard. There are recipes for these and one can substitute lemon juice for vinegar. One will find Vinegar in virtually all ricotta and cottage cheeses, and of course in many cured and pickled foods, olives and yes without question virtually all bottled salad dressings. As a general diet clean-up, the diet avoids use of commercial mayonnaise (unless home made with lemon juice and olive oil), soy sauce, vinegar, mustard, catsup. And if you use them, you may have a swelling, fluid retention reaction.

The candida in the mouth are craving to taste sweet. Understand this and avoid letting this/these spores manipulate you. So deny the spores their lust to proliferate their lifestyle at your expense, and bless yourself in the process. The more powerful and greater proliferation of their chemistry and pathology of these negative organisms in the body, mouth, tissues such as digestive tract, that chemistry’s signal in our minds and mouths is to crave, feel sleepy, grouchy, PMS, depression, a number of different manifestations at different times…while the candida want to live and steal nutrition from the beneficial organisms and our bodies’ needs.

Sequential eating At a meal first have hot beverages such as herb tea or soups and then if you’re inclined to drink things like tomato juice, something like tomato juice. Then have the vegetables and/or fruit GENERALLY AT BREAKFAST ONLY, but after any capsule supplements that one takes. The new info on the capsules is that when from commercial cow bone gelatin, these have pollutants and MSG in them, optional – break open the capsules and put into kefir or vegetable juice before the meal.

After eating the fruit at breakfast, then if they want vegetables, celery or cabbage, etc one would eat their carbohydrates or proteins. At breakfast last – eat hard boiled organic eggs, as there is nothing in this diet to promote problems with the cholesterol in the eggs, one can eat as many eggs as one wants, although one should increase the use of garlic in the diet to cleanse the liver… On this diet I suggest using only organic when eating root vegetables … where the most pesticides and polluting fertilizers are used. Avoid produce from Texas, where I’d heard there farms use human effluent for fertilizer. Human effluent, ie, human sewage is very polluted.

Avoid eating carbohydrates and proteins at the same meal: proteins and carbohydrates, such as pasta or potatoes are not had at the same meal. Eat meat or proteins with vegetables and eat starches with vegetables.

OK: spices, herbs, fresh ground pepper, sea salt, are all fine, even ‘fish sauce’, olive, palm, peanut are OK. Supposedly cidar vinegar doesnt cause inflamation however I havent experimented with this.

OK Carbohydrates eaten occasionally and sequenced after vegetables: buckwheat (although this is a high phosphorus grain), organic polenta or cracked corn, other whole grains such as millet, river rice, brown rice although the later 2 are high in phosphorus.

Avoid margarine unless non-gmo. Use olive oil and organic butter if possible. I also generally avoiding anything from cans, although I will eat canned WILD salmon – you can tell by the date on the can the farther away the expiration date, the fresher the salmon. Or wild, white fleshed fish is also good.

Use grass fed meat, organic poultry or game and fowl

Breakfast. It is better for the metabolism to have a decent morning meal. Start with hot Yerba mate beverage (or Wisdom of the Ancients ‘tea’ bags/boiled water) first. KEFIR (home made and organic) also is important. Then fresh fruit – Green apples -peeled/cored unless organic but wash with soap and water and dry the surface of all fruit whether or not one is paring the fruit, citrus. And/or other fruit… option to include but not necessary although one will feel less hungry for longer and eggs are thermogenic: Hard boiled organic eggs, OR oat meal (a high phosphorus grain), or hot cereal or non gmo grits that are unrefined with no white sugar (especially no beet sugar or artificial sweeteners or rice syrup as that also often is from gmo rice) or brown sugar.

Lunch: perhaps fruit first but rather veg juice before then steamed or raw, well washed with a vegetable wash then rinse to eliminate the pesticides unless organic (then washed anyway) fresh vegetables, either more clean protein such as plain yogurt of roasted goat or another sort of grass fed organic meat or – but not at the same meal with pasta, brown rice, or another whole grained boiled/steamed like rice. Perhaps a baked potato not baked in foil AVOID ALUMINUM FOIL. AVOID STAINLESS STEEL AND ALUMINUM POTS AND PANS. PREFER ENAMEL LINED, OR CERAMIC.

Remember avoiding carbohydrates and proteins at the same meal after your vegetables will give you more energy and help your brain/mental activity after your body has somewhat detoxed from candida.

