Podcasts about adequacy

Send us a textOn this week of Serious Privacy, Paul Breitbarth , Ralph O'Brien of Reinbo Consulting, and Dr. K Royal talk about the controversy with executive changes to the U.S. Federal Trade Commission #FTC, the UK #adequacy extension, and the Norwegian decision about Data Protection Officer #DPO conflicts of interest.Please subscribe in your favorite podcast app - sharing is caring!  Powered by TrustArcSeamlessly manage your privacy program, assess risks, and stay up to date on laws across the globe.With TrustArc's Privacy Studio and Governance Suite, you can automate cookie compliance, streamline data subject rights, and centralize your privacy tasks—all while reducing compliance costs. Visit TrustArc.com/serious-privacy.If you have comments or questions, find us on LinkedIn and Instagram @seriousprivacy, and on BlueSky under @seriousprivacy.eu, @europaulb.seriousprivacy.eu, @heartofprivacy.bsky.app and @igrobrien.seriousprivacy.eu, and email podcast@seriousprivacy.eu. Rate and Review us! From Season 6, our episodes are edited by Fey O'Brien. Our intro and exit music is Channel Intro 24 by Sascha Ende, licensed under CC BY 4.0. with the voiceover by Tim Foley.

AM Best Senior Director Jacqalene Lentz outlines a new Best's Market Segment Report that finds despite weather-related catastrophe losses, overall P/C underwriting results improved in 2024, and AM Best expects the industry to build on its solid rebound in 2025.

Attorneys Kelly Dempsey and Bryan Dunton dive into the results of the 2024 MHPAEA Report to Congress. The EBSA and CMS have continued to improve their focus on network design and adequacy for group health plans. In this episode, Kelly and Bryan discuss how these parity problems manifest themselves in testing and what plans can do to resolve them. 

Karen Mannion, CEO of local development group Forum Connemara, speaks to Joe Caulfield about the ongoing aftermath of Storm Éowyn and Bernard Gloster, HSE, discusses how the storm has put pressure on the health services over the past week.

Irene Rey, Associate Director, Market Practice and Regulatory Policy, ICMA, discusses the adequacy of macroprudential policies for NBFI.

