First American Enterprises d/b/a Heritage Lakeside

National Labor Relations Board - Administrative Judge Opinions

Feb 7, 2019

18-CA-211284 (N.L.R.B. Feb. 7, 2019)

JD–16–19
Rice Lake, WI
UNITED STATES OF AMERICA
BEFORE THE NATIONAL LABOR RELATIONS BOARD
DIVISION OF JUDGES
FIRST AMERICAN ENTERPRISES d/b/a
HERITAGE LAKESIDE
and Case Nos. 18-CA-211284
18-CA-212666
UNITED FOOD AND COMMERICAL 18-CA-216776
WORKERS UNION LOCAL 1189 18-RC-212417
Rachel M. Simon-Miller and Florence Brammer, Esqs.
for the General Counsel.
Robert S. Driscoll and Christopher Schuele, Esqs.
(Reinhart Boerner Van Deuren, S.C), Milwaukee, Wisconsin, for the Respondent.
DECISION
STATEMENT OF THE CASE
ARTHUR J. AMCHAN, Administrative Law Judge. This case was tried in Rice Lake,
Wisconsin on December 12, 2018. UFCW Local 1189 filed the charges in this matter on
December 7, 2017, January 8, 2018 and March 19, 2018. The General Counsel issued the
consolidated complaint on June 27, 2018, and consolidated Case 18-RC-212417 with the unfair
labor practice cases for hearing.
Prior to July 2017, First American Enterprises operated 2 nursing homes in the Rice
Lake, Wisconsin vicinity.1 The Union represented the cooks, dietary aides, activity aides,
housekeeping personnel and certified nursing assistants at one these, Heritage Lakeside, formerly
known as the Rice Lake Convalescent Center. The other facility, Heritage Manor, was not
unionized.

1 In December 2018 Health Dimensions Group managed Heritage Lakeside. First American was only
a conservator.
JD–16–19
2
Between July and October 2017, First American consolidated the nursing homes, moving
most of the patients and employees from Heritage Manor to Heritage Lakeside. It closed
Heritage Manor. On December 4, 2017, Respondent withdrew recognition from the Union,
stating that 47 of the its then bargaining unit employees had come from Heritage Manor and only 5
23 were from the unionized Heritage Lakeside home.
On January 2, 2018, Local 1189 filed a representation petition. A Board election was
conducted on February 1, 2018. The ballots were impounded until March 8. The tally
conducted on that date established that 25 votes were cast for the Union and 25 votes against it. 10
On March 15, the Union filed objections to conduct affecting the results of the election. The
Regional Director ordered a hearing on union objections 1 (Respondent forced employees to sign
a new policy prohibiting discussion of the Union in the workplace) and 3 (unlawful interrogation
and instructing employees to vote if they intended to vote against union representation). These
objections mirror complaint paragraphs 5(c)-5(h).15
On the entire record, including my observation of the demeanor of the witnesses, and
after considering the briefs filed by the General Counsel and Respondent, I make the following
FINDINGS OF FACT20
I. JURISDICTION
First American, a Minnesota corporation, operated Heritage Lakeside, a long-term care
facility in Rice Lake, Wisconsin. Heritage Lakeside is now managed by another business entity.225
Heritage Lakeside annually derives revenues in excess of $100,000. Heritage Lakeside purchases
and receives goods valued in excess of $50,000 directly from points outside of Wisconsin.
Heritage Lakeside admits, and I find, that it is an employer engaged in commerce within the
meaning of Section 2(2), (6), and (7) of the Act and that the Union is a labor organization within
the meaning of Section 2(5) of the Act. 30
II. ALLEGED UNFAIR LABOR PRACTICES
Complaint paragraph 5(a) and (b), August 2017 alleged interrogation and threats
35
The test as to whether an employer’s statement or conduct violates Section 8(a)(1) is whether
it may reasonably be said that the conduct or statement tends to interfere with employee rights
under the Act. The employer’s motive in making the statement or engaging in the conduct is
irrelevant to whether it violated Section 8(a)(1), American Freightways Co., Inc., 124 NLRB
146, 147 (1959).40

