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President • STARKMAN
Best Practices:
- Don't underestimate the role of corporate culture.
- Be prepared: Have a crisis management plan in place.
- Know your crisis response team.
- Move quickly to assess the severity of the crisis.
- Do not delay your first communication.
- Control your messages.
- Be accessible, transparent, and honest.
- Leverage technology to engage constituencies directly and have IT redundancies in place.
- Be accountable.
- Know when to seek expert help.
- Identify third parties to advocate on your behalf.
Deputy Director - FinCEN • U.S. Treasury
Best Practices:
- Conduct a risk assessment to establish your bank's risk profile.
- Establish internal controls by implementing policies and procedures to ensure ongoing compliance.
- Designate an AML Compliance Officer and establish an AML Compliance Committee.
- Conduct independent testing and review of your AML compliance program.
- Establish a training program to ensure that appropriate personnel are trained in your AML compliance program.
- Flag, manage and report suspicious activity.
- Establish, monitor and review your Customer Identification Program to know the true identity of each customer.
- Create a culture of compliance and work closely with regulators and examiners.
- Make sure your transaction monitoring system is risk, cost and organization appropriate.
- Use examinations, audits and their findings as a foundation for continuous AML program improvement.
Managing Partner • Capital Pacific
Best Practices:
- Take advantage of 1031 tax-deferred exchanges to avoid capital gains on commercial property sales.
- Include real estate strategies as part of your estate planning.
- Develop strategies to monetize your commercial real estate.
- Consider commercial real estate as an alternative investment option.
- Consider the differences between leasing versus owning for your unique business needs.
- Seek out buyer representation.
- Create real estate development plans and work with a development partner to support business expansion.
Deputy Director - FinCEN • U.S. Treasury
Best Practices:
- Conduct a risk assessment to identify your MSB's risk profile and to form the basis of your AML program
- Develop and maintain an effective AML program based on solid internal controls.
- Designate a BSA/AML Compliance Officer and establish an AML Compliance Committee.
- Conduct independent testing and review of your BSA/AML compliance program.
- Establish a training program to ensure that appropriate personnel are trained in your AML compliance program.
- Flag, manage and report suspicious activity.
- At certain threshold levels, collect required information from customers to know the true identity of each customer.
- Develop a strong agent oversight program.
- Implement an effective Transaction Monitoring System.
- Use examinations, audits and their findings as a foundation for continuous AML program improvement.
Director • MatchPower Australia Pty Ltd
Best Practices:
- Identify the emotional drivers of prescriber decision making.
- Tailor sales pitches to individual prescribers.
- Aggressively pursue sales after patent expiry.
- Navigate partnerships with confidence, clarity and savvy.
- Address barriers to compliance and persistence.
- Prioritize perception management.
- Orient clinical trial design to more marketable claims.
Principal • JAS Limited
Best Practices:
- Maintain a constructive attitude: Understand that management and regulators share many of the same goals.
- Communicate actively: Maintain an active dialogue with all appropriate regulatory agencies and staff.
- Engage senior executives and business managers: Ensure a culture of responsibility and accountability at the highest levels.
- Engage in dialogue in order to have a voice in legislative policy and regulatory proposals.
- Develop formal and well-defined examination processes.
- Address each regulatory issue or finding rigorously.
- Develop a ‘Black Swan’ program: Be prepared for both common and uncommon scenarios that might have an impact on your business.
Managing Partner • Odgers Berndtson
Best Practices:
- Conduct a 'Digital DNA' gap assessment.
- Start with the board and acquire two or three digital thinkers.
- Next, the management team: Don’t just hire a CDO. Make sure you have two or three genuine digital natives in key positions.
- Conduct a 'digital boot camp' to shock the troops into awareness and prepare them for change.
- Create a cadre of digital advisers and board members who will help develop a new digital business model.
- Recruit or promote to key roles those who will own and implement the various elements of the new strategy.
- Educate and train your non-digital natives to allow them to adapt to a new culture and way of thinking.
President • AML Audit Services
Best Practices:
- Develop a written risk assessment.
- Develop and maintain effective, risk-based AML policies and procedures approved by senior management and/or the board of directors.
- Monitor transactions to ensure regulatory reporting requirements are met and to identify any suspicious activity.
- Provide training to personnel with access to transactions, customers, compliance operations or activity that may be exploited by criminals.
