Baltimore Public Schools Competitive Bid Report

Friends:

http://procurement-reform.org/wp-content/uploads/2015/11/MD-BCPS-Audit-July-2015.pdf

Financial Management Practices Audit Report

Baltimore County Public Schools

July 2015

OFFICE

OFFICE OF LEGISLATIVE AUDITS

DEPARTMENT OF LEGISLATIVE SERVICES

MARYLAND GENERAL ASSEMBLY

For further information concerning this report contact:

Department of Legislative Services

Office of Legislative Audits

301 West Preston Street, Room 1202

Baltimore, Maryland 21201

Phone: 410-946-5900 · 301-970-5900

Toll Free in Maryland: 1-877-486-9964

Maryland Relay: 711

TTY: 410-946-5401 · 301-970-5401

E-mail: OLAWebmaster@ola.state.md.us

Website: www.ola.state.md.us

The following excerpts are from that report, but you can access the full report with the link I've provided above.

Thomas J. Barnickel ill, CPA
Legislative Auditor

"Ladies and Gentlemen:

We conducted an audit of the financial management practices of the Baltimore County Public Schools (BCPS) in accordance with the requirements of the State Government Article, Section 2-1220(e) of the Annotated Code of Maryland. 

The objectives of this audit were to evaluate whether BCPS
procedures and controls were effective in accounting for and safeguarding its assets and whether its policies provided for the efficient use of financial resources. 

Our audit disclosed that BCPS needs to improve certain procurement practices to ensure it obtains goods at services in a cost-effective manner.

For example, BCPS appeared to be paying more than necessary for roof replacements obtained through a purchasing consortium. BCPS paid approximately $31.4 million for roofing services during the period from July 1, 2010 through December 10, 2013. In addition, BCPS procurement policy did not require that a competitive procurement process be used for certain service contracts.

Cont.....

"An executive summary of our findings can be found on page 5 of this report.

The BCPS response to this audit is included as an appendix to this report. We wish to acknowledge the cooperation extended to us during our audit by BCPS.

Respectfully submitted,

Legislative Auditor"

-----------------------------

School Districts should be the FIRST to demand "a competitive procurement process".

In the next few days, and weeks, I will run through a series of reports, similar to Baltimore.  

It is insane to give ANY MANUFACTURER Carte Blanche, and that's EXACTLY what Purchasing Cooperatives do.  The urge to steal is too great.

If your school district buys roofing through a Purchasing Cooperative, you are paying around 50% too much.  Since Garland, and Tremco perpetuate this scheme (all over the internet), would suggest you not fall into their trap.

They can leave.  You must stay behind and be the focus of great public scrutiny, and ridicule.   Or worse.

It must be a horrible way to live (without conscience).

Each day we teach our children not to lie, cheat, or steal.  We then go out and do those very things.  Think about what I've said the next time you look in a mirror.

This is what makes "Honorable" manufacturers like GAF, Carlisle, Firestone, Johns Manville, Barrett, etc. so attractive.

NO PRIVATE OWNERS buy from a Purchasing Cooperative, and NO PRIVATE OWNERS use Garland or Tremco.  So why are they the "Darlings" of Purchasing Cooperatives? 

Purchasing Cooperatives get paid a "Commission" and haven't the slightest inclination to compete.  Instead, they do it through cronyism, manipulation, corrupt politicians, and the like.

NEVER BUY A ROOF THROUGH A PURCHASING COOPERATIVE 

YOU'LL BE SORRY.  

NOTE: Retired 2003, do not solicit nor accept compensation or personal advancement of any kind.

I am humbled by the 120,000+ viewers of this page.  Thank You.  I will help anyone who asks for help, because YOUR schools are important to me.

Reject negativity in all forms, and always remember to keep looking "UP".

Respect.

Robert R. "Ron" Solomon
Public Procurement Analyst
CCC 1325620  Florida
RobertRSolomon@aol.com

Profile:  https://www.linkedin.com/in/robertrsolomon

Coalition for Procurement Reform Honorable Fight Against School Roofing Scams.

