Flipped Again: More Private Equity Groups Speculate on The Three Borough Pool Portfolio


On Saturday, the Wall Street Journal reported on the most recent update in the saga of the Three Borough Pool, a group of 42 buildings which over the last 8 years have been packaged together in one mortgage, speculated on, foreclosed on, refinanced and is currently being broken up and flipped again. This group of buildings is another example of the continuing cycle of predatory equity and is further proof that we have yet to come up with a solution to the problem of speculation in the rent regulated housing market.

UHAB has been tracking and organizing in this portfolio for several years. It is one of the classic examples of predatory equity. Three private equity companies (Normandy Real Estate Partners, Westbrook Partners, and Vantage Properties) partnered up with David Kramer, the president of Colonial Management, to package 42 buildings spread across the Bronx, Brooklyn and Manhattan. The investment group took out a mortgage with Barclays who then packaged the note into a Commercial Mortgage Backed Security (CMBS.) Securities like this were a common tool that many believe contributed to the 2008 financial crisis and are disastrous for affordable housing. In the Three Borough Pool, like other CMBS portfolios (Stuyvesant TownRiverton, Fordham Towers/Robert Fulton Terrace, and the Milbank portfolio) the owners eventually defaulted on their mortgages and the buildings fell into foreclosure. In 2013, UHAB and other housing advocates began working with tenants in the buildings to push for a responsible sale of the properties. However, two of the private equity companies that led the building to foreclosure were able to refinance and pull the buildings out of foreclosure. It is these companies who are now once again selling the buildings.

This weekend’s WSJ piece focuses on 8 of the 42 buildings; these 8 properties were recently sold to a real estate investment company called Black Spruce Management. According to Normandy & Westbrook, prior to the sale they made a lot of repairs to the buildings. This assertion comes as a surprise to the tenants who are facing major condition concerns on a daily basis. HPD code violations have actually increased over the past year, but the problem is actually deeper than that. These buildings have a long history of neglect and failing conditions, and they need more than patch work that could clear violations. The night before this story came out, one of my co-organizers received a call from a tenant in one of these buildings who was in tears because she found a rat in her living room in the apartment she shares with her grandchildren. Tenants in these buildings have suffered from systematic leaks, mold and lack of heat and hot water. These problems are deeper than code violation repair, they are problems which demand more extensive renovation, which would require a large financial commitment. Considering the amount that Black Spruce paid for these buildings, it is unclear if there is financing for this type of deep repair work.

The WSJ story claims that the new debt on these properties is considered low. First of all, the new mortgage of these buildings is an average of about $83,000/unit. This is the same average debt level as when the owners defaulted on the CMBS mortgage. Second, the mortgage does not tell the whole story. The full purchase price on the 8 buildings was over $57 million, or about $110,000/unit. This means about 25% of the financing is equity investment. As Black Spruce mentioned from the article, they are backed by investors: investors who are presumably seeking a return on the millions of dollars they gave to Black Spruce to purchase these buildings. Having a “lower” mortgage at the expense of putting more off the books equity into the deal does not solve the underlying problem: these are rent regulated buildings with low-income tenants and limited ability for rent increases. If the financial stability of the buildings is contingent on large rent increases, this portfolio will fail. Unless, of course, the plan is to either push the current low income residents out of their homes in order to raise rents, or to starve the buildings of money needed for maintenance in an attempt to keep costs down. This is not a new practice. This is Predatory Equity 2.0, the same kind of speculative financial venture that landed these buildings in foreclosure in the first place.

This type of speculation is particularly relevant as we approach June 15th, when the current rent regulations are set to expire. The current rent regulations are not strong enough. Advocates and tenants know that it is impossible for landlords to achieve their financial expectations when they over pay for buildings by continuing to rent to the low and moderate income families who have lived in these buildings for years. Predatory equity, like in the Three Borough Pool, makes rent regulated tenants the victims of harassment as landlords aim to push them out to achieve higher rent increases. It is vital that our legislators in Albany recognize the importance of strengthening the rent regulation laws. It has become a business practice for landlords to buy buildings with the intention of violating our laws and we shouldn’t allow it to continue. The only way we will be able to put a stop to these illegal practices is for our elected officials to reinforce the original intentions of the stabilization laws: to protect tenants in these buildings from being held hostage by greedy landlords who seek to make a profit off the suffering of our neighbors and our communities.