- Independent testing by a qualified professional is required for precious gems dealers on a periodic basis.
- Appoint an experienced and knowledgeable AML compliance officer.
- Ensure accuracy and timely reporting for Form 8300.
Owner • Lind Consulting LLC
Best Practices:
- Don’t waste time trying to shift blame for your situation to your bank, the economy or someone else: Take accountability and focus on improving.
- Preparation is critical: Take the time to understand the metrics and break down your business into its essential components.
- Be realistic about the things you can’t control: Don’t base your turnaround plan on unrealistic assumptions.
- Be honest and communicate effectively with stakeholders in order to reestablish credibility and confidence.
- A turnaround requires a good leader: Be clear about your vision, your plan, and your expectations and lead with compassion.
- Embrace adversity as an opportunity for improvement.
- Develop sounding boards: Follow your instincts but also consider perspectives from independent sources that you trust.
Principal • Ryan Erving Consulting
- Helping clients navigate the process of building high-performing results-driven teams starting with the creation of a realistic road map to build the teams they need to achieve their business goals efficiently and cost effectively.
- 20 years of industry experience in technical staffing and recruiting, personally placing 1,500 people.
- Fortune 500 clients include: Wells Fargo, Kaiser Permanente, Genentech, and Juniper Networks. Guided them through the process of building high performing teams.
- Specializing in technology teams and startups in the early and growth stages.
President • AML Audit Services
Best Practices:
- Produce a written AML risk assessment.
- Develop and maintain effective, risk-based AML policies, procedures and internal controls.
- Monitor transactions across all products and services to ensure regulatory reporting requirements are met and to identify any suspicious activity.
- Provide training to personnel with access to transactions, customers, compliance operations or activity that may be exploited by criminals.
- Know your reliance relationships.
- Independent testing by a qualified professional is required for broker-dealers on an annual basis.
- Conduct periodic self-testing to evaluate adequacy of AML controls.
Principal • The Culhane Company
Best Practices:
- Set a course: Predictive analytics will fundamentally change your business if you commit resources to it.
- Don't always swing for a home run: Singles and doubles can bring you success.
- Demand insights and business impact from the predictive analytics program.
- Invest in the best data resources you can afford.
- Know your modeling data better than anyone else.
- Great PA teams innovate: Demand and reward successful infusion of new methods and technologies.
- Protect your predictive analytic efforts and your business by understanding your data use/regulatory/privacy framework.
President • AML Audit Services
Best Practices:
- Develop a written risk assessment.
- Develop a risk-based AML compliance program of policies, procedures and internal controls tailored to the RMLO.
- Monitor transactions across all products and services to meet regulatory requirements and identify suspicious activity.
- Provide training to personnel with access to transactions, customers, compliance operations or activity that may be exploited by criminals.
- Conduct independent testing by a qualified professional, as required for RMLOs on a periodic basis.
- Ensure accuracy and timely reporting for Form 8300 and Suspicious Activity Reports (SARs).
- Know your reliance relationships.
Quality Consultant • TrustedPeer, Inc.
Best Practices:
- Formalize your business processes and bring them under control; uncontrolled or broken processes impede quality and customer satisfaction.
- Benchmark how your business performs against other players both in and outside of your industry.
- Focus on product reliability: Reliability = Quality + Time.
- Have a standardized method and language for problem solving.
- Top management commitment is essential; senior management sets the tone, direction and policies for quality and customer satisfaction.
- Encourage employee involvement so that all personnel engage in satisfying customer needs and producing quality work throughout all aspects of the business.
- Develop a quality strategy; identify, plan and invest in the key success factors that drive quality and customer satisfaction.
Vice President - Marketing • TrustedPeer, Inc.
Best Practices:
- Understand where your product is in its current life cycle.
- Innovate or reinvent to create a series of product life cycles.
- Make your innovations relevant and important to your customers.
- Reach out to new users through new channels.
- Find strategic partners to bundle or cross-sell your product.
- Maximize all functional areas that affect your product.
- R.I.P. – but don't forget!
President • Carse Consulting
Best Practices:
-
Identify the key players within the company who will make your loyalty program a success and create a steering committee.
- Clarify what "loyalty" means in the context of your business or brand and articulate the specific objectives the program is expected to meet.
- Create a succinct program proposition.