Dinner: – perhaps veg juice before, then raw, steamed or sautéed vegetables, and clean protein or another complex carbohydrate. Meat or poultry from organic and/or grass fed livestock/poultry or Nuts from the shell or raw nuts from the bulk bins are fine. Avoid salty, roasted, dry roasted… from the can or jar. Nuts and seeds between meals is ok although if dealing with phosphorus buildups, balance with dandelion  in any or all forms.

Other product tips, suggestions

Switch to glycerin soap or tea-tree oil and/or Grandpas pine tar soap when you can for face/scalp, and avoid detergents on your skin, etc. I also have begun to use Ivory Soap which is actually very effective to kill bacteria without additives and Kirks coconut-soap, or olive oil soap. Ammonia will cut the film on the bathtub and sink surfaces.


A special supplement for enzymes is key to improve the digestive process to extract complete nutrition in the food where the enzymes promote improved bio-availability for the body, head … Go with the Vits first, and if purchased all at one time, the entire group can run between $400-$500.

Anti-parasitics and colon products – although all are good for the colon

1) Parazyme made by Renew Life, which makes the anti-parasitic I use for Digestive enzymes. Any good anti parasitic as above, Paragone, Parasitin, and any other good herbal anti parasitic will kill candida albicans, although there are also supplements to kill candida albicans. Parasites thrive in a chemistry of contamination…I have suffered from parasites at least Twice – a ruptured appendix (appendicitis is caused by a microscopic parasite behind the appendix), and at another point I passed an enteric parasite. So a diet low in processed foods, most hormone/antibiotic laced commercial dairy with is teaming with shigella and ecoli ( for that reason even organic milk, but generally organic is a little better), sweets, but high in garlic, onions, cruciferous vegetables food from untreated animals diminish parasite aggravation.

The GMO has ecoli also engineered into the grains to serve as an insecticide. This ‘characteristic’ continues to do harm regardless of the physiological turf: people, insect larvae, hog or cattle gut. This is difficult to remedy using conventional methods and 1 time use of anti-parasitics, and limited use of herbals, vits and high quality diet.



2)Grapefruit seed extract +other astringent herbals- Nutribiotics

3)Cloves and Wormwood extract – both made by Q-W & Company. the wormwood herbal has cascara. this is good, but to be used cautiously. Perhaps 1 cap at a time and see the effect.

4)Bentonite or montmorilinite liquid by Sonnes’ No7 treatment – that helps keep down negative bacteria in the lower digestive tract and very effective if interested on detox efforts and when fighting candida albicans. Very effective although I don’t use every day as others may and do. I use Sonne’s 7 occasionally when I am having blowback from ecoli/shigella. Another capsule known as “Perfect 7” also includes montmorilinite

5) Everyday Fiber System Powder – as well as lacto-bacilius by Rainbow Light (at this time out of production). It also has an enzyme product – Optima although this has not been put back onto the market. My conversation with Renew Life’s management them wanting and unprofessional in their fecklessness, or targetted by the NSA to give up groun to restore availability of this effective product.

6)Cleanse Smart by Renew Life, any other gut scrape/gut cleanse product such as the except for the corn silk which concerns me if gmo.

6A) Naturalax 1 or 2 or 3. By Nature’s Way. Combinations in various mixes of cascara or aloe vera plus other herbs effective for the colon. It has laxative properties and will cause candida which if one has a dirty diet or recently cheated, these will kill candida and that will cause gas.


7) lacto- bacilius supplement often found in the refrigeration case or on the shelf in PB8 or Kyodophilus or All Flora or Country Life’s Daily Dophilus without the soy. Excellent reasonably priced product

Herbals, Anti-oxidents, superfoods

8)Dandelion tea (Alvita), dandelion capsules, dandelion root and other herb teas like cranberry tea in form more pure than Celestial Seasons and cranberry and raspberry teas are very good for the liver and kidneys. Even the roasted dandelion root, ground up and added to food, water, taken off the spoon works but isnt then focused to do work in the colon that putting it into capsules will do.

9) Tumeric – I make my own 1000 mg caps from the bottled powder fairly easily found and empty gel caps sold in most sophisticated health food stores (see Health and Harmony contact info below) or Amazon.

