ARTICLE 9 SEARCH BASICS

Transcription

1 PRESENTATION HANDOUT ARTICLE 9 SEARCH BASICS 2015 Presented by Paul Hodnefield Associate General Counsel Corporation Service Company 2015 Corporation Service Company

2 THE ESSENTIALS OF UCC SEARCHES 1) Overview & Essential UCC Concepts a) Nature of UCC Records i) The UCC is a notice filing system. (1) UCC records are not intended to provide all the details of a transaction, such as dollar amounts or terms and conditions. (2) Interested parties must conduct further inquiry to learn the full state of affairs. See cmt. 2. b) Effectiveness of Filed UCC Records i) A UCC record is effective only to the extent it was filed by a party entitled to file the record under See ii) The debtor must authorize the filing of certain records under 9-509(a)(1): (1) Initial financing statement. (2) Amendment to add a debtor (3) Amendment to add collateral (4) Termination statement filed under iii) Authorization by Debtor (1) Methods of authorization: (a) Debtor authorizes in an authenticated record (a)(1) (b) Debtor becomes bound by security agreement, 9-509(b) (c) Debtor acquires collateral in which a security interest continues (c) (d) For a termination statement, 9-509(d)(c) if the debtor has complied with the statutory requirements in 9-513(a) or (c). iv) The secured party of record must authorize the filing of most amendment types under 9-509(d)(1): (1) Termination statement (2) Continuation statement (3) Assignment (4) Party or collateral changes v) Authorization by Secured Party (1) Methods: (a) None specified by Article 9. (b) No statutory requirement that authorization be in writing. (c) Authorization is a question for the courts, not the filing office. See cmt. 2. (i) The filer s authorization is determined under law other than Article 9. The courts generally look to the state law of agency. c) Allocation of Risk i) Initial risk is on the filing party to correctly file a sufficient record that is not seriously misleading. (1) See 9-506(a) and (b) (a seriously misleading financing statement is ineffective). ii) Once filer has satisfied requirements of and filed in the correct location, all risk shifts to the searching party, including: (1) Filing office indexing errors. 1

3 (a) See cmt. 2 ( this section imposes the risk of filing-office error on those who search the files rather than on those who file ). (2) Name errors on records filed in UCC index under other law. (a) See, e.g., In re: Spearing Tool and Manufacturing Co., Inc., 412 F.3d 653(6 th Cir. 2005)(IRS is not bound by the Article 9 debtor name rules). (3) Search logic deficiencies. (4) Interpretation issues. (5) Any other problem that create risk for the secured party. 2) Debtor Names to Search a) The Correct Name of the Debtor i) Rationale: (1) Most effective financing statements will be filed under the correct name of the debtor required by 9-503(a) ii) Correct Name by Debtor Type (1) Registered Organization (a) The name of the organization exactly as provided in the public organic record, such as the articles of incorporation. See 9-503(a)(1). (2) Collateral Administered by Personal Representative (a) The financing statement must provide the individual name of the decedent. See 9-503(a)(2). (b) A sufficient search must be done on the individual name of the decedent as if that person was a living individual. (3) Collateral Held in a Trust that is not a Registered Organization (a) The name of the trust, if the organic documents specify a name (emphasis added). (b) If the trust has no name, search should be conducted on the name of the settlor (aka grantor or trustor ) See 9-503(a)(3)(A). (c) Caution: the name of the trustee is not sufficient as the name of the debtor. A search conducted under the name of the trustee will not disclose active and effective financing statements. (4) Individual (a) Article 9 provides no guidance to help searchers determine the correct name to search for an individual. See 9-503(a)(4). (b) Always search the name provided on the debtor s driver s license, if he or she has one. (c) Search by just last name and first name for broadest results. (d) The best practice is to ensure the UCC search identifies all potentially correct name variations. (5) Other Organizations (a) This is a catch-all category. Unfortunately, 9-503(a)(4) provides no guidance to help an interested party determine the correct name to search. (b) The best practice is to conduct the search under any name that due diligence research suggests could be correct. (6) Unnamed Debtor 2