- Develop a program strategy and financial model.
- Determine the technical and operational infrastructure necessary to implement and support the program.
-
Develop a comprehensive implementation plan.
- Create an ongoing measurement and enhancement plan.
- Have an exit strategy.
President • ClearAction
Best Practices:
- Discover how big are "bad costs" caused by obstacles to customers' ease-of-doing-business.
- Compare ROI of tackling bad costs versus ROI from customer loyalty enticements.
- Collaborate cross-organizationally to end bad costs.
- Motivate everyone to proactively manage their ripple effect on customers.
- Inspire creativity broadly for novel ways to add mutual value.
- Weave customer experience excellence into everything your company does.
- Treat customer experience management as a flowing, integrated system within your company.
Managing Director - Corporate Communications • KM Systems Group
Best Practices:
- Equip multiple levels of management with communications toolkits containing checklists, templates and messages that explain changes.
- Establish productive partnerships that foster transparency among the communications team, executives and key functional areas of the company.
- Use a broad variety of print, text and audiovisual elements to explain new or complex material to employees.
- Create and monitor feedback channels in order to understand wants and needs of employees.
- Develop a crisis communication program with an established team and prepare for multiple crisis scenarios.
- Integrate communications with human resources functions to drive proactive messages that better address employee issues and concerns.
- Elevate the visibility of strategy-related communications to promote transparency and drive consistency across the organization.
Partner • AML Services International
Best Practices:
- Make sure your firm has adequate OFAC reporting procedures in place.
- Conduct an OFAC due diligence for any activity, including mergers and acquisitions, projects with new business partners, and entering into contracts.
- Put an OFAC program in place.
- Establish a screening and reviewing procedure to avoid OFAC-sensitive business dealings, clients or transactions.
- Design an OFAC risk matrix to assess your likelihood of encountering OFAC issues.
- Conduct a review of OFAC policies and procedures using an independent and qualified person.
- Make sure your foreign affiliates comply with OFAC regulations.
Director /Partner • CLIA Consulting
Best Practices:
- Do your country profile analysis (CPA) and develop your market information resources.
- Draw up your European market and language map.
- Audit your company's existing resources.
- Define a policy for language use, including general language skills.
- Identify key mediators (distributors, translators, legal reps, etc.) for each of your markets.
- Build a program for training key personnel that is strategic.
- Develop 'language general skills' and market knowledge.
Principal • Butterfield Speaks
Best Practices:
- Use an Anecdote to illustrate a point.
- Create a Powerbite Story for impact and flexibility.
- Use the Cautionary Tale with caution.
- Use a Hero Story to communicate core values.
- Use the Aspirational Story – Futurecasting – to lead change.
- Use The Analogy to shine new light.
- Learn how to tell a better story.
- Build a Story Room.
- Listening for Stories: The exercise.
Managing Director • CSG Partners
Best Practices:
- Conduct a thorough feasibility study.
- Ensure there's a next generation of management.
- Prepare a confidential information memorandum.
- Hire independent professionals with expertise in ESOPs.
- Raise external capital to finance the ESOP transaction.
- Explain ESOPs to employees thoroughly and frequently.
- Structure a transaction to defer capital gains tax.
Emerging Markets Strategist • Independent Consultant
Best Practices:
Lease Program Manager • DataSales
Best Practices:
- Consider cash flow management as a tool to preserve cash for sales and marketing.
- Work with a lessor with experience and knowledge in your industry.
- Select a partner that is reliable and provides superior customer service in every aspect of your relationship.
- Protect yourself against obsolescence with renewal, upgrade and return options.
- Consider wholesale rollover for certain technologies in your leasing strategy.
- Read the fine print related to end-of-lease notice periods.
- Carefully manage and track your equipment and lease.
President • Mohr World Consulting
Best Practices:
- Analyze where you want your company to be in the short and medium term in terms of your international strategy.
- Be clear about your vision and about the stumbling blocks that might keep you from moving forward.
- Analyze what your competition is doing in terms of products, services and marketing; articulate how yours are better and why.
- If you are offering a new product or service, understand how it improves upon or complements what you are currently offering.
- Ask yourself if you have the resources to develop a product internally; analyze the costs, time, security, cultural issues, and international risks involved.
- If partnering is the best solution, know how to find the right company, develop a win-win agreement and establish governing principles.
