Gaylord Chemical Co. LLC

National Labor Relations Board - Administrative Judge Opinions

Aug 18, 2011

10-CA-038782 (N.L.R.B. Aug. 18, 2011)

JD–47–11
Tuscaloosa, AL
UNTED STATES OF AMERICA
BEFORE THE NATIONAL LABOR RELATIONS BOARD
DIVISION OF JUDGES
GAYLORD CHEMICAL CO., LLC
and Case: 10–CA–38782
UNITED STEELWORKERS INTERNATIONAL
UNION AND ITS LOCAL 887
Kerstin I. Meyers, Esq., for the General Counsel.
Jeffrey A. Schwartz, Esq., (Jackson Lewis LLP),
of Atlanta, Georgia, for the Respondent.
Glen M. Connor, Esq., (Quinn, Connor, Weaver,
Davies & Rouco, LLP), of Birmingham,
Alabama, for the Charging Party.
DECISION
Statement of the Case
IRA SANDRON, Administrative Law Judge. This matter arises out of a complaint
and notice of hearing issued on April 29, 2011, against Gaylord Chemical Company,
LLC (the Respondent or the Company), stemming from unfair labor practice (ULP)
charges filed by the United Steelworkers International Union (USW International) and its
Local 887 (collectively, the Union).
Pursuant to notice, I held a trial in Birmingham, Alabama, on June 27 and 28,
2011, at which I afforded the parties full opportunity to be heard, to examine and cross-
examine witnesses, and to introduce evidence.
Issues
1) Since on about October 25, 2010,1 has the Respondent violated Section
8(a)(5) and (1) of the National Labor Relations Act (the Act) by unlawfully
failing and refusing to recognize and bargain with the Union as the collective-
bargaining representative of unit employees following the Respondent’s
relocation of operations from Bogalusa, Louisiana, to Tuscaloosa, Alabama?

1 All subsequent dates occurred in 2010, unless otherwise indicated.
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2) Since the same date, has the Respondent violated Section 8(a)(5) and (1) by
failing and refusing to provide the Union with information that it had
requested that was relevant and necessary for the Union’s performance
of its duties as the collective-bargaining representative of those employees?
3) Did the Respondent violate Section 8(a)(5) and (1) by creating the new unit
job position of “Lead Shipper” in about January 2011, without providing the
Union prior notice and an opportunity to bargain?

4) Did Marc Smith, Vice President/Manufacturing, in about late September and
on October 25, violate Section 8(a)(1) by interrogating employees about their
union sympathies?
Witnesses and Credibility
The General Counsel called union representatives Daniel Flippo, district director
for District 9, and Michael Tourne, a USW International staff representative; and
employees Doug Mitchell, Wendell Sullivan, and Ronald Talley, all transferees from
Bogalusa to Tuscaloosa. All of the General Counsel’s witnesses appeared
straightforward in demeanor and in their recitation of events, and none displayed any
hints of attempts to embellish or otherwise skew their testimony.
The Respondent called no witnesses, despite the fact that Smith was present
throughout as the Respondent’s designated representative pursuant to my
sequestration order. The Respondent’s failure to call Smith or other
managers/supervisors involved in the events underlying the allegations must be
deemed to raise the suspicion that their testimony would not have controverted that of
the General Counsel’s witnesses and been unfavorable to the Respondent’s case. I
therefore draw an adverse inference against the Respondent on these matters. See
Palagonia Bakery Co., 339 NLRB 515, 538 (2003); Dalikichi Sushi, 335 NLRB 622, 622
(2001); International Automated Machines, 285 NLRB 1122, 1123 (1987), enfd. mem
861 F.3d 730 (6th Cir. 1988).
Accordingly, I credit the testimony of the General Counsel’s witnesses. I note
that most of the salient facts in this case are undisputed, in large measure due to the
parties’ wide range of documentary and factual stipulations.2
Facts
Based on the entire record, including testimony and my observations of witness
demeanor, documents, and stipulations, as well as the helpful posttrial briefs that all
three parties filed, I find the following.
The Respondent is a Louisiana limited liability corporation with an office and
place of business in Tuscaloosa, Alabama, where it is engaged in the business of
manufacturing dimethyl sulfaxide (DMSO). The Respondent has admitted jurisdiction,