The Systems That Govern: the NBA, Racism, and Affordable Housing

By now most of us have heard of — and been disgusted by — the (most recent) statements that allegedly come from  current Los Angeles Clippers owner, Donald Sterling to his girlfriend. If you haven’t, here are a few choice parts:

It bothers me a lot that you want to broadcast that you’re associating with black people. Do you have to?…You can sleep with [black people]. You can bring them in, you can do whatever you want.  The little I ask you is not to promote it on  … and not to bring them to my games.

There has been a lot of anger being directed at Sterling over the past few days. Players from many different teams have had pretty strong reactions: “I couldn’t play for him”; “There’s no room for Sterling in this league”; and comparing the comments to “plantation politics”.

What is almost as shocking as what he said is that this is not the first time that Sterling has come under fire for his overt racism. Deadspin has a full list of the most famous comments he’s on the record as saying. In 2009, Elgin Baylor, the Clippers General Manager from 1986 to 2008, filed an age and racial discrimination suit against his old boss alleging, among other things, that Sterling repeatedly expressed a desire to field a team of “poor black boys from the South … playing for a white coach.”

Beyond his abhorrent racism, Sterling is also a vicious slumlord. In 2009 he was forced to pay $2.73 million in a settlement accusing him of discriminating against Black and Latino tenants. Sterling said he did not like to rent to “Hispanics” because “Hispanics smoke, drink and just hang around the building.” He also stated that “black tenants smell and attract vermin.” The case ended with the largest ever settlement obtained by the US Department of Justice in a housing discrimination case involving rental units.

A vastly disproportionate amount of the low-income tenants we work with are people of color. The systematic link between poverty and race is well documented — though of course it does not mean that all poor people are people of color and that all people of color are poor. The folks who live in affordable housing are, shockingly, folks who are working low-paying jobs or not able to work for any number of reasons.

Low-income tenants are too often vulnerable at the hands of their landlords. NYC’s rent laws are difficult to understand, and landlords are literally paid to exploit the loopholes that exist. And when tenants try and push back, there is always the worry that landlords will take tenants to court over and over again for frivolous charges, forcing tenants to take off work or adding stress that could literally kill them. For example, Sterling was also forced to pay $5 million in legal fees (plus an unknown, large settlement sum) to over a dozen tenants represented by the Housing Rights Center. According to The Nation blogger Dave Zirin:

Not all the plaintiffs, though, lived to see their windfall. Court documents state that on July 12, 2002, “Kandynce Jones was under threat of eviction by [Sterling] even though she had never missed a rent payment. Ms. Jones, who is a senior citizen and a person with a disability, suffered a stroke caused by the stress [of Sterling’s] housing practices. On July 21, 2003, Ms. Jones passed away as a result of that stroke.”

This exploitation is not isolated. It is a direct result of the systems that govern.

On WNYC’s Brian Leher Show this morning, the Washington Post’s Clinton Yates talked about the incredible structures of power at play here.

If you think about what that [Housing Rights Center settlement] is on its own, and the fact that the NBA knew this, understood this, and allowed him to continue unfettered in his ownership of an NBA team points to you — I mean it points you to how the major structures of power really, really work.

This last point — “how the major structures of power really, really work” — is worth repeating and emphasizing. The same type of people that govern the systems of the NBA — wealthy, middle-aged, heterosexual, white men — govern the systems of government that in turn dictate the laws and regulations of housing in New York City and beyond. Yates goes on:

[Sterling] indicates that there is a certain fear of his own feelings, which is that he’s afraid to not be racist because he doesn’t live in a world in which that doesn’t automatically benefit him. And that in itself is a frightening concept if you really think about, again, how the power structures of this country work, where a guy like that is emboldened — and it makes sense to him to operate in discriminatory manors because it makes him more money.

When privileged individuals are encouraged to exploit others in order to become wealthier and more privileged, we know the systems that govern have failed. When it is good for business — and legal — to harass tenants into leaving their homes so you can raise the rent, we know the systems that govern have failed us. When landlords are allowed to take out mortgages they can’t possibly pay back to buy buildings they have no intention of maintaining, we know the systems that govern have failed.

Sterling’s comments and the full backstory behind them should remind us that we need to continue to push our elected officials and organize en mass for a system that works for all people, no matter their race or income.