Friends:

I have a number of new developments on the roofing "Fair Competition" front.  Please be encouraged by the good news as it is available to me. 

"Public Roofing Oversight" would like to endorse them. 

"Honorable" is the highest praise I can give.

I know many of them personally, and find them of the highest moral character.  Like me, they neither subscribe to, or perpetuate, the stereotypical roofer image.

If you ask them a question, they will give you a truthful answer. 

First to CPR:

http://procurement-reform.org/

Details

• Phone

  703-234-4129

• Email

  cpr@procurement-reform.org

• Address

  11130 Sunrise Valley Drive, Suite 350
  Reston, Virginia 20191
  Map

PLEASE visit their site, and join if possible. Fascinating stuff, and very well done.  It should be required reading for every school board member, FM Manager, Consultant, Architect, and Engineer.  

If you are in charge of a buying a publicly funded roof, please be aware that all public projects are subject to oversight by law.  It is foolish to expose the district, and yourself, to unnecessary suit.  I'm working on that post, because your protection, and livelihood, are important to me.  

I'll show you how to buy a school roof, and not end up in jail, or the front page.  

 http://procurement-reform.org/home-box/solutions-to/audits-and-studies/

Click the links below for actual documents, and reports.

"Audits and Studies

Below is a list of audits and studies relating to cooperative procurement.  (Click on the title to download the document.)

Pennsylvania: Ducker-Carlisle Reports –  Open-Bid vs AEPA-Tremco Costs in PA Roofs – Independent study of average open-bid roofing costs in PA vs. costs from AEPA-Tremco projects in PA.

This is a great report, showing actual cost of roofs purchased through the Purchasing Cooperative fraud scheme.  Pay attention to pages 7 and 8.

Maryland: Legislative Audit Agency Report on Open-Bid vs. Cooperative Procurement – Maryland Legislative Audit Agency’s report on Baltimore County’s use of cooperative procurement program for school roofing projects; cites an excess expenditure of $11 MM over the comparable cost of open-bid procurement, on projects in nine schools over three years.

Maryland: EXCERPT FROM – Legislative Audit Agency Report on Open-Bid vs. Cooperative Procurement – Excerpt of the key findings of the Maryland Legislative Audit Agency’s report on Baltimore County’s use of cooperative procurement program for school roofing projects; cites an excess expenditure of $11 MM over the comparable cost of open-bid procurement, on projects in nine schools over three years.

Indiana: State Attorney General’s Official Opinion about Schools and Cooperative Procurement Groups – Concludes “that school corporations are covered by the public work statute and are subject to the procedures for bids and quotes whenever they contract for public work even when the public work is contracted through an educational service center.” The educational service center cited is AEPA, which is one of the major cooperative procurement providers for school districts in more than 20 states. This is the Indiana Attorney General’s opinion that AEPA cannot circumvent the state’s competitive bidding laws by claiming the work is repair or maintenance.

Indiana: State Auditor General’s Report – Detailed analysis of the operation of cooperative purchasing by the State’s Educational Service Centers in conjunction with AEPA; highlights the instances where the Center’s application of AEPA requirements is not in compliance with State public purchasing law and with the State public work law.

Minnesota: State Auditor’s Letter to St. Cloud Schools – Office of the State Auditor review and recommendations regarding the bidding procedure used by the St. Cloud Area School District for roofing repair projects.

New Jersey: Waste And Abuse: Public School Roofing Projects – Details the results of a comprehensive, statewide inquiry into  the repair and replacement of roof systems.  Investigation revealed evidence of widespread cost-gouging; unscrupulous bidding practices; contract manipulation; questionable design, installation and inspection procedures and other abuses.

Texas: Interim Report to the 83rd Legislature by House Committee on Government Efficiency & Reform – Project to examine and make recommendations on purchasing cooperatives created under Chapter 791 of the Texas Government Code, including the bid process and the role of inter-local contracts. Clarify for consistency the following terms: purchasing cooperatives, inter-local contracts, and inter-local agreements."