- Master the issues regarding ownership; know how to dissolve the partnership if it fails.
Chairman • The VanAllen Group
Best Practices:
- Analyze the tangibles and intangibles of business aviation.
- Analyze strategic and tactical use.
- Develop a full budget of costs, staff and time.
- Conduct a brand and corporate culture analysis.
- Secure internal buy-in.
- Analyze the business aviation usage of competitors and best-of-breed aspirational corporations.
- Develop effective standards and policies.
Chairman, CEO • OpenMatters
Best Practices:
- Know the four business models, their respective value and their benefits.
- Assess your leadership team's unrealized preferences, biases, and assumptions.
- Assess your current business model.
- Inventory your tangible and intangible assets.
- Create your new digital business model.
- Implement your new business model.
- Monitor and rebalance your business model to stay on course.
CEO • The VanAllen Group
Best Practices:
- Integrate strategic intent into the aircraft selection process.
- Assemble a transaction team that has the right strategic blend.
- Understand your exit strategies early.
- Understand your tax implications in the transaction.
- Make sure you consider the full range of cost factors.
- Know the pros and cons of various cost-saving strategies.
Former Global Vice President • Unilever
Best Practices:
- Make the business case for doing well by doing good.
- Make the moral case for doing well by doing good.
- Engage the leadership. Make them agents of change.
- Align your company's infrastructure to support a purpose-driven business model.
- Foster the well-being of your employees.
- Make purpose central to your core process. No CSR!
- Enlist an expert advisory board.
Principal • GPChan Consulting
Best Practices:
- Commitment to transparency has to start at the top – and be evangelized throughout the organization.
- Have a clear understanding of the roles and responsibilities of each leadership function in the company.
- Everybody has to be a stakeholder for a strategic plan to be successful.
- Build a strategic plan that is measurable, realistic, adaptable – and visible.
- Always know where and how your money is being spent.
- Establish timely, reliable, and functional reporting structures to monitor performance.
- Revisit and update your plan regularly.
Professor, International Business • University of Victoria
Best Practices:
- Sense, meld and redeploy new knowledge and innovations from subsidiaries.
- Create and maintain a knowledge-sharing architecture.
- Understand how your core competencies and assets are "recontextualized" in a new cultural or geographic context.
- Utilize internal talent to make the most of their global footprint.
- Understand the skill sets of your multicultural employees.
- Have a language strategy for global operations, including a corporate language that travels well across cultural contexts.
Strategic Insights • Alden Taylor
Best Practices:
- Establish a culture of information gathering and dedicate internal resources to it.
- Protect your intellectual property by detecting and mitigating the illegal and unethical appropriation of know-how.
- Focus on intangibles when doing due diligence for M&A, strategic partnerships and joint ventures.
- Substantiate your strategic investment by understanding thoroughly your business environment, based on tightly-correlated information and relevant trends.
- Assess your implementation risk prior to execution by identifying and anticipating the potential changes that can emerge during implementation.
- Identify competitive impact by understanding what motivates competitive behavior as well as your competitor's decision-making processes.
- Evaluate value chain relationships by using intelligence to gain "insight with implications" into the strategies, tactics and decision-making processes of key relationships.
Managing Director • Barclays Wealth Americas
Best Practices:
- Know your market: what you are selling, who your best customers are and what customers want.
- In terms of hiring for your sales staff, know your territory; know who are the high achievers.
- See your salespeople as your customers: They do not work for you, you work for them.
- Create a clear roadmap to success for your salespeople.
- Be as candid, as immediate and as positive as you can be.
- Be reliable because people are watching; make sure they see fairness and thoughtfulness.
- Celebrate victories.
Assistant Professor • University of Nebraska - Lincoln
Assoc. Partner • IBM Global Business Services
Best Practices:
- Ensure that written AML and OFAC compliance programs are comprehensive and risk-based.
- Design and implement an ERA that adequately measures inherent and residual compliance risk, gaps, areas of weakness and opportunity.
- Address gaps and inadequacies with a remediation program that is monitored, measured and reported to the board of directors.
- Document everything! If a process or control is not documented, it never happened.
- Line-of-business managers own compliance processes in their areas, designating compliance officers to lead risk assessment and carry out remedial programs.