1UNITED STATES BANKRUPTCY COURTSOUTHERN DISTRICT OF TEXASHOUSTON DIVISIONIn re:INTRUM AB, et al.,1Debtors.Chapter 11Case No. 24-90575 (CML)(Jointly Administered)NOTICE OF APPEALPursuant to 28 U.S.C. § 158(a) and Federal Rules of Bankruptcy Procedure 8002 and 8003,notice is hereby given that the Ad Hoc Committee of holders of 2025 notes issued by Intrum AB(the “AHC”) hereby appeals to the United States District Court for the Southern District of Texasfrom (i) the Order Denying Motion of the Ad Hoc Committee of Holders of Intrum AB Notes Due2025 to Dismiss Chapter 11 Cases Pursuant to 11 U.S.C. § 1112(b) and Federal Rule ofBankruptcy Procedure 1017(f)(1) (ECF No. 262) (the “Motion to Dismiss Order”) and (ii) theOrder (I) Approving Disclosure Statement and (II) Confirming Joint Prepackaged Chapter 11Plan of Intrum AB and Its Affiliated Debtor (Further Technical Modifications) (ECF No. 263) (the“Confirmation Order”). A copy of the Motion to Dismiss Order is attached as Exhibit A and acopy of the Confirmation Order is attached as Exhibit B. Additionally, the transcript of theBankruptcy Court's oral ruling accompanying the Motion to Dismiss Order and ConfirmationOrder (ECF No. 275) is attached as Exhibit C.Below are the names of all parties to this appeal and their respective counsel:1 The Debtors in these Chapter 11 Cases are Intrum AB and Intrum AB of Texas LLC. The Debtors'service address in these Chapter 11 Cases is 801 Travis Street, Ste 2101, #1312, Houston, TX 77002.Case 24-90575 Document 296 Filed in TXSB on 01/13/25 Page 1 of 62I. APPELLANTA. Name of Appellant:The members of the AHC include:Boundary Creek Master Fund LP; CF INT Holdings Designated Activity Company; CaiusCapital Master Fund; Diameter Master Fund LP; Diameter Dislocation Master Fund II LP; FirTree Credit Opportunity Master Fund, LP; MAP 204 Segregated Portfolio, a segregated portfolioof LMA SPC; Star V Partners LLC; and TQ Master Fund LP.Attorneys for the AHC:QUINN EMANUEL URQUHART & SULLIVAN, LLPChristopher D. Porter (SBN 24070437)Joanna D. Caytas (SBN 24127230)Melanie A. Guzman (SBN 24117175)Cameron M. Kelly (SBN 24120936)700 Louisiana Street, Suite 3900Houston, TX 77002Telephone: (713) 221-7000Facsimile: (713) 221-7100Email: chrisporter@quinnemanuel.comjoannacaytas@quinnemanuel.commelanieguzman@quinnemanuel.comcameronkelly@quinnemanuel.com-and-Benjamin I. Finestone (admitted pro hac vice)Sascha N. Rand (admitted pro hac vice)Katherine A. Scherling (admitted pro hac vice)295 5th AvenueNew York, New York 10016Telephone: (212) 849-7000Facsimile: (212) 849-7100Email: benjaminfinestone@quinnemanuel.comsascharand@quinnemanuel.comkatescherling@quinnemanuel.comB. Positions of appellant in the adversary proceeding or bankruptcy case that isthe subject of this appeal:CreditorsCase 24-90575 Document 296 Filed in TXSB on 01/13/25 Page 2 of 63II. THE SUBJECT OF THIS APPEALA. Judgment, order, or decree appealed from:The Order Denying Motion of the Ad Hoc Committee of Holders of Intrum AB Notes Due2025 to Dismiss Chapter 11 Cases Pursuant to 11 U.S.C. § 1112(b) and Federal Rule ofBankruptcy Procedure 1017(f)(1) (ECF No. 262); the Order (I) Approving Disclosure Statementand (II) Confirming Joint Prepackaged Chapter 11 Plan of Intrum AB and Its Affiliated Debtor(Further Technical Modifications) (ECF No. 263); and the December 31, 2024 Transcript of OralRuling Before the Honorable Christopher M. Lopez United States Bankruptcy Court Judge (ECFNo. 275).B. The date on which the judgment, order, or decree was entered:The Motion to Dismiss Order and the Confirmation Order were entered on December 31,2024. The Court issued its oral ruling accompanying the Motion to Dismiss Order and theConfirmation Order on December 31, 2024.III. OTHER PARTIES TO THIS APPEALIntrum AB and Intrum AB of Texas LLCMILBANK LLPDennis F. Dunne (admitted pro hac vice)Jaimie Fedell (admitted pro hac vice)55 Hudson YardsNew York, NY 10001Telephone: (212) 530-5000Facsimile: (212) 530-5219Email: ddunne@milbank.comjfedell@milbank.com–and–Andrew M. Leblanc (admitted pro hac vice)Melanie Westover Yanez (admitted pro hac vice)1850 K Street, NW, Suite 1100Washington, DC 20006Telephone: (202) 835-7500Facsimile: (202) 263-7586Email: aleblanc@milbank.commwyanez@milbank.com–and–PORTER HEDGES LLPJohn F. Higgins (SBN 09597500)Case 24-90575 Document 296 Filed in TXSB on 01/13/25 Page 3 of 64Eric D. Wade (SBN 00794802)M. Shane Johnson (SBN 24083263)1000 Main Street, 36th FloorHouston TX 77002Telephone: (713) 226-6000Facsimile: (713) 226-6248Email: jhiggins@porterhedges.comewade@porterhedges.comsjohnson@porterhedges.comIV. OTHER PARTIES THAT MAY HAVE AN INTEREST IN THIS APPEALThe following chart lists certain parties that are not parties to this appeal, but that may havean interest in the outcome of the case. These parties should be served with notice of this appealby the Debtors who are aware of their identities and best positioned to provide notice.All Other Creditors of the Debtors, Including, But Not Limited To:• Certain funds and accounts managed by BlackRock Investment Management (UK)Limited or its affiliates;• Capital Four;• Davidson Kempner European Partners, LLP;• Intermediate Capital Managers Limited;• Mandatum Asset Management Ltd;• H.I.G. Capital, LLC;• Spiltan Hograntefond; Spiltan Rantefond Sverige; and Spiltan Aktiefond Stabil;• The RCF SteerCo Group;• Swedbank AB (publ).Any Holder of Stock of the Debtors• Any holder of stock of the Debtors, including their successors and assigns.Case 24-90575 Document 296 Filed in TXSB on 01/13/25 Page 4 of 65Respectfully submitted this 13th day of January, 2025.QUINN EMANUEL URQUHART &SULLIVAN, LLP/s/ Christopher D. PorterChristopher D. Porter (SBN 24070437)Joanna D. Caytas (SBN 24127230)Melanie A. Guzman (SBN 24117175)Cameron M. Kelly (SBN 24120936)700 Louisiana Street, Suite 3900Houston, TX 77002Telephone: (713) 221-7000Facsimile: (713) 221-7100Email: chrisporter@quinnemanuel.comjoannacaytas@quinnemanuel.commelanieguzman@quinnemanuel.comcameronkelly@quinnemanuel.com-and-Benjamin I. Finestone (admitted pro hac vice)Sascha N. Rand (admitted pro hac vice)Katherine A. Scherling (admitted pro hac vice)295 5th AvenueNew York, New York 10016Telephone: (212) 849-7000Facsimile: (212) 849-7100Email: benjaminfinestone@quinnemanuel.comsascharand@quinnemanuel.comkatescherling@quinnemanuel.comCOUNSEL FOR THE AD HOC COMMITTEE OFINTRUM AB 2025 NOTEHOLDERSCase 24-90575 Document 296 Filed in TXSB on 01/13/25 Page 5 of 6CERTIFICATE OF SERVICEI, Christopher D. Porter, hereby certify that on the 13th day of January, 2025, a copy ofthe foregoing document has been served via the Electronic Case Filing System for the UnitedStates Bankruptcy Court for the Southern District of Texas./s/ Christopher D. PorterBy: Christopher D. PorterCase 24-90575 Document 296 Filed in TXSB on 01/13/25 Page 6 of 6EXHIBIT ACase 24-90575 Document 296-1 Filed in TXSB on 01/13/25 Page 1 of 31IN THE UNITED STATES BANKRUPTCY COURTFOR THE SOUTHERN DISTRICT OF TEXASHOUSTON DIVISION)In re: ) Chapter 11)Intrum AB, et al.,1 ) Case No. 24-90575 (CML)))Jointly AdministeredDebtors. ))ORDER DENYING MOTION OF THE AD HOCCOMMITTEE OF HOLDERS OF INTRUM AB NOTES DUE 2025TO DISMISS CHAPTER 11 CASES PURSUANT TO 11 U.S.C. § 1112(B) ANDFEDERAL RULE OF BANKRUPTCY PROCEDURE 1017(F)(1)(Related to Docket No. 27)This matter, having come before the Court upon the Motion of the Ad Hoc Committee ofHolders of Intrum AB Notes Due 2025 to Dismiss Chapter 11 Cases Pursuant to 11 U.S.C. §1112(b) and Federal Rule of Bankruptcy Procedure 1017(f)(1) [Docket No. 27] (the “Motion toDismiss”); and this Court having considered the Debtors' Objection to the Motion of the Ad HocCommittee of Holders of Intrum AB Notes Due 2025 to Dismiss Chapter 11 Cases Pursuant to 11U.S.C. § 1112(b) and Federal Rule of Bankruptcy Procedure 1017(f)(1) (the “Objection”) andany other responses or objections to the Motion to Dismiss; and this Court having jurisdiction overthis matter pursuant to 28 U.S.C. § 1334 and the Amended Standing Order; and this Court havingfound that this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); and this Court having foundthat it may enter a final order consistent with Article III of the United States Constitution; and thisCourt having found that the relief requested in the Objection is in the best interests of the Debtors'1 The Debtors in these Chapter 11 Cases are Intrum AB and Intrum AB of Texas LLC. The Debtors' serviceaddress in these Chapter 11 Cases is 801 Travis Street, STE 2101, #1312, Houston, TX 77002.United States Bankruptcy CourtSouthern District of TexasENTEREDDecember 31, 2024Nathan Ochsner, ClerkCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29662-1 F Filieledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 2 o of f2 32estates; and this Court having found that the Debtors' notice of the Objection and opportunity fora hearing on the Motion to Dismiss and Objection were appropriate and no other notice need beprovided; and this Court having reviewed the Motion to Dismiss and Objection and havingheard the statements in support of the relief requested therein at a hearing before this Court; andthis Court having determined that the legal and factual bases set forth in the Objectionestablish just cause for the relief granted herein; and upon all of the proceedings had beforethis Court; and after due deliberation and sufficient cause appearing therefor, it is HEREBYORDERED THAT:1. The Motion to Dismiss is Denied for the reasons stated at the December 31, 2024 hearing.2. This Court retains exclusive jurisdiction and exclusive venue with respect to allmatters arising from or related to the implementation, interpretation, and enforcement of this Order.DAeucegmubste 0r 23,1 2, 0210294CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29662-1 F Filieledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 2 3 o of f2 3EXHIBIT BCase 24-90575 Document 296-2 Filed in TXSB on 01/13/25 Page 1 of 135IN THE UNITED STATES BANKRUPTCY COURTFOR THE SOUTHERN DISTRICT OF TEXASHOUSTON DIVISION)In re: ) Chapter 11)Intrum AB et al.,1 ) Case No. 24-90575 (CML)))(Jointly Administered)Debtors. ))ORDER (I) APPROVINGDISCLOSURE STATEMENT AND(II) CONFIRMING JOINT PREPACKAGED CHAPTER 11PLAN OF INTRUM AB AND ITS AFFILIATEDDEBTOR (FURTHER TECHNICAL MODIFICATIONS)The above-captioned debtors and debtors in possession (collectively, the“Debtors”), having:a. entered into that certain Lock-Up Agreement, dated as of July 10, 2024 (asamended and restated on August 15, 2024, and as further modified,supplemented, or otherwise amended from time to time in accordance with itsterms, the “the Lock-Up Agreement”) and that certain Backstop Agreement,dated as of July 10, 2024, (as amended and restated on November 15, 2024 andas further modified, supplemented, or otherwise amended from time to time inaccordance with its terms), setting out the terms of the backstop commitmentsprovided by the Backstop Providers to backstop the entirety of the issuance ofNew Money Notes (as may be further amended, restated, amended and restated,modified or supplemented from time to time in accordance with the termsthereof, the “Backstop Agreement”) which set forth the terms of a consensualfinancial restructuring of the Debtors;b. commenced, on October 17, 2024, a prepetition solicitation (the “Solicitation”)of votes on the Joint Prepackaged Chapter 11 Plan of Reorganization of IntrumAB and its Debtor Affiliate Pursuant to Chapter 11 of the Bankruptcy Code (asthe same may be further amended, modified and supplemented from time totime, the “Plan”), by causing the transmittal, through their solicitation andballoting agent, Kroll Restructuring Administration LLC (“Kroll”), to theholders of Claims entitled to vote on the Plan of, among other things: (i) the1 The Debtors in these chapter 11 cases are Intrum AB and Intrum AB of Texas LLC. The Debtors' serviceaddress in these chapter 11 cases is 801 Travis Street, STE 2102, #1312, Houston, TX 77002.United States Bankruptcy CourtSouthern District of TexasENTEREDDecember 31, 2024Nathan Ochsner, ClerkCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Filieledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 2 o of f1 133452Plan, (ii) the Disclosure Statement for Joint Prepackaged Chapter 11 Plan ofReorganization of Intrum AB and its Debtor Affiliate (as the same may befurther amended, modified and supplemented from time to time, the“Disclosure Statement”), and (iii) the Ballots and Master Ballot to vote on thePlan (the “Ballots”), (iv) the Affidavit of Service of Solicitation Materials[Docket No. 7];c. commenced on November 15, 2024 (the “Petition Date”), these chapter 11 cases(these “Chapter 11 Cases”) by filing voluntary petitions in the United StatesBankruptcy Court for the Southern District of Texas (the “Bankruptcy Court”or the “Court”) for relief under chapter 11 of title 11 of the United States Code(the “Bankruptcy Code”);d. Filed on November 15, 2024, the Affidavit of Service of Solicitation Materials[Docket No. 7] (the “Solicitation Affidavit”);e. Filed, on November 16, 2024 the Joint Prepackaged Chapter 11 Plan ofReorganization of Intrum AB and its Debtor Affiliate Pursuant to Chapter 11of the Bankruptcy Code (Technical Modifications) [Docket No. 16] and theDisclosure Statement for Joint Prepackaged Chapter 11 Plan of Intrum AB andits Debtor Affiliate [Docket No. 17];f. Filed on November 16, 2024, the Declaration of Andrés Rubio in Support of ofthe Debtors' Chapter 11 Petitions and First Day Motions [Docket No. 14] (the“First Day Declaration”);g. Filed on November 17, 2024, the Declaration of Alex Orchowski of KrollRestructuring Administration LLC Regarding the Solicitation of Votes andTabulation of Ballots Case on the Joint Prepackaged Chapter 11 Plan ofReorganization of Intrum AB and its Debtor Affiliate Pursuant to Chapter 11of the Bankruptcy Code [Docket No. 18] (the “Voting Declaration,” andtogether with the Plan, the Disclosure Statement, the Ballots, and theSolicitation Affidavit, the “Solicitation Materials”);h. obtained, on November 19, 2024, the Order(I) Scheduling a Combined Hearingon (A) Adequacy of the Disclosure Statement and (B) Confirmation of the Plan,(II) Approving Solicitation Procedures and Form and Manner of Notice ofCommencement, Combined Hearing, and Objection Deadline, (III) FixingDeadline to Object to Disclosure Statement and Plan, (IV) Conditionally (A)Directing the United States Trustee Not to Convene Section 341 Meeting ofCreditors and (B) Waiving Requirement to File Statements of Financial Affairsand Schedules of Assets and Liabilities, and (V) Granting Related Relief[Docket No. 71] (the “Scheduling Order”), which, among other things: (i)approved the prepetition solicitation and voting procedures, including theConfirmation Schedule (as defined therein); (ii) conditionally approved theDisclosure Statement and its use in the Solicitation; and (iii) scheduled theCombined Hearing on December 16, 2024, at 1:00 p.m. (prevailing CentralCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Filieledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 2 3 o of f1 133453Time) to consider the final approval of the Disclosure Statement and theconfirmation of the Plan (the “Combined Hearing”);i. served, through Kroll, on November 20, 2025, on all known holders of Claimsand Interests, the U.S. Trustee and certain other parties in interest, the Noticeof: (I) Commencement of Chapter 11 Bankruptcy Cases; (II) Hearing on theDisclosure Statement and Confirmation of the Plan, and (III) Certain ObjectionDeadlines (the “Combined Hearing Notice”) as evidence by the Affidavit ofService [Docket No. 160];j. caused, on November 25 and 27, 2024, the Combined Hearing Notice to bepublished in the New York Times (national and international editions) and theFinancial Times (international edition), as evidenced by the Certificate ofPublication [Docket No. 148];k. Filed and served, on December 10, 2024, the Plan Supplement for the Debtors'Joint Prepackaged Chapter 11 Plan of Reorganization [Docket 165];l. Filed on December 10, 2024, the Declaration of Jeffrey Kopa in Support ofConfirmation of the Joint Prepackaged Plan of Reorganization of Intrum ABand its Debtor Affiliate Pursuant to Chapter 11 of the Bankruptcy Code [DocketNo. 155];m. Filed on December 14, 2024, the:i. Debtors' Memorandum of Law in Support of an Order: (I) Approving, on aFinal Basis, Adequacy of the Disclosure Statement; (II) Confirming theJoint Prepackaged Plan of Reorganization; and (III) Granting Related Relief[Docket No. 190] (the “Confirmation Brief”);ii. Declaration of Andrés Rubio in Support of Confirmation of the JointPrepackaged Plan of Reorganization of Intrum AB and its Debtor Affiliate.[Docket No. 189] (the “Confirmation Declaration”); andiii. Joint Prepackaged Chapter 11 Plan of Reorganization of Intrum AB and itsDebtor Affiliate Pursuant to Chapter 11 of the Bankruptcy Code (FurtherTechnical Modifications) [Docket No. 191];n. Filed on December 18, 2024, the Joint Prepackaged Chapter 11 Plan ofReorganization of Intrum AB and its Debtor Affiliate Pursuant to Chapter 11of the Bankruptcy Code (Further Technical Modifications) [Docket No. 223];CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Filieledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 3 4 o of f1 133454WHEREAS, the Court having, among other things:a. set December 12, 2024, at 4:00 p.m. (prevailing Central Time) as the deadlinefor Filing objection to the adequacy of the Disclosure Statement and/orConfirmation2 of the Plan (the “Objection Deadline”);b. held, on December 16, 2024 at 1:00 p.m. (prevailing Central Time) [andcontinuing through December 17, 2024], the Combined Hearing;c. heard the statements, arguments, and any objections made at the CombinedHearing;d. reviewed the Disclosure Statement, the Plan, the Ballots, the Plan Supplement,the Confirmation Brief, the Confirmation Declaration, the SolicitationAffidavit, and the Voting Declaration;e. overruled (i) any and all objections to approval of the Disclosure Statement, thePlan, and Confirmation, except as otherwise stated or indicated on the record,and (ii) all statements and reservations of rights not consensually resolved orwithdrawn, unless otherwise indicated; andf. reviewed and taken judicial notice of all the papers and pleadings Filed(including any objections, statement, joinders, reservations of rights and otherresponses), all orders entered, and all evidence proffered or adduced and allarguments made at the hearings held before the Court during the pendency ofthese cases;NOW, THEREFORE, it appearing to the Bankruptcy Court that notice of theCombined Hearing and the opportunity for any party in interest to object to the DisclosureStatement and the Plan having been adequate and appropriate as to all parties affected or to beaffected by the Plan and the transactions contemplated thereby, and the legal and factual bases setforth in the documents Filed in support of approval of the Disclosure Statement and Confirmationand other evidence presented at the Combined Hearing establish just cause for the relief grantedherein; and after due deliberation thereon and good cause appearing therefor, the BankruptcyCourt makes and issues the following findings of fact and conclusions of law, and orders for thereasons stated on the record at the December 31, 2024 ruling on plan confirmation;2 Capitalized terms used but not otherwise defined herein have meanings given to them in the Plan and/or theDisclosure Statement. The rules of interpretation set forth in Article I.B of the Plan apply to this CombinedOrder.CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Filieledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 4 5 o of f1 133455I. FINDINGS OF FACT AND CONCLUSIONS OF LAWIT IS HEREBY FOUND AND DETERMINED THAT:A. Findings of Fact and Conclusions of Law.1. The findings and conclusions set forth herein and in the record of theCombined Hearing constitute the Bankruptcy Court's findings of fact and conclusions of law underRule 52 of the Federal Rules of Civil Procedure, as made applicable herein by Bankruptcy Rules7052 and 9014. To the extent any of the following conclusions of law constitute findings of fact,or vice versa, they are adopted as such.B. Jurisdiction, Venue, Core Proceeding.2. This Court has jurisdiction over these Chapter 11 Cases pursuant to28 U.S.C. § 1334. Venue of these proceedings and the Chapter 11 Cases in this district is properpursuant to 28 U.S.C. §§ 1408 and 1409. This is a core proceeding pursuant to 28 U.S.C.§ 157(b)(2) and this Court may enter a final order hereon under Article III of the United StatesConstitution.C. Eligibility for Relief.3. The Debtors were and continue to be entities eligible for relief under section109 of the Bankruptcy Code and the Debtors were and continue to be proper proponents of thePlan under section 1121(a) of the Bankruptcy Code.D. Commencement and Joint Administration of the Chapter 11 Cases.4. On the Petition Date, the Debtors commenced the Chapter 11 Cases. OnNovember 18, 2024, the Court entered an order [Docket No. 51] authorizing the jointadministration of the Chapter 11 Case in accordance with Bankruptcy Rule 1015(b). The Debtorshave operated their businesses and managed their properties as debtors in possession pursuant toCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Filieledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 5 6 o of f1 133456sections 1107(a) and 1108 of the Bankruptcy Code. No trustee, examiner, or statutory committeehas been appointed in these Chapter 11 Cases.E. Adequacy of the Disclosure Statement.5. The Disclosure Statement and the exhibits contained therein (i) containssufficient information of a kind necessary to satisfy the disclosure requirements of applicablenonbankruptcy laws, rules and regulations, including the Securities Act; and (ii) contains“adequate information” as such term is defined in section 1125(a)(1) and used in section1126(b)(2) of the Bankruptcy Code, with respect to the Debtors, the Plan and the transactionscontemplated therein. The Filing of the Disclosure Statement satisfied Bankruptcy Rule 3016(b).The injunction, release, and exculpation provisions in the Plan and the Disclosure Statementdescribe, in bold font and with specific and conspicuous language, all acts to be enjoined andidentify the Entities that will be subject to the injunction, thereby satisfying Bankruptcy Rule3016(c).F. Solicitation.6. As described in and evidenced by the Voting Declaration, the Solicitationand the transmittal and service of the Solicitation Materials were: (i) timely, adequate, appropriate,and sufficient under the circumstances; and (ii) in compliance with sections 1125(g) and 1126(b)of the Bankruptcy Code, Bankruptcy Rules 3017 and 3018, the applicable Local Bankruptcy Rules,the Scheduling Order and all applicable nonbankruptcy rules, laws, and regulations applicable tothe Solicitation, including the registration requirements under the Securities Act. The SolicitationMaterials, including the Ballots and the Opt Out Form (as defined below), adequately informedthe holders of Claims entitled to vote on the Plan of the procedures and deadline for completingand submitting the Ballots.CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Filieledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 6 7 o of f1 1334577. The Debtors served the Combined Hearing Notice on the entire creditormatrix and served the Opt Out Form on all Non-Voting Classes. The Combined Hearing Noticeadequately informed Holders of Claims or Interests of critical information regarding voting on (ifapplicable) and objecting to the Plan, including deadlines and the inclusion of release, exculpation,and injunction provisions in the Plan, and adequately summarized the terms of the Third-PartyRelease. Further, because the form enabling stakeholders to opt out of the Third-Party Release (the“Opt Out Form”) was included in both the Ballots and the Opt Out Form, every known stakeholder,including unimpaired creditors was provided with the means by which the stakeholders could optout of the Third-Party Release. No further notice is required. The period for voting on the Planprovided a reasonable and sufficient period of time and the manner of such solicitation was anappropriate process allowing for such holders to make an informed decision.G. Tabulation.8. As described in and evidenced by the Voting Declaration, (i) the holders ofClaims in Class 3 (RCF Claims) and Class 5 (Notes Claims) are Impaired under the Plan(collectively, the “Voting Classes”) and have voted to accept the Plan in the numbers and amountsrequired by section 1126 of the Bankruptcy Code, and (ii) no Class that was entitled to vote on thePlan voted to reject the Plan. All procedures used to tabulate the votes on the Plan were in goodfaith, fair, reasonable, and conducted in accordance with the applicable provisions of theBankruptcy Code, the Bankruptcy Rules, the Local Rules, the Disclosure Statement, theScheduling Order, and all other applicable nonbankruptcy laws, rules, and regulations.H. Plan Supplement.9. On December 10, 2024, the Debtors Filed the Plan Supplement with theCourt. The Plan Supplement (including as subsequently modified, supplemented, or otherwiseCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Filieledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 7 8 o of f1 133458amended pursuant to a filing with the Court), complies with the terms of the Plan, and the Debtorsprovided good and proper notice of the filing in accordance with the Bankruptcy Code, theBankruptcy Rules, the Scheduling Order, and the facts and circumstances of the Chapter 11 Cases.All documents included in the Plan Supplement are integral to, part of, and incorporated byreference into the Plan. No other or further notice is or will be required with respect to the PlanSupplement. Subject to the terms of the Plan and the Lock-Up Agreement, and only consistenttherewith, the Debtors reserve the right to alter, amend, update, or modify the Plan Supplementand any of the documents contained therein or related thereto, in accordance with the Plan, on orbefore the Effective Date.I. Modifications to the Plan.10. Pursuant to section 1127 of the Bankruptcy Code, the modifications to thePlan described or set forth in this Combined Order constitute technical or clarifying changes,changes with respect to particular Claims by agreement with holders of such Claims, ormodifications that do not otherwise materially and adversely affect or change the treatment of anyother Claim or Interest under the Plan. These modifications are consistent with the disclosurespreviously made pursuant to the Disclosure Statement and Solicitation Materials, and notice ofthese modifications was adequate and appropriate under the facts and circumstances of the Chapter11 Cases. In accordance with Bankruptcy Rule 3019, these modifications do not require additionaldisclosure under section 1125 of the Bankruptcy Code or the resolicitation of votes under section1126 of the Bankruptcy Code, and they do not require that holders of Claims or Interests beafforded an opportunity to change previously cast acceptances or rejections of the Plan.Accordingly, the Plan is properly before this Court and all votes cast with respect to the Plan priorto such modification shall be binding and shall apply with respect to the Plan.CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Filieledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 8 9 o of f1 133459J. Objections Overruled.11. Any resolution or disposition of objections to Confirmation explained orotherwise ruled upon by the Court on the record at the Confirmation Hearing is herebyincorporated by reference. All unresolved objections, statements, joinders, informal objections,and reservations of rights are hereby overruled on the merits.K. Burden of Proof.12. The Debtors, as proponents of the Plan, have met their burden of provingthe elements of sections 1129(a) and 1129(b) of the Bankruptcy Code by a preponderance of theevidence, the applicable evidentiary standard for Confirmation. Further, the Debtors have proventhe elements of sections 1129(a) and 1129(b) by clear and convincing evidence. Each witness whotestified on behalf of the Debtors in connection with the Confirmation Hearing was credible,reliable, and qualified to testify as to the topics addressed in his testimony.L. Compliance with the Requirements of Section 1129 of the BankruptcyCode.13. The Plan complies with all applicable provisions of section 1129 of theBankruptcy Code as follows:a. Section 1129(a)(1) – Compliance of the Plan with Applicable Provisions of theBankruptcy Code.14. The Plan complies with all applicable provisions of the Bankruptcy Code,including sections 1122 and 1123, as required by section 1129(a)(1) of the Bankruptcy Code.i. Section 1122 and 1123(a)(1) – Proper Classification.15. The classification of Claims and Interests under the Plan is proper under theBankruptcy Code. In accordance with sections 1122(a) and 1123(a)(1) of the Bankruptcy Code,Article III of the Plan provides for the separate classification of Claims and Interests at each Debtorinto Classes, based on differences in the legal nature or priority of such Claims and Interests (otherCaCsaes e2 42-49-09507557 5 D oDcoucmumenetn 2t 9266-32 FFiilleedd iinn TTXXSSBB oonn 1021//3113//2245 PPaaggee 91 0o fo 1f 3143510than Administrative Claims, Professional Fee Claims, and Priority Tax Claims, which areaddressed in Article II of the Plan and Unimpaired, and are not required to be designated asseparate Classes in accordance with section 1123(a)(1) of the Bankruptcy Code). Valid business,factual, and legal reasons exist for the separate classification of the various Classes of Claims andInterests created under the Plan, the classifications were not implemented for any improperpurpose, and the creation of such Classes does not unfairly discriminate between or among holdersof Claims or Interests.16. In accordance with section 1122(a) of the Bankruptcy Code, each Class ofClaims or Interests contains only Claims or Interests substantially similar to the other Claims orInterests within that Class. Accordingly, the Plan satisfies the requirements of sections 1122(a),1122(b), and 1123(a)(1) of the Bankruptcy Codeii. Section 1123(a)(2) – Specifications of Unimpaired Classes.17. Article III of the Plan specifies that Claims and Interests in the classesdeemed to accept the Plan are Unimpaired under the Plan. Holders of Intercompany Claims andIntercompany Interests are either Unimpaired and conclusively presumed to have accepted thePlan, or are Impaired and deemed to reject (the “Deemed Rejecting Classes”) the Plan, and, ineither event, are not entitled to vote to accept or reject the Plan. In addition, Article II of the Planspecifies that Administrative Claims and Priority Tax Claims are Unimpaired, although the Plandoes not classify these Claims. Accordingly, the Plan satisfies the requirements of section1123(a)(2) of the Bankruptcy Code.CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 101 o of f1 1334511iii. Section 1123(a)(3) – Specification of Treatment of Voting Classes18. Article III.B of the Plan specifies the treatment of each Voting Class underthe Plan – namely, Class 3 and Class 5. Accordingly, the Plan satisfies the requirements of section1123(a)(3) of the Bankruptcy Code.iv. Section 1123(a)(4) – No Discrimination.19. Article III of the Plan provides the same treatment to each Claim or Interestin any particular Class, as the case may be, unless the holder of a particular Claim or Interest hasagreed to a less favorable treatment with respect to such Claim or Interest. Accordingly, the Plansatisfies the requirements of section 1123(a)(4) of the Bankruptcy Code.v. Section 1123(a)(5) – Adequate Means for Plan Implementation.20. The Plan and the various documents included in the Plan Supplementprovide adequate and proper means for the Plan's execution and implementation, including: (a)the general settlement of Claims and Interests; (b) the restructuring of the Debtors' balance sheetand other financial transactions provided for by the Plan; (c) the consummation of the transactionscontemplated by the Plan, the Lock-Up Agreement, the Restructuring Implementation Deed andthe Agreed Steps Plan and other documents Filed as part of the Plan Supplement; (d) the issuanceof Exchange Notes, the New Money Notes, and the Noteholder Ordinary Shares pursuant to thePlan; (e) the amendment of the Intercreditor Agreement; (f) the amendment of the FacilityAgreement; (g) the amendment of the Senior Secured Term Loan Agreement; (h) theconsummation of the Rights Offering in accordance with the Plan, Rights Offering Documentsand the Lock-Up Agreement; (i) the granting of all Liens and security interests granted orconfirmed (as applicable) pursuant to, or in connection with, the Facility Agreement, the ExchangeNotes Indenture, the New Money Notes Indenture, the amended Intercreditor Agreement and theCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 112 o of f1 1334512Senior Secured Term Loan Agreement pursuant to the New Security Documents (including anyLiens and security interests granted or confirmed (as applicable) on the Reorganized Debtors'assets); (j) the vesting of the assets of the Debtors' Estates in the Reorganized Debtors; (k) theconsummation of the corporate reorganization contemplated by the Plan, the Lock-Up Agreement,the Agreed Steps Plan and the Master Reorganization Agreement (as defined in the RestructuringImplementation Deed); and (l) the execution, delivery, filing, or recording of all contracts,instruments, releases, and other agreements or documents in furtherance of the Plan. Accordingly,the Plan satisfies the requirements of section 1123(a)(5) of the Bankruptcy Codevi. Section 1123(a)(6) – Non-Voting Equity Securities.21. The Company's organizational documents in accordance with the SwedishCompanies Act, Ch. 4, Sec 5 and the Plan prohibit the issuance of non-voting securities as of theEffective Date to the extent required to comply with section 1123(a)(6) of the Bankruptcy Code.Accordingly, the Plan satisfies the requirements of section 1123(a)(6) of the Bankruptcy Code.vii. Section 1123(a)(7) – Directors, Officers, and Trustees.22. The manner of selection of any officer, director, or trustee (or any successorto and such officer, director, or trustee) of the Reorganized Debtors will be determined inaccordance with the existing organizational documents, which is consistent with the interests ofcreditors and equity holders and with public policy. Accordingly, the Plan satisfies therequirements of section 1123(a)(7) of the Bankruptcy Code.b. Section 1123(b) – Discretionary Contents of the Plan23. The Plan contains various provisions that may be construed as discretionarybut not necessary for Confirmation under the Bankruptcy Code. Any such discretionary provisionCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 123 o of f1 1334513complies with section 1123(b) of the Bankruptcy Code and is not inconsistent with the applicableprovisions of the Bankruptcy Code. Thus, the Plan satisfies section 1123(b).i. Section 1123(b)(1) – Impairment/Unimpairment of Any Class of Claims orInterests24. Article III of the Plan impairs or leaves unimpaired, as the case may be,each Class of Claims or Interests, as contemplated by section 1123(b)(1) of the Bankruptcy Code.ii. Section 1123(b)(2) – Assumption and Rejection of Executory Contracts andUnexpired Leases25. Article V of the Plan provides for the assumption of the Debtors' ExecutoryContracts and Unexpired Leases as of the Effective Date unless such Executory Contract orUnexpired Lease: (a) is identified on the Rejected Executory Contract and Unexpired Lease List;(b) has been previously rejected by a Final Order; (c) is the subject of a motion to reject ExecutoryContracts or Unexpired Leases that is pending on the Confirmation Date; or (4) is subject to amotion to reject an Executory Contract or Unexpired Lease pursuant to which the requestedeffective date of such rejection is after the Effective Date. Thus, the Plan satisfies section1123(b)(2).iii. Compromise and Settlement26. In accordance with section 1123(b)(3)(A) of the Bankruptcy Code andBankruptcy Rule 9019, and in consideration for the distributions and other benefits provided underthe Plan, the provisions of the Plan constitute a good-faith compromise of all Claims, Interests,and controversies relating to the contractual, legal, and subordination rights that all holders ofClaims or Interests may have with respect to any Allowed Claim or Interest or any distribution tobe made on account of such Allowed Claim or Interest. Such compromise and settlement is theproduct of extensive arm's-length, good faith negotiations that, in addition to the Plan, resulted inCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 134 o of f1 1334514the execution of the Lock-Up Agreement, which represents a fair and reasonable compromise ofall Claims, Interests, and controversies and entry into which represented a sound exercise of theDebtors' business judgment. Such compromise and settlement is fair, equitable, and reasonableand in the best interests of the Debtors and their Estates.27. The releases of the Debtors' directors and officers are an integral componentof the settlements and compromises embodied in the Plan. The Debtors' directors and officers: (a)made a substantial and valuable contribution to the Debtors' restructuring, including extensive preandpost-Petition Date negotiations with stakeholder groups, and ensured the uninterruptedoperation of the Debtors' businesses during the Chapter 11 Cases; (b) invested significant timeand effort to make the restructuring a success and maximize the value of the Debtors' businessesin a challenging operating environment; (c) attended and, in certain instances, testified atdepositions and Court hearings; (d) attended and participated in numerous stakeholder meetings,management meetings, and board meetings related to the restructuring; (e) are entitled toindemnification from the Debtors under applicable non-bankruptcy law, organizationaldocuments, and agreements; (f) invested significant time and effort in the preparation of the Lock-Up Agreement, the Plan, Disclosure Statement, all supporting analyses, and the numerous otherpleadings Filed in the Chapter 11 Cases, thereby ensuring the smooth administration of the Chapter11 Cases; and (g) are entitled to all other benefits under any employment contracts existing as ofthe Petition Date. Litigation by the Debtors or other Releasing Parties against the Debtors'directors and officers would be a distraction to the Debtors' business and restructuring and woulddecrease rather than increase the value of the estates. The releases of the Debtors' directors andofficers contained in the Plan have the consent of the Debtors and the Releasing Parties and are inthe best interests of the estates.CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 145 o of f1 1334515iv. Debtor Release28. The releases of claims and Causes of Action by the Debtors, ReorganizedDebtors, and their Estates described in Article VIII.C of the Plan in accordance with section1123(b) of the Bankruptcy Code (the “Debtor Release”) represent a valid exercise of the Debtors'business judgment under Bankruptcy Rule 9019. The Debtors' or the Reorganized Debtors' pursuitof any such claims against the Released Parties is not in the best interests of the Estates' variousconstituencies because the costs involved would outweigh any potential benefit from pursuingsuch claims. The Debtor Release is fair and equitable and complies with the absolute priority rule.29. The Debtor Release is (a) an integral part of the Plan, and a component ofthe comprehensive settlement implemented under the Plan; (b) in exchange for the good andvaluable consideration provided by the Released Parties; (c) a good faith settlement andcompromise of the claims and Causes of Action released by the Debtor Release; (d) materiallybeneficial to, and in the best interests of, the Debtors, their Estates, and their stakeholders, and isimportant to the overall objectives of the Plan to finally resolve certain Claims among or againstcertain parties in interest in the Chapter 11 Cases; (e) fair, equitable, and reasonable; (f) given andmade after due notice and opportunity for hearing; and (g) a bar to any Debtor asserting any claimor Cause of Action released by the Debtor Release against any of the Released Parties. Theprobability of success in litigation with respect to the released claims and Causes of Action, whenweighed against the costs, supports the Debtor Release. With respect to each of these potentialCauses of Action, the parties could assert colorable defenses and the probability of success isuncertain. The Debtors' or the Reorganized Debtors' pursuit of any such claims or Causes ofAction against the Released Parties is not in the best interests of the Estates or the Debtors' variousCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 156 o of f1 1334516constituencies because the costs involved would likely outweigh any potential benefit frompursuing such claims or Causes of Action30. Holders of Claims and Interests entitled to vote have overwhelmingly votedin favor of the Plan, including the Debtor Release. The Plan, including the Debtor Release, wasnegotiated before and after the Petition Date by sophisticated parties represented by able counseland advisors, including the Consenting Creditors. The Debtor Release is therefore the result of ahard fought and arm's-length negotiation process conducted in good faith.31. The Debtor Release appropriately offers protection to parties thatparticipated in the Debtors' restructuring process, including the Consenting Creditors, whoseparticipation in the Chapter 11 Cases is critical to the Debtors' successful emergence frombankruptcy. Specifically, the Released Parties, including the Consenting Creditors, madesignificant concessions and contributions to the Chapter 11 Cases, including, entering into theLock-Up Agreement and related agreements, supporting the Plan and the Chapter 11 Cases, andwaiving or agreeing to impair substantial rights and Claims against the Debtors under the Plan (aspart of the compromises composing the settlement underlying the revised Plan) in order tofacilitate a consensual reorganization and the Debtors' emergence from chapter 11. The DebtorRelease for the Debtors' directors and officers is appropriate because the Debtors' directors andofficers share an identity of interest with the Debtors and, as previously stated, supported and madesubstantial contributions to the success of the Plan, the Chapter 11 Cases, and operation of theDebtors' business during the Chapter 11 Cases, actively participated in meetings, negotiations, andimplementation during the Chapter 11 Cases, and have provided other valuable consideration tothe Debtors to facilitate the Debtors' successful reorganization and continued operation.CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 167 o of f1 133451732. The scope of the Debtor Release is appropriately tailored under the factsand circumstances of the Chapter 11 Cases. In light of, among other things, the value provided bythe Released Parties to the Debtors' Estates and the critical nature of the Debtor Release to thePlan, the Debtor Release is appropriate.v. Release by Holders of Claims and Interests33. The release by the Releasing Parties (the “Third-Party Release”), set forthin Article VIII.D of the Plan, is an essential provision of the Plan. The Third-Party Release is: (a)consensual as to those Releasing Parties that did not specifically and timely object or properly optout from the Third-Party Release; (b) within the jurisdiction of the Bankruptcy Court pursuant to28 U.S.C. § 1334; (c) in exchange for the good and valuable consideration provided by theReleased Parties; (d) a good faith settlement and compromise of the claims and Causes of Actionreleased by the Third-Party Release; (e) materially beneficial to, and in the best interests of, theDebtors, their Estates, and their stakeholders, and is important to the overall objectives of the Planto finally resolve certain Claims among or against certain parties in interest in the Chapter 11Cases; (f) fair, equitable, and reasonable; (g) given and made after due notice and opportunity forhearing; (h) appropriately narrow in scope given that it expressly excludes, among other things,any Cause of Action that is judicially determined by a Final Order to have constituted actual fraud,willful misconduct, or gross negligence; (i) a bar to any of the Releasing Parties asserting anyclaim or Cause of Action released by the Third-Party Release against any of the Released Parties;and (j) consistent with sections 105, 524, 1123, 1129, and 1141 and other applicable provisions ofthe Bankruptcy Code.34. The Third-Party Release is an integral part of the agreement embodied inthe Plan among the relevant parties in interest. Like the Debtor Release, the Third-Party ReleaseCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 178 o of f1 1334518facilitated participation in both the Debtors' Plan and the chapter 11 process generally. The Third-Party Release is instrumental to the Plan and was critical in incentivizing parties to support thePlan and preventing significant and time-consuming litigation regarding the parties' respectiverights and interests. The Third-Party Release was a core negotiation point in connection with thePlan and instrumental in developing the Plan that maximized value for all of the Debtors'stakeholders and kept the Debtors intact as a going concern. As such, the Third-Party Releaseappropriately offers certain protections to parties who constructively participated in the Debtors'restructuring process—including the Consenting Creditors (as set forth above)—by, among otherthings, facilitating the negotiation and consummation of the Plan, supporting the Plan and, in thecase of the Backstop Providers, committing to provide new capital to facilitate the Debtors'emergence from chapter 11. Specifically, the Notes Ad Hoc Group proposed and negotiated thepari passu transaction that is the basis of the restructuring proposed under the Plan and provideda much-needed deleveraging to the Debtors' business while taking a discount on their Claims (inexchange for other consideration).35. Furthermore, the Third-Party Release is consensual as to all parties ininterest, including all Releasing Parties, and such parties in interest were provided notice of thechapter 11 proceedings, the Plan, the deadline to object to confirmation of the Plan, and theCombined Hearing and were properly informed that all holders of Claims against or Interests inthe Debtors that did not file an objection with the Court in the Chapter 11 Cases that included anexpress objection to the inclusion of such holder as a Releasing Party under the provisionscontained in Article VIII of the Plan would be deemed to have expressly, unconditionally,generally, individually, and collectively consented to the release and discharge of all claims andCauses of Action against the Debtors and the Released Parties. Additionally, the release provisionsCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 189 o of f1 1334519of the Plan were conspicuous, emphasized with boldface type in the Plan, the DisclosureStatement, the Ballots, and the applicable notices. Except as set forth in the Plan, all ReleasingParties were properly informed that unless they (a) checked the “opt out” box on the applicableBallot or opt-out form and returned the same in advance of the Voting Deadline, as applicable, or(b) timely Filed an objection to the releases contained in the Plan that was not resolved beforeentry of this Confirmation Order, they would be deemed to have expressly consented to the releaseof all Claims and Causes of Action against the Released Parties.36. The Ballots sent to all holders of Claims and Interests entitled to vote, aswell as the notice of the Combined Hearing sent to all known parties in interest (including thosenot entitled to vote on the Plan), unambiguously provided in bold letters that the Third-PartyRelease was contained in the Plan.37. The scope of the Third-Party Release is appropriately tailored under thefacts and circumstances of the Chapter 11 Cases, and parties in interest received due and adequatenotice of the Third-Party Release. Among other things, the Plan provides appropriate and specificdisclosure with respect to the claims and Causes of Action that are subject to the Third-PartyRelease, and no other disclosure is necessary. The Debtors, as evidenced by the VotingDeclaration and Certificate of Publication, including by providing actual notice to all knownparties in interest, including all known holders of Claims against, and Interests in, any Debtor andpublishing notice in international and national publications for the benefit of unknown parties ininterest, provided sufficient notice of the Third-Party Release, and no further or other notice isnecessary. The Third-Party Release is designed to provide finality for the Debtors, theReorganized Debtors and the Released Parties regarding the parties' respective obligations underthe Plan. For the avoidance of doubt, and notwithstanding anything to the contrary, anyparty who timely opted-out of the Third-Party Release is not bound by the Third-PartyRelease.CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 1 290 o of f1 133452038. The Third-Party Release is specific in language, integral to the Plan, andgiven for substantial consideration. The Releasing Parties were given due and adequate notice ofthe Third-Party Release, and thus the Third-Party Release is consensual under controllingprecedent as to those Releasing Parties that did not specifically and timely object. In light of,among other things, the value provided by the Released Parties to the Debtors' Estates and theconsensual and critical nature of the Third-Party Release to the Plan, the Third-Party Release isappropriatevi. Exculpation.39. The exculpation described in Article VIII.E of the Plan (the “Exculpation”)is appropriate under applicable law, including In re Highland Capital Mgmt., L.P., 48 F. 4th 419(5th Cir. 2022), because it was supported by proper evidence, proposed in good faith, wasformulated following extensive good-faith, arm's-length negotiations with key constituents, and isappropriately limited in scope.40. No Entity or Person may commence or continue any action, employ anyprocess, or take any other act to pursue, collect, recover or offset any Claim, Interest, debt,obligation, or Cause of Action relating or reasonably likely to relate to any act or commission inconnection with, relating to, or arising out of a Covered Matter (including one that alleges theactual fraud, gross negligence, or willful misconduct of a Covered Entity), unless expresslyauthorized by the Bankruptcy Court after (1) it determines, after a notice and a hearing, such Claim,Interest, debt, obligation, or Cause of Action is colorable and (2) it specifically authorizes suchEntity or Person to bring such Claim or Cause of Action. The Bankruptcy Court shall have soleand exclusive jurisdiction to determine whether any such Claim, Interest, debt, obligation or Causeof Action is colorable and, only to the extent legally permissible and as provided for in Article XI,CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 2 201 o of f1 1334521shall have jurisdiction to adjudicate such underlying colorable Claim, Interest, debt, obligation, orCause of Action.vii. Injunction.41. The injunction provisions set forth in Article VIII.F of the Plan are essentialto the Plan and are necessary to implement the Plan and to preserve and enforce the discharge,Debtor Release, the Third-Party Release, and the Exculpation provisions in Article VIII of thePlan. The injunction provisions are appropriately tailored to achieve those purposes.viii. Preservation of Claims and Causes of Action.42. Article IV.L of the Plan appropriately provides for the preservation by theDebtors of certain Causes of Action in accordance with section 1123(b) of the Bankruptcy Code.Causes of Action not released by the Debtors or exculpated under the Plan will be retained by theReorganized Debtors as provided by the Plan. The Plan is sufficiently specific with respect to theCauses of Action to be retained by the Debtors, and the Plan and Plan Supplement providemeaningful disclosure with respect to the potential Causes of Action that the Debtors may retain,and all parties in interest received adequate notice with respect to such retained Causes of Action.The provisions regarding Causes of Action in the Plan are appropriate and in the best interests ofthe Debtors, their respective Estates, and holders of Claims or Interests. For the avoidance of anydoubt, Causes of Action released or exculpated under the Plan will not be retained by theReorganized Debtors.c. Section 1123(d) – Cure of Defaults43. Article V.D of the Plan provides for the satisfaction of Cure Claimsassociated with each Executory Contract and Unexpired Lease to be assumed in accordance withsection 365(b)(1) of the Bankruptcy Code. Any monetary defaults under each assumed ExecutoryCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 2 212 o of f1 1334522Contract or Unexpired Lease shall be satisfied, pursuant to section 365(b)(1) of the BankruptcyCode, by payment of the default amount in Cash on the Effective Date, subject to the limitationsdescribed in Article V.D of the Plan, or on such other terms as the parties to such ExecutoryContracts or Unexpired Leases may otherwise agree. Any Disputed Cure Amounts will bedetermined in accordance with the procedures set forth in Article V.D of the Plan, and applicablebankruptcy and nonbankruptcy law. As such, the Plan provides that the Debtors will Cure, orprovide adequate assurance that the Debtors will promptly Cure, defaults with respect to assumedExecutory Contracts and Unexpired Leases in accordance with section 365(b)(1) of theBankruptcy Code. Thus, the Plan complies with section 1123(d) of the Bankruptcy Code.d. Section 1129(a)(2) – Compliance of the Debtors and Others with the ApplicableProvisions of the Bankruptcy Code.44. The Debtors, as proponents of the Plan, have complied with all applicableprovisions of the Bankruptcy Code as required by section 1129(a)(2) of the Bankruptcy Code,including sections 1122, 1123, 1124, 1125, 1126, and 1128, and Bankruptcy Rules 3017, 3018,and 3019.e. Section 1129(a)(3) – Proposal of Plan in Good Faith.45. The Debtors have proposed the Plan in good faith, in accordance with theBankruptcy Code requirements, and not by any means forbidden by law. In determining that thePlan has been proposed in good faith, the Court has examined the totality of the circumstancesfiling of the Chapter 11 Cases, including the formation of Intrum AB of Texas LLC (“IntrumTexas”), the Plan itself, and the process leading to its formulation. The Debtors' good faith isevident from the facts and record of the Chapter 11 Cases, the Disclosure Statement, and the recordof the Combined Hearing and other proceedings held in the Chapter 11 CasesCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 2 223 o of f1 133452346. The Plan (including the Plan Supplement and all other documents necessaryto effectuate the Plan) is the product of good faith, arm's-length negotiations by and among theDebtors, the Debtors' directors and officers and the Debtors' key stakeholders, including theConsenting Creditors and each of their respective professionals. The Plan itself and the processleading to its formulation provide independent evidence of the Debtors' and such other parties'good faith, serve the public interest, and assure fair treatment of holders of Claims or Interests.Consistent with the overriding purpose of chapter 11, the Debtors Filed the Chapter 11 Cases withthe belief that the Debtors were in need of reorganization and the Plan was negotiated and proposedwith the intention of accomplishing a successful reorganization and maximizing stakeholder value,and for no ulterior purpose. Accordingly, the requirements of section 1129(a)(3) of the BankruptcyCode are satisfied.f. Section 1129(a)(4) – Court Approval of Certain Payments as Reasonable.47. Any payment made or to be made by the Debtors, or by a person issuingsecurities or acquiring property under the Plan, for services or costs and expenses in connectionwith the Chapter 11 Cases, or in connection with the Plan and incident to the Chapter 11 Cases,has been approved by, or is subject to the approval of, the Court as reasonable. Accordingly, thePlan satisfies the requirements of section 1129(a)(4).g. Section 1129(a)(5)—Disclosure of Directors and Officers and Consistency with theInterests of Creditors and Public Policy.48. The identities of or process for appointment of the Reorganized Debtors'directors and officers proposed to serve after the Effective Date were disclosed in the PlanSupplement in advance of the Combined Hearing. Accordingly, the Debtors have satisfied therequirements of section 1129(a)(5) of the Bankruptcy Code.CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 2 234 o of f1 1334524h. Section 1129(a)(6)—Rate Changes.49. The Plan does not contain any rate changes subject to the jurisdiction of anygovernmental regulatory commission and therefore will not require governmental regulatoryapproval. Therefore, section 1129(a)(6) of the Bankruptcy Code does not apply to the Plan.i. Section 1129(a)(7)—Best Interests of Holders of Claims and Interests.50. The liquidation analysis attached as Exhibit D to the Disclosure Statementand the other evidence in support of the Plan that was proffered or adduced at the CombinedHearing, and the facts and circumstances of the Chapter 11 Cases are (a) reasonable, persuasive,credible, and accurate as of the dates such analysis or evidence was prepared, presented orproffered; (b) utilize reasonable and appropriate methodologies and assumptions; (c) have not beencontroverted by other evidence; and (d) establish that each holder of Allowed Claims or Interestsin each Class will recover as much or more value under the Plan on account of such Claim orInterest, as of the Effective Date, than the amount such holder would receive if the Debtors wereliquidated on the Effective Date under chapter 7 of the Bankruptcy Code or has accepted the Plan.As a result, the Debtors have demonstrated that the Plan is in the best interests of their creditorsand equity holders and the requirements of section 1129(a)(7) of the Bankruptcy Code are satisfied.j. Section 1129(a)(8)—Conclusive Presumption of Acceptance by UnimpairedClasses; Acceptance of the Plan by Certain Voting Classes.51. The classes deemed to accept the Plan are Unimpaired under the Plan andare deemed to have accepted the Plan pursuant to section 1126(f) of the Bankruptcy Code. EachVoting Class voted to accept the Plan. For the avoidance of doubt, however, even if section1129(a)(8) has not been satisfied with respect to all of the Debtors, the Plan is confirmable becausethe Plan does not discriminate unfairly and is fair and equitable with respect to the Voting Classesand thus satisfies section 1129(b) of the Bankruptcy Code with respect to such Classes as describedCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 2 245 o of f1 1334525further below. As a result, the requirements of section 1129(b) of the Bankruptcy Code are alsosatisfied.k. Section 1129(a)(9)—Treatment of Claims Entitled to Priority Pursuant to Section507(a) of the Bankruptcy Code.52. The treatment of Administrative Claims, Professional Fee Claims, andPriority Tax Claims under Article II of the Plan satisfies the requirements of, and complies in allrespects with, section 1129(a)(9) of the Bankruptcy Code.l. Section 1129(a)(10)—Acceptance by at Least One Voting Class.53. As set forth in the Voting Declaration, all Voting Classes overwhelminglyvoted to accept the Plan. As such, there is at least one Voting Class that has accepted the Plan,determined without including any acceptance of the Plan by any insider (as defined by theBankruptcy Code), for each Debtor. Accordingly, the requirements of section 1129(a)(10) of theBankruptcy Code are satisfied.m. Section 1129(a)(11)—Feasibility of the Plan.54. The Plan satisfies section 1129(a)(11) of the Bankruptcy Code. Thefinancial projections attached to the Disclosure Statement as Exhibit D and the other evidencesupporting the Plan proffered or adduced by the Debtors at or before the Combined Hearing: (a)is reasonable, persuasive, credible, and accurate as of the dates such evidence was prepared,presented, or proffered; (b) utilize reasonable and appropriate methodologies and assumptions; (c)has not been controverted by other persuasive evidence; (d) establishes that the Plan is feasibleand Confirmation of the Plan is not likely to be followed by liquidation or the need for furtherfinancial reorganization; (e) establishes that the Debtors will have sufficient funds available tomeet their obligations under the Plan and in the ordinary course of business—including sufficientamounts of Cash to reasonably ensure payment of Allowed Claims that will receive CashCCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 2 256 o of f1 1334526distributions pursuant to the terms of the Plan and other Cash payments required under the Plan;and (f) establishes that the Debtors or the Reorganized Debtors, as applicable, will have thefinancial wherewithal to pay any Claims that accrue, become payable, or are allowed by FinalOrder following the Effective Date. Accordingly, the Plan satisfies the requirements of section1129(a)(11) of the Bankruptcy Code.n. Section 1129(a)(12)—Payment of Statutory Fees.55. Article XII.C of the Plan provides that all fees payable pursuant to section1930(a) of the Judicial Code, as determined by the Court at the Confirmation Hearing inaccordance with section 1128 of the Bankruptcy Code, will be paid by each of the applicableReorganized Debtors for each quarter (including any fraction of a quarter) until the Chapter 11Cases are converted, dismissed, or closed, whichever occurs first. Accordingly, the Plan satisfiesthe requirements of section 1129(a)(12) of the Bankruptcy Code.o. Section 1129(a)(13)—Retiree Benefits.56. Pursuant to section 1129(a)(13) of the Bankruptcy Code, and as provided inArticle IV.K of the Plan, the Reorganized Debtors will continue to pay all obligations on accountof retiree benefits (as such term is used in section 1114 of the Bankruptcy Code) on and after theEffective Date in accordance with applicable law. As a result, the requirements of section1129(a)(13) of the Bankruptcy Code are satisfied.p. Sections 1129(a)(14), (15), and (16)—Domestic Support Obligations, Individuals,and Nonprofit Corporations.57. The Debtors do not owe any domestic support obligations, are notindividuals, and are not nonprofit corporations. Therefore, sections 1129(a)(14), 1129(a)(15), and1129(a)(16) of the Bankruptcy Code do not apply to the Chapter 11 Cases.CCaassee 2 244-9-900557755 D Dooccuummeennt t2 29663-2 F Fileiledd i nin T TXXSSBB o onn 1 021/3/113/2/245 P Paaggee 2 267 o of f1 1334527q. Section 1129(b)—Confirmation of the Plan Over Nonacceptance of VotingClasses.58. No Classes rejected the Plan, and section 1129(b) is not applicable here,but even if it were, the Plan may be confirmed pursuant to section 1129(b)(1) of the BankruptcyCode because the Plan is fair and equitable with respect to the Deemed Rejecting Classes. ThePlan has been proposed in good faith, is reasonable, and meets the requirements and all VotingClasses have voted to accept the Plan. The treatment of Intercompany Claims and IntercompanyInterests under the Plan provides for administrative convenience does not constitute a distributionunder the Plan on account of suc

