Appraisal District OperationsSurvey Finds More Properties, More Taxing Units
Comptroller's Report Buying at a Tax Foreclosure Sale Homestead Tax Deferral Changes With almost 16 million property tax parcels to appraise, the state’s 253 county appraisal district (CAD) offices reported operating costs increased more than 6 percent from final expenses in 2001 to 2002. The number of property tax parcels increased almost 2 percent from 2001. These CADs serve 3,743 taxing units – 25 more units than in 2001 – at an annual cost of about $270.5 million.
These are just some of the findings from the Comptroller’s 2002 and 2003 Appraisal District Operations Report. The Comptroller’s Property Tax Division (PTD) asked the 253 appraisal offices to respond by survey about final 2002 operations and projected 2003 budgets and plans. While Texas has 254 counties, the Potter and Randall CADs form a single appraisal office in Amarillo, with one budget and staff.
Taxing units
These CADs reported a total of 3,743 taxing units for tax year 2003, compared to 3,718 in 2002. This represents a net increase of 25 taxing units, after adding for new taxing units and subtracting for taxing units that have dissolved or will no longer levy a property tax.
For 2003, 62 new taxing units will levy a property tax for the first time. Some of these units may be located in more than one CAD. These new units included 16 municipal utility districts, six water control improvement districts, six groundwater conservation districts, five emergency service districts, five cities, five underground water conservation districts, four river authorities, four water districts, three fresh water supply districts, three fire districts, and one each of the following types of special districts: levee improvement, irrigation, water supply, hospital and conservation and reclamation.
Twenty-three taxing units either dissolved or withdrew from their appraisal district or will no longer levy a property tax. Six taxing units consolidated operations with other taxing units.
Property parcels
The total number of taxable parcels (or accounts) increased statewide by 233,045 parcels for a total parcel count of almost 16 million parcels. CADs vary in how they divide and consolidate properties into parcels, particularly personal property accounts. These variations may affect the total parcels reported. CADs will report their final 2003 parcel totals this winter.
The greatest increase in number of parcels occurred with mineral property. CADs added 103,373 mineral accounts — an increase of about 4 percent — to reach a total of 2,973,163 parcels.
The number of real property parcels (land and buildings) increased by 59,797 parcels — to total more than 11 million parcels.
Business personal property accounts saw an increase of more than 4 percent, adding 48,535 parcels. Business personal property accounts totaled 1,156,593.
Unlike 2002, CADs reported more taxable non-business personal property accounts, representing a 13 percent increase. Last year, the only category of property that decreased in number of accounts was this category. CADs reported an increase of 21,340 non-business personal property accounts. Non-business personal property consisted of 180,335 accounts.
In Texas, 21 of the 253 CADs appraise 150,000 or more taxable parcels, representing almost 46 percent of all taxable property parcels. Of these 21 districts, six CADs have more than 300,000 parcels and represent almost 21 percent of all taxable properties -- down from 27 percent in 2002. The six largest districts with more than 300,000 parcels (in order beginning with the largest) are Harris, Dallas, Tarrant, Bexar, El Paso and Travis CADs.
Expenditures
In final 2002 expenses, CADs spent a total of about $257 million, or an average of $16.48 per parcel to appraise. These expenditures were about 6 percent more than in 2001. The average 2002 CAD operating expenses were $1,017,132.
The 2002 expenditures per parcel varied. The lowest per parcel was Crockett CAD at $0 per parcel. Crockett CAD does not report its expenditures separately from the Crockett County Tax Office. At the other end, Somervell CAD reported the highest cost per parcel at $40.69. Somervell CAD has the Comanche Peak power plant.
The 39 mid-sized CADs, with parcel counts from 35,000 to 49,999 parcels, averaged the lowest cost per parcel at $11.55 — up about 3 percent from 2001.
The six largest districts (listed earlier) averaged $23.80 per parcel — up about 5 percent from last year. The size and complexity of urban properties and the higher costs of doing business in these CADs contribute to the higher cost per parcel. See the 2002 CAD Spending by Size table below.