4 (a) Search under the names of the partners, members, associates or other persons that comprise the debtor as if those persons were the debtor. See 9-503(a)(4)(B). b) Prior Names of the Debtor. i) Rationale. (1) If a debtor so changes its name that a filed financing statement becomes seriously misleading, the financing statement remains effective to perfect a security interest in collateral acquired by the debtor before and within 4 months after the name change. See 9-507(c). (2) The secured party can also remain perfected in after-acquired collateral by filing an amendment to add the new debtor name within 4 months of the change. (3) The secured party is under no obligation to file an amendment. (a) Financing statements may be on file solely under a prior name of the debtor for many years after a name change, yet remain fully effective. c) Names of Acquired or Merged Entities. i) Rationale: (1) When a new debtor becomes bound by the security agreement a financing statement filed under the original debtor name remains effective to perfect a security interest in collateral acquired by the new debtor before, and within four months after, the new debtor becomes bound. See 9-508(b). (2) The secured party is under no obligation to file an amendment. (a) Financing statements may be on file solely under the name of a business merged into or acquired by the debtor may remain effective for many years, even if the original debtor ceases to exist. d) Name of Debtor s Transferor of Collateral i) Rationale: (1) Collateral acquired by the debtor may be subject to a prior security interest if the debtor was not a buyer in ordinary course of business. See 9-320(c). (2) The secured party has no obligation to amend its financing statement to add the transferee name in many cases. 3) Determine Search Location a) General Rule: Search Central Index of State Where Debtor is Located i) Rationale: (1) Law of the jurisdiction where the debtor is located governs perfection of a security interest in the collateral (1). ii) Debtor s location is determined under and is based on the type of debtor. (1) Registered Organization under state law. (a) A registered organization created under state law is located in the state where it was organized (e). (2) Registered organization under federal law. (a) Located in the state where the federal law designates (f)(1). (b) Located in the state where the entity designates if the law authorizes the entity to designate its location (b)(2). (i) An entity designates its location by designating a home office or main office. 3

5 (c) If neither of the preceding options apply, the entity is located in the District of Columbia (b)(3). (3) Individual. (a) An individual is located at his or her principal residence (b)(1). (b) If an individual has more than one residence and they are located in different jurisdictions, a search may be necessary in both locations. (4) Other organization. (a) Any other type of organization is located at its place of business (as defined in 9-307(a) or, if it has more than one place of business, at its chief executive office. See 9-307(b)(2) and (3). (5) Location rules only apply if the debtor is located in a jurisdiction whose law generally requires the public filing or registration of a security interest as a condition or result of the security interest obtaining priority over the rights of a lien creditor. See 9-307(c). (a) If the debtor s location does not require filing or registration of a security interest, then the debtor is located in the District of Columbia. iii) Search location within the state. (1) General rule: Search the central filing index of the jurisdiction where the debtor is located. (a) Central filing office within the state is determined by 9-501(a)(2). b) Exception for Real-Estate-Related Collateral i) Types (1) Fixtures (2) Timber to be Cut (3) Minerals to be Extracted ii) Governing Law: (1) The law of the jurisdiction where the collateral is located governs perfection of a security interest in goods by filing a fixture filing (3). iii) Filing office to search within the state: (1) Search the office designated for the filing or recording of a mortgage on the affected real property (a)(1). iv) Caution: A security interest in fixtures can also be perfected by filing a financing statement in the central filing office of the state where the debtor is located. (1) See, e.g., Sturtz Machinery, Inc. v. Dove s Industries, Inc., 2014 U.S. Dist. LEXIS (N.D. Ohio April 8, 2014) (financing statement that described collateral to include fixture filed in central filing office of the state where the debtor was located under UCC took priority over a later-filed UCC fixture filing in the real estate records where the fixtures were located, which was in a different state). 4) Search Logic a) Filing Office Standard Search Logic i) Defined: (1) The official search logic used by the particular filing office for certified searches. ii) Types. (1) Model Standard Search Logic. 4