We reviewed Department of Commerce's hiring policies and procedures to determine if they were adequate for staff overseeing financial matters. This was because Commerce hired a staff member in 2020 who pleaded guilty to felonies in Pennsylvania before being hired by Commerce. Commerce officials told us they were not aware of the staff member's crimnal history. We found that Commerce's hiring policies and procedures were not adequate to mitigate the risks associated with hiring applicants with a criminal history. This is because Commerce's hiring policies and procedures don't include any type of criminal history check for any jobs other than the 1 in statute. Commerce officials told us they don't perform state-level criminal history checks on applicants because they don't think they have the authority to perform them through the KBI. However, an alternative to KBI would be to use a Consumer Reporting Agency to perform criminal history checks. These companies may provide employment screening services that include credit checks, license verification, and criminal history information from state and federal databases. We also found that Commerce didn't adequately document their hiring procedures for 3 of the 5 staff we reviewed. reference check summaries weren't available for 3 of the 5 employees we reviewed, and interview notes were missing for 1 of the 5 employees we reviewed. This means we can't determine if Commerce is following their processes consistently. State retention policies require agencies to retain hiring documentation in the full personnel file for the length of the employee's tenure plus 3 years. However, Commerce officials told us that they don't retain some hiring records past 3 years from the date of hire.