We Need More Resident Control of Our Neighborhoods!

After years of organizing in rapidly gentrifying neighborhoods, a few things have become all too clear. Tenants are being forced out of their homes and communities in order to make room for higher paying tenants.  Landlords skimp on repairs, force tenants into buy-outs, ask tenants to switch neighborhoods to another one of their buildings, and renovate buildings while lowering the quality of life for longer term residents.

The end goal is, of course, landlord profit. In NYC, the rent on a stabilized apartment can be raised about 4 to 7%, depending on the length of the lease, and what the Rent Guideline Board determines for that year.  If a tenant moves out, however, rent can legally be raised 20% through vacancy decontrol, plus 1/40th of the amount spent of “rehabilitating” the unit. When the legal rent hits $2,500 and a tenant moves out, that unit is forever out of confines of rent regulation laws and landlords can charge whatever they want!

Essentially, there is lots of money to be made by convincing long term, low paying residents to move out of a neighborhood.

We see this happening all over New York City.  In Queens, tenants in 6 buildings in foreclosure with Stabilis Capital are being falsely charged with nonpayments. In Upper Manhattan, tenants are charged fees in addition to their rents (washing machine fees, air conditioning fees, etc.) Eventually, those fees add up and a once-affordable apartment suddenly becomes unaffordable. Even in the Bronx, where we imagine most low income housing is located, areas are becoming unaffordable for current residents.  A recent article in Crains NY highlights the problem of gentrification in the Bronx, particularly in Highbridge and along Grand Concourse. Tenant, Lucia Davis, told Crains that “You’d think you could afford to live in the Bronx…But the prices are going up, and a lot of people are moving out.”

And of course in Brooklyn, especially in the neighborhood of Crown Heights, we’ve seen landlords use every tactic under the sun to force out long term residents.  What’s the solution?  Organize! We need to band together to fight for the following changes:

  1. Rent Freeze: the RGB is gearing up to determine how much rent stabilized rents should be raised.  Mayor de Blasio ran on a platform calling for a rent freeze, and we agree!  Rents are too high and too unaffordable for NYC tenants.  Until wages are going up, rents should be frozen.
  2. Displacement Free Zone: About 10 years ago, Fifth Avenue Committee established a displacement free zone within a 100 square blocks of Park Slope. Ben Dulchin, then Director of Organizing, explained:
    “We developed a systematic campaign where we marked out a 100 square block center of the neighborhood and put up posters all around saying, ‘This is a displacement free zone. Different set of rules here. If you’re a landlord in this neighborhood and you’re kicking out tenants because you want to triple the rent, we’re going to target you,” says Dulchin. “We’re going to get so much publicity that we hope that we not only win in some cases, but that we proactively keep away those landlords who would evict people and then raise rents, before those landlords even come to the neighborhood.” We need to declare the entire City a displacement-free zone.
  3. Education of tenant rights: Tenants are given rights by law, but those rights are only recognized as much as tenants themselves enforce them.  If a landlord refuses a rent regulated tenant a lease, that tenant should know that it his/ her right to a renewal lease. Without that knowledge and confidence to speak up, there is greater risk of displacement.  Through tenant associations, tenant unions, block associations, and workshops, we can educate ourselves and our communities about our rights so we each feel empowered to collectively enforce them!
  4. Repercussions for landlords who are breaking the law: Time and time again we encounter landlords who are just not following the law.  They don’t do repairs. They harass long term residents.  They even abandon buildings for months at a time.  And what justice do we have?  Lawsuits take forever, and are not even successful all of the time.  We need a better system to hold landlords accountable and stop them from continuing to profit.  For example, a landlord licensing law would prevent known bad actors from continuing to purchase new property.  Why should a landlord who has 3 buildings in AEP be allowed to purchase new rent regulated property?  That ain’t right!
  5. Raise the Minimum Wage: If we expect tenants to pay rents that are continuously going up, minimum wage also needs to go up.  More and more, low income tenants are paying enormous percentages of their income on rent, and eventually their housing situations, even rent stabilized housing, will be unaffordable to the majority of New Yorkers.  We need to raise minimum wage in NYC to reflect actual cost of living.   In the short run, workers should be able to earn what they are owed and not forced into doing things like working off the clock (Read about wage theft here.)
  6. Keep organizing!  Form a tenant association, join a community group!  If you live in Crown Heights, come out to our next meeting of the Crown Heights Tenant Union on April 17th at 7 pm at the Center for Nursing and Rehabilitation.  For more concrete assistance with organizing, check out our resources tab, and feel free to write to us at thesurrealestate@gmail.com

Council Members Ritchie Torres, Brad Lander, Antonio Reynoso, Helen Rosenthal, Inez Barron Tenants, and Advocates Stand United against Predatory Equity: Call for responsible disposition of more than 1500 apartments currently in foreclosure.

