Why does it take so long to recover from natural disasters? What are the
friction points to a smooth recovery process? Isn't it remarkable that the responding
emergency services to wildfires and other disasters are so prepared, and the recovery is
usually reactive and chaotic? Isn't it time for the insurance industry and the many
recovery stakeholders to better understand the process and take incremental steps to
accelerate not only wildfire recoveries but also all natural-catastrophe recoveries?
My passion for this topic resulted from my frontline involvement in
three wildfires. See "Homeowners Law and Ordinance Coverage Challenges" and subsequent articles on
these fires, which are listed under my IRMI bio. These
real-world laboratories provide the best learning environments.
What Is the Role of Second Responders?
As the number and intensity of extreme weather events continue to rise, insurance professionals, other catastrophe stakeholders, and public officials, often known as "second responders," need to undertake a thorough analysis of the many different friction points that delay recoveries. It is amazing to me that the insurance industry, which professes to use sound risk management practices, has not practiced what it preaches by analyzing opportunities to reduce the impact of losses and by constantly evaluating the effectiveness of our collective recovery efforts. The current practices of second responders are more reactive than proactive.
When disaster strikes, each second responder may have their own
recovery plan or process, but there is little or no coordination among stakeholders'
efforts, nor evidence that they have a checklist of items to address the disaster
conditions they face. Understandably, such a task is monumental when you do not know
the scope of each recovery in advance, but that is really the opportunity to work on
better systems, coordination, and the management of recovery.
In contrast, the "first responders" never show up unprepared and
without a plan. Their proactive training, advanced planning for backup resources,
drills, and professional coordination between units offer many lessons that the
second responders should consider. Their preparation continues even though they
don't know in advance what emergency they will face until they get the call or
arrive at the scene.
The scale of megacatastrophe recoveries requires a whole new set
of best practices and systems to reduce the recovery period. As a starting point,
the financial and human costs of slow recoveries should be quantified. From an
insurance claims perspective, a general rule is that the longer the claim stays
open, the more expensive it becomes. From a disaster survivor's perspective, the
longer a claim takes to resolve, the greater the risk of underinsurance and the
reality of prolonged total disruption of their lives. From a local community
perspective, the potential impacts of a prolonged recovery also have economic
consequences but are often not quantified. Because there are no known tools to
reduce the growing frequency and severity of natural catastrophes, it amazes me that
recovery professionals have not studied and developed better practices to accelerate
recovery.
This article is a call to action for all second responders, both
private and public, to begin collaborating to streamline natural catastrophe
recoveries through better coordination, systems, and practices. The goal is to
accomplish the following.
Contrast the proactive training of first responders with the reactive second responder approach.
Identify some common friction points in most recoveries, both insurance-related and those of other stakeholders.
Provide more detail on how the Combined Systems Technology (CST) recovery
model uses a unified recovery process.
Offer an initial template for beginning a collaboration among stakeholders to develop a Unified Recovery Command process that is like the process used by first responders.
The current natural catastrophe recovery efforts are designed to fail. The time is now to change this trajectory.
First Responder Preparedness Model
Our society expects its first responders to be able to meet any
situation that they may confront when they are called to an incident. This
expectation requires them to train more aggressively to handle a wide range of
situations. After their basic training, they continue with more specialized training
and practice scenarios of various human or natural incidents. After most major
incidents, they develop an after-action report (AAR) that identifies what went right
and what needs improvement. The AAR becomes the continuous-improvement tool that
triggers additional training and planning.
Another attribute of first responders is their ability to identify
high-risk areas and deploy resources based on their risk analysis. As it relates to
wildfire, fire departments in wildfire-prone areas deploy personnel to areas with
the greatest potential to burn on red flag days, days determined by meteorologists
to be windy, dry, and sometimes hot. In the event of an actual wildfire, they often
have their own weather personnel to provide minute-by-minute forecasts as the
wildfire evolves, affecting the intensity and tactics of fighting the fire. In
coordination with local law enforcement personnel, they have evacuation plans to get
people out of harm's way and prevent onlookers from impeding the firefight.
First responders have systems that prepare them to handle threats
aggressively. Their timeline is much shorter than the recovery time frame, but their
preparation has maximized their ability to achieve a quicker, better outcome. If
similar planning, training, and collaboration among recovery entities were in place,
postdisaster recoveries could occur more quickly and with less impact on affected
survivors. Second responders need to adopt the proven planning and training tactics
of the first responders.