One in four (25pc) Irish adults have less than €500 set aside for a rainy day, with almost half of these (9pc) reporting that they have no financial cushion at all. Most people (65pc) have a financial cushion of less than €5,000, while more than half (53pc) have less than €3,000. This is according to the findings of a new survey by Capital Credit Union of more than 3,700 adults, which also revealed that almost half (45pc) of Irish people are saving more regularly than they have in the past and that one in four (24pc) are saving less frequently. Headline findings from the Capital Credit Union survey reveal that: Two in ten (20pc) have an emergency fund of €10,000 or more. More than three in ten people in their 30s have less than €500 of an emergency fund set aside. More than one in ten people aged between 30 and 60 do not have any financial cushion at all. Those in their 70s are the least likely (5pc) to be in this position. Men are more inclined than women to have a large financial cushion in the wings: one in ten (10pc) men have an emergency fund of more than €30,000 but just 6pc of women would have this amount set aside. Furthermore, men are almost twice as likely as women to have a financial cushion of €50,000 or more (5.25pc versus 2.9pc). Table 1: How much money do you have set aside in case of a financial emergency How much money do you have set aside in case of a financial emergency - i.e., emergency savings, excluding savings for home or retirement? Nothing 9% 0 - €100 6% €100 - €500 10% €500 - €1000 11% €1000 - €3000 17% €3000 - €5000 11% €5000 - €10000 15% €10,000- €30000 13% €30000 - €50000 3% €50000+ 4% Figures are rounded off to the nearest zero Commenting on the survey findings, Pat Byrne, Chief Executive Officer at Capital Credit Union said: "It's always important to set aside some savings to tide you over at times of emergency, unforeseen problems - or when income is unexpectedly low. No matter how smooth life is or how financially comfortable you are, life is unpredictable, and things can take a turn for the worse when we least expect it. Having an emergency fund in the wings can be invaluable when the unexpected - such as the loss of a job, someone being unwell, or a car accident - happens. It is a concern that our research shows that one in four Irish adults have less than €500 set aside for a rainy day. This would be unlikely to even last a week if a person lost their job. The majority of Irish adults were found to have a financial cushion of €5,000 but even this might not be enough when a financial emergency hits, particularly if unable to work for a prolonged time - given the high bills which so many families have today. Building up an emergency fund where possible is a core tenet of effective money management. Adequacy is key. Some financial advisers recommend building up a fund equivalent to about three months' of your salary; others advise setting aside a year's salary." Other headline findings from the Capital Credit Union survey include: Two-thirds (66pc) of those in their 20s are saving more regularly now than was the case in the past - making this age group the most likely one to be saving more. By comparison, less than half (46pc) of those aged 30, 40 and 50 say they are saving more regularly now. Of those who have savings, almost three in four (74pc) are likely to be earning little or no interest on it as their money is kept in a readily accessible account. More than half (56pc) of people keep their savings in a readily accessible account so that they can take money out whenever they need to while about one in five (18pc) say they keep all savings in a readily accessible account because they wouldn't know what else to do with the money. Mr Byrne added: "One in four Irish people are saving less regularly than they have in recent years. This tallies with a recent report from the CSO, which found that the amount saved by Irish households has fallen, with households saving about an eighth (12.7pc)...

Back to basics with food after an eating disorder with Dietitian Shane Jeffery, using the five step RAVES model for a positive food relationshipHave you ever thought how complicated eating is these days? We live in a world where we're bombarded with diet culture content and body image ideals – where food is staged with lights and filters and thousands of pretty, perfect plates are just a phone swipe away.In this episode our guest, Accredited Practicing Dietitian Shane Jeffrey from River Oak Health, wants us to pare it all back saying a positive, intuitive relationship with food is within reach for us all, particularly those with eating disorders. Shane's tips on how to start eating again after an eating disorder come down to an easy five step acronym: RAVES.He's spent the last few decades developing the internationally acclaimed RAVES model, which combines science with personal values to reset relationships with food.RAVES stands for Regularity, Adequacy, Variety, Eating Socially and Spontaneity If you are wondering about how to encourage eating again after a loved one has been diagnosed with an eating disorder or improving their relationship with food then listen to this episode! Some of Shane's RAVES tips include:· eating like a 2 year old by bringing back intuitive eating· stoking the energy campfire with regular meals by time not just appetite· and agreeing there should be no good or bad or healthy or unhealthy food – there's just food.If you want to hear more conversations like this one – become an EDFA member so you can access other exclusive content - and follow the Strong Enough podcast so you won't miss an episode.You can find a download of the RAVES model cheat sheet here on the Eating Disorders Families Australia website.If you'd like more information from Shane on RAVES read his blog HERE.#positiverelationshipwithfood#edfa #eatingdisordersfamiliesaustralia#carersupportforeatingdisorders#edfawebinars#RAVES#eatingdisorders#eatingdisorderrecovery#edhelp#eatingdisorderhelp Hosted on Acast. See acast.com/privacy for more information.

It may be too harsh to suggest that the crew of the ship had delusions of adequacy. But they certainly did have to face challenges for which they were ill prepared. I say that because Luke makes two statements in this account that show how bad the situation really was. He says, "we," twice. "We," Luke writes, "gave way to [the strong wind] and were driven along." Then, "we managed with difficulty to secure the ship's boat." It seems Luke was pressed into service in the face of the terrifying storm.

On this episode of Managed Care Cast, we're talking with Simon F. Haeder, PhD, MPA, associate professor of public health at Texas A&M University. His study, "When is a Network Adequate? Consumer Perspectives on Network Adequacy Definitions," explored the factors that consumers consider essential for an adequate provider network, including travel times, inclusive care, and language access.

Tune in to the latest Celtic Down Under podcast On this episode of The Pot Noodle, we discuss the following: * Celtic 3 Sevco 0 In The Glasgow Derby * Our New Signings * Laugh At The Zombie Meltdown * And More Please subscribe to our YouTube channel & our podcast via your favourite podcast app Buy our Merch - T-Shirts & Hoodies available at www.celticdownunder.com Tickets to the upcoming Australia & New Zealand Tour by Gary Og are available via the following Troubadour Presents website - https://troubadourpresents.com/events/gary-og/ Hail Hail Learn more about your ad choices. Visit podcastchoices.com/adchoices

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The excellent Nathan Long of Hargreaves Lansdown talks through with me the Government's pension review, retirement adequacy and its complexities, financial resilience and the work they've done tracking it and we finish with a look ahead to the Budget on 30th October.  HL Savings and Resilience Barometer | July 2024 | HL

Research and Policy Analysts Michelle Murphy and Susanne Rogers chat through the key social welfare asks in Budget Choices 2025. 