2 By Respondent, I mean Heritage Lakeside, regardless of who owned that facility.
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3
Darla Buesser, a current employee and activity aide, was one of 2 union stewards at
Heritage Lakeside. In August 2017, Buesser approached Carolyn Hafele, a dietary aide, and
urged her to sign an application for union membership.3 Buesser told Hafele that the Union was
the only thing that would save her job when Heritage Manor and Heritage Lakeside merged. 5
Buesser warned Hafele that employees transferring from Heritage Manor had greater seniority
than Hafele and that as a result, Hafele might lose her job without the Union.
Hafale was concerned about losing her job in the merger, but it is unclear whether she
had communicated this to Buesser. Hafele filled out the application, which included 10
authorization for Respondent to deduct union dues from her paycheck She gave the completed
application to Buesser who turned it in to Respondent’s business manager, Jackie Damaske-
Frame.
Afterwards, Sarah Noggler, then Hafale’s supervisor, told Hafale that she did not need to 15
join the Union and that Hafale should have talked to Noggler before joining. Hafale then went to
Jackie Damaske-Frame and asked if it was too late to stop the dues deduction.
Two days later, Respondent’s administrator, Derek Joswiak, called Hafale into his office.
He told her that Noggler and Jackie Damaske-Frame should not have been talking to her about 20
joining the Union. He said he would have to get back to her about the dues cancellation. Hafale
told Joswiak that Buesser had told her that only the Union could save her job. Joswiak told
Hafale she had nothing to worry about. There is no credible evidence that Hafale told anyone
that Buesser told her she would be fired if she did not join the Union.
25
About a week later, Joswiak approached Buesser and took her into an empty room.
Joswiak told Buesser that Hafale had told him that Buesser had told Hafale that she would be
fired if she did not join the Union. Buesser denied this. Joswiak told Buesser that he believed
her. Joswiak also told Buesser that he had spoken to his boss, Eric Everson, and that Everson
also did not believe that Buesser had told Hafale that she would be fired if she did not join the30
Union.4 Joswiak asked Buesser to keep their conversation confidential.
A week later, Buesser met with Joswiak, Everson and Carolyn Hafale. Either Joswiak or
Everson or both asked Hafale if she still wanted to belong to the Union; Hafale said that she did
and would leave her union application alone.35
The lead Board case regarding the legality of interrogations is Rossmore House, 269
NLRB 1176 (1984), affd. 760 F.2d 1006 (9th Cir. 1985). Pursuant to the Rossmore test,
[I]t is [well established] that interrogations of employees are not per se unlawful40
but must be evaluated under the standard of “whether under all the circumstances
the interrogation reasonably tended to restrain, coerce, or interfere with rights
guaranteed by the Act.”

3 Hafale voluntarily left Respondent’s employ in March 2018.
4 There is no evidence as to how Buesser’s conversation with Hafele came to Erickson’s attention.
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4
In making that determination, the Board considers such factors as the background, the
nature of the information sought, the identity of the questioner, the place and method of
interrogation, and whether or not the employee being questioned is an open and active union
supporter, Norton Audubon Hospital, 338 NLRB 320, 320-321 (2002).
5
I find the violation alleged in complaint paragraph 5(a) (i), but not the allegations in
5(a)(ii) and 5(b). There is no evidence that Carolyn Hafele told Administrator Derek Joswiak
that Darla Buesser told her that she would be fired if she did not join the Union. Thus, I find that
it was highly coercive for Joswiak to summon Buesser into an empty room by herself and pass
that accusation along to Buesser. It was also highly coercive for Joswiak to tell Buesser that he 10
had discussed this unfounded allegation with his boss, Erik Everson. Regardless of the fact that
Joswiak told Buesser that he believed her denial and that Everson also gave no credence to the
allegation, this conversation would necessarily inhibit Buesser from advocating union
membership to fellow employees. Thus, I find that Respondent, by Joswiak, violated Section
8(a)(1) in this conversation with Buesser.15
However, I do not find that Joswiak violated the Act by telling Buesser to keep their
conversation confidential. He had not disciplined Buesser which distinguishes this case from
those cited by the General Counsel.
20
I also find that Respondent did not violate the Act in asking Hafele whether she still wanted
to be a union member. Hafele had asked Respondent not to deduct union dues. It was
reasonable and not coercive for Joswiak under the circumstances to ask Hafele what she wanted
him to do about the dues deduction.
25
Complaint paragraph 5(c) & (d) & (f)(i) and (ii)
Kayla Anderson was employed as a dietary aide and cook at Heritage Manor from about
July 2014 until August 2017, when she was transferred to Heritage Lakeside. She quit her
employment voluntarily in October 2018. Several times after the representation petition was 30
filed on January 2, 2018, Dietary Manager Melissa Kern came into the home’s kitchen and told
employees that Respondent needed them to vote against union representation. Anderson told
Kern that she had taken off for February 1, did not really care about the outcome of the election
and did not want to come into work. Kern pressed Anderson about coming to work to vote on
February 1 to the point that Anderson thought Kern was threatening her job.35
Carolyn Hafele testified that in early January, Kern asked Anderson and Lilly Swanson
how they planned to vote and that Kern asked 2 other employees on election day how they voted.
Hafele also testified that Kern immediately recorded this in a notebook she was carrying. Kern
denies this. Both Anderson and Swanson testified and neither stated that Kern asked them how 40
they planned to vote. On account of this, I decline to credit Hafele and decline to find that Kern
asked any employees how they planned to vote or how they voted.5 I dismiss all allegations
regarding interrogations by Kern or surveillance of union activities by Kern.