Council Members Antonio Reynoso and Ritchie Torres with UHAB Executive Director Andrew Reicher. Photo from Council Member Brad Lander.
Council Members Antonio Reynoso and Ritchie Torres with UHAB Executive Director Andrew Reicher. Photo from Council Member Brad Lander.

For Immediate Release: March 18, 2014

City Hall — Elected leaders including City Council members Ritchie Torres, Brad Lander, Antonio Reynoso, Helen Rosenthal, and Inez Barron are joining tenants from 42 affordable buildings spread across Manhattan, Brooklyn, and the Bronx and calling on the mortgage holder and the City to negotiate a deal that would end tenants’ suffering. The rent-regulated and HUD subsidized portfolio, known as the Three Borough Pool, is in foreclosure due to irresponsible financial practices called “predatory equity.” Housing advocates across the city, including Banana Kelly Community Improvement Association, CASA New Settlement Apartments, New York Communities for Change, Northwest Bronx Community and Clergy Coalition, Pratt Area Community Council, Tenants and Neighbors, and the Urban Homesteading Assistance Board are assisting residents in their fight to secure the portfolio as affordable housing.

Predatory equity is a disturbing trend that occurs when investors purchase and grossly over-leverage rent regulated housing with the expectation of huge returns. In order to realize financial gains, property owners attempt to illegally raise rents and reduce maintenance and operating costs. This harmful cycle leads to the displacement of low-income families, deterioration of buildings, and the loss of much needed affordable housing.

Advocates say that the Three Borough Pool is emblematic of the problems of predatory equity. In 2007, a private equity joint venture (Normandy Real Estate, Vantage Properties, Westbrook Partners, and David Kramer) packaged the 42 buildings into one portfolio with a $133 million loan. By 2010 the mortgage (now part of a much larger commercial mortgage backed security) was in default. LNR, the mortgage servicer for the security, began foreclosure proceedings in April of 2013. LNR has given the owners until April 2nd to come up with a refinancing plan that would take the buildings out of foreclosure. However, tenants and advocates hope to use the foreclosure as a juncture to transfer the properties to another owner entirely.

“We’re here today to urge any and all financial institutions not to refinance with David Kramer/Colonial Management, Normandy Real Estate, Vantage Properties and Westbrook Management,” said Benjamin Warren, Tenant Association President of 1511-1521 Sheridan Avenue. “Myself and the other residents of this portfolio know what we deserve, and it is not the carelessness of these self-interested corporations. We look forward to better days without these groups.”

The buildings are physically collapsing under the weight of an enormous mortgage. There are over 2,700 HPD violations in the portfolio. Three of the buildings are in City’s Alternative Enforcement Program, an initiative that targets 200 of the most distressed buildings in the City. Tenants, advocates and elected officials are calling on LNR Property to negotiate with the City and transfer the properties to a responsible developer who will bring the buildings back to safe condition and keep them affordable for the families who call them home.

“These guys took $133 million from the bank and not one dime has gone into taking care of the buildings we live in,” said Debra Cooper, a tenant leader at 711 Fairmount Place. “We live with constant leaks. I regularly don’t have heat or hot water. We have no mail boxes and can’t get our mail. Enough is enough. If David Kramer and his friends aren’t going to take care of our homes, it’s time they are sold to someone who can. It’s past time.”

Some members of the City Council used the situation in the Three Borough Pool to call on the City administration to renew its pledge to fight financial speculation on affordable housing. Elected officials believe that one way to dissuade investors from speculative behavior is through expanding City programs like the Alternative Enforcement Program and the Proactive Preservation Program. These programs allow the City to more closely monitor buildings in physical and/or financial distress. Officials are also considering legislation to create a “watch list” of property owners who engage in predatory equity.