- The board of directors leads a culture of compliance throughout the enterprise, is well-trained in compliance and actively involved in the program.
- Ensure that BSA officer is qualified, empowered by the board, adequately funded and independent of lines of business.
- Recognize risk assessment as a dynamic tool and update it as the risk profile of lines of business or the enterprise changes.
- Be proactive! Stay ahead of emerging regulations, new regulatory guidance, shifts in regulatory focus, and emerging exposures.
- Leverage the BSA/AML and OFAC risk assessments to support enterprise risk management and optimize business value.
Managing Director • The VanAllen Group
Best Practices:
- Establish a policy of strategic alignment.
- External reviews should be conducted on a regular basis.
- Establish internal use policies.
- Develop and invest in the business acumen and leadership skills of your aviation providers.
- Set up a risk management policy.
- Learn how to deal with the media.
- Analyze all segments of aircraft ownership.
Principal Consultant • John O'Leary & Associates
Best Practices:
- Create a big game.
- Encourage relentless innovation.
- Promote passion, engagement and self-expression.
- Capitalize on conflict: Give your teams the tools to not only tolerate conflict but also to leverage it.
- Express your distinct personality, identity and brand at the individual, team and company level.
- Foster teams that are mission-driven and result-focused.
- Encourage teams to be self-determined and independent-minded.
Principal Consultant • TechZecs, LLC
Former SVP Organizational Excellence • Symantec Corporation
Best Practices:
Officer-in-Charge • Royal Canadian Mounted Police
Best Practices:
- Develop a comprehensive risk review appropriate to the organization.
- Create a culture of compliance.
- Develop engaging, interactive training programs using real-life examples.
- Look to the outside for a chief anti-money laundering officer to oversee compliance programs.
- Use outside experts for program and systems reviews.
- Integrate AML and fraud solutions.
- Secure your data.
Managing Director • MCorp
Best Practices:
- Focus on the intersection of business, brand strategy and unmet customer wants and needs: Solve real customer problems in a way that is relevant to you.
- Engage in a proven, defined process: Customer experience-driven innovation is a discipline that requires hard work.
- Look at your industry and company through the eyes of your customers: Use customer research to adopt an “outside-in” view of your world.
- Move beyond incremental improvements: Innovation is not about a small fix or closing a known gap, but changing how customers get what they need.
- Build support by creating a business case for customer experience improvements internally.
- Engage customers, employees and other stakeholders throughout the experience design process.
- Prototype, test and refine new services, experiences or products before taking them to market, then monitor them in the marketplace.
TrustedPeer Expert • Global Brand Research
Best Practices:
- Explore business and branding opportunities by conducting initial qualitative brand positioning research in key markets or countries.
- Conduct quantitative positioning research in key markets.
- Select a final brand equity measurement model.
- Create a unified brand positioning that works globally, but is customized for local markets; select rational and emotional brand attributes for tracking.
- Select a best-of-breed tracking tool and tailor it to your specific industry and competitive environment.
- Conduct tracking of brand equity, advertising performance, brand perceptions and behavior in countries with marketing investment.
- Create an ongoing feedback loop by maintaining a close alignment and sharing results within headquarters groups and regional and in-country marketers.
Partner • The Chasm Group
Best Practices:
- Always start from a customer and market perspective.
- Know your crown jewels and use them to decide your next area of growth.
- Expand your product core or reinvent your category to solve more problems for your existing clients.
- Use a market development framework to find target market initiatives.
- Ensure that key mid-level managers across all functions participate in strategic decisions with shared accountabilities, alignment and buy-in.
- Think in terms of 'systems of engagement' and business outcomes.
- Staff your growth business differently than your core with different metrics and skill sets.
Consultant • Casagrande Consulting LLC
Best Practices:
- Know and embrace your truth.
- Get help early because time is not your friend.
- Highly effective institutions are led by a leadership team, with the president and board sharing strategic responsibilities.
- Highly effective teams practice in order to play successfully.
- Measure what’s important.
- Get a coach.
- Get comfortable with and then embrace uncertainty; it is the fuel of creation.
CEO • Telegraph Hill Program Initiatives
Best Practices:
- Strip agile to its essence: the smallest, colocated team of engineers that deliver the highest quality software, at the lowest cost as quickly as possible.
- Data is different: Data-centric projects are different from software application development and require unique skill sets, mindsets and training.
