ANNUAL REPORT

ANNUAL REPORT
2014
PRESIDENT’S
MESSAGE
LISA MCGREEVY
OLA President & CEO
While 2014 was challenging at times, together we not only persevered, we thrived.
We started the year in the midst of a battle to fight back against Operation Choke Point. Thanks
to the efforts of our lobbying teams, we were able to educate Members of Congress on the
repercussions of Operation Choke Point. As a result, we saw two important pieces of legislation
addressing the initiative: letters from Members of Congress sent to federal regulators, and a hardhitting committee report examining the actions of the agencies involved.
In 2014 we also started a new conversation with regulators about how we can work together
to bring innovative credit options to the nation’s consumers. Through regular meetings with the
Consumer Finance Protection Bureau (CFPB) and the Federal Trade Commission (FTC), we were
successful in establishing cooperation and open dialogue between the industry and its regulators.
The year was also a time for coming together. In October, consumer and small business lenders
joined forces in New Orleans for LEND360. This conference demonstrated that collaboration can
occur in the online lending space, and there is much to be learned from one another.
The dialogue we started at LEND360 will continue to influence and inform our efforts in 2015.
New opportunities await us in 2015. With payments legislation on the horizon in the new Congress
and with the expectation of the CFPB’s rule on small dollar credit, we are confident 2015 will be a
year of growth and change for the industry.
Thank you for your support in 2014. We know it wasn’t always easy, but together we have proven
we can overcome any challenge that comes our way.
Looking forward to the best year yet!
q
TABLE OF
CONTENTS
w
e
r
y
Highlights of 2014
Looking Back: 2014 A Year in Review
Our Industry
Goal 1: Keep Our Industry Safe
Capitol Hill Activities
State Legislative Activities
Federal Regulatory Activities
s
Goal 2: Increase the Legitimacy of our Industry
Look for the OLA Seal
Media
Goal 3: Organize Meaningful Events that Spur Conversation in the Industry
Goal 4: Support Our Champions
f
h
OLA BOARD OF DIRECTORS
MARK CURRY
MacFarlane Group
DAVID JOHNSON
Strategic Link Consulting
KEN REES
Elevate
JOHN DALTON
LeadFlash
GLENN MCKAY
Selling Source, LLC
WALT WOJCIECHOWSKI
MicroBilt Corporation
WILLIE DUGAN
The Lead Group
BART MILLER
Centrinex
MARY JACKSON
Enova Financial
JOSH MITCHEM
Mitchem Companies
OLA Annual Report 2014
Special thank you to our Board of Directors for their continued support and guidance
HIGHLIGHTS
OF 2014
JANUARY
OLA met with the Consumer Finance
Protection Bureau (CFPB) to establish dialogue
between the industry and its regulators
MARCH
Senate Banking Subcommittee on Financial
Institutions and Consumer Protection hearing
on the need for a federal charter
Op-ed by Lisa McGreevy published
in American Banker
MAY
OLA met with consumer groups on OLA’s
efforts to combat fraud in the industry
JULY
House Financial Services Subcommittee on
Oversight and Investigations hearing on Operation
Choke Point
OLA Compliance University
SEPTEMBER
OLA’s Lisa McGreevy named one of six
women of alternative finance by Daily Funder
NOVEMBER
Election Day brings shift of power in U.S. Senate
OLA launched “Look for the Seal” campaign
FEBRUARY
OLA/Bretton Woods study released on
online lending market
APRIL
OLA Spring Summit
JUNE
H.R. 4986 “End Operation Choke Point Act”
introduced by Congressman Blaine
Luetkemeyer (R-Mo.)
AUGUST
Cheklist Magazine published a piece on
OLA called, “Examining the Future of Online
Lending”
OCTOBER
Consumer and small business lending
industry leaders gather in New Orleans for
LEND360
DECEMBER
OLA launched consumer outreach
initiative campaign aimed at informing online
loan customers to look for the OLA seal
Op-ed by Lisa McGreevy published in The
Hill
e
LOOKING BACK: 2014
A YEAR IN REVIEW
OUR STRATEGIC GOALS
The three P’s—Payments, Perseverance and Permanency—characterized our
efforts and influenced our strategic goals in 2014. With the launch of Operation
Choke Point in 2013, it was all-hands on deck in 2014 to combat the effects of
the invasive initiative. Through our efforts, Congress became fully engaged, asking
questions and demanding answers from the FDIC, OCC and Justice Department.