5 The two other employees, high school students who apparently worked part-time, did not testify.
Due to the lack of corroboration of Hafele’s testimony by Anderson and Swanson, I also decline to credit
her testimony regarding Kern’s alleged inquiries to the 2 high school students.
JD–16–19
5
Complaint paragraph 5(e,), (g) and (h): implementation of new policy prohibiting other than
“resident-centered” conversations in working areas and accompanying threats.
On January 7, 2018, Certified Nursing Assistant (CNA) LeeAnn Stevens and Darla 5
Buesser had a brief conversation near a nurse’s station. They discussed the need to make all
employees aware of an upcoming union meeting. Patti Urmanski, a charge nurse, was nearby
when this conversation occurred.6
The next day, January 8, 2018, Kristina Taylor, Respondent’s Director of Nursing10
(DON), required employees to attend a brief meeting. At this meeting she told them that she did
not want to hear any talk in the facility unless it was resident-related. Taylor then required the
employees to sign a QCM Form stating, “The only conversation that needs to be heard/discussed
on the floor, in resident’s rooms, dining rooms is resident-centered. Any other topics are not
appropriate and can be discussed on your breaks or your own time.” Approximately 50 of the 15
approximately 70 unit employees were required to sign a QCM Form either by Taylor or other
managers, G.C. Exhs. 4(a)-4(e).
There is no evidence that any Heritage Lakeside employee was aware of the “resident-
centered conversation” rule prior to January 8, 2018. LeeAnn Stevens, Carolyn Hafele and 20
Amber Morgan credibly testified that they had never seen such a written rule, were unaware of
any company policy regarding what could be discussed at the nurses’ station or, of such a rule
being enforced previously.
Respondent was strongly opposed to having the Union represent Heritage Lakeside 25
employees. In January 2018, it posted a flyer that said as much, G.C. Exh. 3. Respondent also
held 3 mandatory meetings for employees in which it encouraged them to vote against union
representation. For these reasons I conclude that the new conversation rule was precipitated by
the upcoming union election, not any inappropriate conversations amongst nurses in front of
residents. As such I find that this change in policy was a violation of Section 8(a)(1), Dayton 30
Hudson, 316 NLRB 477 (1995) at 478 and 486, Nashville Plastic Products, 313 NLRB 462
(1993). Even if I were credit DON Taylor that this rule or policy predated the filing of the
representation petition, it is apparent that the rule was widely disseminated to employees for the
first time and enforced only after the filing of the representation petition of January 2. Therefore,
the rule was established and/or broadly disseminated and/or enforced for the purpose of 35
interfering and restraining employees in the exercise of their Section 7 rights. As alleged in