------------------------------------------- 

I would enthusiastically encourage you to read:

Pennsylvania: Ducker-Carlisle Reports –  Open-Bid vs AEPA-Tremco Costs in PA Roofs – Independent study of average open-bid roofing costs in PA vs. costs from AEPA-Tremco projects in PA.

Watch this video, and you will see a ton of school roofing investigative reports.  Thank you to CPR.

http://procurement-reform.org/home-box/in-the-news/news-videos-about-cp/video/

------------------------------

If you are an RCI Member you should definitely read this:

http://rci-online.org/foundation-supports-procurement-reform-education/
This data is coming at me fast, and that's good news.  I'm trying to get it to you at top speed, but the reading assignment is very demanding.

Thank you to CPR, and I have some good news about NRCA coming soon.

Fight hard, but fight fair.  

NO MORE BID RIGGING THROUGH PURCHASING COOPERATIVES..

I want to close by saying this site is blowing up, and surpassing 300 views per day.  You can see the page view counter at the top of this page.

That's pretty exciting for a guy who doesn't buy, nor sell things.

All I do is educate, and tell the truth.  I think that is my mission, and hope you see it that way too.

NOTE: Retired 2003, do not solicit nor accept compensation or personal advancement of any kind.

Reject negativity in all forms, and always remember to keep looking "UP".

Respect.

Robert R. "Ron' Solomon

Public Profile:   LinkedIn Profile: https://www.linkedin.com/in/robertrsolomon

NATIONAL ROOFING SCAM: Cobb County Georgia, U.S. Communities, and Garland . BID RIGGING, and how it works.

Cobb County Commission is guilty of "Bid Rigging" with the help of U.S. Communities (Purchasing Cooperative), and Garland, Ind. (Roofing Material Manufacturer).  

It could NEVER happen to me:

These guys are lightweights compared to Garland, Cobb County, and U.S. Communities.

So Ron, why should I care about Cobb County, Georgia?  The reason you should care is because this "setup" only ORIGINATES in Georgia, and then used for every city, county, and state in the country as the "Standard".  Laughable.

NOTE:  Retired 2003, do not solicit nor accept compensation or personal advancement of any kind.

The SCAM extends into all territories, and provinces, of Canada as well.  So this little "scheme" in effect excludes all manufacturers (except Garland of course) steals hundreds of millions of dollars annually  from taxpayers.

Joe Tommie is the point man for Cobb County, and knows EXACTLY what he's doing, but you may not.  Cobb County Commission doesn't care who they hurt, as long as they keep getting their 5% "Commission" for lying on Garland's behalf.

That's impossible Ron, they'd be run out of town on a rail.  Well, it's not impossible, and actually more common than you'd think.  Don't take my word for it, and read articles of the contract:

“5.1 Administrative Fees. Supplier shall pay to U.S. Communities a monthly administrative fee based upon the total sales price of all purchases shipped and billed pursuant to the Master Agreement, excluding taxes, in the amount of two percent (2%) of aggregate purchases made during each calendar month (individually and collectively, “Administrative Fees”). 

IS THAT CLEAR?

"Supplier’s annual sales shall be measured on a calendar year basis. All Administrative Fees shall be payable in U.S. Dollars and shall be made by wire to U.S. Communities, or its designee or trustee as may be directed in writing by U.S. Communities. Administrative Fees shall be due and payable within thirty (30) days of the end of each calendar month for purchases shipped and billed during such calendar month". 

U.S. Communities agrees to pay to Lead Public Agency five percent (5%) of all Administrative Fees received from Supplier to help offset Lead Public Agency’s costs incurred in connection with managing the Master Agreement nationally.”

IS THAT CLEAR?