Conleigh, Farhad, Ahlmahz, and Paul debrief on coverage of FERC Order 1920 then discuss resource adequacy, hedging tail risk, and preview business capability models.Ahlmahz Negash, Conleigh Byers, and Farhad Billimoria scan news stories after FERC's release of Order 1920, then Conleigh Byers explains Resource adequacy, and Farhad Billimoria explains Hedging & Tail Risk in Electricity Markets.You can find the podcast on Apple Podcast, Spotify, or wherever you get your podcasts. Share with friends that are energy enthusiasts, like us!03:17 - Short-to-Ground (FERC Order 1920 Edition)On May 13th the Federal Energy Regulatory Commission approved a sweeping long-term transmission planning and cost-allocation rule aimed at modernizing the gridIn the Special Transmission Reform Meeting, Chair Willie Phillips said the U.S. faces "an unprecedented surge in demand for affordable electricity while confronting extreme weather threats to the reliability of our grid and trying to stay one step ahead of the massive technological changes we are seeing in our society."FERC is helping to pave the way for a much-needed investment in our transmission infrastructureThe Federal Energy Regulatory Commission's fact sheet for Order 1920 states that the grid rule contains five major elements:Requirement to conduct and periodically update long-term transmission planning to anticipate future needs.Requirement to consider a broad set of benefits when planning new facilities.Requirement to identify opportunities to modify in-kind replacement of existing transmission facilities to increase their transfer capability, known as “right-sizing.”Customers pay only for projects from which they benefit.Expands states' pivotal role throughout the process of planning, selecting, and determining how to pay for transmission facilities.“Landmark transmission reform could dramatically speed US energy transition”Large Public Power Council's president, John Di Stasio's, written statementAmericans for a Clean Energy Grid's Executive Director, Christina Hayes, applauded FERC for finalizing a, quote, “strong and comprehensive regional planning and cost allocation rule.”Spot market power in the U.S.Wholesale spot prices for the National Electricity Market (NEM)Energy Information Administration's Natural Gas Weekly Update41:03 - Hedging and Tail Risk in Electricity Markets By: Farhad Billimoria , Jacob Mays , Rahmat PoudinehAbstract: A concern persistent in scarcity-based market designs for electricity over many years has been the illiquidity of markets for long-term contracts to hedge away volatile price exposures between generators and consumers. These missing markets have been attributed to a range of factors including retailer creditworthiness, market structure and the lack of demand side interest from consumers. Using a stochastic equilibrium model and insights from insurance theory, we demonstrate the inherent challenges of hedging a legacy thermal portfolio that is dominated by volatile fat-tailed commodities with significant tail dependence. Under such conditions the price required for generators to provide such hedges can be multiples of the expected value of prices. Our key insight is that when the real-world constraints of credit and financing are considered, the volatility of thermal fuels and their co-dependence under extremes may be a key reason as to why electricity markets have been incomplete in terms of long-term hedging contracts. Counterintuitively, in the context of the energy transition, our results show that, ceteris paribus, increasing the penetration of low carbon resources like wind, solar and energy storage, can add tail-diversity and improve contractability.22:16 - The Future of Resource Adequacy in a Decarbonized Grid w/ Conleigh ByersConleigh Byers Resource Adequacy Harvard Energy Policy Seminar 25 4.93MB ∙ PDF file DownloadDownload1:02:23 - Institutions in the electric sector are evolving like the eras of Taylor Swift, but are their business models evolving with them?Public Power Underground, for electric utility enthusiasts! Public Power Underground, it's work to watch!

"Embracing Diversity: The Adequacy and Importance of Cultural Competency Education in Medical School and Residency" by Edward Pingenot, DO, Iyabo O. Muse, MD, FASA, and Renuka George, MD, FASA. From ASRA Pain Medicine News, May 2024. See original article at www.asra.com/may24news for figures and references. This material is copyrighted. Support the Show.

Stothard Deal, vice president of strategic planning for TransUnion's insurance business, discusses the findings of a recent report showing personal lines trends and that the financial picture for insurers is improving.

“There are 18 common types of background checks employers use to verify a new hire. The checks can include: Criminal history Past employment verification Education verification Reference check Drug screening Sexual offenses check Credit background check Social media behavior check Driving record Professional license and certifications check Social security number trace/identity check Global sanctions check Civil offenses check Bankruptcy check Financial regulations check Psychometric tests International background check Gamer profile check Each check is briefly explained along with its purpose and how it helps employers make informed hiring decisions.[1] A background check is a process a person or company uses to verify that an individual is who they claim to be, and this provides an opportunity to check and confirm the validity of someone's criminal record, education, employment history, and other activities from their past. The frequency, purpose, and legitimacy of background checks vary among countries, industries, and individuals. An employment background check typically takes place when someone applies for a job, but it can also happen at any time the employer deems necessary. A variety of methods are used to complete these checks including comprehensive database search and personal references. Regulation edit [18] The Financial Services Authority states in their Training & Competence guidance that regulated firms should have: Adequacy of procedures for taking into account knowledge and skills of potential recruits for the role Adequacy of procedures for obtaining sufficient information about previous activities and training Adequacy of procedures for ensuring that individuals have passed appropriate exams or have appropriate exemptions Adequacy of procedures for assessing competence of individuals for sales roles The Financial Services Authority's statutory objectives: Protecting consumers Maintaining market confidence Promoting public awareness Reducing financial crime. Restriction and laws on Background Check Arrest and conviction records: Title VII of the Civil Rights Act of 1964; Cal. Lab. Code § 432.7; Cal. Lab. Code § 432.8; Cal. Pen. Code § 290.46(k)(2); 775 ILCS 5/2-103; Job Opportunities for Qualified Applicants Act, 820 ILCS 75/15; N.Y. Correct. Law § 752; N.Y. Exec. Law § 296 (15), (16); 18 Pa.C.S. § 9125 Credit/financial checks: Consumer Credit Reporting Agencies Act, Cal. Civ. Code § 1785.13; Cal. Lab. Code § 1024.5; 820 ILCS 70/10 Health checks/medical screening: Americans with Disabilities Act, 42 U.S.C. § 12101, et seq.; Genetic Information Nondiscrimination Act, 42 U.S.C. § 2000ff, et seq.; Cal. Lab. Code § 132a Social media: Cal. Lab. Code § 980; 820 ILCS 55/10(a) Record disposal: 16 CFR Part 682 Record keeping: 29 CFR Part 160 Records/information obtained from consumer reporting agencies, including but not limited to education and employment records, credit and financial records, and social media: Fair Credit Reporting Act, 15 U.S.C. § 1681, et seq.; Consumer Credit Reporting Agencies Act, Cal. Civ. Code § 1785.13(a)(6); Investigative Consumer Reporting Agencies Act, Cal. Civ. Code § 1786.18(a)(7); Cal. Civ. Code § 1786.53 Political affiliation: D.C. Code § 2–1402.11; Wis. Stat. Ann. § 111.321 Polygraph tests: Employee Polygraph Protection Act, 29 U.S.C. §§ 2002, 2006; Cal. Lab. Code § 432.2; 225 ILCS 430/14.1; N.Y. Lab. Law §§ 733–739; 18 Pa.C.S. § 7321. Many employers choose to search the most common records such as criminal records, driving records, and education verification. Other searches such as sex offender registry, credential verification, skills assessment, reference checks, credit reports and Patriot Act searches are becoming increasingly common.[22] Many commercial sites will offer specific searches to employers for a fee. Services like these will actually perform the checks, supply the company with adverse action letters, and ensure compliance throughout the process.” -Wikipedia. --- Support this podcast: https://podcasters.spotify.com/pod/show/antonio-myers4/support

Stefanie Wilder-Taylor is an author, standup comedian, TV personality, writing teacher, and co-host of the popular podcasts For Crying Out Loud, Rose Pricks, and Bored A.F. She created and hosted two seasons of the late-night comedy parenting show Parental Discretion with Stefanie Wilder-Taylor for NickMom on Nickelodeon. Stefanie has written six books for Simon & Schuster, starting with the irreverent best-seller Sippy Cups Are Not for Chardonnay: And Other Things I Had to Learn as a New Mom. She followed up with Naptime Is the New Happy Hour: And Other Ways Toddlers Turn Your Life Upside; It's Not Me, It's You: Subjective Recollections of a Terminally Optimistic, Chronically Sarcastic and Occasionally Inebriated Woman;  I'm a Big Deal: And Other Delusions of Adequacy; Gummi Bears Should Not Be Organic: And Other Opinions I Can't Back Up with Fact, and her most recent, Drunk-ish: A Memoir of Loving and Leaving Alcohol, set for release in January 2024.Stefanie has made appearances on several popular TV shows, such as Oprah, GMA, 20/20, Dr. Oz, Dr. Phil, Larry King Live, Fox and Friends, HLN, CNN, Dr. Drew, and Katie Couric. She has also been featured in The New York Times, People Magazine, US Weekly, and Parenting Magazine. Although she is busy, she manages to make time for everything. Stefanie resides in Los Angeles with her husband and three children. Additionally, she has a penchant for Botox, which is quite expensive. Become a member at https://plus.acast.com/s/unimpressedpodcast. https://plus.acast.com/s/unimpressedpodcast. Hosted on Acast. See acast.com/privacy for more information.

On this week of Serious Privacy, Paul Breitbarth of Catawiki and Dr. K Royal of Crawford & Company kick off Season 5 with a Bang! As usual, we launch the new season on Data Privacy - Data Protection Day and what a year we've had so far! If you have comments or questions, find us on LinkedIn, Twitter @podcastprivacy @euroPaulB @heartofprivacy and email podcast@seriousprivacy.eu. Rate and Review us! Proudly sponsored by TrustArc. Learn more about the TRUSTe Data Privacy Framework verification. upcoming webinars.#heartofprivacy #europaulb #seriousprivacy #privacy #dataprotection #cybersecuritylaw #CPO #DPO #CISO

Dr. Gillett and Nurse Practitioner James O'Hara delve into a conversation addressing the potential risks associated with omega-3 fatty acids. 00:00 Introduction00:12 Emerging Risks Associated with Omega Fatty Acids5:41 Synthesizing Insights from Four Significant Randomized Trials16:00 Insights from Animal and Canine Studies18:51 Examination of a DHA-Specific Trial20:13 Addressing the Adequacy of a 500mg EPA Dosage22:39 Exploring the Field of Nutrigenomics24:57 Findings from a Cod Liver Oil Study25:53 Investigating Blood Viscosity Concerns27:13 Focusing on DHA Exclusive Trials30:10 Unraveling the Link between Omega Fatty Acids and Gum Recession30:43 Contrasting DHA versus EPA31:41 Impact of Oxidized Fish Oil37:54 Closing Thoughts and OutroStudies/References ► https://www.jacc.org/doi/epdf/10.1016/j.jacc.2023.05.024► https://www.ahajournals.org/doi/10.1161/CIRCULATIONAHA.120.052209► https://jamanetwork.com/journals/jama/fullarticle/2773120► https://pubmed.ncbi.nlm.nih.gov/30415628/► https://www.nejm.org/doi/pdf/10.1056/NEJMoa1811403?articleTools=true► https://www.acc.org/clinical-topics/arrhythmias-and-clinical-ep/~/media/67142EC297834666B0CF741690027D9D.pdf► https://www.ahajournals.org/doi/pdf/10.1161/CIRCULATIONAHA.107.712984► https://www.jstage.jst.go.jp/article/circj/86/5/86_CJ-21-0615/_pdf► https://www.ahajournals.org/doi/pdf/10.1161/CIRCEP.112.971515► https://pubmed.ncbi.nlm.nih.gov/2694923/► https://pubmed.ncbi.nlm.nih.gov/18779276/► https://pubmed.ncbi.nlm.nih.gov/17490962/► https://pubmed.ncbi.nlm.nih.gov/2685599► https://pubmed.ncbi.nlm.nih.gov/12145002/► https://pubmed.ncbi.nlm.nih.gov/18555744/► https://pubmed.ncbi.nlm.nih.gov/24970858/► https://pubmed.ncbi.nlm.nih.gov/29846653/► https://www.deepdyve.com/lp/wiley/effect-of-packaging-and-encapsulation-on-the-oxidative-and-sensory-ElE1I6yjXd?key=dd_plugin&utm_campaign=pluginGoogleScholar&utm_source=pluginGoogleScholar&utm_medium=plugin► https://doi.org/10.1080/19390211.2023.2252064For High-quality labs:► https://gilletthealth.com/order-lab-panels/For information on the Gillett Health clinic, lab panels, and health coaching:► https://GillettHealth.comFollow Gillett Health for more content from James and Kyle► https://instagram.com/gilletthealth► https://www.tiktok.com/@gilletthealth► https://twitter.com/gilletthealth► https://www.facebook.com/gilletthealthFollow Kyle Gillett, MD► https://instagram.com/kylegillettmdFollow James O'Hara, NP► https://Instagram.com/jamesoharanpFor 10% off Gorilla Mind products including SIGMA: Use code “GH10”► https://gorillamind.com/For discounts on high-quality supplements►https://www.thorne.com/u/GillettHealth#podcast #omega #omega3 #cells #health #gilletthealthAdvertising Inquiries: https://redcircle.com/brandsPrivacy & Opt-Out: https://redcircle.com/privacy

Episode #288. Discover the truth about the canola oil debate with Dr Gil Carvalho. A respected physician and research scientist, Dr Carvalho unpacks the complexities of canola oil's role in our health. With no ties to industry, his unbiased perspective sheds light on how canola oil affects our bodies, its comparison to other oils, and the science behind the headlines. Tune in for a candid conversation that promises to enhance your understanding help you make informed dietary decisions. Specifically, we discuss: Introduction (00:00) What Inspired the Canola Oil Video (01:58) Defining Canola Oil: Origins and Composition (06:35) The Most Common Claims About Canola Oil (12:13) Research Methodology in Canola Oil Investigation (17:45) The Significance of Human Data in Canola Oil Research (22:48) Understanding Meta-analysis Studies and Epidemiological Approaches (26:37) Assessing the Adequacy of Canola Oil Research (42:07) Canola Oil's Impact on Blood Lipids and Cardiovascular Health (46:20) Canola Oil vs. Nuts and Seeds for Weight Loss (50:36) Canola Oil Consumption and the Risk of Heart Attack/Stroke (56:48) Canola Oil and Blood Glucose Control (1:00:57) Canola Oil's Influence on Body Weight (1:04:29) Is Canola Oil Inflammatory? (1:08:54) Examining the "Wash-IN-DIET Canola Oil" Study by Junker R and Kratz M (1:11:24) Lipid Peroxidation: Canola Oil Oxidation (1:14:44) Research on Liver Fat and Canola Oil (1:21:50) Linoleic Acid Consumption and Total Mortality (1:23:10) Reception of the Canola Oil Video within the NutritionMadeSimple Community (1:25:59) Addressing Common Questions About Canola Oil (1:33:02) Assessing Research Funding from the Canola Industry (1:37:19) Making the Case for Canola Oil Toxicity (1:40:19) Is Canola Oil Classified as an Ultra-Processed Food? (1:42:48) Future Studies Required for a Comprehensive Understanding of Canola Oil and Human Health (1:46:50) Conclusion (1:48:07) You can learn more about Dr Gil Carvalho here, and connect with him on Twitter/X and Facebook. For straightforward, science-based nutrition information, visit his YouTube channel Nutrition Made Simple. You can also access his research publications for more. Optimise your health with InsideTracker's biomarker analysis. Get exclusive access to InsideTracker's new ApoB test and a 20% discount on your first order at insidetracker.com/simon. Enjoy, friends. Simon Want to support the show? The best way to support the show is to use the products and services offered by our sponsors. To check them out, and enjoy great savings, visit theproof.com/friends. You can also show your support by leaving a review on the Apple Podcast app and/or sharing your favourite episodes with your friends and family. Simon Hill, MSc, BSc (Hons) Creator of theproof.com and host of The Proof with Simon Hill Author of The Proof is in the Plants Watch the episodes on YouTube or listen on Apple/Spotify Connect with me on Instagram, Twitter, and Facebook Nourish your gut with my Plant-Based Ferments Guide Download my complimentary Two-Week Meal Plan and high protein Plant Performance recipe book

With increasing costs of living and an unpredictable economic environment, the concept of paying a “living wage” is gaining attention from businesses and governments around the world. As pay adequacy becomes a mandated disclosure for many companies via the European Union's Corporate Sustainability Reporting Directive (CSRD), paying a living wage is becoming a growing priority for organizations that are focused on creating a sustainable business.PwC recently published the inaugural Global Living Wage survey to provide deeper insights on this topic and its impact to businesses. In this episode, host Heather Horn welcomes PwC partners Barry Murphy and Paula Letorey to discuss the survey results, market trends, and key steps organizations should take now to prepare for market and regulatory movement.In this episode, you'll hear discussion of:4:43 - Why PwC conducted the Global Living Wage survey7:13 - Defining a “living wage”9:45 - Key findings from the survey17:01 - Common challenges to adopting a living wage22:28 - The relationships among living wage, workplace fairness, and pay equity24:58 - Reporting and disclosure considerations28:47 - The impact of suppliers and the value chain31:19 - What investors are looking for in living wage strategy and disclosures36:35 - The role of the finance team in supporting and engaging with the business on this topicFor our findings and takeaways on the survey, check out our publication, Living Wage: An Emerging Standard. Further, check out PwC UK's Workforce Hopes and Fears Survey for more insights on workforce transformation, trends, and disruptors, and how business leaders are navigating its changing nature.Barry Murphy is PwC's Global ESG leader for Tax and Legal Services. Based in the UK, he has 20 years of experience advising clients on their domestic and international tax affairs. He is also focused on driving compliance solutions with a “digital first” approach. Paula Letorey is a partner within PwC UK's Workforce practice. She has over 15 years of experience advising clients on matters relating to employment taxes and broader pay governance and regulation. She has developed robust risk management solutions for areas such as domestic employment tax on a global basis, off-payroll working, national minimum wage, and holiday pay.Heather Horn is PwC's National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC's accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather's accounting and auditing expertise includes financial instruments and rate-regulated accounting.Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com.