The Suppression and Recovery Gap
After the fire is suppressed, first responders generally have
limited additional duties. Their checklists include a wide range of tasks during
this interim period to ensure the electrical lines are disconnected and the natural
gas is extinguished. Once those functions are done, they usually have best practices
in place to allow initial visits by survivors and their insurance representatives
but, more importantly, to keep curious community members out of the area.
In this interim period, one of the first recovery activities is to establish a Disaster Recovery Center (DRC) where survivors can begin receiving information on next steps in their recovery. The most important assistance at this point is to help them find lodging and file an initial claim for funds to replace personal items needed for daily living. Money is easy to dispense, but the daunting task of finding temporary housing is an early hurdle. While they can begin learning about their insurance coverage during this time, the real need is to explain how this will play out in their immediate recovery. Generally, the DRC remains open for 30 days, after which the various recovery agencies return to their places of business, requiring survivors to reach out to each agency rather than have a central clearinghouse for information and ever-changing recovery updates.
The closure of the DRC and the return of homes and businesses to
the survivors mark the end of the planned and coordinated recovery in the first
responders' suppression plan. Hopefully, in this interim period, some preliminary
decisions were made about the structure of the recovery organization. In many cases,
the county or community emergency management team steps up to the plate to serve as
the recovery coordinator.
While this seems like a logical solution, it complicates
coordination among nongovernmental entities such as homebuilders and insurers. In
addition, this effort will require considerable additional personnel, which will
take time and training to bring up to speed. The first major task is to organize and
carry out debris removal before any rebuilding can occur and to ensure the
infrastructure is repaired before building permits are issued. The debris removal
generally takes at least 6 months.
Colorado Springs Together (CST) Unified Command Model
Within hours of losing 347 homes during the Waldo Canyon Fire in
the Mountain Shadows neighborhood of Colorado Springs, the mayor made a crucial
decision to have a local retired businessman manage the recovery, aided by the
city's resources. Within a day, the newly designated Colorado Springs Together (CST)
leader, working with the mayor and the city's emergency manager, decided to
establish a separate public-private partnership (P3) to manage all aspects of the
recovery.
The CST team included the major community governmental entities as
well as many private-sector stakeholders (e.g., insurers, contractors,
communications, behavioral health, realtors, bankers, and nonprofits) who directed
the recovery. The survivors were represented by three homeowners associations and
were considered our customers. The CST team focused on accelerating the recovery and
reducing the inevitable bottlenecks that occur in such recoveries.
Because everyone was involved in the decision-making process,
issues were resolved as expeditiously as possible. All debris was removed within 4
months of the fire, and the first survivors moved into their houses at the end of
the fifth month. By the end of 18 months, CST discontinued its meetings because it
was evident that the recovery was well on its way to beating the traditional
benchmark, and there was no further need for its oversight. While CST had no
preplan, the team was able to operate as a de facto recovery incident command role,
continually collaborating with all stakeholders, public and private.
There were three other keys to the relative speed of recovery.
The establishment of a neighborhood recovery location that assisted in keeping recovery resources and meetings near the recovering neighborhood.
Weekly communications kept all stakeholders and survivors updated on critical information on a need-to-know basis.
Continual involvement of survivors in their own recovery process in rebuilding their neighborhood.
A one-size-fits-all organizational structure does not work in all
instances. Preferably, the stakeholders can agree on an organizational structure
before any loss occurs and develop a skeletal structure and a postloss plan to
address any disaster that may confront their community, county, or state. Without
understanding the dynamics and scope of potential disasters, it is critical to
create a flexible template that can quickly adapt to the incident loss. The key is a
planning mechanism that allows stakeholders to quickly start the recovery process
once the initial disaster is over.
After 18 months, the P3 entity discontinued its formal operations and placed itself in legal suspension for future use. Although the recovery was not yet complete, all the recovery issues had been addressed, and it was just a matter of time to finalize the remaining home rebuilds. The collective action of the recovery team, including the survivors, created the conditions for this very rapid recovery, with far less friction than is typical in many wildfire recoveries.
What Slows Recoveries?
Each catastrophe presents its own challenges to the second responders. As the team starts, there are three essential tasks they face.
Identify the survivors, develop a contact list, and get them situated in temporary housing.