2 Jt. Exhs. 1(a)–13.
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and I so find.
For decades prior to 2010, the Respondent’s chemical plant (the plant or the
facility) was located in Bogalusa, Louisiana, and the Union—the USW International and
its designated local union—represented a unit of all production and maintenance hourly
paid workers employed there. The local union’s number designation and the ownership
of the facility have changed through the years.
In terms of the Union’s structure, there are two types of locals. The first is an
amalgamated local, a smaller unit that is part of a “mother local,” which handles its
finances; the second is a full-fledged independent local. Locals report to districts, which
are divided for administrative purposes into sub-districts. The districts report directly to
the USW International. There are 13 districts nationwide, as established by the USW
International’s executive board and constitution, as amended on July 1, 2008: Alabama
comes under the jurisdiction of District 9, whereas Louisiana is under District 13.3
On September 1, 2007, the Respondent purchased the facility from its
predecessor, Temple Inland. Their purchase agreement provided that the lease on the
Bogalusa plant would expire, and the parties anticipated that the operations would be
relocated.
On July 31, 2007, the Respondent and the Union entered into a memorandum of
agreement (MOA), providing that the Respondent would honor the provisions of the
existing labor agreement, with certain modifications and changes.4
In about February 2009, the Respondent informed employees that it was closing
the Bogalusa facility and was opening a new facility in Tuscaloosa. In the same time
period, the Respondent extended job offers to all employees in the Bogalusa bargaining
unit who were willing to relocate to Tuscaloosa.
On March 29, 2009, the Respondent and the Union signed a new collective-
bargaining agreement, effective through August 31, 2011, or the cessation of operations
at the Bogalusa facility (with certain qualifications not here relevant).5 Representatives
of the USW International, District 13, and Local 13-189 (an amalgamated local) signed
on behalf of the Union. The parties, on about March 27, 2009, also entered into an
MOA providing, inter alia, that employees would enjoy continued employment during
and after relocation.6 As in negotiations for the 2007 MOA, Tourne participated in
negotiations for these agreements and signed as a representative of the International.
On September 6, the Respondent began the process of closing its Bogalusa
facility and relocating its equipment, supplies, materials and products to Tuscaloosa.
The entire relocation process took approximately 108 days. The Tuscaloosa facility
began producing DMSO, the sole product manufactured at the plant, on December 16.