The landscape of the U.S. competitive wholesale electricity markets can be intricate, especially as rising consumer demand makes meeting resource adequacy, clean energy, and affordability goals even more challenging. Keeping focus on these goals requires constant attention and leadership, and the Electric Power Supply Association (EPSA) is one of the key organizations advocating for competitive power suppliers while pushing towards a reliable, innovative, and sustainable future for the power sector. To share the inside scoop on EPSA's process, this week's guest to the Energy Central Power Perspective Podcast is the organization's President and CEO, Todd Snitchler. Listen in as Todd identifies the complexities of the energy sector that drive the need for EPSA and how the organization coordinates and advocates for market solutions and collaboration towards critical stability and progress. In this episode, Todd shares with podcast host Jason Price and producer Matt Chester unparalleled insights on the trajector of the power industry, EPSA's focus in the coming years, and how the industry as a whole must constantly be shifting to attain balance between supply, demand, and market dynamics. Key Links: Energy Central Post with Full Episode Transcript: https://energycentral.com/o/energy-central/episode-145-advocacy-energy-and-ensuring-resource-adequacy-wholesale-electricity Did you know? The Energy Central Power Perspectives Podcast has been identified as one of the industry's 'Top 25 Energy Podcasts': blog.feedspot.com/energy_podcasts/

Energy is more than just power, it's prosperity. It's been proven around the world that countries that have adequate electricity prosper. Countries that have an abundance of power sources prosper even more.  But energy today is fighting a battle for […] The post Power Adequacy For Our Energy Future first appeared on Voices of Montana.

Theme of this week's readings: The Adequacy of Our Christ Within

Ever feel unqualified to do what God has called you to do? Pastor Jeremiah teaches from 2 Corinthians that if we are trying qualify ourselves through the law, we will never be good enough. However, when we surrender to Jesus, we are enough through Christ

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3.1 Definition and Importance of Consideration. Consideration is a fundamental concept in contract law that involves the exchange of something of value between the parties as a prerequisite for a valid contract. Law students should delve into the characteristics and importance of consideration: a) Bargained-for Exchange: Consideration requires a mutual exchange where each party gives something of value in return for the promise or performance of the other party. b) Legal Sufficiency: The consideration exchanged must have legal value, which can include money, goods, services, a promise to perform, or a promise to refrain from doing something. c) Adequacy of Consideration: Courts generally do not inquire into the adequacy of consideration, meaning that the value exchanged does not need to be equivalent. However, grossly inadequate consideration or instances of fraud could be relevant. 3.2 Exceptions: Promissory Estoppel. Promissory estoppel is a doctrine that allows a promise to be enforced even if there is no valid consideration. Law students should understand the elements of promissory estoppel and its application: a) Clear and Definite Promise: The promise made by one party must be clear, definite, and reasonably relied upon by the other party. b) Reliance: The promisee must have reasonably relied on the promise to their detriment. c) Injustice: Enforcing the promise is necessary to prevent injustice or unconscionable behavior. 3.3 Landmark Case: Ricketts v. Scothorn (1898). The case of Ricketts v. Scothorn provides an illustration of the principle of promissory estoppel. In this case, a grandfather promised his granddaughter a sum of money. The granddaughter relied on this promise to her detriment by quitting her job and making arrangements based on the expected funds. When the grandfather later refused to fulfill his promise, the court held that promissory estoppel applied, and the granddaughter was entitled to the promised sum due to her reasonable reliance. 3.4 Conclusion. A solid grasp of consideration and its role in contract law is essential for law students. By understanding the concept of bargained-for exchange, legal sufficiency, and the exceptions such as promissory estoppel, students can navigate the complexities of contract formation and identify situations where valid consideration may not be present, yet a promise can still be enforced. --- Send in a voice message: https://podcasters.spotify.com/pod/show/law-school/message Support this podcast: https://podcasters.spotify.com/pod/show/law-school/support

In this episode of Serious Privacy, Paul Breitbarth of Catawiki and Dr. K Royal share a healthy serving of privacy popcorn featuring India's new law, Georgia's new law, Meta news, Argentina and Kenya and Worldcoin, China, NIST Cybersecurity Framework call for comments, and more, including California's adequacy decision from the Dubai International Financial Center. If you have comments or questions, find us on LinkedIn, Twitter @podcastprivacy @euroPaulB @heartofprivacy and email podcast@seriousprivacy.eu. Rate and Review us! Proudly sponsored by TrustArc. Learn more about the TRUSTe Data Privacy Framework verification. upcoming webinars.#heartofprivacy #europaulb #seriousprivacy #privacy #dataprotection #cybersecuritylaw #CPO #DPO #CISO

This episode of the EPRI Current Podcast dives into the crucial and timely topic of Resource Adequacy, exploring the process of ensuring that energy systems have enough capacity to meet customer demands. Joining host Bill Florence are EPRI's Senior Engineer, Irene Danti Lopez, and Techinical Leader, Genevieve de Mijolla to discuss EPRI's multi-year initiative and research program to focus on the issue of Resource Adequacy. This conversation also looks at the changing resource mix, including renewables, and the effects of climate change, as well as examines how Resource Adequacy modeling can accurately model extreme weather events and climate change.  Learn more at https://www.epri.com/    If you enjoy this podcast, please subscribe and share! And please consider leaving a review and rating on Apple Podcasts/iTunes.    Links and Resources:  Resource Adequacy Philosophy: A Guide to Resource Adequacy Concepts and Approaches: https://www.epri.com/research/products/000000003002024368  Representing the Demand Side in Resource Adequacy: https://www.esig.energy/representing-the-demand-side-in-resource-adequacy/  Redefining Resource Adequacy for Modern Power Systems: https://www.esig.energy/resource-adequacy-for-modern-power-systems/   Follow EPRI: LinkedIn https://www.linkedin.com/company/epri/  Twitter https://twitter.com/EPRINews      EPRI Current examines key issues and new R&D impacting the energy transition. Each episode features insights from EPRI, the world's preeminent independent, non-profit energy research and development organization, and from other energy industry leaders. We also discuss how innovative technologies are shaping the global energy future. Learn more at www.epri.com 

Welcome to The Nonlinear Library, where we use Text-to-Speech software to convert the best writing from the Rationalist and EA communities into audio. This is: Meta-level adversarial evaluation of oversight techniques might allow robust measurement of their adequacy, published by Buck Shlegeris on July 26, 2023 on The AI Alignment Forum. Summary: Many proposed AGI alignment procedures involve taking a pretrained model and training it using rewards from an oversight process to get a policy. These procedures might fail when the oversight procedure is locally inadequate: that is, if the model is able to trick the oversight process into giving good rewards for bad actions. In this post, we propose evaluating the local adequacy of oversight by constructing adversarial policies for oversight processes. Specifically, we propose constructing behaviors that a particular oversight process evaluates favorably but that we know to be bad via other means, such as additional held-out information or more expensive oversight processes. We think that this form of adversarial evaluation is a crucial part of ensuring that oversight processes are robust enough to oversee dangerously powerful models. Introduction A core element of many scenarios where AI ends up disempowering humanity (e.g. "Without specific countermeasures") are oversight failures: that is, failures resulting from working with a really powerful model without being able to tell if its actions are resulting in good or bad outcomes. For example, suppose we're using a model to help us write code for the datacenter on which we run our powerful models. This model may be able to insert subtle security vulnerabilities that we are unable to detect. This inability to distinguish whether actions have good outcomes might cause our model to be misaligned when we train on our erroneous rewards, and it might also bottleneck various techniques for preventing models from taking bad actions. Before we put a model to use in a specific situation, we really want to be sure that the oversight process we're using to train it can tell whether a model is taking actions that are bad on average. We will call an oversight process "locally adequate" for a specific model and deployment setting if, for actions taken by that model in that setting, the process is able to identify when an action would have harmful consequences (in cases where the model knows). In this piece, we'll describe a way to determine whether an oversight process is locally adequate. We'll do this by training the model to perform actions that both: could be very bad if they were done in production don't look bad to the oversight process. This is an example of what we'll call "meta-level adversarial evaluation": rather than finding inputs that make a model fail, we're finding models that make an oversight process fail. Previous discussions of adversarial evaluation in AI alignment have mostly been about object-level adversarial evaluation (though the Superalignment blog post mentioned meta-level adversarial evaluations). For instance, continuing with the example of the model writing code that might have subtle security vulnerability, we could train a variant of our model to insert security flaws into the software it's writing that lead to a particular visible outcome (e.g. deleting a file on a server that the model wasn't supposed to have access to), without the oversight process realizing that the software is flawed. In other cases, we can evaluate the local adequacy of oversight in a specific situation by switching to another equally challenging situation where we have access to some held-out information which we can use to evaluate whether a model's output was in fact bad even though the oversight process judged it as good. We argue that it is likely that when working with dangerously powerful models, we'll be able to run these evaluations to get a confident sense of whether oversight processes are locally adequate for a particular mod...

Welcome to The Nonlinear Library, where we use Text-to-Speech software to convert the best writing from the Rationalist and EA communities into audio. This is: Meta-level adversarial evaluation of oversight techniques might allow robust measurement of their adequacy, published by Buck on July 26, 2023 on LessWrong. Summary: Many proposed AGI alignment procedures involve taking a pretrained model and training it using rewards from an oversight process to get a policy. These procedures might fail when the oversight procedure is locally inadequate: that is, if the model is able to trick the oversight process into giving good rewards for bad actions. In this post, we propose evaluating the local adequacy of oversight by constructing adversarial policies for oversight processes. Specifically, we propose constructing behaviors that a particular oversight process evaluates favorably but that we know to be bad via other means, such as additional held-out information or more expensive oversight processes. We think that this form of adversarial evaluation is a crucial part of ensuring that oversight processes are robust enough to oversee dangerously powerful models. Introduction A core element of many scenarios where AI ends up disempowering humanity (e.g. "Without specific countermeasures") are oversight failures: that is, failures resulting from working with a really powerful model without being able to tell if its actions are resulting in good or bad outcomes. For example, suppose we're using a model to help us write code for the datacenter on which we run our powerful models. This model may be able to insert subtle security vulnerabilities that we are unable to detect. This inability to distinguish whether actions have good outcomes might cause our model to be misaligned when we train on our erroneous rewards, and it might also bottleneck various techniques for preventing models from taking bad actions. Before we put a model to use in a specific situation, we really want to be sure that the oversight process we're using to train it can tell whether a model is taking actions that are bad on average. We will call an oversight process "locally adequate" for a specific model and deployment setting if, for actions taken by that model in that setting, the process is able to identify when an action would have harmful consequences (in cases where the model knows). In this piece, we'll describe a way to determine whether an oversight process is locally adequate. We'll do this by training the model to perform actions that both: could be very bad if they were done in production don't look bad to the oversight process. This is an example of what we'll call "meta-level adversarial evaluation": rather than finding inputs that make a model fail, we're finding models that make an oversight process fail. Previous discussions of adversarial evaluation in AI alignment have mostly been about object-level adversarial evaluation (though the Superalignment blog post mentioned meta-level adversarial evaluations). For instance, continuing with the example of the model writing code that might have subtle security vulnerability, we could train a variant of our model to insert security flaws into the software it's writing that lead to a particular visible outcome (e.g. deleting a file on a server that the model wasn't supposed to have access to), without the oversight process realizing that the software is flawed. In other cases, we can evaluate the local adequacy of oversight in a specific situation by switching to another equally challenging situation where we have access to some held-out information which we can use to evaluate whether a model's output was in fact bad even though the oversight process judged it as good. We argue that it is likely that when working with dangerously powerful models, we'll be able to run these evaluations to get a confident sense of whether oversight processes are locally adequate for a particular model and deployment envir...

While Dr. K Royal is traveling, Paul Breitbarth of Catawiki turns our attention to the Middle East for this episode of Serious Privacy. He speaks with Lori Baker, the Vice President Legal & Director of Data Protection for the DIFC Commissioner's Office. The DIFC - the Dubai International Financial Center - has a special status in the United Arab Emirates and therefore also their own data protection law, going back to 2004. Paul and Lori talk about data protection in the Emirates, how the legislation compares to other laws we know such as the GDPR, and international data flows to and from the DIFC.Resources:The website of the DIFC and the overview of adequacy decisionsThe books discussed:What We May Become by Teresa MessineoThe Fire by Night by Teresa MessineoThe Second Sleep by Robert Harris  As always, if you have comments or questions, find us on LinkedIn, Twitter @podcastprivacy @euroPaulB @heartofprivacy and email podcast@seriousprivacy.eu. Rate and Review us! #heartofprivacy #seriousprivacy #privacy #dataprotection #cybersecuritylaw #CPO #DPO

Drs Madhukar H. Trivedi and Christoph U. Correll discuss the predictors of suicidal ideation, attempt, and death as well as how to address the topic of suicidality with patients and their loved ones. Relevant disclosures can be found with the episode show notes on Medscape (https://www.medscape.com/viewarticle/984464). The topics and discussions are planned, produced, and reviewed independently of advertisers. This podcast is intended only for US healthcare professionals. Resources Depression https://emedicine.medscape.com/article/286759-overview Prevalence of Suicidality in Major Depressive Disorder: A Systematic Review and Meta-Analysis of Comparative Studies https://pubmed.ncbi.nlm.nih.gov/34603096/ Twelve-Month Prevalence of and Risk Factors for Suicide Attempts in the World Health Organization World Mental Health Surveys https://pubmed.ncbi.nlm.nih.gov/20816034/ Persistent Depressive Disorder https://www.ncbi.nlm.nih.gov/books/NBK541052/ Risk and Protective Factors for Suicide and Suicidal Behavior https://www.div12.org/wp-content/uploads/2012/10/Suicide-Risk-Factors-with-Graphics-Div12.pdf Prevention of Suicide by Clozapine in Mental Disorders: Systematic Review https://pubmed.ncbi.nlm.nih.gov/36640481/ Lithium Suicide Prevention: A Brief Review and Reminder https://pubmed.ncbi.nlm.nih.gov/30834169/ Trauma-Focused Psychotherapies for Post-Traumatic Stress Disorder: A Systematic Review and Network Meta-analysis https://pubmed.ncbi.nlm.nih.gov/34473342/ Intranasal Esketamine and Current Suicidal Ideation With Intent in Major Depression Disorder: Beat the Clock, Save a Life, Start a Strategy https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7203410/ Dextromethorphan/Bupropion (Rx) https://reference.medscape.com/drug/auvelity-dextromethorphan-bupropion-4000211 Status Update on the Sheehan-Suicidality Tracking Scale (S-STS) 2014 https://pubmed.ncbi.nlm.nih.gov/25520892/ Psychometric Properties of the Beck Depression Inventory-II: A Comprehensive Review https://pubmed.ncbi.nlm.nih.gov/24402217/ The 9-Item Concise Health Risk Tracking – Self-Report (CHRT-SR9) Measure of Suicidal Risk: Performance in Adult Primary Care Patients https://pubmed.ncbi.nlm.nih.gov/36865066/ Maximizing the Adequacy of Medication Treatment in Controlled Trials and Clinical Practice: STAR(*)D Measurement-Based Care https://pubmed.ncbi.nlm.nih.gov/17406651/ Psychometrics of the Self-Report Concise Associated Symptoms Tracking Scale (CAST-SR): Results From the STRIDE (CTN-0037) Study https://pubmed.ncbi.nlm.nih.gov/29325238/ Mechanisms of Action and Clinical Efficacy of NMDA Receptor Modulators in Mood Disorders https://pubmed.ncbi.nlm.nih.gov/28711661/ Psychoplastogens: A Promising Class of Plasticity-Promoting Neurotherapeutics https://pubmed.ncbi.nlm.nih.gov/30262987/ Zuranolone in Major Depressive Disorder: Results From MOUNTAIN-A Phase 3, Multicenter, Double-Blind, Randomized, Placebo-Controlled Trial https://pubmed.ncbi.nlm.nih.gov/36811520/ GABA Receptor Positive Allosteric Modulators https://www.ncbi.nlm.nih.gov/books/NBK554443/# Conjoint Therapy https://dictionary.apa.org/conjoint-therapy

Full article: https://www.ajronline.org/doi/full/10.2214/AJR.22.28745  Artificial intelligence tools are already used in the practice of radiology, but there are questions about their accuracy and generalizability. Juliet Alla, MD discusses a study examining the technical adequacy of several body composition AI tools when applied to a set of heterogenous sample of outside imaging studies. Special guest Dr. Tara Retson, with multiple publications on algorithm development and the role of AI in radiology, joins us to discuss the implications for clinical practice.

Resource adequacy, innovation and making sure employees are equipped with the training and technological skills to best meet the needs of customers are key areas of focus for Colorado Springs Utilities and Travas Deal, who was sworn in as CEO of the public power utility in February.