Create a strong communication team that can effectively deal with survivors and media.
Begin the physical cleanup of the debris so rebuilding can commence.
Ideally, the team would delegate each task to a subteam to carry
it out, so they can move on to other longer-term recovery tasks. The more
effectively these tasks are executed, then the more effectively the signal will be
sent to the survivors that a plan is in place and that the second responders have
their interests as the focal point.
Another key consideration in this initial phase is an assessment of the local resources available to support recovery. Depending on the size and location of the catastrophe, a realistic determination of the local recovery capabilities is critical. All disasters create a "demand surge" that affects the short- and long-term speed of recovery. If the team recognizes these potential resource shortfalls early, it will give them a head start in ensuring they have the resources in place to keep the recovery moving as quickly as possible.
On the surface, all these steps seem simple. In practice, they are very difficult to execute. The challenge for all second responders is to continually work out the frictional points to speed the final recovery for their customers, the survivors. Recoveries require preparation, planning, and execution.
It is helpful to have a unified task force within the overall
recovery organizational structure to address more technical questions. These can
involve insurance, construction, and code issues. A unified recovery team can
anticipate many such questions; if the team can't answer the questions, team members
know how to find the answers. Let's take a brief look at some examples of the
friction points that certain stakeholders will face.
Insurance and claims issues
Determine the codes and governmental regulations
applicable to the rebuild effort.
Address underinsurance or coverage gaps
proactively.
Handle adjuster shortages, turnover, and location,
and manage multiple catastrophes simultaneously.
Mortgagee issues
Applying the insurance proceeds to the existing
mortgage and bridging to a new rebuild mortgage rate is very hard for
consumers to understand. This uncertainty leads to delays in
policyholders finalizing their construction contracts.
Facilitate the endorsement and allocation of claim
checks.
Homebuilder issues
Address the impact of the sudden localized demand
surge caused by the disaster.
Manage the construction timelines for widely
dispersed jobsites rather than more centralized locations.
Regulatory and governmental issues
Scale up building departments to handle the surge of
building permits.
Seek and manage the Federal Emergency Management
Agency, Small Business Administration, and state funds for the overall
recovery project, as well as for individual homeowners.
Restore the neighborhood's basic
infrastructure.
Community and survivor issues
Quantify the potential costs on local businesses and
the loss of tax revenues for the affected communities.
Understand the different recovery challenges for
vulnerable people (i.e., the elderly, disabled, uninsured, renters, and
non-English speaking populations).
Not all items will apply to all catastrophes, but being prepared
to address them is critical for a smooth, fast, and complete recovery.
Unified Recovery Command System
In the early days of fighting wildfires, there was no incident
command system to manage the many different entities called to fight the fire. Over
time, and after many AARs, a more formal incident command system was established to
help minimize wildfire footprints. In practice, this development provided four major
benefits.
The foundation of the incident command system rests on proactive planning
and practice rather than postloss improvisation.
The system is designed to coordinate the suppression effort rather than having each individual entity do their own thing.
In implementing the unified command, a consensus is reached on what needs to be done and the sequencing of the suppression effort.
The size of the incident disaster and the scale of recovery are considered.
As these disasters keep getting larger and more frequent, using good organizational and management tools, such as an incident command system, provides an opportunity to achieve many objective and subjective goals that first responders are already pursuing.
While a smaller, local, and more focused organization is
preferable, many locales will likely be unable to develop a formal local team. If
this situation arises, unified teams may be better formed at the county or state
level in high-risk areas and could help local entities manage their recoveries
virtually.
There is no reason why the most affected stakeholders—insurers and
contractors—cannot undertake internal reviews and adjust their systems to initiate a
mutual dialogue and develop ideas to minimize friction points for themselves and the
public. The biggest opportunity here is to streamline postcatastrophe recovery
processes. Two keys are essential in these early discussions: consensus and
proactive ways to simplify the process for everyone. This focus on reduction is a
different approach from the current focus on prevention and mitigation strategies
being explored by many states. These conversations on mitigation practices may even
lead to more robust conversations on the eventual development of effective recovery
organizations. The collective goal should be a win-win for all stakeholders, not a
situation where some win and others lose.