This led to lenders finding new bank relationships and payment processing
partners.
We set three main goals in 2014:
Goal 1: Keep Our Industry Safe
•
Protect the industry from legislative and regulatory interference at the
state and federal levels
•
Calm the regulatory space
•
Explore additional payment opportunities
Goal 2: Drive the Legitimacy of Our Industry
•
Effective communications external and internal
•
Grow sphere of influence
•
New attendees
•
New lending verticals
OLA Annual Report 2014
Goal 3: Organize Meaningful Events that Spur Conversation in the
Industry
OUR
INDUSTRY
OUR MEMBERS
11
NEW
93
MEMBERS
While OLA experienced a significant drop in membership due to Operation Choke Point, we were able to add 11 new
companies to our member roster.
ONLINE SHORT-TERM LENDING STATISTICAL ANALYSIS REPORT
In February 2014, OLA partnered with Bretton Woods, Inc. to conduct the first and largest to date analysis of customer and
loan characteristics. The study looked at 60 million applications and 9 million loan records over a four year period (2009-2012)
from three specialty credit bureaus. This data was augmented with 1.6 million loan records from four loan portfolios provided
by three lenders.
The study was intended to help inform the public policy debate, help members better understand customer demographics
and loan characteristics, and establish a baseline from which the annual report is conducted.
Three overall conclusions were drawn from the study:
1. A significant percentage of customers pay their loans as required
2. Traditional two week loans fit into a continuum of credit services and can be less costly to borrowers than overdraft
charges.
3. There is movement from the traditional 2 week “payday” product to installment loans (three to 12 months terms). OLA
members are moving almost exclusively to longer term, more flexible loan products as a direct result of customer
feedback and need.
THE MARKET
The study found that the unsecured consumer credit continuum was $70.5 billion.
Product
Volume
(2012)
Growth
(2012-13)
Overdraft Protection
(Underserved)
$8.3 B
83.10%
-1.50%
Payday Loan
(Storefront)
$30.1 B
16.00%
-2.30%
Payday Loan
(Internet)
$18.6 B
23.00%
9.10%
Deposit Advance
$4.3 B
9.30%
Discontinued
Installment Loan
$9.5 B
45.00%
4.00%
t
THE CUSTOMER
The study found that the average customer is 39 years old with a median income of $30,000.
$35,000
$33,263
$30,000
$25,000
$30,000
$26,167
$25,622
$22,476
$21,600
$20,000
$15,000
$10,000
$5,000
$0
Mean
Median
Bureau A
Bureau B
Bureau C
THE LOAN
The study found:
•
Average loan: $388
•
Range: $300-500
•
Annually, most customers took out two to four loans, with 30 percent of borrowers only taking out one loan each year
•
Number of days customers were indebted ranged from 70 to 106 days
•
71 percent of the loans borrowed were reported as paid
•
72 percent of loans had no delinquency flags
•
89 percent had no charge-off flags
Most of the applications for loans came from the states below:
%
Bureau B
%
Texas
12.32%
Texas
21.53%
California
10.40
California
10.65
Florida
7.50
Florida
6.93
Ohio
5.34
Pennsylvania
3.78
New York
4.67
Ohio
3.63
Illinois
3.86
Illinois
3.60
North Carolina
3.77
Louisiana
3.60
New Jersey
2.74
Alabama
3.25
Virginia
2.66
Missouri
2.85
Tennessee
2.58
New York
2.77
Top 10
55.84%
Top 10
62.59%
OLA Annual Report 2014
Bureau A
GOAL 1:
KEEP OUR INDUSTRY SAFE
AMPLIFYING OUR VOICE IN THE HALLS OF CONGRESS
By working closely with our champions in Congress, OLA was successful in mitigating the impact of
Operation Choke Point and beating back the tide of government overreach.
Letters of Support from Congress
Over 60 members of the House and Senate have signed letters expressing concern with Operation Choke
Point to agencies including:
• Department of Justice
• Federal Deposit Insurance Corporation
• Office of the Comptroller of the Currency
• Federal Reserve Bank
Congressman Blaine Luetkemeyer (R-Mo.) and over 30 other Members of Congress issued a letter
on October 16 to the Offices of the Inspectors General of the Department of Justice (DOJ) and the
Federal Deposit Insurance Corporation (FDIC), requesting that the staff responsible for Operation
Choke Point be investigated for their role in shutting out legal businesses. The letter also laid out the
case for abuse of executive authority.