10)OPC- pycnogenol 100mgs or Pynogenol or French Maritime Pine Bark Extract (by Vitamins Because), an excellent supplement but I am very sensitive to the green tea extract in it…. however, I am sensitive to the green tea extract in anything, so I generally avoid all supplements with green tea and anything with additional phosphate bonded elements such as calcium which is used to add ‘calcium’ unnecessarily while attempting to keep the anti-oxidant ingredients in the body for longer so the green tea acts to slow the function of the kidneys. One should take the tablet supplements after food and be certain to take enzymes to promote optimal digestive function to extract optimal nutrition from the supplements for the body’s and brain’s use.

11)OPC –Grape Seed Extract 100mgs, or bilberry (by Natures’ Way); and/or or black raspberry (by Genesis Today), and/or Red Raspberry caps by “Natures Answer

12)Green drink/tablets of spirulina and chlorella – Green Energy by Super Nutrition. or Earthrise Spirulina Greens blend Or E3AFA is another good green product. E3AFA Blue green algae. Or Earthrise, Supergreens and more as mentioned above

13) Germanium Sequioxide (by Jarrow)

14)CoEnzyme Q10 at least 100 mcg daily. 300mg-400mg +if fighting tooth aches, tooth root issues


15)Vit C 3000 mgs-10,000 mgs Rainbow Light brand (although you have to wash off the gmo soy lecithin coating the vit) daily will kill decay in the teeth and roots. I suggest avoiding the commercial toothpastes with fluoride. Switch to the natural nonfluoride. Also Ester C is a good Vit C product

16)Vit E – Deva brand (non gmo) at least 400mgs daily at least unless very active and then in THAT case take 1200mgs, on a low fat diet and on fat burners such as L-Carnitine, then use 800mgc to 1200mgs. Go non GMO.

17)Multivitamins such as SuperNutrition Brand – Women’s Blend or Perfect Family

18)Vit B complex Solgar Megasorb use if without soy lecithin or other gmo ingredients

19) Gentle Iron + vits C, B-12, Folic Acid. Nature’s Bounty – not bad for a plebe brand.


20)Oil of evening primrose, (Sports Research) is better than borage or flax seed which aren’t bad. Sports Research is non gmo

21)fish oil capsules –Krill or Nordic Naturals Complete Omega 3-6-9

22) Astaxanthin – by Sports Research –a fish oil family superfood for nerves, muscles, joints

Other superfoods

23)royal bee jelly and bee pollen. YS and Burts, Shiloh Farms are very good, however go organic to be gmo and herbicide free.

24)a good garlic supplement – Garlicin and any of the others are fine or a garlic w/selenium supplement

25)Kyolic “108” and “106”. Very good garlic supplement although one of tem has hawthorne, which is high phosphorus and I avoid that.

26) any good ginseng supplement and other thermo genic supplements suh as cayenne, etc

27)Colostrum and permutations of colostrums although this has phosphotodyl choline, and can tend to contribute to inflamation if detoxing from Round-up

28)Cayenne – any good name to also kill neg bacteria in digestive tract and heart cavity. It also is good for metabolism. Some people are sensitive to ‘nightshade’ including all hot peppers, green peppers, eggplant (take out the seed/pulp core of this), cherries, tomatoes, potatoes (peel the skin of these).

29)Nature’s Way Urinary Plus Cranberry or any good pure cranberry herbal and other Nature’s Way herbal combinations are very good. Nature’s Way also has Dandelion capsules and other combinations with dandelion such as Leg Veins although this combination has horse chestnut which is hard on people very sensitive to high phosphorus foods.

30)fat burner such as L-carnitine a safe supplement, although you will need to take extra Vit E which is the nerve cushion/fat soluble vitamin… if on fat burners and low fat diet, you will need more Vit E to protect the nerves and prevent ‘self electrocution’ when the nerves emit electro chemicals in order to make the muscles function and if that process is impaired by ‘free radical’ build up and nerve cushion problems from insufficient E, then in the tissues that remains and muscles are further polluted with more body and environmental pollution.

31)Super Lysine Plus (this is the name of the product) made by Quantum\ except for the Tricalcium phosphate in this, which I find a problem and as a result, I infrequently use this product


Linda R. PageHealthy Healing; Hulda R. ClarkThe Cure for All Diseases.

Health and Harmony (listed with information in New York, NY on Hudson Street below Grove in the West Village By phone: 212 691 3036/fax 212 691 0855) in Manhattan. One can order via phone.

The Proprietor is Ramsy and his mother, Byoul, or other management such as Tarique will take your order and ship I think UPS or USPS, and tell them if you order from them that I recommended the store to you. If you order a fair amount, he probably will give you some sort of discount although I cannot promise that. His prices are reasonable however, and if you shop there regularly and in abundance, he sometimes omits charge for some small items.