3 See GC Exh. 13 at 5–6.
4 Jt. Exh. 1(b).
5 Jt. Exh. 2.
6 Jt. Exh. 3.
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The Bogalusa plant closed in about January 2011.
As early as the week ending September 11, unit employees from Bogalusa
began relocating to Tuscaloosa. By the week ending October 30, 12 of approximately
18 unit employees from Bogalusa had permanently transferred to the Tuscaloosa
facility. They perform job functions substantially similar to those they performed in
Bogalusa. Two other employees have been hired to work at the plant. The Respondent
concedes that the Tuscaloosa plant operates in basically unchanged form and that it
continues to employ as a majority of its employees individuals who were previously
employed at its Bogalusa facility.7
At the Union’s request, I conducted an in camera inspection of eight
authorization cards from current employees that are in the Union’s possession. One
was undated, one was dated January 27, 2011; two were dated February 2, 2011; two
were dated February 3, 2011; one was dated February 8, 2011; and one was dated
February 10, 2011.
Union Requests to Bargain and for Information
Flippo, the Union’s District 9 director, sent an August 31 letter to Smith and Paul
Dennis, the Respondent’s president and chief executive officer. He stated that the
Union understood a majority of employees at Tuscaloosa were from the Bogalusa unit,
and he requested bargaining, as well as a list of names, job classifications, seniority
dates, rates of pay and benefits for unit employees.8 He sent them a similar letter,
again requesting bargaining and the same information, on September 23.9
By September 30 letter, Dennis asked Flippo what District 9’s legal basis was for
asserting that it was the employees’ bargaining representative.10
By letter of October 19 to Dennis and Smith, Flippo stated that the USW
International was the certificated bargaining representative.11 He again requested
bargaining and once more requested the information for which he had asked in the
letters referenced above, as well as information concerning, inter alia, 1) criteria used to
transfer employees; 2) compensations package to employees who had relocated; 3)
wage rates and classifications at both facilities; 4) wages paid to each employee; 5)
overtime hours; 6) job descriptions/and or job duties, departments, and classifications;
7) compliance with OSHA standards and reporting requirements; 8) cost of medical and
other insurance; 9) all plant rules and regulations; 10) various leave amounts and
costs; 11) bonuses; 12) workers’ compensations programs; 13) amount and cost of
safety equipment; 14) any other fringe benefits; and 15) most recent EEO-1 report filed.
Flippo testified that he wanted the information so that his staff could prepare to

7 See Jt. Exh. 11, showing that of the 14 current unit employees, 12 came from Bogalusa.
8 Jt. Exh. 4.
9 Jt. Exh. 5.
10 Jt. Exh. 6.
11 Jt. Exh. 7.
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negotiate a collective-bargaining agreement for the Tuscaloosa facility, which would
become an amalgamated local.
Dennis responded by letter of October 25, in which he stated that neither the
USW International nor District 9 was the certified bargaining representative for
employees at the plant, and he therefore denied the Union’s demand for bargaining and
requests for information.12
Unilateral Change
The Respondent admittedly created a new unit job position called “lead shipper”
in about January 2011 without providing the Union with prior notice and an opportunity
to bargain, and I so find.
Interrogation
Within a week or two after Mitchell transferred to Tuscaloosa in mid-September,
Smith asked him in to his temporary office in a trailer, to talk about leadership. Early on,
Smith asked, “why I thought we needed a union”?13 Mitchell answered rhetorically, why
not? Smith then explained his leadership philosophy, drawing pictures on a sketch pad
as he went along. He said that there was more flexibility and less expense without a
union. Mitchell asked what those expenses were. Smith replied, union dues and legal
fees for the Company for attorneys negotiating and reviewing contracts.
On the morning of October 25, Smith asked Talley to come to his office at the
Tuscaloosa facility. There, Smith asked him “why we wanted a union or needed a
union”?14 Talley replied with his reasons for wanting union representation. Smith then
stated that a union was divisive, was an added expense to the company and to
employees, and restrained company growth. He discussed his concept of team
leadership and said that management would be holding a “townhall meeting” to dispel
rumors.15
Analysis and Conclusions
Failure to Recognize and Bargain
The Board has long held that, following an employer’s relocation, a union is
entitled to continued recognition and to have an existing collective-bargaining
agreement remain in effect, provided operations and equipment remain substantially the
same at the new location, and a substantial percentage of employees at the old facility
transfer to the new location. Rock Bottom Stores, 312 NLRB 400, 402 (1993), enfd. 51
F.3d 366 (2nd Cir. 1995).Westwood Import Co., 251 NLRB 1213, 1214 (1980), enfd.