Reports on Operation Choke Point
Congressman Darrell Issa (R-Calif.), chairman of the Oversight and Government Reform Committee,
released a report on May 29, 2014, concluding that Operation Choke Point was created by the
DOJ to “choke out” companies that the Obama administration considers a “high risk” or otherwise
objectionable, despite the fact that they are legal businesses.
On December 8, 2014, the House Oversight and Government Reform Committee released a new
report, “Federal Deposit Insurance Corporation’s (FDIC) Involvement in ‘Operation Choke Point’,”
detailing the agency’s close relationship with the DOJ to target legal businesses the administration
deemed morally objectionable. The report revealed that the DOJ actively partnered with the FDIC in
the prosecution of Choke Point. According to the report, the FDIC originated the list of “high risk”
industries included in the DOJ subpoenas, and senior officials at the FDIC opposed certain industries
on purely moral grounds.
Legislative Efforts
H.R. 4986, “End Operation Choke Point Act”
The “End Operation Choke Point Act,” was introduced by Congressman Blaine Luetkemeyer
on June 26. If passed, the legislation would create a safe harbor for banks that provide banking
services for businesses that operate legally in the U.S. The legislation also assures small businesses,
operating responsibly and within the bounds of the law, access to the U.S. banking and payments
systems. Additionally, the legislation guarantees that consumers will continue to have access to
legitimate businesses that they rely on for many services. A hearing on the bill was held on July 15.
Fourteen bipartisan co-sponsors signed on to support the legislation.
H.R. 1566, “Consumer Credit Access, Innovation and Modernization Act”
The “Consumer Credit Access, Innovation and Modernization Act” was sponsored by Congressman
Luetkemeyer on April 15, 2013. If passed, the legislation would create a federal charter for nonbank lenders ensuring that consumers have access to new and innovative financial products. A
March 26 hearing was held on the bill. Eighteen bipartisan co-sponsors signed on to support the
legislation.
u
CAPITOL HILL
ACTIVITIES
o Richard J. Osterman, acting general counsel,
Federal Deposit Insurance Corporation
March 26: Senate Banking Subcommittee on Financial
Institutions and Consumer Protection
Hearing entitled, “Are Alternative Financial Products
Serving Consumers?”
•
Industry witnesses included:
o Stephanie Klein, Director, NetCredit Consumer
Lending, Enova International
o Michael Flores, CEO, Bretton Woods, Inc.
April 8: House Financial Services Committee
•
Hearing entitled, “Who’s in Your Wallet: Examining How
Washington Red Tape Impairs Economic Freedom.”
•
Eight Republican members and five Democratic
members asked questions regarding Operation Choke
Point, despite the hearing being more broadly focused
on regulatory reform.
July 15: House Financial Services Subcommittee on Oversight
and Investigations
•
Hearing entitled, “The Department of Justice’s
Operation Choke Point.”
•
Witnesses included:
o Stuart F. Delery, assistant attorney general,
Department of Justice
o Scott G. Alvarez, general counsel, Federal
Reserve Board
o Daniel P. Stipano, deputy chief counsel, Office of
the Comptroller of the Currency
•
Richard Osterman of the FDIC, and Stuart Delery of the
DOJ, gave conflicting accounts of which agency was
driving Operation Choke Point.
July 15: House Financial Services Subcommittee on Financial
Institutions and Consumer Credit
•
Hearing entitled, “Examining Regulatory Relief Proposals
for Community Financial Institutions, Part II.”
•
Hearing focused on H.R. 4986, “End Operation Choke
Point Act.”
•
The legislation was reported favorably from the
committee.
July 17: House Judiciary Subcommittee on Regulatory
Reform, Commercial and Antitrust Law
•
Hearing entitled, “Guilty Until Proven Innocent? A
Study of the Propriety & Legal Authority for the Justice
Department’s Operation Choke Point.”
•
Every Republican member of the subcommittee
attended the hearing.
•
Two Democrats attended.
OLA Annual Report 2014
•
STATE LEGISLATIVE
ACTIVITIES
California: The OLA state team’s efforts in California were mainly
centered around taking proactive steps to close the lending gap
between the current $255 payday loan and $2,500 installment loan,
while ensuring that no further erosion of the current statute occurred.