6 (a) General: (i) Developed as part of the Model Administrative Rules ( MARS ) by the International Association of Commercial Administrators ( IACA ) to help filing offices implement Revised Article 9 in (ii) Used by approximately 35 state-level filing offices. (b) Rules applied to search requests by MARS (i) Organization Name Searches: 1. There is no limit to the number of matches that may be returned in response to the search criteria. 2. No distinction is made between upper and lower case letters. 3. The character & (the ampersand) is deleted and replaced with the characters and each place it appears in the name. 4. Punctuation marks and accents are disregarded. For the purposes of this rule, punctuation and accents include all characters other than the numerals 0 through 9 and the letters A through Z (in any case) of the English alphabet. 5. The following words and abbreviations at the end of an organization name that indicate the existence or nature of the organization are disregarded to the extent practicable as determined by the filing office s programming of its UCC information management system: 6. The word the at the beginning of an organization debtor name is disregarded. 7. All spaces are disregarded. (ii) Individual Name Searches: 1. For first personal name and additional name(s)/intitial(s) of individual debtor names, initials are treated as the logical equivalent of all names that begin with such initials, and first personal name and no additional name(s)/intitial(s) is equated with all additional name(s)/intitial(s). For example, a search request for John A. Smith would cause the search to retrieve all filings against all individual debtors with John or the initial J as the first personal name, Smith as the surname, and with the initial A or any name beginning with A in the additional name(s)/intitial(s) field. If the search request were for John Smith (first personal name and surnames with no designation in the additional name(s)/intitial(s) field), the search would retrieve all filings against individual debtors with John or the initial J as the first personal name, Smith as the surname and with any name or initial or no name or initial in the additional name(s)/intitial(s) field. 2. If the name being searched is the surname of an individual debtor name without any first personal name or additional name(s)/intitial(s) provided, the search will retrieve from the UCC information management system all financing statements with individual debtor names that consist of only the surname. iii) Model Standard Search Logic Concerns (1) Ending Noise Words Defined: 5

7 (a) Words, phrases and abbreviations at the end of an organization name that indicate the existence or nature of the organization. (2) Treatment of Ending Noise Words (a) Identifying Noise Words (i) Most state-level filing offices programmed the search logic to recognize exact matches of noise words on a designated list after disregarding punctuation. (ii) A minority of state-level filing offices programmed the search system to look for a string of text after disregarding punctuation and spaces. (b) Disregarding Noise Words (i) Some state-level filing offices programmed the search logic to disregard all ending noise words starting at the end of the name and working back to the left until no recognized noise words remain. (ii) A minority of filing offices programmed the search logic to disregard only the first noise word found at the end of the name. iv) Best uses: (1) Search to reflect after filing. (2) Verify effectiveness of record that fails to sufficiently provide the name of the debtor under 9-506(c). b) Non-uniform Official Search Logic i) Types: (1) Exact match. (a) Returns only records that provide the exact text of the search string, including correct endings, spaces and punctuation. (b) Unforgiving of any name deviation. (2) Phone book. (a) Also known as begins with search logic. (b) Returns all records that match the entered text sequence at the beginning of the name. (c) Commonly used for systems designed to search land records, such as DC, AK and HI. (d) May require scroll through review of multiple results pages. (i) See Summit Staffing of Polk County Inc., 305 B.R. 347 (Bankr. M.D. Fla. October 15, 2003) and In re: John s Bean Farm of Homestead, Inc., 2007 Bankr. LEXIS 3817 (S.D. Fla. Nov. 1, 2007) (explanation of the burden imposed on the searcher to scroll through multiple screens of search results when using the Florida central filing office phone book style search logic). ii) Limitations (1) Exact match may miss effective financing statements with name variations due to indexing errors or other causes. (2) Phone book logic may return excessive number of results. (3) Effective records may not appear in alphabetical order on phone book searches. iii) Best uses: (1) Search to reflect after filing. 6

8 (2) Verify effectiveness of record that fails to sufficiently provide the name of the debtor under 9-506(c). c) Unofficial Filing Office Search Logic. i) General (1) Often available online for free. (2) Majority of jurisdictions use Phone Book search logic. ii) Limitations: (1) Generally not well documented. (a) Jurisdictions rarely invest resources necessary to document unofficial search logic. (2) Requires learning by trial and error. (a) A searcher may think they ve conducted a reliable search if it discloses records. (b) The risk for those who rely on the search results comes more from the records missed on a search, not those found. (3) Many of the free systems do not provide images. (a) Images of disclosed records are critical for reliable interpretation of results. (4) May not provide full details of disclosed records. (a) Some filing offices offer the unofficial search logic solely for users to identify names to submit for official searches. iii) Best uses: (1) To get general idea of number and nature of records on file. (a) Should not be used for reliance purposes. d) Search Logic Offered by Private Third-Party Providers. i) General (1) Uses more reliable search logic based on hybrid keyword, starts with and sounds like programming. (2) Providers usually offer excellent documentation and training for most reliable results. ii) Limitations: (1) Cost. Private systems charge fees for use based on the value added in the search process. iii) Best uses: (1) Due diligence, where decision makers will rely on the results. (a) Discloses records with name variations that need to be considered as part of the transaction. (2) Identify notice recipients. (a) When searching for notice purposes it is critical to identify every party that could potentially require notice. Better safe than sorry. That requires a broader search of potentially-effective record. (3) Determine relative priorities. (a) Search will disclose most mis-indexed records as well as those filed in the UCC records, but where name sufficiency is controlled by other law, such as tax liens. 5) Interpreting Record Contents a) Filing Office Information 7