The antioxidant/supplements are not a cheap part of the strategy, however, the food part of the strategy is generally inexpensive – processed food usually costs more than unprocessed food so in the short and long run, even if one is switching in some cases to organic, one is spending a better quality dollar than for what was previously spent for and wasted on processed food.

Read the Gospels for the interaction of the Lord Yeshua and the people when they needed healing and wholeness. Notice that the Levitical diet in that time was what people used. Food in that era was either ‘clean’ adhering to Levitical law or unclean. There was no processed food or BigPharma antibiotics and other BigPharma drugs used on the people today. Although people are sick and infirmed from sin and iniquity/sins of the fathers and lawlessness then as well as today, today people make their lives worse via sedentary life style, processed food and bigPharma, medtech/mengele medical profession corruption and pollution.

The US medical system is a volume based revenue model. This means that the more people ignorated to fall in and remain in it are the way the system makes money and self-enriches by parasiting off of the peoples’ ignorance.

The Lord is a rewarder of them who diligently seek Him. And in seeking Him one gains wisdom and understanding. One also gains faith to trust Him for better quality of life and health, however one also can avoid the medtech system and its operating strategy with the Lord and better nutrition and life style choices.

I have only gotten ‘flu’ when I have had some sort of infection or had eaten junk food and came into contact with cold germs. Once I’d gotten flu when I had a bad tooth infection that later needed root canal, which happened after my dentist had forgotten to deal with a bad cavity and my diet had trended into junk during the holidays and insufficient exercise, not enough antioxidants. Everyone else with that flu, however lost a week of work in bed while in my case with my constitution generally better, I only had the ‘bad cold’/cough.

This diet will prevent (assuming clean personal habits, not living near or on a toxic waste dump or major polluter, and no pets – pets often have parasites and in general make it more difficult to prevent in ones environment bacteria from pet fecal matter), reverse cavities and with the coQ10 in large amounts; fix gall bladder problems – as long as one doesn’t overeat or eat food from animals polluted with antibiotics and Bigpharma livestock pharma, do polluted dairy and put pressure on a problemed gall bladder, generally my diet strategy will also prevent gout. It will hinder if not prevent arthritis (the strategy uses clean fats and avoids the heavy metals from the cookware, other sources which the negative bacteria in the body and joints find useful for thriving in the anaerobic environment) and other auto immune illnesses.

Bless the Lord!

Clean, grass fed livestock and cooking things such as goatmeat (from goats not treated with any sort of pharma or fed gmo grains

Roasted Goat or any other game or grass fed livestock- clean, grass fed meat… unless using organic (pure and free of any sort of pharm or gmo grains): US cattle, US lamb, US pork, buffalo, ‘hacked’ or goat shoulder the shank cut in half, or whole is one is going to roast it on a spit or in a large oven but otherwise cut to fit the cookware. Rinse, bake w/lid on the pot at 350F approx 1 hr 50 min to 2 hours depending on the amount of meat in the pot.

Avoid cloned cows/cattle for milk and meat. We’ve got plenty of animals. Why clone something God made just fine? If one takes responsible care of their livestock they can breed the good ones without the problems, but they inbreed, give them hormones, make them sick, give them anti-biotics, and this is the pathetic food supply they attempt to feed to us.

*The US Government is “out there” as death merchants, so if it’s not military hardware, then it’s something like GMO food. GMO and the associated herbicides are for population reduction. Policy going by the name of ‘Sustainabilty” are pawned off on the people, sleazily destroying them, slowly exterminating them one forkful at a time, while yielding an annuity to nazi part of the medical system and bigPharma. If people trust their life and health to the medical system and bigPharma, it surely will kill them sooner or later. The medical system also will say people have some illness or disease because some people are targets or if perhaps is too ignorant to stand up to the system.  People need to be responsible for their own health and lives, if not by the Lord, even by wisdom that trickles down into the world about food quality and quality of life and other ways of interacting with society and its disorder. This includes in what way you interact with medical system and bigPharma. Using its services and products vs believing it is life-giver and maintainer when it is neither, puts the user at risk for its vanity. This vanity grows by the day as the Day of the Lord is here.