In this effort, the industry went on the offensive with S.B. 1280. The
legislation would have required the commissioner of the Department
of Business Oversight to establish a licensure program with fair rate
of return for unsecured consumer loans. The legislation passed the
Senate Financial Institutions Committee unanimously, but did not
make it through the senate.
Missouri: S.B. 694 passed both chambers of the Missouri state
legislature before being vetoed by Gov. Jay Nixon in July. S.B. 694
would have modified the law as it relates to payday loans. This bill
would not have directly impacted OLA members.
OLA also worked with Rep. Tony Dugger (R-141) to file H.B. 2130,
which would have defined “open-end credit.” The bill passed the
Missouri House, but was not pursued in the state Senate because of
the elimination of the ballot threat.
Rhode Island: The OLA state team was on the defense in Rhode
Island as a bill was introduced that would have put the industry out
of business in the state. H 7285, or the “Payday Reform Bill,” was
held in the House as the Finance Committee recommended that the
measure undergo further study.
o
BUILDING SUPPORT IN THE STATES
State Summit
The OLA State team hosted its first State Summit in
Washington, D.C. in conjunction with OLA’s Compliance
University. More than 30 attendees heard from the state team
on the growing importance of state laws in the industry, and
the plan of attack for 2014 and 2015.
Attorneys General
This year the Attorney General Outreach Program focused on
three priorities:
1. Education on the effects of Operation Choke Point
2. Proactive industry efforts on the Federal Charter
3. Continued education to prevent multi-state actions (in
particular given the Western Sky cases)
RAGA Capital Markets Roundtable
Republican Attorneys General Association (RAGA) hosted
its first Capital Markets Roundtable in New York City
in September. While at the event, the OLA state team
met with several stakeholders, including the Community
Financial Services Association (CFSA), Advance America
and Community Choice Financial. The state team talked
with Advance America and CFSA regarding its joint lawsuit
challenging the processes in which federal agencies executed
Operation Choke Point.
NAAG Consumer Protection
The state team attended the National Association of Attorneys
General (NAAG) Consumer Protection Seminar in Rhode Island
in October. The conference brought together staff from nearly
all 50 states. Operation Choke Point was a topic of discussion
during a panel on third party payment processing. The panel
also discussed the proactive efforts being taken by processors
to eliminate fraud while still doing business.
STATE REGULATORY
ACTIVITIES
The proposal was first shared with the Washington state
regulators. This year, a rule was promulgated from the
proposal, and the nation’s first lead generation registration rule
was implemented in the state. The state team will be working
with the regulators in the other states to expand these rules to
those areas.
The state team also met with several state commissioners
and held a meeting with the leadership of the state regulators
association, in our effort to grow our relationships in the states
as licensing becomes even more important.
OLA Annual Report 2014
The OLA state team formed the Lead Generator Working
Group to draft a registration proposal to take to state
regulators in states, such as Washington, California, Illinois and
South Carolina, which were aggressively working to license
lead generators.
FEDERAL REGULATORY
ACTIVITIES
OLA kicked off the year by starting a new conversation with
regulators. The goal was to establish a mutual cooperation and open
idea sharing dialogue between the industry and its regulators. OLA
established regular meetings with the Consumer Finance Protection
Bureau (CFPB), meeting every six weeks. OLA also met regularly
with the Federal Trade Commission (FTC), looking for ways to
work together to combat fraud in the industry. In order to open up
the dialogue between the CFPB and the industry, OLA offered the
suggestion of organizing a roundtable with industry leaders and the
CFPB.
In addition to OLA’s efforts to work with regulators, the team also
reached out to consumer groups to continue this new conversation.
In February, OLA kicked off its outreach efforts by meeting with
Pew Charitable Trusts, Center for American Progress, Consumer
Federation of America and the National Consumer Law Center.
NACHA Return Rate Thresholds
NACHA proposed several amendments to its rules regarding
unauthorized, administrative and other returns, including
non-sufficient funds fees.
In response to the proposed amendments, OLA met with
NACHA, and organized a coalition to file a comment letter in
early January 2014.
BUILDING RELATIONSHIPS
The year was focused on building better relationships.
Between regular meetings with regulators, OLA invited
representatives from the CFPB and FTC to speak at OLA
conferences and events.