There are also provisions in the vendor agreement that appear to be more applicable to an organization that is trying to maximize sales vs. a cooperative that is trying to save its users money, such as:

“(d) Sales Commitment. Supplier shall market the Master Agreement through Supplier’s sales force or dealer network that is properly trained, engaged and committed to offering the Master Agreement as Supplier’s primary offering to Public Agencies. Supplier’s sales force compensation and incentives shall be greater than or equal to the compensation and incentives earned under other contracts to Public Agencies.”

IS THAT CLEAR?

But Ron, why haven't they been caught, and taking up permanent residency under the jail?  They think no one is watching them, but I GUARANTEE that many people much smarter than me, and with far more resources, are on top of it.  

When the whip comes down, it will show no mercy.   

I ASSUME that most of you care about your tax dollars being wasted, and lining the pockets of lying politicians, and lying "Salesmen".   I'm showing you how they do it, and who they are.  Perhaps your own civic responsibility will speak to you, where I cannot?

---------------------------------------------------------------------------

If you are a manufacturer, consultant, contractor, or distributor, you have a RIGHT to compete for your own tax dollars.  In fact, you have an OBLIGATION to your client base if you are a manufacturer, or distributor.  

ALWAYS SUBMIT A VOLUNTARY ALTERNATE!

Taxpayers are paying twice as much for an average roof, and a grotesquely fraudulent warranty.  It's actually a "Maintenance Agreement", and you will pay TOP DOLLAR for repairs (real or imagined).  

------------------------------------------------------------------------

When the DOJ catches up to Garland, I suspect their fate will eclipse even Tremco.  It was kind of funny how Garland refers to Tremco as "One Bad Apple".   That's like a Witch calling the Devil a "Bad Apple".  Hilarious.

If not for Purchasing Cooperatives lying for them, nobody would even know they exist.  So, evaluate your reputation, and career, before stealing some of that "easy' money.   I'm looking at you Architects, and Engineers, who "sign off" on the scam for exorbitant fees.  More on that later.....

Friends, you are really coming through for me.  I'm very thankful, and genuinely humbled by the amazing increase in viewers.   Approximately 7,000 visits per month, and I rarely use PICTURES!  In roofing world, that's quite a feat.

On the "Interesting Scale" reading this material has all the charm, and drama of watching a car rust, but for many of you, it's how you feed your families.   I know that.

Reject negativity in all forms, and always remember to keep looking "UP". 

Respect.

Robert R. "Ron" Solomon

Public Procurement Analyst

Florida Certification

CCC 1325620  

NOTE:  Retired 2003, do not solicit nor accept compensation or personal advancement of any kind.

   

Public Procurement: What HUD says might surprise you.

"So Ron, why on earth did you choose HUD as an example of fair, open, transparent, bidding?  I thought they'd be the last government agency to be held up as the reference standard."  

That's why I chose them.  

At any rate, this is what HUD says about procurement, and I've added a few comments to help translate the tortuous language of government.  About halfway through, throw a glass of ice water in your face, and continue reading. 

This guy reads a lot of my stuff;

Here we go:

-----

https://portal.hud.gov/hudportal/documents/huddoc?id=cdbgchapter14.pdf  

CHAPTER 14: PROCUREMENT
CHAPTER PURPOSE & CONTENTS
This chapter provides an overview of the federal procurement requirements. It covers the basics of Part 85.

SECTION TOPIC

14.1 Overview of Procurement Requirements

When a grantee elects to hire a contractor, whether to administer a program, complete a task or do construction, those contractors must be procured competitively. This section highlights the procurement rules.

Key Topics in This Section: Procurement requirements and methods

Regulatory/Statutory Citations: 570.502, 570.610, 85.36
Other Reference Materials on This Topic: CPD Notice 96-05, Executive Order 12549

Both grantees and subrecipients must follow federal procurement rules when purchasing services, supplies, materials, or equipment. The applicable federal regulations are contained in:

State and local governments and Indian tribes – 24 CFR Part 85. A copy of Part 85 is included in the attachments to this chapter;

Nonprofits, institutions of higher education and hospitals – OMB Circular A-110, as implemented through 24 CFR Part 84.

