…Despite the fact that 100 percent coinsurance may sound like complete coverage and is used that way in medical insurance, that’s not what it means in business income insurance. At best, there had been a failure of communication between the broker and the insured. At worst, the broker was guilty of professional negligence. When an insured sued its broker, the court ruled that the latter was true.2 The broker’s case wasn’t helped when the customer service representative responsible for the account testified in her deposition that she didn’t understand business income coinsurance even after it was explained to her! An expert for the insured testified that agreed value business income coverage was available. To obtain agreed value the insured would have been required to complete a business income worksheet. The insured had completed a worksheet a number of years earlier, but it was disputed whether the broker had recommended agreed value coverage after that. It was clear that no worksheet had been completed immediately prior to the inception of the policy in effect at the time of the loss.

Lessons To Be Learned: Waive Coinsurance—Set Adequate Limit

 

There are several lessons to be learned. Foremost is the need for agreed value to avoid any coinsurance penalty. The second is the need to set an amount of insurance that covers the insured’s exposure and satisfies the coinsurance requirement. Because of the difference among insureds with respect to potential business income loss compared to an insured’s coinsurance basis, a variety of coinsurance percentages are available. Insurance Services Office (ISO) rules allow the insurer to offer 50, 60, 70, 80, 90, 100, or 125 percent. The selected coinsurance percentage is applied to the coinsurance basis to determine the amount of insurance necessary to satisfy the coinsurance requirement. The business income worksheet is the tool used to determine the coinsurance basis.

 

ISO Business Income Report/Worksheet

 

This article is based on the ISO form CP 15 15 06 95 Business Income Report/Work Sheet. The report part of the title refers to the forms use to report values for the business income reporting-form endorsement.3 We’re concerned with the worksheet aspects of the form and will refer to it as BI worksheet.

 

A number of insurers have developed their own worksheets. Almost all are similar to the ISO worksheet, but some are more user-friendly.4 (Some insureds’ operations are ill-suited to the worksheet format. For example, most public school districts are funded by state aid and local taxation. In the event that the schools are destroyed by an insured peril, some revenue will be lost, such as tuition from outof- district students or state aid if it is tied to the number of pupil-days of attendance, but most of the school district’s revenues will continue. Underwriters are sometimes willing to recognize this problem and permit the insured to eliminate tax revenues from the worksheet when calculating coinsurance basis.)

 

All insureds should complete a worksheet to determine how the coverage fits their needs. It’s not the insurance adviser’s or the underwriter’s job to complete the worksheet. That’s a task for the insured or its financial advisers. However, there are key roles for insurance practitioners in the process. Insurance Practitioners Roles Producers, consultants, risk managers, and underwriters need to understand how the form is completed in order to guide the insured. Understanding the form is also important when evaluating the information the insured submits.

 

Even the most competent financial officers can stumble; unless they are familiar with business income coverage, they may overlook deductions or misinterpret the instructions. Furthermore, a quick glance at page one of the business income worksheet shows that if the insured wants agreed value coverage with coinsurance suspended, the insured has to stipulate an agreed value (which will become the minimum amount of insurance to be carried) and a coinsurance percentage. This is an area where the assistance of the firm’s insurance advisers is clearly needed.

 

There are two steps to setting an amount of business income insurance and selecting a coinsurance percentage. One is estimating the firm’s maximum possible business income loss, and the other is completing the business income worksheet.

 

The steps can be done in either order, but calculating expected maximum loss (EML)5 first will enable the insured to decide if the exposure is important enough to proceed with completing the business income worksheet and, if the exposure is meaningful, that it warrants the time and effort needed to develop the required information.

 

Estimating Expected Maximum Loss

 

EML is an area where an insurance practitioners’ expertise can be very useful. Among the items to be considered are:

 

• time required to restore damaged property;

 

• seasonal fluctuations;

 

• anticipated changes in income and expenses during the period of restoration;

 

• key processes and bottlenecks;

 

• noncontinuing expenses not deducted in the worksheet;

 

• extended business income loss;

 

• extra expenses required to continue business to the extent possible; and

 

• an allowance for possible errors in estimates.