Reilly Dolan, assistant director of the Division of Financial
Practices at the FTC, addressed OLA members at a board
meeting in February and also at Compliance University in July.
Attendees of the OLA Spring Summit also heard from Nikhil
Singhvi, an attorney with the FTC’s Consumer Protection
a
Bureau. In addition to Singhvi, Corey Stone, assistant
director of the Office of Deposits, Cash, Collections,
and Reporting Markets at the CFPB, also spoke at the
conference.
Building Relationships with Banks
OLA also worked with its members to better establish
relationships with banks. In order to achieve this goal, OLA
designed a PowerPoint program to help educate OLA
member companies on how to better establish and maintain
relationships with banks.
OLA also worked very closely with banks and payment
processors in 2014 to successfully defend them in 12 class
action lawsuits stemming from Operation Choke Point.
DATA ISSUES
OLA and its members submitted 179 fraud reports to the
FTC. OLA also released a press statement in July applauding
the FTC’s actions against Williams Scott & Associates, LLC,
a debt collector that was attempting to collect debts from
consumers that did not owe money.
OLA released a press statement in September praising
the CFPB and FTC’s actions against a group of 16 lenders
accused of funding loans that consumers never approved,
and making unauthorized debits from their bank accounts.
FTC’s Reilly Dolan addressing attendees at OLA Compliance University
OLA Annual Report 2014
DoD Military Lending Act
OLA issued a comment letter in December in response to
amendments proposed by the Department of Defense (DoD)
to the Military Lending Act. In the letter, OLA suggested DoD
await further clarification from Congress before expanding
the definition of consumer credit to include products like
installment loans.
GOAL 2: INCREASE THE
LEGITIMACY OF OUR INDUSTRY
Look for the OLA Seal Campaign
OLA launched its “Look for the
OLA Seal” initiative aimed at
educating potential customers
on the importance of choosing
an online lender committed
to protecting consumers from
fraud. The OLA seal can only
be displayed by OLA members,
who are required to comply with
the OLA Best Practices. When
clicked, the seal is designed to
redirect visitors to the OLA website, where they can read
more about our commitment to consumers, and obtain
important information such as consumer resources, tips and
a copy of the Best Practices.
Phase 1, which launched on November 11, aimed to
inform OLA members about the effort, and give companies
the opportunity to get the embedded seal added to their
websites. Currently, over 75 percent of OLA member
companies are displaying the seal.
The consumer outreach phase of the initiative launched on
December 8, The educational effort, which included digital
advertising and outreach to consumers applying for loans,
was designed to take the guessing game out of choosing a
trustworthy lender. Our advertising efforts, which included
both banner and video ads, were targeted at states with the
most loan customers: Texas, California, Ohio, Florida, Illinois
and New Jersey. We also launched ads in Washington, D.C.
publications, in an effort to keep regulators and opinion
leaders informed about our initiative.
Within the first month, the video ad had received over
360,000 completed views, while the banner ads had been
seen over 3 million times.
In addition to our advertising efforts, we also reached out
to consumer groups, to inform them about our initiative.
These groups included, the Center for American Progress,
Consumer Federation of America, Consumer Financial
Protection Bureau, National Consumer Law Center and Pew
Charitable Trusts.
An op-ed written by Lisa McGreevy appeared in The Hill on
Thursday, Dec. 11. The op-ed, entitled, “Helping Consumers
Choose an Online Lender They Can Trust,” informed readers
about the campaign and OLA’s ongoing commitment to
stopping fraud in the industry.
Additionally, OLA and its members funded a mystery
shopper to ensure that all companies, not just OLA
members, are treating customers appropriately. All instances
of fraud detected through this ongoing effort will be reported
to the appropriate regulatory and enforcement agencies.