**Atkins authored his diet long before any prolific use of early versions of gmo such as steroids, growth hormones, pharma in the animals and fish and ‘fisheries’. Feedlot cattle became in vogue about that time, but the use of steroids, and other contaminants in their feed has been perhaps only over the last 40 or so years, although feed-lotting also now has been including gmo grains and gmo seeds, and garbage such as processed food. Live stock pollution of such a nature became the reason our Olympic athletes and those involved in professional athletics in which the athletes are tested for performance hormones, the athletes had to go to grass/organic livestock, dairy, poultry and eggs, wild fish, any animal product pure and without contamination of any sort of animal/livestock or fishery pharma so as to not test positive in the athletes’ bodies.

Moreover, dairy pharma: stimulant hormones and dairy antibiotics are known to be a contributing factor in increasing incidence of breast cancer in women. I urge complete elimination of any of these sorts of contaminated animal products and by products from one’s diet.

There also are other problems such as the electro-magnetic/extremely low frequency wave, and the interference with one’s brain chemistry and now prolific in the environment by way of space based and earth based science/tech, that there are challenges to mankind with regard to the manner in which these technologies present hurdles to the quality of life. Technologies such as HAARP and SQID are neither benefit nor benign to mankind.

Moreover the danger in the environment to the gmo and associated herbicides now including war crime chemicals such as “Agent Orange” are not only serious toxins to man, animals and their associated food supply, the natural balance between the environment and fauna and insects that support agriculture and the beautiful environment with which God blessed us all is at risk by the evil schemes of science hijacked and co-opted for the policy of ‘Sustainability’ or that which is the policy interested to see the world’s population reduced by 8/9s.

“The Earth is the Lord’s and the fullness thereof, and they that dwell therein.”



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“BHC Report Modernization Initiative” DOCID fr13no08-39 Nov 13, 2008 Vol 73 No 220 pps 67159-67173

Via email:
Ms. Jennifer Johnson
Board of Governors of the Federal Reserve System Division of Banking Supervision and Regulation
Constitution Ave, NW
Washington, DC 20551
Fax: 202 452-3819
Fax 202 452 3102

Cc: OMB Desk Officer
Office of Information and Regulatory Affairs
US Office of Management and Budget
New Executive Office Building Rm 10235
725 17th street, NW
Washington, DC 20503
Fax 202 395 6974

Ms. Monica Posen
Team Leader Regulatory Reporting Division
Federal Reserve Bank of New York
New York, NY 10045-0001
(212) 720-8239

DOCID fr13no08-39 Nov 13, 2008 Vol 73 No 220 pps 67159-67173
“BHC Report Modernization Initiative” proposal to separate and included data currently not specifically tracked in the following reports: FR Y-9C, FR Y-9SP, FR Y-9ES, the FDIC’s Report of Condition and Income FFIEC 031 and 041, and the Office of Thrift Supervision’s TFR form 1313

Dear Ms. Johnson and To Whom It May Concern In Regulatory Comments:

Thank you for availing the analyst community and public to participate in the due process effort of the regulatory framework. I appreciate the opportunity to comment on matters of concern related to data collection for the Bank Holding Company Report with associated reporting numbers referenced above.

Although the FR Y-9 family of reports historically has been the primary source of financial information on BHCs between on-site inspections, and with that decision makers of all sorts use the financial information from these reports to detect emerging financial problems, to review performance and conduct pre-inspection analysis, to monitor and evaluate capital adequacy, to evaluate BHC mergers and acquisitions, and to analyze a BHC’s overall financial condition to ensure safe and sound operations, I appreciate that the Fed and our other regulators have made the effort to collect all necessary and pertinent data for themselves and the users of these financial reports and data to understand the health as well as performance of the individual financial institutions as well as the health performance of peers and other members of the financial depository sector.

Recently while interested to review the current release of Bank Holding Company Performance Report (“BHCPR”) as well as understand a particular bank holding company’s condition, I downloaded a Y-9C from the website, as well as BHCPR along with definitions for these reports and analytical tools.

I found distressing the aggregation of interest revenue with fee revenue that apparently could be include in fee income, however for US GAAP reasons, is included in these line items summing to data field 4107 on the for form FR Y-9C. I suggest a separate memo field for fees and another field – a separate field – for Fair Value changes to interest revenue at the present time captured in BHC for FR Y-9C data field 4107.

I am interested to understand the banks/bank holding companies’ pure interest revenues (see Note a) (and in the Interest Expense Line datafields) for lending rather than an amalgamated Interest revenue number fuddled with fee income amortized into the Interest revenue numbers one finds on the BHC FR Y-9C and related reports as well as the other reports I mentioned above.