12 Jt. Exh. 8.
13 Tr. 177.
14 Tr. 39; 41.
15 Dennis and Smith conducted such a meeting on October 27. The General Counsel does
not allege that anything they said violated the Act.
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681 F.2d 664 (9 th Cir. 1982). The “substantial percentage” requirement is met if the
transferees from the old facility constitute at least approximately 40 percent of the new
facility’s employee complement. Rock Bottom Stores at 402; Harte & Co., 278 NLRB
947, 948 (1986); Westwood Import Co. at 1216 fn. 8.
Here, the Respondent has admitted, both in its answer and/or by stipulations,
that it has continued to operate the Tuscaloosa facility in basically unchanged form and
that a majority of its Tuscaloosa employees were previously employed at the Bogalusa
facility. The Respondent also admittedly refused to bargain after the Union’s August 31
September 23, and October 19 requests for such.
The Respondent provided no evidence that the Union has ever lost the support
of a majority of unit employees, whether in Bogalusa or Tuscaloosa, and does not now
argue this as a basis for nonrecognition of the Union. Accordingly, I need not discuss
whether the Union’s presumption of majority support was rebuttable because the
collective-bargaining agreement, by its express terms, terminated upon the relocation.
Suffice to say, the Respondent failed to establish that at the time it withdrew recognition,
the union had actually lost majority status. See Levitz Furniture Co. of the Pacific, 333
NLRB 717, 717 (2001). Nor does the Respondent now argue that the Union waived any
rights to represent relocated employees.
Rather, the Respondent contends that it has no current bargaining obligation
because of the following factors combined: 1) the conjunctive definition of the certified
bargaining representative as both the International and its designated Local 189; 2) the
significant distance of the move; 3) the absence of animus behind the decision to locate;
4) the Union’s internal requirement that employees continue to express a desire for
unionization; 5) the geographic definition in the collective-bargaining agreement
(Bogalusa); and 6) the solicitation by the Union of post-relocation authorization cards.16
The Respondent’s counsel concedes that he can cite no Board decisions or court cases
directly supporting the Respondent’s position (R. Br. at 6).
The Respondent’s collective-bargaining relationship has been with the USW
International, not separately with its subordinate components, whose bargaining
authority and representational authority derived entirely from their affiliation with the
USW International. I therefore deem wholly lacking in merit the Respondent’s assertion
that the conjunctive definition of the certified bargaining representative in the labor
agreement, and/or the post-relocation change in union district or local jurisdiction,
stripped the Union of its representational status.
Nor did the fact that the move was some distance away deprive the Union of that
status. To hold otherwise would be to allow an employer to evade its collective-
bargaining obligations simply by moving further away—leading to the untenable result of
making relocation more onerous on unionized employee.