2002 CAD Spending by Size While the average 2002 cost per account statewide was $16.48, grouping the CADs by account sizes shows the cost per account varies — with the largest group of districts exceeding the state average. Number of Accounts Number of Districts Average 2002 Expenses Average Cost Per Account/Parcel Below 5,000 4 $56,948 $12.65 5,000 to 9,999 28 $117,282 $14.13 10,000 to 14,999 25 $160,441 $12.80 15,000 to 19,999 26 $212,647 $12.06 20,000 to 24,999 17 $291,504 $13.10 25,000 to 34,999 45 $424,023 $14.84 35,000 to 49,999 39 $488,846 $11.55 50,000 to 74,999 24 $809,692 $13.39 75,000 to 149,999 24 $1,405,697 $13.40 150,000 to 300,000 15 $3,090,216 $15.41 Over 300,000 6 $16,718,118 $23.80 The adopted 2003 budgets represented more than a 5 percent increase above 2002 expenses and totaled more than $270.5 million. Using 2002 taxable property parcels/accounts, the average cost per parcel runs $17.32 per parcel. See the Appraisal District Spending, 1982-2003 table below.
Appraisal District Spending, 1982-2003 While CAD budgets have risen on an average cost per account in the past 21 years, the CADs received a smaller percentage of the taxes levied by taxing units. Year Average Cost Per Account Total Spent Percent Change Spending as Percent of Taxes Levied 1982 $10.25 $110.8 million — 1.69% 1983 $10.47 $122.9 million + 10.92% 1.70% 1984 $10.69 $130.5 million + 6.18% 1.61% 1985 $10.92 $137.2 million + 5.13% 1.53% 1986 $10.91 $139.7 million + 1.82% 1.45% 1987 $10.96 $140.1 million + 0.29% 1.41% 1988 $11.44 $148.1 million + 5.71% 1.41% 1989 $11.52 $152.4 million + 2.90% 1.37% 1990 $12.00 $157.7 million + 3.48% 1.32% 1991 $12.25 $165.6 million + 5.00% 1.10% 1992 $12.80 $170.5 million + 2.96% 1.23% 1993 $12.89 $179.0 million + 2.40% 1.19% 1994 $13.10 $179.8 million + 2.98% 1.17% 1995 $13.11 $184.7 million + 2.73% 1.18% 1996 $13.16 $188.2 million + 1.89% 1.13% 1997 $13.42 $196.2 million + 4.24% 1.14% 1998 $13.66 $203.5 million + 3.72% 1.12% 1999 $14.74 $217.5 million + 6.88% 1.10% 2000 $15.14 $227.5 million + 4.60% 1.04% 2001 $16.09 $241.7 million + 6.24% 1.01% 2002 $16.67 $256.5 million +6.12% 1.01% 2003* $17.32 $270.5 million +5.50% n/a *2003 reflects adopted budget, not final expenditures. Property Tax Code Section 6.06(b) and (d) require local taxing units to fund CAD budgets and give taxing units veto power after the CAD directors adopt the CAD budget. Taxing units in three CADs — Lee, Presidio and Wheeler CADs — vetoed their 2003 budget.
CAD budget payments by taxing units are allocated based on the property taxes levied by each taxing unit in comparison to the total taxes of all units within the CAD. CADs reported that the total tax levy used to allocate their budgets increased from $24 billion in 2001 to almost $25.5 billion in 2002. About 1 percent of property taxes levied goes to pay CAD operating expenses.
CAD directors
A board of directors governs CAD operations and establishes goals and policies. State law requires that if the county tax assessor-collector is not appointed to the CAD board, the county assessor-collector serves as a non-voting CAD director. County tax assessor-collectors, however, are ineligible to serve if they serve as the chief appraiser or if the county commissioners’ court contracted for county taxes to be collected by another taxing unit or the CAD.
Texas has a total of 1,560 CAD directors, with an average of six members on each CAD board.
Almost 42 percent, or 643 directors, are taxing unit officials — that is, they are county tax assessor-collectors, school board members, county commissioners, city council members or other elected officials. County tax assessor-collectors in 128 counties serve as nonvoting board members.
Directors in 69 CADs serve staggered two-year terms.
CAD boards in 217 districts have legal counsel on retainer. CADs reported that 196 boards — same as last year — have purchased liability insurance with an average coverage per board of more than $1 million.
Appraisal review boards
CAD directors appoint appraisal review board (ARB) members to handle taxing unit challenges and taxpayer disputes with the appraisal office.
In 2003, there were 1,446 members serving on review boards, up from 1,445 in 2002. More than 18 percent (270) of the 1,446 ARB members are newly appointed. That compares to 364 new ARB members in 2002. Most ARBs average six members.