 

Insureds tend to be overly optimistic when estimating how long it will take to restore operations following serious damage. Insurance practitioners can help them explore the various facets of the exposure to develop a more accurate EML. (This is a just a cursory overview of the issue of developing EML. A full treatment is beyond the scope of this article.6)

 

Relationship of EML and Coinsurance Basis

 

Once EML is estimated, its relationship to the coinsurance basis enables the insured to select an appropriate coinsurance percentage and amount of insurance. Here is one method for selecting a coinsurance limit.

 

• If the EML is less than 50 percent of the coinsurance basis, the coinsurance percentage selected will be 50 percent and the agreed value and amount of insurance will be equal to 50 percent of the coinsurance basis.

 

• If the EML is greater than 50 percent, but less than 125 percent, of the coinsurance basis, it should be rounded off to the next higher available coinsurance percentage and the agreed value and amount of insurance set equal to that percentage of the coinsurance basis.

 

• If the EML is greater than 125 percent of coinsurance basis, 125 percent will be the selected coinsurance percentage. The agreed value will be 125 percent of the coinsurance basis, but the amount of insurance will be equal to the insured’s EML — otherwise, the insured could be badly underinsured in the event of a loss even though no coinsurance penalty will apply.

 

Exhibit 1 shows some examples of coinsurance percentage selection. The insured is asked to select a coinsurance percentage and an agreed value on page 1, but the coinsurance basis and the EML will have to be estimated before those values can be properly calculated. Using the Business Income Worksheet to Calculate the Coinsurance Basis The BI worksheet is the way to calculate coinsurance basis. It’s a vital step whether agreed value applies or not —- selecting a coinsurance percentage without completing the worksheet is pure guesswork.

 

Insurers put coinsurance provisions in policies to maintain rating integrity. Left to their own devices, most insureds will underinsure. If rates are predicated on full insurance, the rates will be too low to pay the losses. If the rate is set high enough to produce adequate premium, insureds that do insure to value will be overcharged. For most property exposures, coinsurance is based on insurable value. The complication for business income insurance is that the coinsurance basis can include items that the insured will never be able to claim as part of a business income loss. The reason for this is that business income insurance does not indemnify the insured for discontinuing expenses. ISO and others have tried, without success, to come up with a general formula that would base coinsurance on net income plus only continuing expenses, but were defeated by the problem of deciding what should be included in continuing expenses.

 

For example, consider rent expense for a tenant — often a very substantial item. Most leases provide that rent will be waived when the damage to the premises exceeds 50 percent. Therefore, many insureds may not include rent in their EML calculations, as more than 50 percent damage is the likely scenario for EML. However, business income losses can occur when damage is less than 50 percent and, for some insureds, their EML may be based on the time needed to restore a key piece of equipment or a key process, even though damage to the premises is less than 50 percent. As a result, in some cases, rent would be a continuing expense and in others, a discontinuing expense.

 

The BI worksheet deducts only those items that clearly will discontinue when operations are interrupted. Even if there are other expenses that will always discontinue for a particular insured, they cannot be deducted in calculating the coinsurance basis; as we will see, the form is very specific on what can be deducted.

 

Completing the Worksheet

 

Let’s look at some key points that will help an insurance practitioner to guide insureds through the process of completing the form.

 

Page One: Information

 

The first page is primarily devoted to informational material (see Exhibit 2). However, there are some important points to notice.

 

First, note that the form says that the work sheet must be completed on an accrual basis. Cash-basis accounting is widely used, mostly by smaller businesses. Such businesses are generally insured under businessowners policies that often have a time limit (generally one year) for business income recovery, rather than a dollar limit of insurance, thereby making the worksheet unnecessary.

 

If a firm that uses cash-basis accounting is insured under a business income coinsurance form and wishes to obtain agreed value coverage, the matter should be discussed with the underwriter before the form is completed. Cash-basis accounting does not match expenses and income as well as accrual basis accounting and, therefore, a worksheet prepared based on cash-basis accounting will generally not be acceptable to underwriters. It is doubtful that an insured would incur the expense to convert cash-basis records to accrual-basis just to obtain an agreed value option. There are other options available: the aforementioned businessowners policy and two options in the commercial property form, the monthly limit of indemnity and the maximum period of indemnity.

 

Prior forms required conformity with Generally Accepted Accounting Principles (GAAP). Because not all businesses use GAAP, this is a point that should be discussed with the insured. An example of non-GAAP accounting close to home is insurance-company accounting. Insurance companies must use statutory accounting as specified by the law of their domiciles. Most insurers also prepare GAAP accounting statements, but those that don’t should either convert the calculations to GAAP or advise the underwriter that the BI worksheet was prepared based on statutory accounting. The treatment of many expenses (e.g. commissions paid and equipment purchased) under statutory accounting resembles cash-basis accounting and will substantially differ from GAAP for some firms.

