Garage Work Bench Kits

The Dremel Work Station can be tilted in 15-degree increments. View larger.

Flexibility for Intricate Work
Whether you're buffing stones or sanding parts of a radio-controlled airplane, you'll appreciate that you can tilt the Dremel Work Station in 15-degree increments from 15 to 90 degrees horizontal -- perfect for more focused, intricate work. When you're grinding or polishing materials, the tool holder prevents slippage by keeping tools at 90 degrees, and the telescoping FlexShaft tool stand lets you adjust to any height between 16 and 29 inches. Once you've finished working for the day, place bits, collets, and wrenches in the tool caddy for easy clean-up and storage.

Easy Setup and Durable, User-Friendly Design
Easy to set up and operate, the Work Station features straightforward, durable construction. Clips keep messy cords from obscuring your visibility as you work, and inch and metric markings on the base allow for precise measurements and ensure that your adjustments are consistent, too. Compatible rotary tools attach and detach smoothly so you can polish, grind, or drill holes in stone, metal, or glass for rivets, eyelets, or cold connections of any sort.

What's in the Box
Work Station, accessory nest, mounting wrench, and instructions

This work station holds Dremel rotary tool models 100, 200, 275, 285, 300, 395, 595 and 850 (tool not included)

Black Toenail Causes

Black & Decker WM125

Recent trauma to your toe may have caused the toenail to become black. This is because it is bruised. Runners may experience black toenails from running in new shoes or without socks. In this case blood has gathered under the nail. Most common among people who have developed black toenails is toenail fungus.

Nail fungus is caused by a variety of factors. Wearing shoes still laden with sweat increases risk of toenail fungus. Cutting your toenails too short increases infection risk. Also public areas such as pools, gyms, showers, and saunas are common places to spread fungus. It is advised to wear sandals as much as possible around these places to greatly reduce infection. Cutting your toenails too short may cause minor cuts giving a chance for a fungus to take hold.

Toenail Fungus Symptoms

Symptoms of toenail fungus include a discoloration of the nail. Usually discoloration is black, green, brown, or yellow. Nails might become brittle and crack. Often they'll become thick and foggy as well. You might experience a slight plain when walking on your infected toe. Perhaps you'll also smell a faint smell coming from under the nail.

Steps For Treatment

Ingested prescription medications are not recommended for treating nail fungus. This is because they have extremely negative side effects. The powerful toxins in these pills fight fungus however they'll also cause damage to your liver and kidneys. This could result in liver disease and in rare cases result in death. Over the counter medications usually are ineffective at treating fungus.

I found the best remedy was to treat my toenail fungus first with regular beer. Beer has natural anti-fungal properties. For treatment, I would soak my nails in beer for thirty minutes each application. I applied this twice a day. Following my remedy with beer I used a natural toenail treatment.

With this combination of approaches along with prevention methods I was able to see noticeable results of my black toenail fungus healing in about two weeks.

I finally cured my toenail fungal infection after much trial and error. Learn about how I successfully treated my toenail fungus and avoid wasting time on ineffective treatments. The treatment remedy I used can be found at toenail-fungus.org

Vietnam's regional focus for industrial development is in the Southeast. Prospective investors and government bodies are planning for what is hoped to be the boom of the Mekong Delta in 2020. The delta is one of Southeast Asia's largest food exporting regions, producing the tropical fruit for much of the region. Currently, Ho Chi Minh City (HCM) is the most developed city in the southeast; however, in less than a decade, HCM City will be just one of several urban centers for the production of economic, industrial, commercial, science and technology, transport and international exchange services. By all projections, in 2020 this region will be known to the world as a robust industrial sector.

Global Industrial

Vietnam's government is investing heavily to dramatically improve its transit systems and energy production. The national and provincial roads currently are undergoing upgrades and expansions, to creating access from HCM City to the rest of the country. As HCM and the Mekong Delta region will be the driving force behind the new economy's infrastructure, moving goods and people quickly around the country will be a critical component. Even more importantly, the regions industrial capacity, coal, thermal and hydroelectric power stations will be the driving forces fueling the economy. Power stations are now being constructed and will be ready by 2015.

The current shortage of skilled labour in the rural areas of the Mekong Delta are predicted to end by 2020. According to the Ministry of Labour, vocational training in the area has developed rapidly in recent years, with the addition of 11 vocational training colleges and 20 vocational secondary schools. Unemployment dropped to 14.13% in 2008, down 6.45 points in only three years. The continuing trends in labour development and growing infrastructure and commerce are expected to dramatically reduce unemployment and unskilled labour.