ARBs retain legal counsel in 89 CADs — three less than in 2002. ARBs in 177 CADs — two less than in 2002 — have obtained liability insurance at more than $1 million per ARB.
ARB members in 246 districts receive a per diem for their ARB service — the same as last year.
CAD directors also may appoint temporary review board members. Property Tax Code Section 41.66(f) prohibits an ARB member from communicating with another person about a protested property except during the ARB hearing or in another protest in which the property is part of a sample of properties. If an ARB member does communicate about a protested property outside of the hearing, then a temporary ARB member must take that member’s place to hear the protest. Twenty-nine districts — down from 37 in 2002 — appointed temporary members in case a regular ARB member could not serve.
Ag advisory board
Property Tax Code Section 6.12 requires the chief appraiser — with the advice and consent of the CAD’s board — to appoint three or more members to an agricultural advisory board. The advisory board advises the chief appraiser on the appraisal and use of land designated for agricultural, open space or timberland appraisal.
Some 179 CADs — seven more than 2002 — have active agricultural advisory boards, with a state membership totaling 694 members.
CAD staff
Full-time CAD employees numbered 4,099 statewide, compared to 4,042 in 2002, a gain of 57 full-time positions. Of these employees, about 1,486 are appraisers.
The number of part-time employees decreased from 240 in 2002 to 200 in 2003. Some 24 districts employ only part-time appraisers. In some CADs, chief appraisers perform all appraisal work or have contracts with private appraisal firms.
A staff appraiser’s average salary ranged from a low of $24,075 to an average high of $36,453 – an overall 3-percent increase from 2002.
Employees in 183 CADs receive mileage allowances, and 219 districts provided staff with employment benefits, including insurance and/or retirement programs.
Almost 88 percent of the CADs — 227 — budget training funds for staff to meet or retain state certification standards. CADs reported 2,029 employees are registered with the Board of Tax Professional Examiners.
Of these state-registered employees, 1,398 employees have attained the registered professional appraiser designation, 336 are registered Texas assessors, 121 are registered Texas collectors and 106 individuals have all three designations.
Twenty-two CADs contract with a taxing unit to serve as the appraisal office. These CADs, therefore, have no employees. The chief appraisers are employees of taxing units that operate the appraisal office by contract with the CAD board. The statistical data for these chief appraisers and their staffs were not included in the average salaries.
Salaries of 231 chief appraisers averaged $52,088 for the 2003 budget, about a 3-percent increase from the 2002 average salary of $50,785. Chief appraisers in 229 CADs receive employment benefits, such as expense accounts, mileage, medical insurance and/or retirement programs.
About 179 CADs have liability insurance for the chief appraiser, with an average coverage of more than $1 million.
Reappraisals
State law requires CADs to reappraise property in their districts at least once every three years. Numerous CADs reappraise property every year. For the 2002 tax year, 189 CADs — 75 percent — completed reappraisals, while 144 CADs planned to reappraise for the 2003 tax year.
In their last reappraisal, 205 CADs used both in-house staff and an outside appraisal firm for their reappraisal. In the remaining districts, 35 CADs used staff only and 12 CADs used appraisal firms alone for the reappraisal. By contract, Haskell CAD has Stephens CAD provide appraisal services.
Chief appraisers in 228 districts conducted an in-house ratio study in 2002, compared to 229 districts in 2001.
Property Tax Code Section 6.025 requires that CADs shall, to the extent practicable, coordinate their appraisal activities so as to encourage and facilitate the appraisal of the same property appraised by each district at the same value. CADs in 207 counties had taxing units with boundaries in other counties and, thus, overlapping properties. CADs in 155 counties contractually agreed to work together on these overlapping properties.
When appraising properties, CADs in 170 counties inspect all property.
Property Tax Code Section 22.01 requires a person to render for taxation all income producing personal property that he or she owns or manages and controls as a fiduciary on January 1. A chief appraiser may require a person to render any other taxable property that he or she owns or manages.
CADs in 214 counties reported that property owners filed 538,930 renditions, up from 463,032 in 2001. Of those renditions filed, 135 CADs reported that 316,116 were renditions for business personal property totaling more than $101 billion in taxable value.