For illustrative purposes, here I have copied material from the – Report of Income for Bank Holding Companies, Schedule HI—Consolidated Income Statement

Interest income

  1. Interest and fee income on loans:

(1) In domestic offi ces:
(a) Loans secured by 1–4 family residential properties ………………………………… 4435 1.a.(1)(a)
(b) All other loans secured by real estate …………………………………………………….. 4436 1.a.(1)(b)
(c) All other loans ……………………………………………………………………………………….. F821 1.a.(1)(c)
(2) In foreign offi ces, Edge and Agreement subsidiaries, and IBFs ………………………4059 1.a.(2)

  1. Income from lease fi nancing receivables ………………………………………………………4065. 1.b.
  2. Total interest income (sum of items 1.a through 1.g) ……………………………………….4107 1.h.

With the BHC Report data gathered on FR Y-9C tracking US GAAP, the banking regulators have adopted and incorporated into the reports Financial Accounting Standard (“FAS”) 91 (see Note b) which permits including in the measurement of interest revenue, a mixed reporting in this line item by including various fees as well as when taking the “Fair Value Option” on loan and lease assets’ interest and probably associated fee income that are also then amortized in data field 4107, or where ever it is amortized over the life of the associated loans and leases.

In general now we see reported in this series of :4435, 4436,F821, and the Total Interest Income in 4107 a misrepresentation of the pure price to lend, while confusing the number with other management decisions that determine associated fees that the banking associations while FAS 91 was being promulgated and during the due process period, probably heckled the FASB to include in the Interest income so as to make the number appear larger when the actual price summing to the revenues from loans extended to customers, clients and counterparties, perhaps would be much less.

Not to mention, as well as when management for one reason or another decides that it is going to revalue a tangible asset, which then dumps the associated interest and fee revenue number into this series of data fields, giving us a ‘polluted’ number in datafield 4107.

If we wanted to understand pure interest revenues for a pure yield measure of all loans and leases portfolio’d, we’re not going to find it while it is obfuscated with fees and Fair value option revaluations. For these later items such as fees associated close enough to be amortized in this line (see Note c)

Loan pricing strategies not to mention pricing based on the cost management incurs for the loans it makes, again are based on different economic decisions and differently enough on the other related product provided here. Although there are services rendered in the lending process that FAS 91 permits attached to the loan as measured here aggregating in data field 4107.

Also given of late, the Federal Reserve proposes to implement a number of changes to the FR Y-9C and FR Y-9SP reporting requirements to better support the surveillance and supervision of individual BHCs and enhance the monitoring of the industry’s condition and performance, my suggestions for better transparency and improved disclosure on interest revenue quality rather than mix of items all of which have been based on different economic decisions and for internal reporting purposes I conjecture are used for management performance measurement. Thus, my suggestions should gain traction.

Meanwhile, as the Fed believes its current proposed revisions reflect a thorough and careful review of data needs in a variety of areas as BHCs encounter the most turbulent environment in more than a decade, and that the revisions now will include new data items focusing on areas in which the banking industry is facing heightened risk due to market turmoil and illiquidity and weakening economic and credit conditions. Also, the Federal Reserve proposes certain revisions due to changes in accounting standards and amendments to regulatory capital requirements. To minimize reporting burden, where possible, the Federal Reserve has sought to establish reporting thresholds for proposed new data items” (from the Instructions for the FR Y-9C).

For all the reasons the Fed is asking for new data, I am urging if not separate fields on Schedule HI (and as well as on other Federal Reserve parallel reports and also associated reports of the FDIC and the OTS) to give a pure interest revenue number in data fields 4435, 4436,F821, and the Total Interest Income in 4107. And because fee income at the present time camped into and I consider is fouling the datafield 4107 should be reported separately or in a memo, at the very least where the use of the memo field method for fees that management claims are associated closely enough to amortize in this line and in turn goose the interest revenue number, as well as another memo field for the increase that management is claiming from tangible assets it chose to revalue under the fair value option need themselves to be reported in an environment urging better disclosure and transparency.

Although not completely arbitrarily, as I’d noted management produces these 2 aforementioned components economically independent enough that analysts and decision makers who are users of this data as well as parallel data on parallel regulatory reports would want the transparency and improved disclosure to distinguish what – fee – revenues are attributable to management decisions rather than the competitive environment and interest rate environment behind the pricing for its lending. The Fair Value Option and FAS 157 revaluations impact on the income statement absolutely warrant separate or memo reporting.