9 i) File Number (1) Types: (a) Sequential (i) Each record receives a number on increment higher than the one before it. (b) Intelligent (i) Number may include code that identifies the filing office, file date, sequence within that date or other information. (ii) An intelligent file number can help an informed searcher to identify when there are potential problems with the record that could affect priority, such as: 1. Refile of a wrongful rejection. 2. Assigned date processed rather than date received. (c) Hybrid (i) Includes elements of both sequential and intelligent numbers. Can provide useful information to a researcher that understands the number used by a particular filing office. ii) File Date (1) Should be the date received by the filing office. iii) Lapse Date (1) Should be exactly 5 years from the file date. Any discrepancy could indicate a problem with how the filing office indexed the record. b) Filer-Provided Record Contents i) Debtor Name (1) Do not assume name variations make the record ineffective until after conducting further inquiry to verify the sufficiency of the record. ii) Debtor Address (1) Not required for sufficiency under 9-502(a). (a) Required only to avoid filing office rejection under 9-516(b)(5)(A). (2) Errors in the address will not make a financing statement seriously misleading. (3) Addresses can change and the secured party is under no obligation to file an amendment. (4) Best Interpretation Practice: (a) Never use the address to filter out UCC records with a matching debtor name from search results without first conducting further research to verify that is a different debtor. iii) Debtor Organization Information (1) Organization information is no longer required for filing in the vast majority of states, but will be found on nearly all records filed prior to July 1, Those records may provide the debtor s: (a) Type of Organization (b) Jurisdiction of Organization (c) Organizational Identification Number (or indication debtor has none). (2) Not required for sufficiency under 9-502(a). (a) Required only to avoid filing office rejection under 9-516(b)(5)(C). (3) Errors in the organization information will not make a financing statement seriously misleading. 8

10 (4) Best Interpretation Practice: (a) Never use the organization information to filter out UCC records with a matching debtor name from search results without first conducting further research to verify that is a different debtor. iv) Secured Party Name (1) The secured party name is not held to the same strict standard for sufficiency as debtor names. (2) Permissible secured party name variations: (a) Trade name (b) Representative name (c) Statement of capacity (d) Successor or predecessor in interest (e) Typographical errors (3) The name provided for the secured party cannot make a financing statement seriously misleading. (4) Best Interpretation Practice: (a) Never use the secured party name to filter out UCC records with a matching debtor name when conducting a due diligence search. v) Secured Party Address (1) Not required for sufficiency under 9-502(a). (a) Required only to avoid filing office rejection under 9-516(b)(5)(A). (2) Errors in the address will not make a financing statement seriously misleading. (3) Addresses can change and the secured party is under no obligation to file an amendment. (4) Best Interpretation Practice: (a) If the secured party can be reached through the name and address provided, the record probably satisfies the requirements for sufficiency. vi) Collateral (1) General (a) The collateral description merely needs to reasonably identify what is covered. See 9-108(a). (b) Reasonable identifications may include: (i) Specific description (ii) Type (iii)category (iv) Formula (v) Other reasonable descriptions. (c) Caution Courts will determine sufficiency of collateral descriptions on a case-by-case basis. (2) Serial & Model Numbers (a) Minor errors in serial or model numbers generally will not make a financing statement seriously misleading. (i) See, e.g., Maxus Leasing Group v. Kobelco America, Ltd., 2007 U.S. Dist. LEXIS (N.D.N.Y. Feb. 26, 2007) (error in serial number of crane did not make financing statement seriously misleading where other 9