The increased opportunities for more foreign-owned companies to invest and operate in Vietnam is leading to higher interest in Vietnam company formation from entrepreneurs all over the world. While company registration processes can be difficult at times, the requirements have become more consistent. Company incorporation agents are another way to improve efficiency of setting up your business in Vietnam.

The Mekong Delta had an average GDP of 12.1% between 2006 and 2009. With investors flocking to the country and with the economic development that is expected, the increase by 2020 will be significant. Plans to improve the infrastructure are expected, connecting the Mekong Delta to the entire country of Vietnam. Most importantly, to the rest of the world, the industrial activity in Mekong Delta will be on the map by 2020.

Healy Consultants is a leading corporate services firm, headquartered in Singapore, and specialising in company incorporation, including helping clients to complete Vietnam company registration. For more information, visit http://www.healyconsultants.com.

1. "The first risk is to assume that baby boomers have a level of financial acumen that eliminates the need for proper suitability analysis".

Sky Enterprise USA

2. "A second risk comes from the very product innovation that has generally served your customers so well".

3. "A third risk is a failure to analyze the status of these new products under the federal securities laws."

Chairman Schapiro goes on to say that equity indexed annuities are securities as well as life settlements and may constitute a "selling away" problem amongst other concerns. She explains: "Equity-indexed annuities are only one example of a financial product that a firm might erroneously treat as a non-security. Other examples include tenants-in-common exchanges, and life settlements. NASD considers all of these products to be securities, subject to firm supervision.

The NASD is the "watchdog of the SEC" and its sole existence is to protect the investment public. One of their preoccupations is to keep in check the "egregious overcharging" of fees that are generated by manufactured investment products. There seems to be a correlation by the NASD as to their concern with the nature and size of fees that have been generated by the life settlement transaction.

The question remains; are life settlement transactions securities? The question of whether life insurance settlements are to be treated as securities is divided into two parts-whether we are discussing the back end sales activity, i.e. the distribution of interests in a policy or pool of policies, or the front end activity, i.e. the solicitation and facilitation of the sale of a policy to a life settlement company. Once the policy has been sold into the secondary market then one could conclude that the "transfer for value rule" has been applied and the insurance contract could be construed as a security. Many, however, would conclude that the up-front transaction of a life settlement would not be subjected to securities law and jurisdiction.

Why all the Fuss?

Does the life settlement market deserve such attention? According to the 2004 Life Insurers Fact Book, compiled by the American Council of Life Insurers, there is .4 trillion of life insurance in-force on 167 million policies. Coupled with the fact that emerging demographics show our beloved "Baby Boomers" are hitting retirement and you can clearly see that the life settlement market is getting on everyone's radar screen.

Moreover, according to the Conning Research and Consulting whitepaper, "Life Settlements, The Concept Catches On" 2006, they explain that the average life settlement offer approximates 25% and 30% of face amount." If it is true that approximately 35% of all settlement proceeds will be re-deployed into new investment vehicles for growth or income then one can draw the conclusion that broker-dealers should have a vested interest. This rings particularly true where there is competition for registered representative recruiting where he or she can potentially increase their gross commissions.

This article will examine the potential NASD issues and possible solutions towards the adoption of life insurance settlement program. It is not intended to support the notion that a life settlement is a security, but to give a better understanding in the event that a broker-dealer wishes to add the strategy as a new profit center.
The first consideration from a compliance perspective is how to treat the life settlement. Some wire-house compliance departments for example have treated life-settlements as a passive referral and do not except compensation. The common thought being that they can reap the compensation by re-deploying the proceeds towards a traditional product such as a stock, bond or mutual fund. In that way, as the reasoning goes, they did not complete a securities transaction and therefore did not violate NASD procedure. Moreover, many of these firms use the life settlement strategy towards the replacement of underperforming or outmoded insurance.

For example: Client Clara has a ,000,000 life insurance policy and is paying ,000 a year in premiums. Broker Bob tells her that she can sell the policy in the secondary market and use the proceeds to pay for new coverage with a new no-lapse guarantee. She sells the policy for 0,000 and uses the money to buy a new ,500,000 with premiums less than her original premium costs.

Many broker-dealers have adopted this passive non-compensation approach to life settlements. Other broker-dealers see the product a way to offset lagging markets and infuse new streams of revenue for the firm.
We need to become more educated towards understanding of how to address complex compliance issues as it pertains to life settlements. There are many factors that go into how the life settlement program should be installed into a BD system. For example: Should the BD look at the program as a security or strictly as an outside business activity. There are few firms that can provide answers to these complex questions that will provide consulting as it concerns life settlements.