 

The form also requires that the same method be used at the beginning and end of the accounting period (e.g., LIFO [last in — first out], FIFO [first in — first out], specific identification, etc.) As noted above, in order to obtain the agreed value option, the insured must insert the agreed value and the coinsurance percentage in the form and certify that the form is a correct report of values. Note that a signature is required.

Pages Two and Three: Financial Analysis

 

The second page calls for financial information that should be supplied by the insured (see Exhibit 3). At first glance, it resembles the profit and loss statement (P&L) produced by a firm’s accountants; a common slip-up that financial people with no insurance background make when completing these forms is assuming that all the items in the P&L should somehow be crammed into the form. The information called for in the worksheet differs in a number of important respects from that found in the P&L. First, most of the expense items found in the P&L are not used as part of the worksheet calculation. That’s one major reason why the coinsurance basis is not the same as the EML. The second major reason for the difference between coinsurance basis and EML is that the coinsurance basis is calculated based on a 12-month period, while EML will seldom involve exactly 12 months and may be much shorter or much longer.

 

Other differences between the P&L and the worksheet arise from the exclusion of certain types of income and from differences in the calculation of certain items. We’ll comment on those as we come to them.

 

Page 2 contains two sets of identical double columns. The left-hand set of columns is captioned “12 Month Period Ending ____________.” The date entered should be the ending date of the insured’s latest financial statements. The items in the two columns are completed based on data obtained from those statements. That date will almost never be the same as inception date unless the policy period coincides with the insured’s fiscal year and the form is being completed some time after policy inception — leaving the insured without agreed value for part of the policy year. The right-hand set of columns is captioned “Estimated for 12 Month Period Beginning __________.” This blank is filled in with the policy inception date, and the items are completed based on the insured’s estimate for the 12 months following inception. (This is another reason why EML and coinsurance basis are not the same; for a firm whose business is rapidly expanding, EML may be based on a period starting the last day of the policy period and continue on thereafter; the period of indemnification for a business income loss does not end with the expiration of the policy.) Nonmanufacturing Columns One column in each set is for manufacturing operations and the other is for nonmanufacturing. We’ll start with examining the nonmanufacturing column; it’s easier to understand and nonmanufacturing businesses are now dominant in the U.S. economy — in 2008, the service sector contributed 67.8 percent of GDP (gross domestic product).7

 

Item A is Gross Sales, which is the starting item in most accounting profit and loss statements. Items B, C, and D do not apply to nonmanufacturing. The deductions shown in item E are standard accounting classifications of expenses that will discontinue if no sales are made. Prepaid freight refers to freight charges that the insured pays on behalf of the purchaser and for which the insured is reimbursed; essentially, a wash. Most firms record bad debts as a percentage of sales, based on long-term experience. This is an acceptable method to use when completing the form. Collection expenses include charges imposed by credit card companies. Returns and allowances and discounts are self-explanatory. Deducting E from A yields item F, Net Sales.

 

Other earnings from operations are added at item G. This includes rent from, perhaps, subletting a portion of the insured’s premises, but not rental income from other properties. Investment income is not included; investments will continue to produce income even if the insured’s premises are totally destroyed. Item H, the final total on page 2, is labeled “Total Revenue.” That’s something of a misnomer. It doesn’t include revenues from investments or from properties located at other premises.

 

Pages Three and Four: Financial Analysis Continued

 

The financial analysis continues on pages 3 and 4 (see Exhibit 4, p.26 & 27). The first item on page 3 is item H, Total Revenues, carried forward from page 2. The form then calls for a deduction for cost of goods sold, which is calculated on page 4. Nonmercantile firms, such as engineers, attorneys, even insurance agents, that do not sell any products do not have a cost of goods sold item in their financial statements. They can, therefore, omit this entire item.