In this episode of Serious Privacy, Paul Breitbarth of Catawiki and Dr. K Royal of Crawford & Company talk with dr. Laura Drechsler, Research Fellow at the Centre for IT and IP Law (CITIP) at the Catholic University of Louvain, Belgium. They discuss Laura's work on cross-border data transfers, comparing the decisions of the European courts and the guidance of the data protection authorities with the adequacy decisions that have been published by the European Commission. It is clear there is still a lot to learn from the past on how to do adequacy and other data transfers right.As always, if you have comments or questions, let us know - LinkedIn, Twitter @podcastprivacy @euroPaulB @heartofprivacy @trustArc and email podcast@seriousprivacy.eu. Please do like and write comments on your favorite podcast app so other professionals can find us easier. The Leadercast PodcastThe fun way to grow you and your top talent.Listen on: Apple Podcasts Spotify As always, if you have comments or questions, find us on LinkedIn, Twitter @podcastprivacy @euroPaulB @heartofprivacy and email podcast@seriousprivacy.eu. Rate and Review us! #heartofprivacy #seriousprivacy #privacy #dataprotection #cybersecuritylaw #CPO #DPO

Will India's Data Protection Bill Lead to EU Adequacy for India? Well, that is tough to say. But Supratim shares that it will open pathways for data exchange with many countries as data protection standards shall have similarities. Take a listen to the preview conversation between Supratim Chakraborty and Punit Bhatia now. The full episodes come up next week. RESOURCES Websites www.fit4privacy.com , www.punitbhatia.com Podcast https://www.fit4privacy.com/podcast Blog https://www.fit4privacy.com/blog YouTube http://youtube.com/fit4privacy Take a look at our 12-step GDPR Compliance checklist. --- Send in a voice message: https://podcasters.spotify.com/pod/show/fit4privacy/message

In this episode of Serious Privacy, Paul Breitbarth of Catawiki and Dr. K Royal of Outschool bring you a recap of a very busy week in privacy. Earlier this week, we released a special episode on the UK data protection and digital information bill. But today you get the episode we actually intended for you this week, a regular weekend privacy episode, including information on the #Thingy, cookie banners, BCRs, and more.Resources discussed: IAPP state privacy law trackingHusch Blackwell state privacy law trackerTexas federal decision abortion fundsTexas lawsuit by five women being denied abortionsTexas bill on preventing abortion sites (and the actual bill)As always, if you have comments or questions, let us know - LinkedIn, Twitter @podcastprivacy @euroPaulB @heartofprivacy @trustArc and email podcast@seriousprivacy.eu. Please do like and write comments on your favorite podcast app so other professionals can find us easier. The Annual TrustArc Global Privacy Benchmarks survey is open until March 31st, and we want to hear from you. How is the industry shifting, and what trends do you foresee? This doesn't assess individual or company privacy competency. Rather, it allows you to shape the future of privacy protection initiatives. Please, share your views on how enterprise's manage data protection and privacy. As always, if you have comments or questions, find us on LinkedIn, Twitter @podcastprivacy @euroPaulB @heartofprivacy and email podcast@seriousprivacy.eu. Rate and Review us! #heartofprivacy #seriousprivacy #privacy #dataprotection #cybersecuritylaw #CPO #DPO

Jacob Mays, PhD, Matt Schroettnig, Ahlmahz Negash, PhD, and Paul Dockery discuss a paper Prof. Mays co-authored on contractual form in electricity reliability obligations, how it applies to the program getting developed in the Northwest, and what perspective he has on electric market development in the Northwest.06:52 - discuss recently published article by Professor Mays and Han Shu Shu, Han, and Jacob Mays. "Beyond capacity: contractual form in electricity reliability obligations." arXiv preprint arXiv:2210.10858 (2022). episode from the last time Prof. Mays was on Public Power Underground 23:54 - applying Prof. Mays insights to the Western Power Pool's Western Resource Adequacy Program47:27 - thoughts on the NYT article on electric utility deregulation Why are Energy Prices so High? Some Experts Blame Deregulation by Ivan Penn twitter thread by @MichaelGiberso3 in response to the article substack post on  Knowledge Problem by Lynn Kiesling RTO Insider article in response to the NY Times piece Ari Pesckoe twitter thread in response to the article 54:56 - New Segment!: Ahlmahz's Insightful Question of the Week!1:01:43 - Short to Ground; where we TL;DR our way through the rest of the news NWPCC: NW Needs More Reserves to Maintain Resource Adequacy Pause in Storms Allows Utilities, State Responders Valuable Time to Regroup Washington State Report: Salmon Remain ‘In Crisis' IOUs Report Significant Demand Reduction With Time-of-Use Rates With EVs PG&E, Energy Vault Seek OK for Biggest U.S. Long-Duration Storage System Eugene Board Votes to Develop Decommissioning Plan Goforth, T., Nock, D. Air pollution disparities and equality assessments of US national decarbonization strategies. Nat Commun 13, 7488 (2022). https://doi.org/10.1038/s41467-022-35098-4 Texas PUC nears market redesign decision amid criticism performance credit will not spur new generation Rachel Dibble has been named the vice president of bulk marketing at the Bonneville Power Administration Spot Market Power La Nina NOAA Climate Forecasts WY2023 Water Supply Forecast 1:11:53 - we talk a lot more about Texas's controversial Performance Credit MechanismYou can find the podcast on Apple Podcast, Spotify, or wherever you get your podcasts. Remember to share this with any friends you have that are electric utility enthusiasts like us!Public Power Underground, for electric utility enthusiasts! Public Power Underground, where you're valued and appreciated.

CHEST January 2023, Volume 163, Issue 1 Kazuhiro Yasufuku, MD, joins CHEST Podcast Moderator, Dominique Pepper MD, to discuss whether a biomarker-based approach to EBUS-TBNA sample assessment could provide a simple alternative to ROSE. DOI: https://doi.org/10.1016/j.chest.2022.07.003

On 13 December 2022, the European Commission published the long-awaited draft adequacy decision for the EU-U.S. Data Privacy Framework, among podcast listeners also known as the Thingy. In this episode of Serious Privacy, Paul Breitbarth of Catawiki and Dr. K Royal of Outschool talk about the adequacy decision, and what they consider is missing from it. Resources:Draft Adequacy DecisionIAPP Privacy Shield - DPF comparisonODNI Redress ProcessExecutive Order 14086OECD Policy Framework on Digital Security As always, if you have comments or questions, let us know - LinkedIn, Twitter @podcastprivacy @euroPaulB @heartofprivacy @trustArc and email seriousprivacy@trustarc.com. Please do like and write comments on your favorite podcast act so other professionals can find us easier. 

On this episode of Serious Privacy, Paul Breitbarth of Catawiki and Dr. K Royal of Outschool discuss the 10-7 series of deliberately machinated and long-awaited political events surrounding the EU-US data transfer mechanism that is intended to replace the Privacy Shield, invalidated under Schrems II back in 2020 - the “thingie.” Plus, the UK-US joint statement on adequacy consideration. These various events comprise the Executive Order (the Fact sheet along with the information on the European Commission site), the Department of Commerce statement, the Department of Justice from the Office of the Attorney General on the Data Protection review Board final rule, and the NOYB's response. As expected, and TrustArc predicted, those companies who remained in the Privacy Shield will have a transition plan. For additional information, please also see various analyses from the IAPP and the Future of Privacy Forum.  Carry the conversation further and connect with us to discuss.As always, if you have comments or questions, let us know - LinkedIn, Twitter @podcastprivacy @euroPaulB @heartofprivacy @trustArc and email seriousprivacy@trustarc.com. Please do like and write comments on your favorite podcast act so other professionals can find us easier. 