6 While it is unclear as to whether Respondent’s awareness of the Stevens-Buesser conversation
precipitated the new rule discussed herein, I infer its promulgation was related to the union organizing
drive and the upcoming election. I specifically discredit the testimony of Director of Nursing Kristina
Taylor that the rule dissemination was precipitated by her learning that 2 CNAs were discussing their
boyfriends in front of a resident. If that were the case there would be no need to have the entire nursing
staff acknowledge the rule in writing and no need for a rule that was so broadly worded. Moreover,
Taylor did not mention this “inappropriate” conversation to employees when meeting with them the next
day. The fact that Respondent did not offer employees any explanation for the promulgation of this rule
or its timing, a week after the representation petition was filed, gives rise to an inference that
promulgation was unlawful and intended to interfere with employees’ Section 7 rights, Shore and Ocean
Services, 307 NLRB 1051 (1992).
JD–16–19
6
complaint paragraph 5(g) and (h), promulgation of the rule therefore violated Section 8(a)(1) of
the Act,
In addition, Taylor’s statements to employees when promulgating or disseminating the rule
violated the Act as alleged in complaint paragraph 5(e) per the long-standing principles 5
enunciated in American Freightways. By requiring the majority of the bargaining unit to sign the
QCM form, and her verbal statements, Taylor was strongly suggesting that disciplinary action
would be taken if employees violated the newly disseminated and illegal rule.
The illegality of the rule and Taylor’s statements are not in any way negated by the 10
admission of former employee Kayla Anderson that she was aware that having inappropriate
conversations in front of residents was part of an employee’s role as a health care provider. That
a nurse might understand that he or she should not talk about the employee’s sex life or the
resident’s medical condition in front of the patient does not mean that an employee could not talk
about wages, hours and working conditions (including the desirability or not of union 15
membership) in front of residents so long as it did not interfere with the quality of care rendered.
The promulgation of Respondent’s “resident-centered” conversation rule, in of itself,
warrants ordering a new election.
20
The Board’s usual policy is to direct a new election whenever an unfair labor practice occurs
during the critical period. However, the Board has departed from this policy in cases where it is
virtually impossible to conclude that the misconduct could have affected the election results. In
determining whether the misconduct could have affected the election result, the Board has
considered the number of violations, their severity, the extent of dissemination, the size of the 25
unit and other relevant factors, Clark Equipment Co., 278 NLRB 498, 505 (1986).
In this instant case, there are many factors supporting an order for a second election: the
timing of the unfair labor practice, starting a little more than 3 weeks before the election and
continuing throughout the critical period; the closeness of the election result (25-25); the 30
dissemination of Respondent’s illegal policy to about 70% of the bargaining unit; and the
identity of the officials committing the violation, i.e., the director of nursing and the dietary
department manager.
Complaint paragraph 5(f) (iii)35
Melissa Kern told Lily Swanson and Carolyn Hafele that if they voted for the Union, they
were saying that she was a bad boss. Kern testified that she told a group of employees that if she
was a fair boss, there was no need for a union. The General Counsel alleges that Kern’s remark
to Hafele, Swanson and others is an illegal threat that a vote for the Union is incompatible with 40
having a good relationship with their supervisor. I do not find any precedential support for the
proposition that Kern’s statements violate Section 8(a)(1). Therefore, I dismiss complaint
paragraph 5(f)(iii).
JD–16–19
7
Complaint paragraph 5(i)
Respondent’s employee handbook contains the following rule:
5
Rice Lake Convalescent Center has various types of confidential business information
which must be protected. Such confidential information includes, but is not limited to,
the following examples…All personnel file information, employee names, addresses,
home phone numbers, salary or wage information, medical data and any other
information about our employees.10
The legality of Respondent’s confidentiality rule is governed by the Board’s recent decision
in The Boeing Company, 365 NLRB No. 154 (2017). In Boeing, the Board delineated 3
categories of “rules.” Category 1 rules are those which are lawful because they either (1) do not
prohibit or interfere with employee Section 7 rights when reasonably interpreted, or (2) the 15
employer’s justification for the rule outweighs the potential adverse impact on protected rights.
Category 2 rules are those which warrant individualized scrutiny as to whether they prohibit or
interfere with section 7 rights and whether legitimate justifications outweigh any adverse impact
on these employee rights. Category 3 rules are those which are unlawful because the
justification for their maintenance does not outweigh their adverse impact on employee Section 7 20
rights. A rule which is not unlawful to maintain, may be unlawful as applied. However,
application of Respondent’s rule is not an issue in this case.
DON Kristina Taylor testified that the rule is intended to insure that the business office
not divulge personal information. I do not find that explanation credible because if that was 25
Respondent’s concern, it would not have put the rule in a handbook applicable to all employees.
Moreover, it never informed employees that the rule was applicable only to office personnel.
Finally, the rule is not limited to personnel file information, it prohibits disclosure of “any other
information about our employees.”
30
Respondent argues in its brief at page 7 that no employee would reasonably interpret this
rule to prohibit discussion of wages. It contends that since employees would not conclude that it
violated the rule to tell each other their names or phone numbers, they would not reasonably
believe they were prohibited from discussing wages. I find this argument unpersuasive. The
likely understanding of this rule would be that employees are not to discuss their wages or other 35
employees’ wages regardless of whether they are free to exchange names, addresses and phone
numbers. Finally, Respondent has no legitimate business justification to prohibit employees
from discussing salary or wage information, thus the rule, as written, violates Section 8(a)(1).
Alleged illegal threats to employees that Respondent needed them to vote against union 40
representation (complaint paragraph 5(d) and 5(f)
As a general rule, an employer does not violate the Act by encouraging employees to vote
against union representation, or seeking the help of employees to convince others to vote against
union representation. The Board has on at least on one occasion found such encouragement or45
solicitation of “no” votes to violate the Act in the context of other unfair labor practices, Modern
JD–16–19
8
Manufacturing Company, 261 NLRB 534-35 (1982). I see no reason to depart from the general
rule in this case and therefore dismiss complaint paragraphs 5(d) and 5(f) insofar as they allege
that such solicitation for “no” votes was illegal.7
Summary of Conclusions of Law5
I find that Respondent violated the Act in the following respects and no others:
On August 17, 2017, Respondent, by Administrator Derek Joswiak, violated Section 8(a)(1)
by interrogating Darla Buesser about a union-related a conversation with Carolyn Hafele.10
On or about January 8, 2018, Respondent, by Director of Nursing, Kristina Taylor, violated
Section 8(a)(1) by threatening employees not to engage in union activity.
On January 8, Respondent violated Section 8(a)(1) by promulgating, or for the first time, 15
disseminating and/or enforcing a rule forbidding conversations in work areas other than those
that are “resident-centered.”
Respondent’s “Non-disclosure” policy in its Employee Handbook violates Section 8(a)(1) in
so far as it prohibits employees from discussing salary or wage information.20
Recommendations Regarding Objections
I recommend that the election be set aside and remanded to the Regional Director for the
purpose of conducting a second election since the Respondent committed a significant unfair 25
labor practice during the critical period. By this I mean its promulgation, dissemination and
enforcement of the “resident-centered” conversation rule. Additionally, during the critical period,
Respondent impliedly threatened employees with discipline if they violated this rule.
REMEDY30
Having found that the Respondent has engaged in certain unfair labor practices, I shall
order it to cease and desist therefrom and to take certain affirmative action designed to effectuate
the policies of the Act.