16 R. Br. at 5–6.
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Whether or not the relocation was motivated by antiunion or other unlawful
reasons is not determinative of the Union’s right to continued representational status.
See J.R. Simplot Co., 311 NLRB 572, 579; Westwood Import Co., supra at 1213
(1993).
The Respondent’s brief fails to specify any evidence supporting its claim that the
Union has an internal requirement that employees continue to express a desire for
unionization. I will not shoulder that responsibility or address this point further.
Although the geographic definition in the collective-bargaining agreement was
Bogalusa, there was no language “at no other locations,” and other provisions in the
agreement unequivocally demonstrate that the parties envisioned a dismantlement of
the Bogalusa plant and transfer of its operations elsewhere. Moreover, the parties
signed an MOA regarding post-relocation employment of Bogalusa employees. As
noted, the Respondent does not allege that Union ever waived any rights to represent
them after the relocation.
Finally, the Union’s decision to collect authorization cards in no way serves as
an admission against interest or supports the Respondent’s suggestion that the Union
was required to file a representation petition to establish post-relocation majority status.
Indeed, the card check revealed that the Union continued to enjoy such status after the
move to Tuscaloosa.
Accordingly, I conclude that the Respondent was required to continue to
recognize the Union and bargain with it as the collective-bargaining representative of
the plant’s Tuscaloosa unit employees and that its failure to do so since on about
October 25 violated Section 8(a)(5) and (1) of the Act.
Failure to Provide Information
An employer is obliged to supply information requested by a collective-bargaining
representative that is relevant and necessary for the latter’s performance of its
responsibilities to the employees it represents. NLRB v. Acme Industrial Co., 385 U.S.
432 (1967); NLRB v. Truitt Mfg. Co., 351 U.S. 149 (1956). When the requested
information concerns terms and conditions of employment of bargaining-unit, that
information is presumptively relevant, and the respondent must provide it. Chrysler,
LLC, 355 NLRB No. 54, slip op. at 13 (2010); Contract Flooring Systems, 344 NLRB
925, 928 (2005).
Here the information that the Union sought by its letters of August 31, September
23, and October 19 related directly to unit employees’ terms and conditions of
employment, including wages and other compensation, and health and safety matters.
Accordingly, the information that that the Union requested was presumptively relevant,
the Respondent has never claimed otherwise, and I conclude that the Respondent
violated Section 8(a)(5) and (1) since on about October 25 by failing to furnish it.
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Unilateral Change
An employer violates Section 8(a)(5) and (1) of the Act when it unilaterally makes
substantial changes on subjects of mandatory bargaining; to wit, employees’ wages,
hours, or other terms and condition of employment, without first affording notice and a
meaningful opportunity to bargain to the union representing employees. NLRB v. Katz,
369 U.S. 736 (1962); United Cerebral Palsy of New York City, 347 NLRB 603, 608
(2006). An employer’s creation of new positions in the bargaining unit is such a
mandatory subject of bargaining. Spurlino Materials, LLC, 353 NLRB 1198, 1198
(2009), reaffirmed 355 NLRB No. 77 (2010), enfd. __F.3d ___ (7th Cir. 2011).
I therefore conclude that by admittedly creating the new unit job position of “lead
shipper” in about January 2011, without providing the Union prior notice and an
opportunity to bargain, the Respondent violated Section 8(a)(5) and (1) of the Act.
Alleged 8(a)(1) Violations
A statement from an employer is an unlawful threat under Section 8(a)(1) if it
interferes with, restrains, or coerces employees in the exercise of their Section 7 rights.
29 U.S.C. § 158(a). Not all employer interrogations are per se illegal. Rather, the test
is whether, under all the circumstances, the interrogation tends to interfere with,
restrain, or coerce employees. Matthews Readymix, Inc., 324 NLRB 1005, 1007
(1997); Rossmore House, 269 NLRB 1176, 1176–1178 (1984).
Here, Smith, a high-level manager, called Mitchell and Talley individually into his
office and asked them why they wanted a union, in conversations in which he attempted
to persuade them that they and the Company would be better off without their having
union representation. In these circumstances, I conclude that Smith’s questions had the
reasonably foreseeable effect of discouraging employees from supporting the Union
and thereby constituted unlawful interrogation.
Ergo, I conclude that the Respondent violated Section 8(a)(1) by unlawfully
interrogating employees in about late September and on October 25 about their union
sympathies.
Conclusions of Law
1. The Respondent is an employer engaged in commerce within the meaning of
Section 2(2), (6), and (7) of the Act.
2. The Union is a labor organization within the meaning of Section 2(5) of the
Act.
3. By the following conduct, the Respondent has engaged in unfair labor
practices affecting commerce within the meaning of Section 2(6) and (7) of the Act and
violated Section 8(a)(5) and (1) of the Act:
(a) Failed and refused to recognize and bargain with the Union as the collective-
bargaining representative of unit employees in Tuscaloosa, Alabama.
(b) Failed and refused to provide the Union with information that the Union
requested concerning the terms and conditions of employment of unit employees.
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(c) Created the new unit job position of lead shipper without first providing the
Union notice and an opportunity to bargain.
4. By interrogating employees about their union sympathies, the Respondent has
engaged in unfair labor practices affecting commerce within the meaning of Section 2(6)
and (7) of the Act and violated Section 8(a)(1) of the Act.
Remedy
Having found that the Respondent has engaged in certain unfair labor practices, I
find that it must be ordered to cease and desist and to take certain affirmative action
designed to effectuate the policies of the Act.
Since the Respondent unilaterally created a new unit position of lead shipper, the
Respondent shall be ordered to make any unit employees whole for any loss of
earnings and other benefits they may have suffered. The make-whole remedy shall be
computed in accordance with Ogle Protection Service, Inc., 183 NLRB 682 (1970), enfd.
444 f.2D 502 (6th Cir. 1971), with interest at the rate prescribed in New Horizons for the
Retarded, 283 NLRB 1173 (1987), compounded daily as prescribed in Kentucky River
Medical Center, 356 NLRB No. 8 (2010).
On these findings of fact and conclusions of law and on the entire record, I issue
the following recommended17
ORDER
The Respondent, Gaylord Chemical Co., LLC, Tuscaloosa, Alabama,
its officers, agents, successors, and assigns, shall
1. Cease and desist from
(a) Failing and refusing to recognize and bargain with the Union as the
collective-bargaining representative of unit employees in Tuscaloosa, Alabama.
(b) Failing and refusing to provide the Union with information that the Union
requests that is relevant and necessary for it to perform its duties as a collective-
bargaining representative.
(c) Creating new unit job positions without first providing the Union with notice
and an opportunity to bargain.
(d) Interrogating employees about their union sympathies.
(e) In any like or related manner interfering with, restraining, or coercing
employees in the exercise of the rights guaranteed them by Section 7 of the Act.
2. Take the following affirmative action necessary to effectuate the policies of the
Act.