Involving the notion that a life settlement is a security, it is critical to understand what a security is to determine if it is applicable to life settlements. The keystone case on the definition of securities is SEC v. W.J. Howey.1 In Howey, the Supreme Court was asked to define the term "investment contract" since the term is used in the definition of a security under the Securities Act of 1933. In its decision, the Court defined an investment security as any transaction that: Involves the investment of money, in a common enterprise, with an expectation of profit, and which occurs solely from the efforts of others. It is immaterial if the enterprise is evidenced by formal certificates or nominal interests in physical assets. In SEC v. Mutual Benefits Corp. the Eleventh Circuit affirmed a U.S. District Court finding that Mutual Benefits was involved in a viatical settlement contract that qualified as "investment contracts" under the securities act of 1933 and 1934. Prior to the Mutual benefits case the settlement industry consistently cited a district court decision, SEC v. Life Partners Inc. as the basis for insurance regulation of the settlement business. Despite losing, the SEC has persisted in its opinion that investments in settlements are securities. The precedent set by SEC v. Mutual Benefits has created a cavalcade of potential securities issues that should be looked at by a seasoned expert in the settlement/NASD industry.
Just as important is the fact that many Broker-Dealers have chosen to ignore the life settlement in the hopes that they can one day claim ignorance. This "stick your head in the sand" posture is a recipe for disaster because empirically the NASD has made it quite clear that they will not tolerate this kind of strategy under any circumstances.
Common sense dictates that in order to avoid problems is to always place the client's best interest first, thus preventing problems by not being compliant.

There are many rules, regulations and strategies that would apply to life settlements under NASD guidelines. This article will only examine some very germane issues. It is important to note that any prudent compliance department will need to adopt written procedures on processing life settlements.

RECOMMENDED NASD PROCEDURES

In offering life settlement services in a prudent SEC and NASD compliant manner we must understand how the strategy must apply NASD procedures. Thus far, the SEC and the NASD have not definitively become the official SROs of the life settlement industry although they have prosecuted and taken punitive actions on RRs. To be sure, the NASD has declared that the back-end of the transaction is a security and has made it clear that "fractionalization "is a dangerous area of the product. The program has gained in popularity and the aforementioned regulation body will likely lead the regulatory charge. It is therefore extremely important to understand written procedures concerning: While there are over 20 identifiable issues and strategies that may influence NASD procedures, here are 7 that should apply immediately:

1. NASD Rule 2320 (g) (1) (Best Execution)
2. NASD Rule 2110 "Standards of Commercial Honor and Principles of Trade"
3. NASD Rule 2310 "Recommendations to Customers" (Suitability)
4. NASD Rule 2430 "Charges for Services Performed"
5. NASD Rule 3030 "Outside Business Activities of an Associated Person"
6. NASD Rule 3040 "Private Securities Transactions of an Associated Person"
7. NASD Procedures (*should be Written and Consistent)

NASD Rule 2320: Best execution via the "3 Quote Rule" is applicable anytime there is an offering to the general public. That is to say, we as professionals are held to the highest of standards and have a fiduciary to get the best pricing for our clients. This due diligence process is to ensure against improper favorite company choice and price fixing. The fact that the firm has multiple offers may not be enough. Indeed, it is extremely important to have more than 3 quotes to get best execution, due to the providers that will"take a pass" at acquiring the insurance contract. Today, there are broker-dealers currently engaging in life settlements that are likely in violation of this procedure.

NASD Rule 2110: High Standards of Commercial Honor and Principles of Trade are paramount to stay compliant. The NASD has ruled and punished both broker-dealers and registered representatives combining rule 2110/ 3030 & 3040 as it pertains to life settlements. It is important to note that their may be "failure to supervise" issues where selling away and private placements are conducted.

NASD Rule 2310: The NASD has made it clear that we all must conduct our business in manner consistent with the customer's objectives and corresponding suitability. Moreover, we must disclose all material facts and maintain full disclosure. By not offering a beneficial strategy when appropriate is in direct conflict with NASD Rule 2310 (b) (4). (B.D. Beware)

NASD Rule 2430: Charges, if any, for services performed, including miscellaneous services such as collection of moneys due for principal, dividends, or interest; exchange or transfer of securities; appraisals, safe-keeping or custody of securities, and other services, shall be reasonable and not unfairly discriminatory between customers .States that regulate excessive fees must be adhered to appropriately. Empirically speaking the NASD sees excessive fees to be anything over 5-6%. Since life settlements create value in excess of the insurance policies cash surrender value then a payout grid can be established to comply with NASD rule 2430. One should seek out professional consultation concerning this very paramount issue.

NASD Rule 3030: No person associated with a member in any registered capacity shall be employed by, or accept compensation from, any other person as a result of any business activity, other than a passive investment, outside the scope of his relationship with his employer firm, unless he has provided prompt written notice to the member. As previously stated, the NASD has made it clear that life settlements are included in their interpretation of "selling away" and it is a paramount area of concern where improper supervision exists.