Call to Action
As these large natural disaster incidents increase, there is little question that the existing methods for handling their recoveries are either outdated or just never designed for the scale of these disasters. Reflecting on the reactive approach to wildfire recovery, it is time to apply proven risk management techniques to facilitate recovery from these natural catastrophes. Slow and uncoordinated recoveries serve no one. They negatively affect our communities, economy, business bottom lines, and our citizens' well-being. First responders have found a way to systematically develop better systems for fighting fires. Now is an opportunity to build on their systems to improve recovery. We need to find ways to significantly shorten this process as an industry and society.
How should you react to this "call to action"? Can we afford to
continue to deny the need to find new ways to minimize the impacts of disasters on
our residents? How do we initiate this change? Here are three ideas that you can
take to initiate this process.
Share this article with your peers and discuss with them the steps you could take to make this happen.
Reach out to your local community leaders and see what plans, if any, they
have for handling recovery, or suggest the need to develop a more comprehensive
catastrophe recovery process for your community or geographical area.
Reach out to your customers to make sure they understand the complexities of recovering after a catastrophe and have sufficient insurance protection. Additionally, recruit them to lobby their local leaders to plan and train for a proactive recovery program.
Many readers are active in their local communities and professional associations. Both activities offer further chances to make this happen.
The clock is ticking … it is time to begin implementing these recommended changes to make the next wildfire or other disaster recovery better wherever it occurs.
Opinions expressed in Expert Commentary articles are those of the author and are not necessarily held by the author's employer or IRMI. Expert Commentary articles and other IRMI Online content do not purport to provide legal, accounting, or other professional advice or opinion. If such advice is needed, consult with your attorney, accountant, or other qualified adviser.
Why does it take so long to recover from natural disasters? What are the friction points to a smooth recovery process? Isn't it remarkable that the responding emergency services to wildfires and other disasters are so prepared, and the recovery is usually reactive and chaotic? Isn't it time for the insurance industry and the many recovery stakeholders to better understand the process and take incremental steps to accelerate not only wildfire recoveries but also all natural-catastrophe recoveries?
My passion for this topic resulted from my frontline involvement in three wildfires. See "Homeowners Law and Ordinance Coverage Challenges" and subsequent articles on these fires, which are listed under my IRMI bio. These real-world laboratories provide the best learning environments.
What Is the Role of Second Responders?
As the number and intensity of extreme weather events continue to rise, insurance professionals, other catastrophe stakeholders, and public officials, often known as "second responders," need to undertake a thorough analysis of the many different friction points that delay recoveries. It is amazing to me that the insurance industry, which professes to use sound risk management practices, has not practiced what it preaches by analyzing opportunities to reduce the impact of losses and by constantly evaluating the effectiveness of our collective recovery efforts. The current practices of second responders are more reactive than proactive.
When disaster strikes, each second responder may have their own recovery plan or process, but there is little or no coordination among stakeholders' efforts, nor evidence that they have a checklist of items to address the disaster conditions they face. Understandably, such a task is monumental when you do not know the scope of each recovery in advance, but that is really the opportunity to work on better systems, coordination, and the management of recovery.
In contrast, the "first responders" never show up unprepared and without a plan. Their proactive training, advanced planning for backup resources, drills, and professional coordination between units offer many lessons that the second responders should consider. Their preparation continues even though they don't know in advance what emergency they will face until they get the call or arrive at the scene.
The scale of megacatastrophe recoveries requires a whole new set of best practices and systems to reduce the recovery period. As a starting point, the financial and human costs of slow recoveries should be quantified. From an insurance claims perspective, a general rule is that the longer the claim stays open, the more expensive it becomes. From a disaster survivor's perspective, the longer a claim takes to resolve, the greater the risk of underinsurance and the reality of prolonged total disruption of their lives. From a local community perspective, the potential impacts of a prolonged recovery also have economic consequences but are often not quantified. Because there are no known tools to reduce the growing frequency and severity of natural catastrophes, it amazes me that recovery professionals have not studied and developed better practices to accelerate recovery.
This article is a call to action for all second responders, both private and public, to begin collaborating to streamline natural catastrophe recoveries through better coordination, systems, and practices. The goal is to accomplish the following.
The current natural catastrophe recovery efforts are designed to fail. The time is now to change this trajectory.