In addition to federal regulations, most states and many local governments have laws and regulations regarding procurement. Each entity receiving CDBG funds should be aware of state and/or local laws that may affect procurement policies.

Grantees should adopt procurement policies that describe how the grantee or subrecipient will procure supplies, materials, services, and equipment. The policy should assure that all purchases are handled fairly and in a manner that encourages full and open competition. Grantees should follow the procedures established in the policy, and document how all procurements were handled.
The “essence of good procurement” can be summarized as follows:

Identify and clearly specify standards for the goods or services the grantee or subrecipient wants to obtain;
Seek competitive offers to obtain the best possible quality at the best possible price;

Use a written agreement that clearly states the responsibilities of each party;
Keep good records; and
Have a quality assurance system that helps the grantee or subrecipient get what it pays for.  

RRS: This may also be accomplished with a "Performance and Payment" Bond.  Very cheap insurance for the taxpayer (typically 1%), and guarantees the project will be finished properly, or the bonding company steps in, and hires someone else (at no expense to taxpayers).

Believe me, no roofing contractor on earth wants their bonding company to take over.  They will forfeit all assets the bonding company required to issue the bond in the first place.  BRUTAL.

Basically CDBG (November 2007) 14-1
HUD, Office of Block Grant Assistance
Chapter 14: Procurement
There are four methods of procurement that are identified in the federal regulations:
Small purchase procedures;
Sealed bids;
Competitive proposals; and
Non-competitive proposals.

Please note that the following training manual text is an abbreviated summary of the procurement rules and grantees are encouraged to read Part 85.36 in its entirety (attached) as well as any applicable state or local procurement laws.

14.1.1 Small Purchase Procedures
The small purchase procedures allow recipients to acquire goods and services totaling no more than $100,000, without publishing a formal request for proposals or invitation for bids.
This method of procurement is typically used to purchase commodities such as equipment or other materials.
In the event that a grantee is purchasing materials that will exceed $100,000, they must use the sealed bid process.
The small purchases method can also be used to acquire eligible types of services, such as professional consulting, environmental review, or planning. This method cannot be used if the services contract will exceed $100,000 in value. If the services contract will exceed $100,000, the grantee must issue an RFP under the competitive proposals approach (see below).

In general, the small purchases procedures also should not be used to acquire construction contractors. It is recommended that these acquisitions occur under the sealed bid approach outlined below.

Under the small purchases method, grantees send a request for quotes to potential vendors with a detailed description of the goods or services needed. In return, they receive competitive written quotations from an adequate number of qualified sources.

Each quote should include pricing information that allows the grantee to compare costs across bidders and ensure cost reasonableness.

Documentation of the quotes shall be maintained in the grantee’s files.

The award should be made to the lowest responsive and responsible source.

RRS: Is that clear? LOWEST and RESPONSIBLE.  

14.1.2 Sealed Bids (Formal Advertising)
Sealed bids (Formal Advertising) should be used for all construction contracts or for goods costing more than $100,000.

Competitive sealed bidding requires publicly solicited sealed bids and a firm-fixed-price lump sum or unit price contract is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is lowest in price.
In order for formal advertising to be feasible, the following minimum conditions must be present:
A complete, adequate and realistic specification or purchase description is available.
Basically CDBG (November 2007) 14-2
HUD, Office of Block Grant Assistance
Chapter 14: Procurement
Two or more responsible suppliers are willing and able to compete effectively for a grantee's business.

The procurement lends itself to a firm fixed-price contract, and the selection of the successful bidder can appropriately be made principally on the basis of price.

When the competitive sealed bid (formal advertising) process is used, the following requirements apply:

Publication Period: The invitation for bids must be publicly advertised and bids solicited from an adequate number of suppliers.  RRS:  Note, they say "suppliers", as in plural.  "Competition" is not ONE manufacturer, and 4 of their vendors.  What incentive would the manufacturer have to compete?