7 Thus, while I credit Carolyn Hafele’s testimony that Melissa Kern tried to get her assistance in
convincing Lily Swanson to vote “no,” I find this did not violate the Act.
JD–16–19
9
On these findings of fact and conclusions of law and on the entire record, I issue the
following recommended8
ORDER5
The Respondent, Heritage Lakeside, Rice Lake Wisconsin, its officers, agents,
successors, and assigns, shall
1. Cease and desist from10
(a) impliedly threatening employees with discipline if they engage in union or otherwise
protected discussions in work areas.
(b) promulgating and/or disseminating and/or enforcing a rule in reaction to a union 15
organizing campaign that forbids union or other protected conversations in work
areas.
(c) interrogating employees as to their conversations soliciting support from other
employees for the Union.20
(d) maintaining a rule in its employee handbook that can reasonably be read to prohibit
employees from discussing salary and wage information.
(e) In any like or related manner restraining or coercing employees in the exercise of the 25
rights guaranteed them by Section 7 of the Act.
2. Take the following affirmative action necessary to effectuate the policies of the Act.
(a) Rescind its rule prohibiting any conversations in work areas that are not “resident-30
centered.”
(b) Rescind or revise its employee handbook rule to clarify that employees are not
prohibited from discussing salary and wage information with each other—unless that
information had been obtained as a result of their access to official personnel files.35