Elsewhere on the Y-9C we find fee income which includes the investment banking reported revenue; what made this fee revenue different enough to report here, while with most bank holding companies and financial holding companies that chose to file the Y-9C, this includes its lending services often a part of ‘facilities’ of lending and service products provided to customer/clients.
Thank you again for this due process and accepting my contribution to the Bank Holding Company Data collection project and suggestions to improving what data we are provided on the FR Y-9C and all parallel reports that ask for interest revenue.

Andrea Psoras
Consultant and Analyst
New York, NY 10026
(212) 666 2569

  1. I also suggest for and on the FDIC reports for small and large banks, as well as OTS chartered thrifts which data is captured and reported on the Thrift Financial Report “TFR”, that this memo field separation (2 memo fields) for associated fees that FAS 91 and the financial regulators permit amortized against the life of the associated loan or lease in this line and that reported independently of the Fair Value affects on associated tangible assets at the very present time amortizable into these interest revenue lines as permitted by FAS 91.
  2. Board of Governors of the Federal Reserve System Instructions for Preparation of Consolidated Financial Statements for Bank Holding Companies, Reporting Form FR Y–9C, Reissued March 2007. Page HI-2, (2) Loan origination fees, direct loan origination costs, and purchase premiums and discounts on loans held for investment, all of which should be deferred and recognized over the life of the related loan as an adjustment of yield under FASB Statement No. 91 as described in the Glossary entry for ²loan fees.² See exclusion (3) below. (3) Loan commitment fees (net of direct loan origination costs) that must be deferred over the commitment period and recognized over the life of the related loan as an adjustment of yield under FASB Statement No. 91 as described in the Glossary entry for ²loan fees.² (4) Investigation and service charges, fees representing a reimbursement of loan processing costs, renewal and past-due charges, prepayment penalties, and fees charged for the execution of mortgages or agreements securing the bank holding company’s loans. (5) Charges levied against overdrawn accounts based on the length of time the account has been overdrawn, the magnitude of the overdrawn balance, or which are otherwise equivalent to interest. See exclusion (6) below. (6) The contractual amount of interest income earned on loans that are reported at fair value under a fair value option.


  1. Instructions for Y-9C “Assets and liabilities accounted under the fair value option — Under U.S. generally accepted accounting principles (GAAP) (i.e., FASB Statement No. 159, “The Fair Value Option for Financial Assets and Financial Liabilities” (FAS 159); FASB Statement No. 155, “Accounting for Certain Hybrid Financial Instruments” (FAS 155); and FASB Statement No. 156, “Accounting for Servicing of Financial Assets” (FAS 156)), the bank holding company may elect to report certain assets and liabilities at fair value with changes in fair value recognized in earnings. This election is generally referred to as the fair value option. If the bank holding company has elected to apply the fair value option to interest-bearing financial assets and liabilities, it should report the interest income on these financial assets (except any that are in nonaccrual status) and the interest expense on these financial liabilities for the year-to-date in the appropriate interest income and interest expense items on Schedule HI, not as part of the reported change in fair value of these assets and liabilities for the year-to-date. The bank holding company should measure the interest income or interest expense on a financial asset or liability to which the fair value option has been applied using either the contractual interest rate on the asset or liability or the effective yield method based on the amount at which the asset or liability was first recognized on the balance sheet. Although the use of the contractual interest rate is an acceptable method under GAAP, when a financial asset or liability has a significant premium or discount upon initial recognition, the measurement of interest income or interest expense under the effective yield method more accurately portrays the economic substance of the transaction. In addition, in some cases, GAAP requires a particular method of interest income recognition when the fair value option is elected. For example, when the fair value option has been applied to a beneficial interest in securitized financial assets within the scope of Emerging Issues Task Force Issue No. 99-20, “Recognition of Interest Income and Impairment on Purchased and Retained Beneficial Interests in Securitized Financial Assets,” interest income should be measured in accordance with the consensus in this Issue”
  2. c)

Noninterest income:

  1. Income from fi duciary activities …………………………………………………………………….  4070 5.a.
  2. Service charges on deposit accounts in domestic offi ces …………………………………..4483. 5.b.
  3. Trading revenue2 …………………………………………………………………………………………    A220 5.c.
  4. (1) Fees and commissions from securities brokerage ………………………………………. C886.. 5.d.(1)