Cost of Goods Sold Calculation

 

For mercantile nonmanufacturing firms, cost of goods sold is generally a large item; it can amount to 75 percent or more of revenues. The worksheet form entitled “Supplementary Information” on page 4, used to calculate cost of goods sold, follows standard accounting practice for nonmanufacturing firms: opening inventory plus net cost of goods purchased less closing inventory equals cost of goods sold. The fourth item in the calculation of cost of goods sold, “cost of merchandise sold,” can be misleading. All merchandise purchases, whether sold during the period or not, should be added. If only merchandise sold is added, the deduction of closing inventory will understate the costs of goods sold if any of the closing inventory includes merchandise that was purchased, but not sold, during the period. The resulting cost of merchandise sold amount is the first entry in item I, Deduct on page 3. The second item to be deducted on page 3 is cost of services purchased from outsiders (nonemployees) that do not continue under contract and that are resold by the insured. Given the level of outsourcing in business today, services purchased from others can be a large item. It could include work performed by contractors. For example, consider an alarm monitoring company that sells alarm equipment and provides monitoring service, but hires independent contractors to do the equipment installation. It could deduct the cost of the subcontracted work. This is an item that should be brought to the attention of the person.

 

Ordinary Payroll Limitation or Exclusion endorsement

 

Ordinary payroll is a very large expense for many firms. Ordinary payroll is defined in the form to mean the entire payroll expense (including employee benefits, workers compensation premiums, Federal Insurance Contributions Act [FICA] taxes paid by the employer, and union dues paid by the employer) for all employees of the insured except officers, executives, department managers, and employees under contract. Additional employees may be removed from the definition of ordinary payroll either by name or by job classification, giving the insured the flexibility to tailor the coverage to its needs.

 

The endorsement offers three options: 1) eliminate ordinary payroll entirely, 2) limit coverage to 90 days following the date of loss, or 3) limit coverage to 180 days following the date of loss. If the insured does not expect to continue paying ordinary payroll in the event of a loss and if the time needed to train employees when operations resume is not consequential, total elimination of ordinary payroll may substantially reduce the insured’s coinsurance basis and, therefore, the amount of insurance needed to comply with coinsurance.

 

The 90- and 180-day limitation options are appropriate for insureds that want some ordinary payroll coverage or that expect that the time needed to restore operations will be within those periods. The total elimination and the 90-day limitation both increase the business income rate. Therefore, the premium has to be calculated both with and without the endorsement so that the insured can see if the savings are worthwhile. There is no rate increase for the 180-day limitation, so if it is appropriate for the insured, there is no downside from the point of view of premium. If the 90- or 180-day limitations are selected, the deduction is based on the total ordinary payroll to the extent that it exceeds the ordinary payroll during the 90- or 180-day period with the highest ordinary payroll.

 

Even though the form defines business income for coverage purposes as “… continuing normal operating expenses incurred, including payroll” (emphasis added), insurers will not always agree to pay all ordinary payroll that the insured pays during the business income loss period. The loss determination provision in the business income form limits coverage as follows:

 

The amount of Business Income loss will be determined based on:

 

3. The operating expenses, including payroll expenses, necessary to resume ‘operations’ with the same quality of service that existed just before the direct physical loss or damage; (emphasis added) Insurers have argued, in many cases, that continuing ordinary payroll was not necessary to resume operations. One of the most famous disputes over continuing ordinary payroll involved the huge Malden Mills fire in 1995, which totally devastated the plant that produced the popular Polartec fabric. Immediately after the fire, Aaron Feuerstein, the controlling stockholder of Malden Mills, announced that he would continue payroll and benefits for all employees for 60 days because it was the right thing to do. Whether that was a necessary continuing expense was one of the issues in the dispute between Malden Mills and its insurers that was finally settled for $300 million, the largest industrial fire damage claim payout in Massachusetts history.8

 

To enable the insured and the insurer to settle this point in advance, ISO has introduced a Discretionary Payroll Expense endorsement (CP 15 04). This endorsement states that payroll expenses for the job classifications or employees identified in the endorsement’s schedule will be covered as continuing normal operating expenses, regardless of whether such expenses are necessary to resume operations. If an insured does not eliminate ordinary payroll, this endorsement should be brought to its attention. Otherwise, the insured may discover after a loss that coverage it thought it had purchased is not available because the insurer feels that some or all of the ordinary payroll expense it incurred during the period of restoration was not necessary to resume operations. In such a case, the insurer will undoubtedly argue that the failure of the insured to purchase the discretionary payroll endorsement supports its position.