“Affordable housing exists to ease the burden on middle and low income New Yorkers who are looking for a decent standard of living,” said Council Speaker Melissa Mark-Viverito. “This situation highlights the need for further oversight to prevent affordable housing from being undermined by speculative and predatory equity practices in the future.”

“The loss of affordable housing to the practice of predatory equity has created a crisis in our communities that will only become more severe if we fail to take action,” said Councilmember Ritchie Torres, Chair of the Committee on Public Housing. “These properties belong in the hands of new, responsible owners, committed to their preservation and long-term affordability. As a concrete step to address these abuses I have proposed legislation that would create a publically accessible watch list of property owners that engage in this negligent and abusive practice.”

“What these predatory investors are doing is simply unconscionable; everyone in this city deserves a safe, affordable, and well-maintained place to call home,” said Council Member and Bronx delegation leader Annabel Palma. “The administration must take aggressive action against these irresponsible owners and make good on its promise to preserve the city’s affordable housing stock.”

“No one should live in an apartment with mold, water damage or rusted, broken pipes in New York City. It’s time to close the gap between the rights of tenants and obligations of property owners. When homeowners across the country were facing foreclosure because the banking industry had gone rogue, the federal government stepped in to regulate the industry and offer financial assistance through the HAMP modification program. Tenants are no less important than property owners,” said Council Member Mark Levine. “It’s time for the City to step in to empower tenants and to put an end to these abuses. No one’s quality of life should be diminished because of negligent slumlords.”

“Predatory private equity is sucking the life out of our communities, leaving buildings vacant and in decay across New York City. Thousands of long time, hard working residents will be forced from their homes and this is unacceptable,” said Council Member Ydanis Rodriguez. “The city must step in to save these tenants or else this disturbing trend will continue wreaking havoc in our most vulnerable communities. Going forward, the state needs to put safeguards in place to prevent these practices because in every scenario, NYC residents and taxpayers are losing.”

“Today I’m proud to stand with the tenants of the Three Borough Pool. Predatory lending is rooted in disingenuous dealings and tenant harassment, practices that have allowed building owners to shed affordable housing in the race for greater profits, said Council Member Helen Rosenthal. “On the Upper West Side, advocates and tenant leaders have stood firm against speculators like Meyer Orbach whose portfolio includes 25 buildings located between West 106th and West 109th Street. Like the investors behind the Three Borough Pool, The Orbach group has used frivolous litigation and intimidation tactics to push long-term rent regulated tenants from their homes and strip regulated apartments of their affordability through vacancy decontrol. These actions are unconscionable and we must call on every available recourse in our city government to help tenants save their buildings, protect their homes, and preserve their quality of life.”

“Together, we have the opportunity to ensure that over 1,500 families live free from bad conditions, harassment, speculation and fear,” said Sheila Garcia, an organizer at CASA New Settlement Apartments. “Tenants across these buildings want a landlord who will follow the laws and listen to their concerns. Tenants across these buildings have raised families and built communities that we cannot let be destroyed, period, but especially not in the name of speculation.”

“Brooklyn tenants living in HUD subsidized buildings that are part of this foreclosure pool have had enough,” said Jon Furlong, Assistant Organizing Director at the Pratt Area Community Council (PACC). “PACC is proud to stand with the tenants from ALL the affected buildings to ensure they get the repairs and services they deserve. We must continue working together to prevent this type of speculation in multi-family buildings.”

“We’re pleased to see the City Council standing with Three Borough Pool tenants in their fight for a better deal,” said Kerri White, Director of Organizing and Policy at the Urban Homesteading Assistance Board. “However, as a City, we need to figure out ways we can stem speculation on affordable housing in the first place. Tenants shouldn’t have to suffer for years and face foreclosure, waiting for the opportunity to fight for something better.”


Stabilis Press Conference

Here is  a video with footage from the Stabilis press conference and building tour on December 3rd. Letitia “Tish” James, who will become our Public Advocate in just a few days, spoke beautiful words of solidarity with the tenants. Tenants spoke about the hardships and appalling conditions they have endured while living in a building with a negligent landlord. Then the tenants lead a tour of the apartments to show some of these conditions. Please watch and share!