First Responder Preparedness Model
Our society expects its first responders to be able to meet any situation that they may confront when they are called to an incident. This expectation requires them to train more aggressively to handle a wide range of situations. After their basic training, they continue with more specialized training and practice scenarios of various human or natural incidents. After most major incidents, they develop an after-action report (AAR) that identifies what went right and what needs improvement. The AAR becomes the continuous-improvement tool that triggers additional training and planning.
Another attribute of first responders is their ability to identify high-risk areas and deploy resources based on their risk analysis. As it relates to wildfire, fire departments in wildfire-prone areas deploy personnel to areas with the greatest potential to burn on red flag days, days determined by meteorologists to be windy, dry, and sometimes hot. In the event of an actual wildfire, they often have their own weather personnel to provide minute-by-minute forecasts as the wildfire evolves, affecting the intensity and tactics of fighting the fire. In coordination with local law enforcement personnel, they have evacuation plans to get people out of harm's way and prevent onlookers from impeding the firefight.
First responders have systems that prepare them to handle threats aggressively. Their timeline is much shorter than the recovery time frame, but their preparation has maximized their ability to achieve a quicker, better outcome. If similar planning, training, and collaboration among recovery entities were in place, postdisaster recoveries could occur more quickly and with less impact on affected survivors. Second responders need to adopt the proven planning and training tactics of the first responders.
The Suppression and Recovery Gap
After the fire is suppressed, first responders generally have limited additional duties. Their checklists include a wide range of tasks during this interim period to ensure the electrical lines are disconnected and the natural gas is extinguished. Once those functions are done, they usually have best practices in place to allow initial visits by survivors and their insurance representatives but, more importantly, to keep curious community members out of the area.
In this interim period, one of the first recovery activities is to establish a Disaster Recovery Center (DRC) where survivors can begin receiving information on next steps in their recovery. The most important assistance at this point is to help them find lodging and file an initial claim for funds to replace personal items needed for daily living. Money is easy to dispense, but the daunting task of finding temporary housing is an early hurdle. While they can begin learning about their insurance coverage during this time, the real need is to explain how this will play out in their immediate recovery. Generally, the DRC remains open for 30 days, after which the various recovery agencies return to their places of business, requiring survivors to reach out to each agency rather than have a central clearinghouse for information and ever-changing recovery updates.
The closure of the DRC and the return of homes and businesses to the survivors mark the end of the planned and coordinated recovery in the first responders' suppression plan. Hopefully, in this interim period, some preliminary decisions were made about the structure of the recovery organization. In many cases, the county or community emergency management team steps up to the plate to serve as the recovery coordinator.
While this seems like a logical solution, it complicates coordination among nongovernmental entities such as homebuilders and insurers. In addition, this effort will require considerable additional personnel, which will take time and training to bring up to speed. The first major task is to organize and carry out debris removal before any rebuilding can occur and to ensure the infrastructure is repaired before building permits are issued. The debris removal generally takes at least 6 months.
Colorado Springs Together (CST) Unified Command Model
Within hours of losing 347 homes during the Waldo Canyon Fire in the Mountain Shadows neighborhood of Colorado Springs, the mayor made a crucial decision to have a local retired businessman manage the recovery, aided by the city's resources. Within a day, the newly designated Colorado Springs Together (CST) leader, working with the mayor and the city's emergency manager, decided to establish a separate public-private partnership (P3) to manage all aspects of the recovery.
The CST team included the major community governmental entities as well as many private-sector stakeholders (e.g., insurers, contractors, communications, behavioral health, realtors, bankers, and nonprofits) who directed the recovery. The survivors were represented by three homeowners associations and were considered our customers. The CST team focused on accelerating the recovery and reducing the inevitable bottlenecks that occur in such recoveries.
Because everyone was involved in the decision-making process, issues were resolved as expeditiously as possible. All debris was removed within 4 months of the fire, and the first survivors moved into their houses at the end of the fifth month. By the end of 18 months, CST discontinued its meetings because it was evident that the recovery was well on its way to beating the traditional benchmark, and there was no further need for its oversight. While CST had no preplan, the team was able to operate as a de facto recovery incident command role, continually collaborating with all stakeholders, public and private.
There were three other keys to the relative speed of recovery.
A one-size-fits-all organizational structure does not work in all instances. Preferably, the stakeholders can agree on an organizational structure before any loss occurs and develop a skeletal structure and a postloss plan to address any disaster that may confront their community, county, or state. Without understanding the dynamics and scope of potential disasters, it is critical to create a flexible template that can quickly adapt to the incident loss. The key is a planning mechanism that allows stakeholders to quickly start the recovery process once the initial disaster is over.