(2) Investment banking, advisory, and underwriting fees and commissions ……………..C888.. 5.d.(2)
(3) Fees and commissions from annuity sales ………………………………………………………C887. 5.d.(3)
(4) Underwriting income from insurance and reinsurance activities ………………………… .C386 5.d.(4)

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“War is a Racket” by Major General (Ret) Smedley Butler – connect the dots to Wall Street with blood on its hands…

Smart people listen to what the media reports and sort of smell a rat, but are either too busy, or too reluctant to believe the worst. Some may let their minds actually wonder or discern ie that there is conspiracy lurking behind the news and perhaps in much of what’s reported to us, but ? Who, what, where, when and why are often a little too seemingly unconnected and oblique. Since before the Civil War, but more so now because our Constitution and our Republic are broken, and fair government for all Americans is quite broken, meetings behind closed doors (among the, I hate the expression, but the wealthy among the ‘power elite’), sadly have an effect on the health of our domestic commerce, our society, and our quality of life. That’s why secret societies such as Skull/Bones, enjoy some degree of ‘reverence’, or Knights of Columbus or Malta aka SMOM or Templars, Society of Jesus (Jesuits), etc even high levels of ‘freemason’ in our neo-feudal society have, and have had short and long term deleterious effects on our domestic commerce and our quality of life and society.

People of these inner circles of means and power that then hurt our future and had contempt for their fellow Americans behind their self-interests included Smedley Butler, a man among them but not OF them (1) and (a). We understand this by “War is a Racket”. Published in 1935, “War Is a Racket” is the title of two works, a speech and a booklet, by retired United States Marine Corps Major General and two time Medal of Honor recipient Smedley D. Butler, according to Wikipedia. In them, Butler frankly discusses from his experience as a career military officer how business interests commercially benefit (war profiteering) from warfare.

After his retirement from the Marine Corps, Butler made a nationwide tour in the early 1930s giving his speech “War is a Racket”. The speech was so well received that he wrote a longer version as a small book with the same title that was published in 1935 by Round Table Press, Inc., of New York. The booklet was also condensed in Reader’s Digest as a book supplement which helped popularize his message. In an introduction to the Reader’s Digest version, Lowell Thomas, the “as told to” author of Butler’s oral autobiographical adventures, praised Butler’s “moral as well as physical courage”.[1 wiki note] and
Published 2010 by World Classics Books

(1) (a –  see below: John 8:23, I John 4:4, 17)

Born in West Chester, PA, Smedley Darlington Butler[1] (July 30, 1881 – June 21, 1940) was a United States Marine Corps major general, the highest rank authorized at that time, and at the time of his death the most decorated Marine in U.S. history. During his 34-year career as a Marine, he participated in military actions in the Philippines, China, in Central America and the Caribbean during the Banana Wars, and France in World War I. Butler is well known for having later become an outspoken critic of U.S. wars and their consequences, as well as exposing the Business Plot, a purported plan to overthrow the U.S. government.

By the end of his career, Butler had received 16 medals, five for heroism. He is one of 19 men to receive the Medal of Honor twice, one of three to be awarded both the Marine Corps Brevet Medal and the Medal of Honor, and the only Marine to be awarded the Brevet Medal and two Medals of Honor, all for separate actions.

In 1933, he became involved in a controversy known as the Business Plot, when he told a congressional committee that a group of wealthy industrialists were planning a military coup to overthrow Franklin D. Roosevelt, with Butler selected to lead a march of veterans to become dictator, similar to other Fascist regimes at that time. The individuals involved all denied the existence of a plot and the media ridiculed the allegations. A final report by a special House of Representatives Committee confirmed some of Butler’s testimony.

In 1935, Butler wrote a book entitled War Is a Racket, where he described and criticized the workings of the United States in its foreign actions and wars, such as those he was a part of, including the American corporations and other imperialist motivations behind them. After retiring from service, he became a popular activist, speaking at meetings organized by veterans, pacifists, and church groups in the 1930s.

Rather than dying in battle, sadly in 1940, he was off’d in a friendly, chummy hospital in his home town at that point, Philadelphia. I figured that those who hated his disinclination to head the junta against Roosevelt, also knew he would smell a crafted war strategy which Stinnett describes in “Day of Deceit: The Truth About FDR and Pearl Harbor ” (2)

(a) (John 8:23, I John 4:4, 17) and also v17


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