“BREAKING: Tenants Officially Submit Creditor Claim in US Bankruptcy Court”

Bathroom, 1894 Cornelia
Bathroom, 1894 Cornelia on 8/21

This morning, after several months of preparation, tenants at six buildings in Ridgewood, Queens entered Bankruptcy Court to make an official claim against their landlord, Steven Kates. Because of poor, inhabitable conditions, tenants are asserting that their landlord owes them money, as well as insisting on emergency repairs and relief. 

As a result of organizing efforts leading to pressure being put on both Stabilis Capital (the lender) and Dafnonas Estates (the management company), repairs are getting done.  Holes have been patched, smoke detectors have been installed, walls have been painted.  Still, much is yet to be done. Katrina, a pregnant woman residing in 1894 Cornelia, for example, lives with an enormous hole in her bathroom (pictured above) which rains water every time the upstairs neighbor takes a shower.  Worried about mold effecting her unborn baby’s health, Katrina is afraid to step foot in that section of the apartment.  Why are the walls being painted in this building while Katrina is forced to live with emergency conditions?

Through bankruptcy court, tenants hope to force Stabilis and Dafnonas to the negotiating table and have a conversation about long term building preservation. Katrina and her neighbors have identified CATCH, a mutual housing nonprofit developer, as a group they would like to own their building. (From conversations with their attorneys, UHAB knows that Stabilis is not interested in long term ownership.)

The buildings are located in Ridgewood, Queens, which the New York Times has declared the new place for young Brooklynites to move. For this reason, Stabilis probably hopes to make a lot of money flipping these properties.  Young hipsters (gentrifiers), who normally are willing to pay higher rents, are being pushed out of Brooklyn and across the border into Queens. As so often happens in situations like this one, long term tenants, like the ones in the 6 Stabilis Buildings, are feeling the squeeze. As tenant leader Denise Serrano told us a few weeks ago:

 I grew up in Williamsburg, and thanks to rising rents my family was forced to move. I raised my children in this building, and on behalf of myself and my neighbors, I do not want to see that displacement happen again here.

When blogs like Brooklyn Mag are posting articles with the headline, “Should we all give up and move to Queens?” they should be aware that Ridgewood is not an just an affordable enclave for young artists, it’s home to many people — many people who are not, to put it mildly, “giving up.”

Predatory Equity in 2013: New Organizing Tools

Since 2008, UHAB and our allies have learned a lot about how financial malfeasance in the rent regulated housing market puts low income tenants at risk. As Wall Street rejoices over the “rebound” in housing prices, we know the truth: the rebound goes hand in hand with a rebound in speculation and overleveraging. Last year, we created the Life Cycle of Predatory Equity that reveals that Predatory Equity to be a cyclical process: an overleveraged mortgage, harassment, neglect, foreclosure, and overleveraging again. Unfortunately, since 2008, we’ve seen many buildings enter their second cycle.

Buildings entering the second round of Predatory Equity often are faced with a new speculative landlord who will use familiar tactics to try and “improve the underperforming asset.” (i.e., Landlord speak for “increase rents by pushing regulated tenants out.”) One common tactic that’s  particularly popular in gentrifying neighborhoods is a “buy-out,” where landlords offer tenants seemingly large sums of money to vacate their units. The money is never very much – hardly even enough to move. (One tenant we work with was offered $6,000 and a bus ticket to Philadelphia where, her landlord said, “housing is more affordable.”)

Fighting these buy-outs is important: when tenants opt to leave, landlords are automatically able to raise rent by 20%, contributing to the erosion of affordable housing stock in New York, and potentially even bringing the unit out of rent regulation.  If a tenant decides to stay, landlords can only raise rent by 4% to 7.75% depending on length of lease.

We developed a fact sheet on these kinds of buy outs while working with tenant groups at 1153 and 1159 President Street in the rapidly-gentrifying neighborhood of Crown Heights. Check it out here.

News isn’t all bad: in the past few years, we’ve seen some buildings get preserved for long term, quality affordable housing. We’ve seen tenants successfully organize to reclaim their buildings from predatory banks, and are currently in the preservation pipeline

Finally, with the help of graphic designer/artist Donna Choi, we developed an organizing tool that we’re using to engage tenants fighting to break the cycle of Predatory Equity. The infographic, available in English and Spanish, explains how developers buy buildings that are in foreclosure and illustrates how tenants can organize and to demand that the building is sold to a developer of their choosing.

We encourage you to these resources and use them!