11 information in financing statement provided a starting point for further investigation). (b) Some errors could cause a financing statement to be seriously misleading, but the court will decide on a case-by-case basis only after it is too late for the searcher to avoid risk. (i) See, e.g., In Re: Pickle Logging, Inc., 286 B.R. 181 (Bankr. M.D. Ga. Nov. 18, 2002)(financing statement that provided a model number and serial number for a specific piece of equipment that were each off by one digit was seriously misleading where nothing was obviously wrong with the numbers, the incorrect model number corresponded to other equipment owned by the debtor and the value difference between the correct model and the incorrect model was not enough to raise a red flag). (3) Incorporation by Reference to Attached Exhibits or Schedules (a) General Rule: (i) Reference to collateral description in a separate document is sufficient, provided the referenced document is attached to the UCC record. (b) If the filer fails to attach the referenced document, the financing statement fails to indicate the collateral and is insufficient under 9-502(a). (i) See, In Re: Duesterhaus Fertilizer, Inc., 347 B.R. 646 (Bankr. C.D. Ill. Aug. 28, 2006) (an In Lieu financing statement failed to satisfy the requirements of 9-502(a)(3) where the collateral statement provided the information required by 9-706, but original pre-ra9 financing statement was not attached to indicate the collateral). (ii) See also, In Re: Lynch, 313 B.R. 798 (Bankr. W.D. Wis. Jul. 27, 2004) (collateral description was insufficient where it merely referenced a security agreement not attached to the financing statement because it did not indicate the collateral covered by the financing statement as required by the state s version of 9-502(a)(3)). (c) Caution! (i) Filing offices tend to separate attachments for scanning and they can get lost. If that occurs, it is filing office error and the risk of loss falls on the searcher. (ii) A searcher cannot safely assume the filer failed to attach a referenced document until after further inquiry. (4) Best Practice Recommendation: (a) Searcher should give the benefit of the doubt to the filer and err on the side of caution when determining what is covered by a collateral description until further inquiry establishes specifically what is covered. (b) The threshold for sufficiency of a collateral description is so low that that the searcher must contact the secured party to determine the scope of nearly all collateral statements. 6) Interpreting the Effect of Amendments a) Termination Statement i) Purpose (1) To indicate the financing statement to which it relates is no longer effective. ii) Interpretive Considerations 10

12 (1) The filing of a termination statement does not necessarily make the related financing statement ineffective. (a) A termination statement, like most amendments, is only effective to the extent it was authorized by the secured party of record. See and 9-509(d). (b) A termination statement authorized by one secured party of record does not affect the financing statement with respect to another secured party of record. (2) Filing office treats a termination statement as an amendment. (a) Record remains active in the index until the lapse date. (b) Filing office is required to accept additional amendments after the filing of a termination. iii) Risks (1) Unauthorized Filings: (a) Unauthorized Termination Statement Filed by Mistake (b) Unauthorized Termination Statement from Refinance Transaction (2) Effect of Unauthorized Filing (a) Financing statement remains effective. (3) Caution: (a) Effectiveness of a termination statement cannot be determined from either the filing office summary listing or the filed UCC record. (b) Authority to file is established under law other than Article 9 and is not part of the public record. (c) The only way to determine whether a termination statement is effective is to conduct further inquiry of the secured parties involved. (i) See In re: Rag East, LP, 2013 Bankr. LEXIS 796 (Bankr. W.D. Penna March 4, 2013) (security interest of lender that relied on forged termination statement was subordinate to prior secured party because the termination statement was not authorized and, therefore, not effective). (4) Best Practices (a) Treat a termination statement as notice that the security interest may not exist. (b) Contact the Secured party or parties to verify that they authorized the filing. b) Continuation Statement i) Purpose (1) To continue the effectiveness for 5 years from the date the financing statement would have lapsed in the absence of the filing of a continuation statement. See 9-515(e). (2) Keeps the record active in the filing office records for an additional 5-year period. ii) Interpretive Considerations (1) Active does not equal Effective. (a) The filer s compliance with Article 9 determines the effect of a continuation. The filing office has no power to make the record effective or ineffective by accepting, rejecting or mis-indexing the record. (2) A continuation statement filed prior to the 6-month period specified in 9-515(d) is not effective, even if the filing office accepts it. (a) The filing office is required to reject continuation statements submitted early under 9-520(a) and 9-516(b), but some slip through. 11