 

Power, Heat, and Refrigeration Deduction Endorsement

 

The Power, Heat, and Refrigeration Deduction endorsement (CP 15 11) is available only for manufacturers. It enables a  extended business income. These are not part of the coinsurance basis; they are part of the estimated maximum loss, as discussed earlier.

 

The sum of items J and K, item L on the top of page 4, is described as 100 percent of the insured’s estimated 12-month business income exposure and additional expenses. Very few firms will have exactly a 12-month estimated period of restoration, and most of those will have expenses that will discontinue even though they couldn’t be deducted in the BI Worksheet. Therefore, item L it is not a very useful figure. Calculating the EML for the firm is by far the better procedure.

 

Differences for Manufacturing Firms

 

Two items are treated differently in the manufacturing columns as compared to the nonmanufacturing columns. For manufacturers, net sales must be converted to net production during the period, and the cost of goods sold calculation does not follow standard accounting procedure the way it does for nonmanufacturers. For a manufacturing firm, business income insurance covers loss of production rather loss of sales. The causes of loss form specifically excludes: “Any loss caused by or resulting from: (a) Damage or destruction of ‘finished stock’; or (b) The time required to reproduce ‘finished stock’.”

 

Finished stock is defined as stock that the insured has manufactured. Income loss arising from damage to finished stock can be covered by adding the Manufacturers Selling Price endorsement (CP 99 30) to the property policy.

 

Items B, C, and D in the left-hand columns in each pair of columns on page 2 are the simple calculations used to convert sales for a period to production during the period. The sales figure for goods manufactured by the insured is composed of goods manufactured prior to the policy period and goods manufactured during the policy period. To determine what portion of sales were accounted for by goods manufactured during the policy period, the inventory on hand at the beginning of the policy period is deducted. Since some goods are produced in the current policy period, but not sold, the finished stock inventory at the end of the policy period is added. The resultant total is the production during the policy period.

 

Converting Inventory Values

 

The one complication is that accounting records show inventories on a cost basis, whereas the worksheet is based on selling price. To find the sales value of production, those values have to be converted to a selling price basis. That’s done by dividing the inventory at cost by the cost of goods sold percentage. The cost of goods sold percentage is a key ratio for monitoring a firm’s operations. It is easily calculated by dividing the cost of goods sold by sales, as illustrated in Exhibit 6, Converting Inventory Values from Cost to Selling Price.

 

If inventory were valued at cost instead of at selling price in the example given in Exhibit 6, the sales value of production for the period would be incorrectly shown as $19,600,000. In most cases, as in this example, the difference between using cost instead of selling price is not great; in fact, if the opening and closing inventory values are the same, there will be no difference at all. When the difference between the opening and closing inventories is large, there will be a substantial difference. This might occur when production is shutdown for some time to work-off excess inventories, when a firm converts to just-in-time procurement, etc.

Adjusting Cost of Goods Sold

 

The second adjustment is usually more substantial. Although the ISO form calls the calculation “cost of goods sold” for both manufacturing and nonmanufacturing operations, it’s not what accountants mean by cost of goods sold for a manufacturing firm. The cost of goods sold deduction for manufacturers in the BI worksheet calls for deducting only raw materials and factory supplies consumed. From an accounting perspective, factory labor and factory overhead are also deducted to calculate the cost of goods sold for a manufacturing firm. A common error in preparing the form for a manufacturing firm is to insert cost of goods sold as shown in the firm’s accounting records in the first line in I, Deduct on page 3, which is labeled “cost of goods sold,” without going through the indicated calculations on page 4. Exhibit 7 shows the difference for a hypothetical manufacturer between using the amount shown for cost of goods sold in its accounting records rather than the amount derived from the calculation that is called for in the BI worksheet. As you can see, the difference can be substantial. A quick review of the insured’s P & L statement will show the error. If the cost of goods sold for a manufacturer in its P & L is the same as in the BI worksheet, the calculation is incorrect.

 

The other BI worksheet calculations for a manufacturer are the same as those for a nonmanufacturer. Summary

 

Selecting a coinsurance percentage for business income coverage is not intuitive. Business income coverage applies to net income and continuing expenses, but because the business income report/worksheet calls for deducting only certain expenses, some discontinued expense may be included in the coinsurance basis. The solution is to calculate an insured’s estimated maximum loss and relate it to the coinsurance basis.