8 If no exceptions are filed as provided by Sec. 102.46 of the Board’s Rules and Regulations, the
findings, conclusions, and recommended Order shall, as provided in Sec. 102.48 of the Rules, be adopted
by the Board and all objections to them shall be deemed waived for all purposes.
JD–16–19
10
(c) Within 14 days after service by the Region, post at its Rice Lake, Wisconsin facility
copies of the attached notice marked “Appendix.”9 Copies of the notice, on forms
provided by the Regional Director for Region 18, after being signed by the 5
Respondent’s authorized representative, shall be posted by the Respondent and
maintained for 60 consecutive days in conspicuous places including all places where
notices to employees are customarily posted. In addition to physical posting of paper
notices, the notices shall be distributed electronically, such as by email, posting on an
intranet or an internet site, and/or other electronic means, if the Respondent 10
customarily communicates with its employees by such means. Reasonable steps shall
be taken by the Respondent to ensure that the notices are not altered, defaced, or
covered by any other material. In the event that, during the pendency of these
proceedings, the Respondent has gone out of business or closed the facility involved
in these proceedings, the Respondent shall duplicate and mail, at its own expense, a 15
copy of the notice to all current employees and former employees employed by the
Respondent at any time since August 17, 2017.
(d) Within 21 days after service by the Region, file with the Regional Director a sworn
certification of a responsible official on a form provided by the Region attesting to the 20
steps that the Respondent has taken to comply.
Dated, Washington, D.C. February 7, 2019
25

Arthur J. Amchan
Administrative Law Judge

9 If this Order is enforced by a judgment of a United States court of appeals, the words in the notice
reading “Posted by Order of the National Labor Relations Board” shall read “Posted Pursuant to a
Judgment of the United States Court of Appeals Enforcing an Order of the National Labor Relations
Board.”
c/A,/,.^. av„,a,,,_
JD–16–19
APPENDIX
NOTICE TO EMPLOYEES
Posted by Order of the
National Labor Relations Board
An Agency of the United States Government
The National Labor Relations Board has found that we violated Federal labor law and has
ordered us to post and obey this notice.
FEDERAL LAW GIVES YOU THE RIGHT TO
Form, join, or assist a union
Choose representatives to bargain with us on your behalf
Act together with other employees for your benefit and protection
Choose not to engage in any of these protected activities.
WE WILL NOT impliedly threaten employees with discipline if they engage in
conversations that are not “resident-centered” in work areas.
WE WILL NOT interrogate employees about their conversations in which they seek to
encourage other employees to support United Food and Commercial Workers Local 1189 or any
other union.
WE WILL NOT in any like or related manner restrain or coerce employees in the
exercise of the rights guaranteed them by Section 7 of the Act.
WE WILL, rescind our rule forbidding conversations in work areas that are not
“resident-centered.”
WE WILL, rescind or revise our employee handbook so as to make clear that employees
are allowed to discuss salary and wage information unless they have acquired such information
from their access to other employees’ personnel files.
FIRST AMERICAN ENTERPRISES d/b/a
HERITAGE LAKESIDE
(Employer)
Dated By
(Representative) (Title)
JD–16–19
The National Labor Relations Board is an independent Federal agency created in 1935 to enforce the National Labor
Relations Act. It conducts secret-ballot elections to determine whether employees want union representation and it
investigates and remedies unfair labor practices by employers and unions. To find out more about your rights under
the Act and how to file a charge or election petition, you may speak confidentially to any agent with the Board’s
Regional Office set forth below. You may also obtain information from the Board’s website: www.nlrb.gov.
Towle Building, Suite 790, 330 Second Avenue South, Minneapolis, MN 55401-2221
(612) 348-1757, Hours: 8 a.m. to 4:30 p.m.
The Administrative Law Judge’s decision can be found at www.nlrb.gov/case/18-CA-211284 or by using the
QR code below. Alternatively, you can obtain a copy of the decision from the Executive Secretary, National
Labor Relations Board, 1015 Half Street, S.E., Washington, D.C. 20570, or by calling (202) 273-1940.
THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE
THIS NOTICE MUST REMAIN POSTED FOR 60 CONSECUTIVE DAYS FROM THE DATE OF POSTING AND MUST NOT BE
ALTERED, DEFACED, OR COVERED BY ANY OTHER MATERIAL. ANY QUESTIONS CONCERNING THIS NOTICE OR
COMPLIANCE WITH ITS PROVISIONS MAY BE DIRECTED TO THE ABOVE REGIONAL OFFICE’S
COMPLIANCE OFFICER, (414) 930-7203.