- There is no silver bullet: No one perfect software development process fits all companies and all deliverables.
- Integrate nimbly: Larger companies need software architectures and development processes that allow them to develop software as fast as smaller companies.
- There is no process priesthood: Coaching is better than top-down management for improving software processes.
- Talent is global: Multiple resourcing strategies, often global, are essential for finding the right talent fast.
- Product management is essential: Good software is built from good requirements clearly specified by business process experts.
Director • Instant Insights Lab
Best Practices:
- Define clear objectives before you even start.
- Ensure the right team is in place.
- Make sure all potential phases are considered and understood.
- Design the right method within each of the phases.
- Identify and locate your target audience.
- Ensure you have the right stimulus material.
- You must understand how the findings will be used and shared.
Managing Principal • R.A. Potter Advisors
Best Practices:
- To a prospective client your message sounds very much like your competitor's. Create clear customer preference by adding proof, relevant stories, benchmarks and testimonials.
- Your value is not in your solution – without client problems your solutions have no value. Focus your communications on client problems to increase your value to clients.
- Differentiate on the client – find and align to what is unique about them instead of forcing the client to differentiate on you.
- Pay more attention to your long-term clients and treat them better than prospective clients.
- Focus on improving the skills level of your elite performers.
- Client acquisition/retention involves more than mastering theory; it requires building complex skills through deliberate practice. Your goal is to change behaviors and outcomes not just change minds.
- Commit to building strong relationships and deep connections; it will increase your win rate by 200-300 percent.
Consulting Partner: Healthcare Innovation • Outsell, Inc
Best Practices:
- Validate your claims about your product before presenting it to potential investors, partners and customers.
- Construct a three-track business plan: expected, worst case, and stretch (or reasonable upside).
- Address value propositions for three constituencies: health care providers, payers and patients.
- Explore non-dilutive grant opportunities before trying to raise expansion capital.
- Once pilot commitment is secured, become the driver of the pilot project plan.
Principal • TCGen, Inc.
Best Practices:
- Use the Design Thinking approach to create breakthrough product concepts.
- Establish a Marketing Requirements Process to capture the "voice of the customer."
- Establish a Product Portfolio Management Framework.
- Create a Product Roadmap.
- Create a Technology Roadmap.
- Leverage Social Networking Technologies to improve product definition and product strategy.
- Develop a Strategic Product Plan for the year.
President • Amon-Higa & Associates
Best Practices:
- Partner with a team leader who is accountable for the total, end-to-end customer experience.
- Engage the hearts and minds of the cross-functional team which is responsible for the customer's experience.
- Implement the Design for Delight methodology and use it consistently.
- Conduct "follow me homes" to observe customers in their natural environment, using your product.
- Identify moments of truth in the customer experience.
- Build "closed loop" voice of customer listening posts.
- Conduct quarterly customer experience reviews.
Senior Vice President • DVS Group
Best Practices:
-
Consolidating Operations: Know your business, understand present and future costs.
- Build vs. Buy: Determine whether "building" or "buying" is the best way to expand your company.
-
Geographic Expansion: Learn your new market and what it takes to succeed in it.
-
Acquisition: Do due diligence on potential targets.
-
Divestiture: Understand the true impact on your operations.
-
Preparing to Sell Your Company: Weigh the timing, maximize value, then create a strong company narrative.
-
Handle Internally vs. Outsource: Assess your own cost and effectiveness, then demand specifics from potential vendors.
Principal • Governance and Compliance Initiatives, LLC
Best Practices:
- Do a bribery risk assessment.
- Conduct due diligence on agents.
- Put controls in place.
- Implement an anti-bribery policy and program.
- Implement a policy-and-program training and communications plan.
- Put program governance in place.
- Delegate day-to-day program operational responsibility to a senior officer.
- Respond to bribery allegations and apply lessons learned.
- Document, document, document.
Principal Consultant • Dimension Data
Best Practices:
- Lead with people, not technology.
- Create a user segmentation plan that acknowledges your organization has multiple types of users.
- Develop a future-ready technology plan that meets your organization's needs.
- Select the correct “blend” of individual solutions to fit your unique, unified plan.
- Create an internal “catalog” of solutions.
- Conduct policy and process review.
- Ensure that an adoption management plan is developed and managed with as much effort as the technology rollout plan.
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