NASD Rule 3040: Provides, among other things, that prior to participating in a securities transaction outside the course or scope of his or her employment, a person associated with a member firm must give that firm prior written notification. In addition, if the firm is notified that the associated person may receive selling compensation, it is required to issue written approval or disapproval.

Licensing and Compensation Issues

The "Desk Drawer Broker Dealer"
This strategy is very simplistic in nature and is a logical alternative to partnering with a single Funder. The interested broker-dealer would create a selling agreement with specialized broker-dealer component that would conduct the life settlement transaction for a fee. All transactions would meet NASD requirements including best execution. The broker-dealer with the unwanted policy would transact under an arms length arrangement.

NASD "Blue Sky"Regulations
Aside from having a general securities license series 7 and series 63 there are some guidelines that should be adhered to. Although there is confusion by many of the Funders as to how life settlement transactions should be conducted from state to state, it is logical that the broker-dealer and its Registered Representative must maintain registrations in the state from which the compensation originates, i.e., the Funder's home state of business transactions. It should be emphasized however, that it is good business practice by a RR to become authorized in every state that he or she plans on conducting the business of life settlements.

Variable Policy Clearing
Although many of the policies sold in the secondary market are fixed, there is the occasion when "variable rescue" may come into play. In this situation it is always advisable to clear through a "desk drawer" broker-dealer as mentioned above. Needless to say, moving the sub-accounts to the policy's money market does not constitute a fixed product and thus is not sufficient to avoid potential NASD regulation.

USAPatriot Act
USA PATRIOT Act in October 2001Life settlement transactions are not excluded and should comply with all rules and regulations concerning the USA Patriot Act. Therefore, in order to comply with anti-money laundering (AML) laws, it follows that a normal business model of compensation payment could include the settlement broker firm notifies its contracted employee and RR/BD of the specific dollar amount of a transfer that will derive from a source Provider firm. The Registered Representative notifies the broker-dealer about the payment amount and its source to ensure Blue Sky registrations. After the broker-dealer receives the payment to the Registered Representative (in compliance with NASD guidelines), the Registered Representative will deposit the funds into his LLC bank account (in compliance with the aforementioned IRS guidelines), and provide separate invoices that meet uniform and specific identification requirements to both the agent's broker-dealer and to the life settlement broker firm. The invoices will be signature executed by each entity and returned to the Registered Representative for inclusion in a permanent file as the compensation recipients. After payment is made by the Registered Representative's LLC to the agent's broker-dealer and to the life settlement broker firm, the latter will provide the Registered Representative with an electronic copy of the specific case file that the Registered Representative will keep in the same permanent file as the related invoice copies.

Conclusion
The Life Insurance Settlement is an emerging and often misunderstood industry. While the idea of selling an insurance policy has been around for over a century, we are now entering an era where it may become commonplace. The secondary market, while still in its infancy, seems to have "turned the corner" and is quickly becoming a permanent part of our financial and wealth management planning. As the industry expands and matures we will see more and more seniors benefit from the strategy. Moreover, we will see Registered Representatives enjoy creating new a new source of funds for their clients which they in turn will place in a more suitable and more appropriate investment. Today, more than ever, broker-dealers and wire-houses are placing into effect "written procedures" or are learning the potential benefits of the secondary market for life insurance. If conducted with prudence and with strict adherence to NASD rules and regulations life settlements should become a major component of mainstream wealth management for the broker-dealer and wire-house community.

Jonathan H. Proby, CSA, MBA is a South Florida native having been born and raised in Coral Gables, Florida. He is the author of "The Seven Most Costly Financial Mistakes Made By Seniors", "The Ten Most Essential Things That You Must Know When Selling Your Insurance Policy", and "Life Insurance Settlements and the NASD... A Study in Compliance", is the past host of the Southern Most Wall Street Report on Conch FM and has authored other literary and columnist works.

Jonathan frequently provides lectures and workshops for approved continuing education to professionals such as CPAs, (CPE) Attorneys, (CLE) Financial Planners (CFP) and Insurance Agents (CE). Jonathan has provided lectures on advanced wealth management and estate planning strategies including "Life Settlements, Premium Financing, Charitable Giving, Premium Financed Life Insurance and The Insurance Audit". Through his lectures, Jonathan has introduced and taught these strategies to notables including the Florida Bar, the Society of Financial Service Professionals, The Financial Planning Association, The Florida Institute of CPAs, the National Association of Estate Planners and Councils with distinguished honors of the "NAEPC Speakers Bureau" and at Georgetown School of Law. Jonathan is president of Institutional Life Settlement Advisors, http://www.ilsallc.com and can be contacted at 877-438-4572.