The publication should be published at least once in a newspaper of general circulation, providing sufficient time prior to bid opening. If the publication period is not of sufficient time to attract adequate competition, the bid may have to be re-advertised.

Clear Definition: The invitation for bids, including specifications and pertinent attachments, must clearly define the items or services needed in order for bidders to properly respond to the invitation.  

Public Opening: All bids must be opened publicly at the time and place stated in the invitation for bids. The public is allowed at that time to review the bids.

RRS: Think about that for a minute.  "The public is allowed at that time to review the bids".


Selection and Contracting: A firm-fixed-price contract award must be made by written notice to the responsible bidder whose bid, conforming to the invitation for bids, is lowest. Where specified in the bidding documents, factors such as discounts, transportation costs and life cycle costs must be considered in determining which bid is lowest.

Rejection of all Bids: All bids may be rejected when sound documented reasons exist. Such documentation shall be made a part of the files.

14.1.3 Competitive Proposals
Competitive proposals are used to purchase professional services where the total cost will exceed $100,000. Under this procurement method, the grantee must publish a written request for submissions and then review these submissions based on established selection criteria.

The grantee must solicit proposals from an adequate number of qualified sources.


To learn more about excluded parties, go to: http://www.epls.gov/
Basically CDBG (November 2007) 14-4

HUD, Office of Block Grant Assistance  

-----

I provided the link earlier if you care to read additional attachments.

ALL public procurement agencies (local, state, and federal) have published laws, and ALL devote large sections specifically to "Fair Competition" on  ALL publicly funded projects.  

The word "Competition" is twisted, and manipulated by those who cannot accept measurable units.  It's easy for an Administrator to get sucked into the vortex of a "Predatory Sales Model".  

I cannot reasonably expect an Administrator to have intimate knowledge of all construction trades, and sub trades.  

*****

Friends, I know this is like watching paint dry, but the people who are stealing your tax dollars are frauds, and depend upon you to get bored, or simply quit.  I've been at this for 10 years now, and am neither bored, nor have the slightest desire to "quit".  

I derive ZERO pleasure when people lose their jobs, careers, families, and sometimes "Freedom".   Just this one, and then we'll move on:


http://wikiroof.blogspot.com/2014/05/va-official-admits-to-64-counts-of.html

The work is tedious, time consuming, and at times, heartbreaking.
----- 


NOTE: Retired 2003, do not solicit nor accept compensation or personal advancement of any kind.

You, my respected readers, depend upon me to tell only the truth.

I know that.  

Reject negativity in all forms and always remember to keep looking "UP".

Respect.

Robert R. "Ron" Solomon
Public Procurement Analyst
Florida State Certified 
CCC 1325620

Tremco and the SEC - Buyer Beware

Friends, this is the reality of Tremco.  

The SEC is suing Tremco, AND their Attorney.  The DOJ has already fined Tremco $61,000,000.00, and now the SEC has them for lying.  

That sounds like a lot of money right?  You may be interested to know the public facilities who got scammed, received NOTHING.  To put it in context, a brand new high school costs approximately $50,000,000.00.  

Unless you like to play "blindfolded, high stakes poker", I'd stay as far away from Tremco as humanly possible.  You administrators should do your homework, or be pulled down with them.  The WORSE decision you could possibly make is buying Tremco through a Purchasing Cooperative.

There is no such thing as "Pre-Compete" in roofing.  EACH project is wildly variant, and a "parts list" is worthless.  I challenge any roofing estimator to prove they can. 

I challenge Tremco to prove they can, and will stake $10,000.00 of my own money proving they can't.  Money goes to a school of my choice.  

NOTE:  Retired 2003, do not solicit nor accept compensation or personal advancement of any kind.

Not ONE person in this country can successfully argue Tremco's "Exclusive Vendor" status in public works.  All under the guise:  "We buy in bulk", "We Pre-Compete for you", "Our vast negotiating power.....blah, blah, blah.