17 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.
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(a) Recognize and bargain on request with the Union.
(b) Furnish the Union with the information that it requested on August 31,
September 23, and October 19, 2010.
(c) Upon the Union’s request, rescind or bargain over the new unit position of
lead shipper.
(d) Make unit employees whole for any loss of earnings and other benefits they
suffered as a result of the unilateral creation of the new unit position of lead shipper, as
set forth above in the Remedy section.
(e) Within 14 days after service by the Region, post at its facility in Tuscaloosa,
Alabama, copies of the attached notice marked “Appendix.”18 Copies of the notice, on
forms provided by the Regional Director for Region 10, after being signed by the
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, notices should be distributed electronically, such as by email, posting on an
inranet or an internet site, and/or other electronic means, if the Respondent 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 copy of the
notice to all current employees and former employees employed by the Respondent at
any time since October 1, 2010.
(f) 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 steps that the Respondent has taken to comply.
Dated, Washington, D.C. August, 18, 2011
____________________
Ira Sandron
Administrative Law Judge

18 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.”
JD–47–11
Tuscaloosa, AL
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 fail and refuse to recognize and bargain with the United Steelworkers
Union (the Union) as your recognized collective-bargaining representative.
WE WILL NOT fail and refuse to provide the Union with information that it requests that
is relevant and necessary for it to perform its duties as your collective-bargaining
representative.
WE WILL NOT create new unit job positions without first affording the Union notice and
an opportunity to bargain.
WE WILL NOT question you about your union sympathies.
WE WILL NOT in any like or related manner interfere with, restrain, or coerce you in the
exercise of your rights under Section 7 of the Act, as set forth at the top of this notice.
WE WILL bargain with the Union on its request.
WE WILL furnish the Union with the information that it requested on August 23,
September 23, and October 31, 2010, concerning your terms and conditions of
employment.
WE WILL, on the Union’s request, rescind our creation of the lead shipper position or
bargain with the Union over it.
WE WILL make any unit employees whole, with interest, for any loss of earnings and
other benefits suffered as a result of our unilateral creation of the lead shipper position.
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GAYLORD CHEMICAL CO., LLC
(Employer)
Dated By
(Representative) (Title)
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.
233 Peachtree Street N.E., Harris Tower, Suite 1000, Atlanta, GA 30303-1531
(404) 331-2896, Hours: 8 a.m. to 4:30 p.m.
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, (404) 331-2870.