After 18 months, the P3 entity discontinued its formal operations and placed itself in legal suspension for future use. Although the recovery was not yet complete, all the recovery issues had been addressed, and it was just a matter of time to finalize the remaining home rebuilds. The collective action of the recovery team, including the survivors, created the conditions for this very rapid recovery, with far less friction than is typical in many wildfire recoveries.
What Slows Recoveries?
Each catastrophe presents its own challenges to the second responders. As the team starts, there are three essential tasks they face.
Ideally, the team would delegate each task to a subteam to carry it out, so they can move on to other longer-term recovery tasks. The more effectively these tasks are executed, then the more effectively the signal will be sent to the survivors that a plan is in place and that the second responders have their interests as the focal point.
Another key consideration in this initial phase is an assessment of the local resources available to support recovery. Depending on the size and location of the catastrophe, a realistic determination of the local recovery capabilities is critical. All disasters create a "demand surge" that affects the short- and long-term speed of recovery. If the team recognizes these potential resource shortfalls early, it will give them a head start in ensuring they have the resources in place to keep the recovery moving as quickly as possible.
On the surface, all these steps seem simple. In practice, they are very difficult to execute. The challenge for all second responders is to continually work out the frictional points to speed the final recovery for their customers, the survivors. Recoveries require preparation, planning, and execution.
It is helpful to have a unified task force within the overall recovery organizational structure to address more technical questions. These can involve insurance, construction, and code issues. A unified recovery team can anticipate many such questions; if the team can't answer the questions, team members know how to find the answers. Let's take a brief look at some examples of the friction points that certain stakeholders will face.
Not all items will apply to all catastrophes, but being prepared to address them is critical for a smooth, fast, and complete recovery.
Unified Recovery Command System
In the early days of fighting wildfires, there was no incident command system to manage the many different entities called to fight the fire. Over time, and after many AARs, a more formal incident command system was established to help minimize wildfire footprints. In practice, this development provided four major benefits.
As these disasters keep getting larger and more frequent, using good organizational and management tools, such as an incident command system, provides an opportunity to achieve many objective and subjective goals that first responders are already pursuing.
While a smaller, local, and more focused organization is preferable, many locales will likely be unable to develop a formal local team. If this situation arises, unified teams may be better formed at the county or state level in high-risk areas and could help local entities manage their recoveries virtually.
There is no reason why the most affected stakeholders—insurers and contractors—cannot undertake internal reviews and adjust their systems to initiate a mutual dialogue and develop ideas to minimize friction points for themselves and the public. The biggest opportunity here is to streamline postcatastrophe recovery processes. Two keys are essential in these early discussions: consensus and proactive ways to simplify the process for everyone. This focus on reduction is a different approach from the current focus on prevention and mitigation strategies being explored by many states. These conversations on mitigation practices may even lead to more robust conversations on the eventual development of effective recovery organizations. The collective goal should be a win-win for all stakeholders, not a situation where some win and others lose.
Call to Action
As these large natural disaster incidents increase, there is little question that the existing methods for handling their recoveries are either outdated or just never designed for the scale of these disasters. Reflecting on the reactive approach to wildfire recovery, it is time to apply proven risk management techniques to facilitate recovery from these natural catastrophes. Slow and uncoordinated recoveries serve no one. They negatively affect our communities, economy, business bottom lines, and our citizens' well-being. First responders have found a way to systematically develop better systems for fighting fires. Now is an opportunity to build on their systems to improve recovery. We need to find ways to significantly shorten this process as an industry and society.
How should you react to this "call to action"? Can we afford to continue to deny the need to find new ways to minimize the impacts of disasters on our residents? How do we initiate this change? Here are three ideas that you can take to initiate this process.
Many readers are active in their local communities and professional associations. Both activities offer further chances to make this happen.
The clock is ticking … it is time to begin implementing these recommended changes to make the next wildfire or other disaster recovery better wherever it occurs.
Opinions expressed in Expert Commentary articles are those of the author and are not necessarily held by the author's employer or IRMI. Expert Commentary articles and other IRMI Online content do not purport to provide legal, accounting, or other professional advice or opinion. If such advice is needed, consult with your attorney, accountant, or other qualified adviser.