Ahoy! and welcome to another episode of CISO Tradecraft -- the podcast that provides you with the information, knowledge, and wisdom to be a more effective cyber security leader.  My name is G. Mark Hardy, and today we're going to -- talk like a pirate.  ARRR As always, please follow us on LinkedIn, and make sure you subscribe so you can always get the latest updates. On today's episode we are going to talk about the 9 Cs of Cyber Security.  Note these are not the 9 Seas that you might find today, the 19th of September, which happens to be the 20th annual International Talk like a Pirate Day.  They are the nine words that begin with the letter C (but not the letter ARRR): Controls, Compliance, Continuity, Coverage, Complexity, Competency, Communication, Convenience, Consistency. Please note that this talk is inspired by an article by Mark Wojtasiak from Vectra, but we have modified the content to be more aligned with our thoughts at CISO Tradecraft. Now before we go into the 9 Cs, it's important to understand that the 9 Cs represent three equal groups of three.  Be sure to look at the show notes which will link to our CISO Tradecraft website that shows a 9-box picture which should make this easier to understand.  But if you're listening, imagine a three-by-three grid where each row corresponds to a different stakeholder.  Each stakeholder is going to be concerned with different things, and by identifying three important priorities for each, we have our grid.  Make sense?  Okay, let's dig in. The first row in our grid is the focus of Executive Leaders. First, this group of executives such as the CEO, CIO, and CISO ensure that the IT controls and objectives are working as desired.  Next, these executives want attestations and audits to ensure that compliance is being achieved and the organization is not just paying lip service to those requirements.  Thirdly, they also want business continuity.  IT systems must be constantly available despite attacks from ransomware, hardware failures, and power outages. The second row in our grid is the focus of Software Development shops. This group consists of Architects, Developers, Engineers, and Administrators.  First, they need to ensure they understand the Coverage of their IT systems in asset inventories -- can we account for all hardware and software.  Next, developers should be concerned with how Complexity in their environment can reduce security, as these tend to work at cross-purposes.  Lastly, developers care about Competency of their teams to build software correctly; that competency is a key predictor of the end quality of what is ultimately produced. The third and final row in our grid is the focus of Security Operations Centers. This group consists of Incident Handlers and Responders, Threat Intelligence Teams, and Business Information System Officers commonly known as BISOs.  They need to provide clear communication that informs others what they need to do, they need processes and tools that enable convenience so as to reduce friction.  Finally, they need to be consistent.  No one wants a fire department that only shows up 25% of the time. So now that we have a high-level overview of the 9 C's let's start going into detail on each one of them.  We'll start with the focus of executive leaders.  Again, that is controls, compliance, and continuity. Controls- According to James Hall's book on Accounting Information Systems[i], General Computer Controls are "specific activities performed by persons or systems designed to ensure that business objectives are met." Three common control frameworks that we see inside of organizations today are COBIT, COSO, and ITIL. COBIT®, which stands for The Control Objectives for Information Technology was built by the IT Governance Institute and the Information Systems Audit and Controls Organization, better known as ISACA®.  COBIT® is primarily focused on IT compliance, audit issues, and IT service, which should not be a surprise given its roots from ISACA® which is an Audit and Controls organization.  Overall, COBIT® 2019, the latest version, is based on the following six principles[ii] (note that the prior version, COBIT® 5[iii], had five): Provide stakeholder value Holistic approach Dynamic governance system Governance distinct from management Tailored to enterprise needs End-to-end governance system COSO  stands for The Committee of Sponsoring Organizations of the Treadway Commission.  Their latest version is the 2017 Enterprise Risk Management - Integrated Framework, which is designed to address "enterprise risk management and the need for organizations to improve their approach to managing risk to meet the demands of an evolving business environment.[iv]"  COSO states that internal controls are a PROCESS, effected by leadership, to provide reasonable assurance with respect to effectiveness, reliability, and compliance[v].  The framework consists of five interrelated principles[vi]: Governance and culture Strategy and objective-setting Performance Review and revision, and Information, communication, and reporting To support these principles, COSO defines internal controls as consisting of five interrelated components: Control environments, Risk Assessments, Control Activities, Information and Communication, and Monitoring Activities. The third framework is ITIL®, which stands for Information Technology Infrastructure Library. First published in 1989 (the latest update is 2019/2020), ITIL® is managed and maintained by AXELOS, a joint venture between the Government of the United Kingdom and PeopleCert, which acquired AXELOS in 2021. According to their website[vii], "ITIL 4 is an adaptable framework for managing services within the digital era.  Through our best practice modules, ITIL 4 helps to optimize digital technologies to co-create value with consumers, drive business strategy, and embrace digital transformation." (Talk about buzzword compliance).  ITIL® 4 focuses on process and service management through service strategy, service design, service transition, service operation, and continual service improvement.  What is interesting is that there is no third-party assessment of ITIL® compliance in an organization, only individual certification. At the end of the day an organization needs to pick one of these popular control frameworks and show controls are being followed.  This isn't just a best practice; it's also required by Sarbanes Oxley.  SOX has two sections that require control attestations that impact cyber.  Section 302 requires corporate management, executives, and financial officers to perform quarterly assessments which: Evaluate the effectiveness of disclosure controls, Evaluate changes in internal controls over financial reporting, Disclose all known control deficiencies and weaknesses, and Disclose acts of fraud. Since financial services run on IT applications, cybersecurity is generally in scope for showing weaknesses and deficiencies.  SOX Section 404 requires an annual assessment by both management and independent auditors.  This requires organizations to: Evaluate design and operating effectiveness of internal controls over financial reporting, Disclose all known controls and significant deficiencies, and disclose acts of fraud. Once we understand the requirements for controls, we need to be Compliant. Compliance is the second C we are discussing today.  Remember the CFO and CEO need to produce annual and quarterly reports to regulators such as the SEC.  So, if you as a CISO can help them obtain a clean bill of health or fix previous audit findings, you help the business. A useful tool to consult in terms of compliance is a concept from the Institute of Internal Auditors known as the three lines model or three lines of defense[viii].  This model has as a foundation six principles: Governance Governing body roles Management and first- and second-line roles Third line roles Third line independence, and Creating and protecting value The first line of defense is the business and process owners who maintain internal controls.  You can think of a software developer who should write secure software because there is an IT Control that says so.  That developer is expected to run application security scans and vulnerability scans to find bugs in their code.  They are also expected to fix these issues before releasing to production.  The second line of defense are elements of an organization that focus on risk management and compliance.  Your cyber team is a perfect example of this.  If the developer doesn't fix the application vulnerabilities before sending code to production, then the company is at risk.  Cyber teams generally track and report vulnerability findings to the business units to ensure better compliance with IT controls. Finally, the third line of defense is internal audit.  Internal audit might assess an IT control on secure software development and say we have an issue.  The developers push out bad code with vulnerabilities.  Cyber tells the developers to fix, yet we are observing trends that the total vulnerabilities are only increasing.  This systemic risk is problematic, and we recommend management comply with the IT controls by making immediate fixes to this risky situation. Now, other than the observation that the ultimate line of defense (internal auditors) is defined by the Institute of Internal Auditors (no conflict of interest there), note that internal auditors can report directly to the board.  Developers and CISOs typically cannot.  One of the most powerful weapons in an auditor's toolbox is the "finding."  The U.S. Code defines what represents a finding[ix] in the context of federal awards, to include: Significant deficiencies and material weaknesses in internal control and significant instances of abuse Material noncompliance with the provisions of Federal statutes or regulations Known questioned costs, specifically identified by the auditor, greater than $25,000 for a type of compliance requirement Internal auditors have both a mandate from and access to the board to ensure that the organization meets compliance requirements.  So, if you've been unsuccessful in getting funding for what you consider a critical security asset, maybe, just maybe, you casually point that out to the auditors so that it ends up in a finding.  After all, findings get funded.  Don't get caught, though, or you'll have some explaining to do to your boss who previously turned you down. Management cares a lot about Continuity. Remember, if the business is down, then it's not making money, and it's probably losing money by the hour.  If the business isn't making money, then they can't pay for the cyber department.  So, among your goals as a cyber executive is to ensure the continuity of revenue-generation services.  To start, you must identify what those activities are and find ways to protect the services by reducing the likelihood of vulnerabilities found in those systems.  You also need to ensure regular backup activities are occurring, disaster recovery exercises are performed, Business Continuity Plans are tested, and tabletops are executed.  Each of these activities has the potential to identify gaps which cause harm to the continuity that executives care about. How do you identify revenue-generating elements of the business?  Ask.  But do your homework first.  If you're a publicly traded company, the annual report will often break out lines of business showing profit and loss for each.  Even if it's losing money today, it still may be vital to the organization.  Think, ahem, about your department -- you're probably not making a profit for the company in the security suite, but your services are definitely important.  Look at the IT systems that support each line of business and assess their criticality to the success of that business component.  In today's digitized workplace, the answer will almost always be "yes," but since you don't have unlimited resources, you need to rack and stack what has to be protected first.  A Business Impact Analysis, or BIA, involves meeting with key executives throughout the organization, assessing the importance and value of IT-supported business processes, ranking them in the order in which they need to be assured, and then acting on that knowledge.  [I thought we had done an episode on BIA, but I checked back and couldn't find one.  So, expect to learn more about that in a future episode.] Backups and disaster recovery exercises are a must in today's world of ransomware and surprise risks, but make sure that you're not just hand-waving and assuming that what you think is working really is working.  Do what I call "core sampling" -- get with your team and dig way down until you reach some individual file from a particular date or can observe all logs collected for some arbitrary 5-minute period.  It's not that that information is critical in and of itself, but your team's ability to get to that information quickly and accurately should increase your confidence that they could do the same thing when a true outage occurs. Lastly, tabletop exercises are a great way to ensure that your team (as well as others from around the organization, up to and including senior leadership) know what to do when certain circumstances occur.  The advantage of tabletops is that they don't require much time and effort from the participants to go through emergency response procedures.  The disadvantage of tabletops is that you risk groupthink when everyone thinks someone else took care of that "assumed" item.  Companies have been caught flat-footed when the emergency diesel generator doesn't kick in because no one in the tabletop tests ever thought to check it for fuel, and the tank was empty.  Things change, and there's nothing like a full-scale test where people have to physically go to or do the things they would in a true emergency.  That's a reason why kids in school don't discuss what to do in a fire drill, they actually do what needs to be done -- get out of the building.  Be careful here you don't have a paper tiger for a continuity plan -- it's too late when things start to come apart to realize you hadn't truly done your homework. Those are the three Cs for executives -- controls, compliance, and continuity.  Now let's move on to developers. If you remember, the three Cs for developers are coverage, complexity, and competency. Developers need to care about Coverage. When we talk about coverage, we want to ensure that we know everything that is in our environment.  That includes having a complete and up-to-date asset inventory, knowing our processes are free from security oversight, as well as ensuring that our security controls are deployed across all of our potential attack surfaces.  "We've got your covered" is usually considered reassuring -- it's a statement that someone has thought of what needs to be protected. Specifically, our technical team members are the only ones who can generally tell if the IT asset inventory is correct.  They are the ones who run the tools, update the agents (assuming we're not agentless), and push the reporting.  If the scanning tools we use are missing hardware or software, then those gaps represent potential landing zones for enemy forces.  The Center for Internet Security's Critical Controls start with these two imperatives.  Essentially, if you don't know what you have, how can you secure it? Knowing our processes is key.  For developers today, it's much more likely that they're using a DevOps continuous integration / continuous delivery, or CI/CD process, rather than the classic waterfall methodology.  Agile is often an important part of what we do, and that continuous feedback loop between developer and customer helps to ensure that we cover requirements correctly (while being careful to avoid scope creep.)  Throughout our development cycle, there are numerous places where security belongs -- the art we call DevSecOps.  By putting all of our security processes into version control -- essentially automating the work and moving away from paper-based processes, we create a toolchain that automates our security functionality from pre-commit to commit to acceptance to production to operations.  Doing this right ensures that security in our development environment is covered. Beyond just the development pipeline, we need to cover our production environment.  Now that we've identified all hardware and software and secured our development pipeline, we need to ensure that our security tools are deployed effectively throughout the enterprise to provide protective coverage.  We may know how many servers we have, but if we don't scan continuously to ensure that the defenses are running and up to date, we are effectively outsourcing that work to bad actors, who fundamentally charge higher billing rates than developers when they take down critical systems via ransomware. In his book Data and Goliath, Bruce Schnier wrote, "Complexity is the worst enemy of security, and our systems are getting more complex all the time.[x]" Complexity is inversely correlated to security. If there are two hundred settings that you need to configure properly to make containers secure, that's a big deal.  It becomes a bigger deal when the team only understands how to apply 150 of those settings.  Essentially, your company is left with fifty opportunities for misconfiguration to be abused by bad actors.  Therefore, when possible, focus your understanding on how to minimize complexity.  For example, instead of running your own containers on premises with Kubernetes, try using Amazon Elastic Container Services.  There's a significant amount of configuration complexity decrease.  In addition, using cloud-based services give us a lot of capabilities -- elastic scaling, load balancers, multiple regions and availability zones, and even resistance to DDoS attacks.  That's a lot of overhead to ensure in a high-availability application running on servers in your data center.  Consider using AWS lambda where all of that is already handled as a service for our company.  Remember that complexity makes security more difficult and generally increases the costs of maintenance.  So only increase complexity when the business benefit exceeds the costs. From a business connectivity perspective, consider the complexity of relationships.  Many years ago, data centers were self-contained with 3270 green screens (or punched card readers if you go back far enough) as input and fan-fold line printer generated paper as output.  Essentially, the only connection that mattered was reliable electrical power. Today, we have to be aware of what's going on in our industry, our customers, our suppliers, consumers, service providers, and if we have them, joint ventures or partners.[xi]  This complex web of competing demands stretches our existing strategies, and sometimes rends holes in our coverage.  I would add to that awareness, complexity in our workforce.  How did COVID-19 affect your coverage of endpoints, for example?  Most work-from-home arrangements lost the benefit of the protection of the enterprise security bubble, with firewalls, scanners, and closely-manage endpoints.  Just issuing a VPN credential to a developer working from home doesn't do much when junior sits down at mom's computer to play some online game and downloads who-knows-what.  Consider standardizing your endpoints for manageability -- remove the complexity.  When I was in the Navy, we had exactly two endpoint configurations from which to choose, even though the Navy-Marine Corps Intranet, or NMCI, was the largest intranet in the world at the time.  Although frustrating when you have to explain to the admiral why his staff can't get fancier computers, the offsetting benefit is that when an emergency patch has to get pushed, you know it's going to "take" everywhere. Number six is Competency -- another crucial skill for developers. If your organization doesn't have competent developers, then more vulnerabilities are going to emerge.  So how do most other industries show competencies?  They use a licensure and certification process.  For example, teenagers in the United States must obtain a driver's license before they are legally approved to drive on their own.  Nearly all of us have been through the process -- get a manual when you get a learner's permit, go to a driving school to learn the basics, practice with your terrified parents, and after you reach the minimum age, try not to terrify the DMV employee in the passenger seat.  In the UK, the Driver and Vehicle Standards Agency recommends a minimum of 47 hours of lessons before taking the driving test, which still has only a 52% pass rate on the first attempt[xii]. Now ask yourself, is developing and deploying apps riskier than driving a car?  If so, consider creating a Developer Driver's License exam that identifies when developers are competent before your company gives them the SSH keys to your servers.  Before your new developer sits for the exam you also need to provide the training that identifies the Rules of the Road.  For example, ask: When a new application is purchased, what processes should be followed? When are third party vendor assessments needed?  How does one document applications into asset inventory systems and Configuration Management Databases? If you can build the Driver's Education Training equivalent for developer and measure competency via an exam, you can reduce the risk that comes from bad development and create a sense of accomplishment among your team. So, to summarize so far, for executives we have controls, compliance, and continuity, and for developers we have coverage, complexity, and competency.  It's now time to move to the last three for our security operations center:  clarity, context, and community. The seventh C is Communication. Let's learn from a couple quotes on effective communication. Peter Drucker said, “The most important thing in communication is hearing what isn't said.”  When you share an idea do you look at the person you are informing to see if they understand the idea?  What body language are you seeing?  Are they bored and not facing you, are they engaged and leaning in and paying close attention, or are they closed off with arms crossed?  We've probably all heard the term "active listening."  If you want to ensure the other party understands what you're saying (or if you're trying to show them you understand what they are saying), ask the listener to repeat back in their own words what the speaker has just said.  You'd be amazed how few people are needed to play the game of "telegraph" and distort a message to the point it is no longer recognizable. George Bernard Shaw said, “The single biggest problem in communication is the illusion that it has taken place.”  When you present a technical topic on a new risk to executives, ask questions to ensure they understand what you just shared.  If you don't do so, how do you know when you might be overwhelming them with information that goes right over their heads.  There's always the danger that someone will not want to look stupid and will just nod along like a bobblehead pretending to understand something about which they have absolutely no clue.  Richard Feynman had said, "If you can't explain it to a six-year-old, you don't understand it yourself."  Well, let me offer G Mark's corollary to that quote:  "If you can't explain it to a six-year-old, you can't explain it to your board."  And sometimes the big boss.  And sometimes your manager.  And sometimes your co-worker.  Ask for feedback; make sure the message is understood. Earl Wilson said, “Science may never come up with a better office communication system than the coffee break.”  When you want to launch a really important initiative that needs group buy-in, did you first have one-on-ones to solicit feedback?  Did you have an ear at the water cooler to understand when people say yes but really mean no?  Do you know how to connect with people so you can ask for a favor when you really don't have the resources necessary to make something happen?  Unless you are in the military, you can't issue lawful orders to your subordinates and demand that they carry them out.  You have to structure your communication in such a way that expectations are made clear, but also have to allow for some push-back, depending on the maturity of the relationship you've developed with your team.  [War story:  Just this past week, Apple upgraded to iOS 16.  We use iPhones exclusively as corporate-issued handsets, so I sent a single sentence message to my senior IT team member:  "Please prepare and send an email to all who have an iPhone with steps on how to update the OS soonest.  Thank you."  To me, that seemed like clear communication.  The next day I get a response, "People are slowly updating to 16.0 on their own and as the phone prompts them."  After a second request where I point out "slowly" has not been our strategy for responding to exploitable security vulnerabilities, I get a long explanation of how Apple upgrades work, how he's never been questioned in his long career -- essentially the person spent five times as much time explaining why he will NOT do the task rather than just doing it.  And today 80% of the devices are still not updated.  At times like this I'm reminded of Strother Martin in Cool Hand Luke:  "What we have here is failure to communicate."  So, my lesson for everyone is even though you think your communications are crystal clear, they may not be perceived as such.] Our last quote is from Walt Disney who said, “Of all our inventions for mass communication, pictures still speak the most universally understood language.”  If you believe that pictures are more effective than words, think about how you can create the best pictures in your emails and slide decks to communicate effectively.  I remember a British officer who had visited the Pentagon years ago who commented, "PowerPoint is the language of the US military."  I think he's right, at least in that context.  Ask yourself, are pictures part of your language? Convenience is our eighth C that we are going to talk about. How do we make something convenient?  We do it by automating the routine and removing the time wasters.  In terms of a SOC, we see technology in this space emerging with the use of Security Orchestration, Automation, and Response, or SOAR technologies.  Convenience can come in a lot of ways.  Have we created helpful playbooks that identify a process to follow?  If so, we can save time during a crisis when we don't have a minute to spare.  Have we created simple processes that work via forms versus emails?  It's a lot easier to track how many forms have been submitted and filter on field data versus aggregating unstructured emails.  One thing you might consider as a way to improve convenience are Chatbots.  What if someone could ask a Chatbot a Frequently Asked Question and get a quick, automated, and accurate response?  That convenience helps people, and it saves the SOC time.  If you go that route, as new questions get asked, do you have a way to rank them by frequency and add them as new logic to the chatbot?  If you do, your chatbot gets more useful and provides even greater convenience to the workforce.  How great would it be to hear your colleagues saying it was so convenient to report an incident and see that it was handled in such a timely manner.  Find ways to build that experience and you will become the partner the business wants. Last, but not least, is the 9th C of Consistency. Want to know how to create an audit finding?  Try not being consistent.  Auditors hate that and love to point out inconsistencies in systems.  I'm sure there are auditors right now listening to this podcast smiling with joy saying, "yup, that's me."  Want to know how to pass every audit standard?  Try passing the CARE Standard for cyber security.  CARE is a Gartner acronym that means Consistent, Adequate, Reasonable and Effective.  Auditors look at the Consistency of controls by performing tests to determine if the control is working the same way over time across the organization.  Auditors also look for Adequacy to determine if you have satisfactory controls in line with business needs.  Auditors ensure that your practices are Reasonable by identifying if there exist appropriate, fair, and moderate controls.  Finally, auditors look at Effectiveness to ensure the controls are producing the desired or intended outcomes.  So, in a nutshell, show Auditors that you CARE about cyber security. Okay, let's review.  Our nine Cs are for executives, developers, and SOC teams.  Executives should master controls, compliance, and continuity; developers should master coverage, complexity, and competency; and SOC teams should focus on clarity, communications, and consistency.  If you paid careful attention, I think you would find lessons for security leaders in all nine boxes across the model.  Essentially, don't conclude because boxes four through nine are not for executives that you don't need to master them -- all of this is important to being successful in your security leadership career. Well thanks again for listening to the CISO Tradecraft podcast as we discussed the 9 C's.  And for International Talk Like a Pirate Day, I do have a rrr-request:  if you like our show, please take a few seconds to rate us five stars on your favorite podcast provider.  Another CISO pointed out to me this past week that we came up first on Spotify when searching for C-I-S-O, and that's because those rankings are crowd-sourced.  It's a great way to say thank you for the time and effort we put into our show, and I thank you in advance.  This is your host G. Marrrrk Hardy, and please remember to stay safe out there as you continually practice your CISO Trrrradecraft. References https://www.vectra.ai/blogpost/the-9-cs-of-cybersecurity-value https://en.wikipedia.org/wiki/Information_technology_controls https://www.isaca.org/resources/cobit https://www.apexgloballearning.com/cobit-vs-itil-governance-framework-company-choose-infographic/ https://www.slideshare.net/alfid/it-control-objectives-framework-a-relationship-between-coso-cobit-and-itil https://internalaudit.olemiss.edu/the-three-lines-of-defense/ https://www.linkedin.com/pulse/15-quotes-effective-communication-jim-dent-lssbb-dtm/ https://www.gartner.com/en/articles/4-metrics-that-prove-your-cybersecurity-program-works?utm_medium=socialandutm_source=facebookandutm_campaign=SM_GB_YOY_GTR_SOC_SF1_SM-SWGandutm_content=andsf249612431=1andfbclid=IwAR1dnx-9BqaO8ahzs1HHcO2KAVWzYmY6FH-PmNoh1P4r0689unQuJ4CeQNk   [i] Hall, James A. (1996).  Accounting Information Systems.  Cengage Learning, 754 [ii] https://www.isaca.org/resources/news-and-trends/industry-news/2020/cobit-2019-and-cobit-5-comparison [iii] https://www.itgovernance.co.uk/cobit [iv] https://www.coso.org/SitePages/Enterprise-Risk-Management-Integrating-with-Strategy-and-Performance-2017.aspx [v] https://www.marquette.edu/riskunit/internalaudit/coso_model.shtml [vi] https://www.coso.org/Shared%20Documents/2017-COSO-ERM-Integrating-with-Strategy-and-Performance-Executive-Summary.pdf [vii] https://www.axelos.com/certifications/itil-service-management/what-is-itil [viii] https://www.theiia.org/globalassets/site/about-us/advocacy/three-lines-model-updated.pdf [ix] https://www.law.cornell.edu/cfr/text/2/200.516 [x] https://www.goodreads.com/quotes/7441842-complexity-is-the-worst-enemy-of-security-and-our-systems [xi] https://www.pwc.com/gx/en/issues/reinventing-the-future/take-on-tomorrow/simplifying-cybersecurity.html [xii] https://www.moneyshake.com/shaking-news/car-how-tos/how-to-pass-your-uk-driving-test

Read more > Listen to the podcast (duration: 38:39) > In this episode of The Venture, Andrew Roth shares a conversation with Samuel Rhee, Chairman, Chief Investment Officer, and cofounder of Endowus, a Singapore-based financial technology company that transformed the city-state's cumbersome social security investment process into a fully digital experience. It's now the only investment platform in Singapore approved for the investment of all funds, an eye-popping trillion-dollar wealth market. Samuel talks about Endowus' mission to solve the retirement adequacy problem with financial literacy, expert advice, lower costs, elimination of hidden fees, and a corporate culture that puts the client first.See www.mckinsey.com/privacy-policy for privacy information

In this episode of The Venture, Andrew Roth shares a conversation with Samuel Rhee, Chairman, Chief Investment Officer, and cofounder of Endowus, a Singapore-based financial technology company that transformed the city-state's cumbersome social security investment process into a fully digital experience. It's now the only investment platform in Singapore approved for the investment of all funds, an eye-popping trillion-dollar wealth market. Samuel talks about Endowus' mission to solve the retirement adequacy problem with financial literacy, expert advice, lower costs, elimination of hidden fees, and a corporate culture that puts the client first. Read more > Listen to the podcast (duration: 38:39) >

Our tour around the globe starts in South America. Chile has been seen in retirement circles as an early pioneer in reforming their retirement system in the late 1970's.  While studied and admired by many, there are many more layers to the story when viewed from historical and current events.  Host Josh Cohen talks to two individuals who have played a meaningful role in shaping the system.  University of Chicago educated Martin Costabal led efforts in the Chilean government to implement the new system in the midst of the Cold War.  Cristian Rodriguez has led the largest retirement plan provider in the country, and is making the case for the systems long term survival. Travel with us to Chile to hear about their unique history and hopefully learn from their creative retirement solutions.    Key Takeaways: [:21] Josh Cohen, your host, states the main objective of Season 2: to explore how other countries around the world organized their retirement systems to accommodate a work force that is living longer and working much differently than what the previous generation did.   [3:50] Other countries looked up to Chile since they had updated and reformed their retirement system and it used to be viewed as a success. Josh talks about the wider political circumstances in Chile.   [5:03] Josh begins to explore the current state of the Chilean system by starting with its beginnings; that is why he talks with Martin Costabal who participated in its creation within the Chilean government.   [6:21] Martin shares how he got an offer from the University of Chicago that changed his life; he explains his personal and professional reasons for moving to the United States.   [10:30] General Augusto Pinochet Ugarte was self-declared president in Chile after a coup, while Martin was studying abroad.   [11:13] In August, 1974, Martin acquired an MBA from the University of Chicago and goes back to Chile to work in the Ministry of Economics with the purpose of instituting policies to reprivatize many industries and battling out of control inflation. He found that an economic blueprint called “The Brick” was already in place with those same goals.   [16:17] Martin focused on creating a new retirement system for Chile along with a group of 20 people, based on some foundations from “The Brick.”   [19:20] Cristian Rodriguez, Chairman of the Board of AFP Habitat, speaks about the organization and its role in managing pensions. Cristian has been working with Habitat for the past 23 years in several positions, he gives an overview of its evolution over the years.   [22:04] The Chilean retirement system lays on three pillars: 1. The government-backed foundational pillar (The solidarity pillar), 2. The employment based pillar (The contribution pillar), and 3. A voluntary saving system (similar to the IRA in the USA). Cristian talks about the pros and cons of each.   [34:47] One challenge for the system in Chile is that not all workers save the same. That is why there is a need to modernize the first pillar to include the informal and independent kinds of work that are becoming more and more prevalent worldwide. People also need to achieve a better understanding of the retirement system and the outcomes they will be generating.   [38:20] Josh talks about four main factors of any retirement system: Access, Adequacy, Alignment of Interest, and Innovation. He also shares his insights in regards to the Chilean retirement system.