 

The coinsurance basis is estimated using the BI worksheet. The form is completed on an accrual basis. The form consists of two sets of double columns, one set for the most recent fiscal year and one set for the policy year. One of the columns in each set is for manufacturing and the other is for nonmanufacturing, which includes nonmercantile firms such as lawyers, engineers, etc.

 

For nonmanufacturing risks, the calculation of coinsurance basis uses common accounting terminology, but in the calculation for manufacturing risks what the form calls “cost of goods sold” is not what accountants mean for manufacturer’s cost of goods sold. Manufacturers must also convert from sales to production when completing the form, as BI coverage applies to loss of production for a manufacturer. In addition to the listed deductions that are available to all insureds, insureds that elect Ordinary Payroll Limitation or Exclusion endorsement (CP 15 10) can eliminate all ordinary payroll or limit coverage to 90- or 180-day periods.

 

Manufacturers can elect the Power, Heat, and Refrigeration Deduction endorsement (CP 15 11) that eliminates power, heat, and refrigeration expenses except for those that continue under contract. A final section in the form contains some special calculations for mining properties.

 

Estimating maximum loss and completing the business income worksheet can be complex. However, when it’s done properly, the result is proper and cost-effective coverage.

 

Endnotes

 

1. In 1986, as part of simplified wording revisions, ISO changed the title of this coverage from business interruption to business income. Business interruption is still widely used to refer to this coverage, but, as we’re discussing an ISO form, we’ll use business income or the acronym BI, which works for either, but which, unfortunately, is also used in liability insurance to mean bodily injury.

 

2. Wanner Metal Worx, Inc., Etal. vs. Hylant- Maclean, Inc., 2003 Ohio 1814, 2003 WL 1826558 (Ohio App. 2003).

 

3. The Business Insurance Premium Adjustment Endorsement is an interesting approach to the coinsurance problem. While the endorsement doesn’t suspend coinsurance, the insured can set the amount of insurance high enough to be certain that there will be no coinsurance penalty and that a refund of the portion of the premium that was based on unnecessary coverage will be provided. At the end of the period, the insured submits the report/worksheet; the amount of insurance actually needed is determined and the premium charge adjusted to that amount. Any excess over the deposit premium is returned to the insured. No additional premium is charged because coinsurance was not suspended. The one defect of the form is the inclusion of an additional limit on recovery. This added limitation is based on the net income and operating expenses that the insured would have experienced, had no loss occurred, during the 12 months following the date of the physical loss or damage. That sum is multiplied by the coinsurance percentage shown in the declarations. If the result is smaller than the stated limit of insurance or the full reporting limitation, that smaller result is the most that the insurer will pay. This limitation can result in a lower amount of coverage being this endorsement were not included in the policy. This limitation does not apply when the 125 percent coinsurance option is selected.

 

However, 125 percent coinsurance is rarely the best choice for an insured; it would be sensible only when the maximum expected loss is higher than the coinsurance basis. Since few insureds elect 125 percent coinsurance, the premium adjustment endorsement is seldom used.

 

4. For examples of individual company forms see: Liberty Mutual, https://property.libertymutual.com/Marketing/ pages/BItraining/bi_worksheet_proper_income_ values.html; Travelers, http://www.travelers.com/iwcm/trv/docs/BINo nManufacturers.pdf; Chubb, http://www.specialtybrokerageservices. com/pdf/Innovator%20 BI%20Software%20Worksheet.pdf.

 

5. I have used EML rather than PML (probable maximum loss), which is usually defined to be the largest loss expected if all loss prevention facilities works as expected, or MFL (maximum foreseeable loss), which is the largest loss expected if loss prevention does not function, to indicate that this is an area that the insured and his advisers should discuss to develop an appropriate estimate that fits the insured’s comfort level.

 

6. For additional information on the topic, see Trupin, Jerome, and Arthur Flitner, Commercial Property Risk Management and Insurance, 8th Edition, (American Institute for CPCU, Malvern, PA, 2008): Chapter 8, on which this material is based, and Trupin, Jerome, and Arthur Flitner “Magnum BI,” American Agent and Broker ( January 2010).

 

7. Source: http://en.wikipedia.org/wiki/United_States.

 

8. “The Mensch of Malden Mills,” CBS, 60 Minutes ( July 3, 2003), available at www.cbsnews.com/stories/2003/07/03/60min utes/main561656.shtml.