13 (3) A continuation statement filed after the lapse date is not effective and the filing office is required to reject it. iii) Risks (1) Continuation statement file date may be after the lapse date if filing office later agrees to file a wrongfully-rejected record. (a) Searcher cannot assume a late continuation statement is not effective until after further inquiry of the parties and filing office. iv) Best Practices (1) Verify the filing dates of all continued financing statements disclosed by the search to ensure the record remains effective. c) Assignments i) Purpose (1) Assigns the right to amend the financing statement with respect to some or all of the collateral. See 9-514(b). ii) Interpretive Considerations (1) Assignment does not assign the security interest! (a) Assignment, full or partial, simply adds the assignee as a secured party of record. (2) Assignor remains a secured party of record with the power to file effective amendments. (a) See (a party remains a secured party of record until an amendment is filed to delete the party). iii) Risks (1) Assignor may not receive a required notice under Article 9. (a) Failure to provide notice, such as notice of a PMSI in inventory, may affect the priority of security interest. (2) Searcher may incorrectly assume assignor no longer has an interest in the financing statement. (3) Assignor may still retain a claim on the collateral perfected by the assigned financing statement. (4) If assignor with no further claim on collateral later enters into another security agreement with the debtor, the financing statement may give it priority of later filers. iv) Best Practices (1) Conduct further inquiry to determine the existing claims of assignee and assignor. (2) Obtain authority to file whatever records are necessary to ensure searcher obtains and maintains proper authority. (a) E.g., amendment to delete the assignor as secured party, subordination or other appropriate agreement. (3) Send notices to all assignor secured parties in addition to the assignee secured parties. d) Other Amendment Issues i) Amendment Filed After Termination (1) Effectiveness: (a) A subsequent amendment is only effective to the extent the financing statement remains effective following the filing of the termination statement. 12

14 (b) A continuation statement filed after the filing of a termination statement cannot revive the effectiveness of a fully-terminated financing statement. (2) Interpretation: (a) Amendments filed after a termination statement may indicate that the secured party is unaware of an unauthorized filing. The searcher must contact the secured party to verify the status of the record. ii) Conflicting Amendment Actions (1) Incompatible amendment actions indicate the secured party needs to conduct further inquiry to determine the effect of the record. (a) See, e.g., Official Committee of Unsecured Creditors v. City National Bank, N.A., 2011 U.S. Dist. LEXIS 51628(N.D. Cal. 2011)( placing of check marks in both Box 8 and Box 2, as well as the detailed information in the former, constituted discrepancies of sufficient significance to alert potential creditors of a prior encumbrance on the debtor's assets. The error was confusing but not seriously misleading). iii) Missing Amendments (1) Some land record offices may have difficulty linking UCC amendments to the initial financing statement by file number. (a) Amendments in these offices are indexed under the debtor name. (2) If a financing statement disclosed by a search in one of these offices, D.C., for example, provides more than one debtor name, the interested party should also do a search on the other names. Amendments to the financing statement may be indexed under one of those other names. e) Non-Article 9 Amendment Attempts i) Types: (1) Subordination Agreement (2) Separation Agreement (fixtures) (3) Statement of No Interest ii) Effect of Non-Article 9 Amendments (1) Attempts to file such amendments have no effect on the record. (2) These records represent contractual agreements between secured parties, do not affect the rights of third-parties and, consequently, no public record filing is necessary or effective. iii) Caution: (1) Non Article 9 amendments may contain information that triggers the need for an interested party to conduct further inquiry. Searchers should carefully review the contents of these records for that reason. 13

15 Presenter Biography Paul Hodnefield is Associate General Counsel for Corporation Service Company ( CSC ). In addition to his duties at CSC, he currently serves as Co-Chair of the ABA Joint Task Force on Filing Office Operations and Search Logic. Mr. Hodnefield is a Fellow of the American College of Commercial Finance Lawyers. He is also an active participant with the International Association of Commercial Administrators (IACA) Secured Transactions Section. Prior to joining CSC, Mr. Hodnefield served as an adjunct professor at the University of Minnesota law school, where he taught courses on public records and business ethics. Contact Information Paul Hodnefield Associate General Counsel Corporation Service Company 2345 Rice St., Suite 230 Roseville, MN (800) ext paul.hodnefield@cscglobal.com Rev