OLA issued cease and desist letters to any company found
in violation of the OLA Best Practices. OLA members and
consumers alike were also asked to continue policing and
reporting to OLA any websites they suspect are engaging in
fraudulent behavior.
d
OP-EDS:
“Helping Consumers Choose an Online Lender They Can Trust”
Op-ed by Lisa McGreevy, The Hill
“New Conversation Needed on Consumer Credit”
Op-ed by Lisa McGreevy, American Banker
“Examining the Future of Online Lending”
Op-ed by Lisa McGreevy, Cheklist Magazine
PRESS STATEMENTS:
OLA Statement on OGR Report on FDIC
and Operation Choke Point
New Campaign Will Help Consumers Borrow
Online with Confidence
Statement on Pew Charitable Trusts’
Online Lending Study
Online Lenders Alliance Applauds FTC Action Against Fraudulent
Debt Collectors
Online Lenders Alliance Praises FTC Action Against Lenders That
Intentionally Defrauded Consumers
“U.S. Shuts Down Two Online Lenders” The Wall Street Journal
“Online lenders that defraud consumers should be
prosecuted and put out of business,” said Lisa McGreevy,
chief executive of the Online Lenders Alliance.
OTHER:
“Six Women of Alternative Finance”
Daily Funder
OLA Annual Report 2014
GOAL 3: ORGANIZE MEANINGFUL
EVENTS THAT SPUR
CONVERSATION IN THE INDUSTRY
g
Spring Summit
Nearly 230 attendees, including 195 OLA members and 32
non-members, made their way to the Renaissance Hotel in
Washington, D.C. for Spring Summit, April 30–May 1.
While in Washington, attendees heard from Rep.
Luetkemeyer and Sen. Pat Toomey (R-Pa.), and learned
more about the happenings on Capitol Hill and in the halls of their state legislatures.
Attendees also made their way to Capitol Hill to advocate for our industry at more than
60 meetings with their elected officials in the House and Senate.
Attendees also heard from representatives from the FTC and CFPB.
OLA Compliance University
Compliance officers and legal counsels gathered for the third annual OLA Compliance
University event, July 29–30 in Washington, D.C. The event was focused on ensuring
that member companies were up to speed on the latest regulatory and compliance
issues.
This annual event is designed to focus on the culture of compliance, what it means and
how it should be implemented. It also serves as a networking opportunity for industry
professionals and attendees, and a chance to hear first-hand from regulatory agencies.
At this year’s event, April Breslaw, deputy assistant director of supervision at the CFPB
and Reilly Dolan, assistant director of the Division of Financial Practices at the FTC,
briefed attendees on their receptive agencies’ activities and their impact on the industry.
The event helped equip attendees with the knowledge on how to proceed should their
company receive a letter from the CFPB, and what to expect from an examination.
The program also featured a workshop on sovereign nation lending. Each participant of
Compliance University received a certificate of completion for attending.
LEND360
We set out to do something unique and new by bringing
together consumer and small business lenders for
LEND360, Oct. 14–17 at the Sheraton in New Orleans. LEND360 demonstrated that
synergy can occur in the online lending space, and discussed best practices to ensure
the longevity of our industry.
The conference brought together close to 500 attendees, who heard from industry
leaders in small business, consumer and marketplace lending. This year was the first
year the event was expanded to include attendees from industries outside of consumer
lending, and approximately 15 percent of attendees hailed from the small business and
merchant cash advance industry.
OLA Annual Report 2014
In addition to speeches from industry leaders on the future of online lending, attendees
also had the opportunity to hear from Louisiana Governor Bobby Jindal (R), Senator
David Vitter (R-La.) and Congressman Sean Duffy (R-Wis.) on such topics as Operation
Choke Point and their thoughts on the 2014 election and the possibilities of the new
Congress.
Felix Lipov / Shutterstock.com
GOAL 4: MAKE OUR MARK
THROUGH POLITICAL ACTION
j
OLA POLITICAL ACTION
COMMITTEE
The OLA-PAC is the political action committee
for the Online Lenders Alliance.
The goal of the OLA-PAC is to provide support
to candidates at the federal and state level that
are committed to free enterprise, open and
competitive markets and our industry.
Total Overall Giving: $409,975
Federal vs State
Federal: $295,100
State: $114,875
Democrat vs Republican
Democrat: $98,900
Republican: $311,075
FEDERAL
House vs Senate
House: $166,700
Senate: $128,400
Democrat vs Republican
Democrat: $61,000
Republican: $234,100
STATE
Legislature vs Attorney General
Legislature: $10,000
Attorney General: $104,875
Democrat vs Republican
Democrat: $37,900
OLA Annual Report 2014
Republican: $76,975
A SPECIAL THANKS TO OUR SPONSORS
P.O. BOX 320130
ALEXANDRIA, VA 22320
703.567.0327
WWW.OLADC.ORG