IT IS A LIE that defrauds our schools (you pay for it).

I'm looking forward to the day when Tremco is finally debarred from the GSA.  Take Garland too, and we will have eliminated the "Predatory Sales Models" in roofing by 99%.  

https://probesreporter.com/news/analysis-rpm-international-finally-gets-around-disclosing-its-sec-probe 

"Analysis: RPM International Finally Gets Around to Disclosing its SEC Probe"

Submitted by Probes Reporter on Mon, 2014-08-04 08:00

RPM

"Last week RPM International (RPM) disclosed it is under investigation by the SEC.  This was not news to us.  We have been tracking undisclosed SEC investigative activity on the company dating back to Aug-2012.  We review the pertinent facts, our research history, and give our take on why a disclosure now could be more dangerous than investors may realize. 

Facts of Interest or Concern:

In an earnings press release last week(link is external), RPM International said in part,

“RPM was notified by the Securities and Exchange Commission on June 24, 2014, that it is the subject of a formal investigation pertaining to the timing of its disclosure and accrual of loss reserves with respect to the previously disclosed fiscal 2013 GSA and Department of Justice investigation into compliance issues relating to Tremco roofing division's GSA contracts.”

Though the company says it was notified on 24-Jun-2014, our research history suggests this SEC investigation has a long tail to it, dating back potentially as far as 2012. 

Since Aug-2012, the SEC has been blocking our access to records on RPM over concern their release could interfere with law enforcement proceedings.  We received the same denial in Jul-2013 and again in Jan-2014. As a matter of law, the SEC was acknowledging some sort of investigative activity.

In May-2014 we published a research note indicating the SEC had confirmed an active-and-ongoing investigation involving RPM.  At that time our research showed no signs of disclosure of SEC investigative activity for the prior two years.  

Our Take:

With the shares up 2.4% on the day of the earnings release (versus an S&P 500 that was essentially flat), it appears investors are ignoring the SEC aspect of earnings release.  We think that is misplaced.  Here’s why --

• Don’t get distracted by the company saying it was notified by the SEC on 24-Jun that it was subject of a formal investigation. That doesn’t mean it started then.  Again, the results of our works suggests RPM sat on this SEC investigation for at least the past two years, perhaps longer.  In our experience, it's bad when a company waits a long time to disclose an SEC probe.  It begs the critical question, “What changed to prompt the disclosure?”
   
• Public companies are generally not required to disclose the existence of SEC probes.  They are only required to disclose matters deemed material.  That management now disclosed means they likely now view it as material.  Why?  We say ignore the implications of this at your own peril.
   
• That the investigation is now formal could signal an escalation and/or that the company is not quite cooperating the way the SEC would like. 
   
• In formal SEC investigations, subpoenas are frequently involved.  Good questions to ask the company is were they subpoenaed, to whom they were sent, and what the subpoenas sought."   

Note:   New SEC investigative activity could theoretically begin or end after the date covered by this latest information which would not be reflected here.

---------------------------------------------------------

This is not "gossip" friends, but public record.  

Tremco Stock:  

http://www.secform4.com/insider-trading/110621-2.htm

Friends, I have in excess of 100,000 views here, and  humbled.   NONE of this benefits me in any way, other than the personal satisfaction that comes from exposing scams perpetrated upon schools, and taxpayers.  

You notice that Tremco isn't trying to steal any of Wal-Mart's money.  You won't either because they'd have to compete for it.  Tremco will NEVER compete.  Just ask them.  I dare you.

I am thankful for your interest, and time spent with me here.  I realize what a precious commodity time is, and my appreciation grows each day.

Reject negativity in all forms, and always remember to keep looking "UP".

Respect.

Robert R. "Ron" Solomon

Public Procurement Analyst

Director, Roof Consultant's Alliance

CCC 1325620

RobertRSolomon@aol.com

Tampa, Florida