Taxpayer protests
For tax year 2002, CADs mailed more than 9 million appraisal notices, of which almost all contained estimated taxes on the proposed taxable values. Only about 17,000 notices were a “shorter” version allowed by Property Tax Code Section 25.19(i), with no estimated taxes.
About 83 percent (210) CADs mailed their reappraisal notices in May or earlier.
Property owners filed almost 12 percent more written protests than in the previous year, for a state total of 734,941 protests in 247 CADs. In 2001, officials reported a total of 658,575 protests reported by 244 CADs. About 64 percent (some 448,006) of the protesting taxpayers met with CAD staff in informal hearings to attempt a settlement without continuing to a formal ARB hearing.
ARBs scheduled 379,325 formal hearings for these filed protests — an increase of 72,489 formal hearings or about 24 percent from last year. More than 137,497 taxpayers, however, did not attend their scheduled hearing, representing almost a 36 percent “no show” rate. In 2001, about 40 percent were “no shows.”
Property Tax Code Section 41.71 requires ARBs by rule to provide taxpayers with hearing times in the evening or on a Saturday or Sunday. ARBs in 62 counties offered protest hearings during all three times — Saturday, Sunday, and evenings. About 109 ARBs offered protest hearings in the evenings, another 62 ARBs offered hearings on Saturday and evenings. Four ARBs offered hearings on a Saturday, while one offered hearings on Saturday and Sunday. Some 15 ARBs did not offer an alternate time.
Taxing units also may file written challenges to the ARB if they disagree with CAD decisions. In 2002, eight taxing units — compared to only two in 2001 — filed challenges.
The chart Twenty-One Year Review of Appraisal District Workload below highlights the history of the appraisal district workload with notices, challenges and scheduled ARB hearings since appraisal districts began in 1982.
Twenty-One Year Review of Appraisal District Workload In 2002, CADs mailed fewer appraisal notices but scheduled more ARB hearings than in 2001. Year Taxable Parcels Appraisal Notices Sent Taxing Unit Challenges ARB Hearings Scheduled 1982 10,811,817 6,509,076 235 52,707 1983 11,736,724 2,978,839 88 33,875 1984 12,206,774 4,629,682 270 151,144 1985 12,568,931 4,731,365 66 91,665 1986 12,803,055 4,428,225 106 125,246 1987 12,786,518 5,054,336 184 163,085 1988 12,937,341 3,977,007 39 170,711 1989 13,225,514 4,160,375 156 157,947 1990 13,139,219 7,191,615 32 178,124 1991 13,518,442 7,199,515 193 209,889 1992 13,320,845 7,465,478 36 196,503 1993 13,546,649 8,383,541 154 166,056 1994 13,723,699 7,810,313 10 218,538 1995 14,099,466 8,241,057 5 195,097 1996 14,304,085 7,654,301 19 189,769 1997 14,617,741 7,586,079 4 149,771 1998 14,847,469 8,160,120 3 189,622 1999 14,756,523 8,743,293 8 248,526 2000 15,022,588 8,420,244 18 234,691 2001 15,385,913 9,364,893 2 306,836 2002 15,618,958 9,068,428 8 379,325 Roll approval
CADs and ARBs continue to complete their work timely. In 2002, ARBs in 181 districts approved the appraisal records on or before July 20, 2002, the mandatory deadline for ARB approval. The remaining 72 ARBs approved the appraisal records after July 20, 2002.
Sixty-seven ARBs – compared to 65 in 2001 – approved the records before hearing all the protests as allowed by the Property Tax Code Section 41.12.
ARBs approved appraisal rolls listing almost $1.4 trillion in 2002 value, more than 5 percent increase in total value than in 2001. Chief appraisers in 235 districts certified those appraisal rolls to taxing units by July 25, the mandatory date.
Late corrections
After an ARB approves the appraisal records, it may change the records for specific reasons set out in Property Tax Code Sections 25.25 and 41.411. Like 2001, the most common late change was for Section 25.25(c), property improperly included on the appraisal roll by the appraisal district. About 25 CADs reported this type of change on 6,717 properties worth over $1 billion.
Other Section 25.25(c) late changes were those filed for clerical errors and multiple appraisals of the same property. Clerical errors for 2,322 properties worth less than $1 billion occurred in 36 CADs. Twenty-one districts reported multiple appraisals on a total of 663 parcels worth more than $211 million.
Section 41.411, the “no-notice” appeal, allows property owners to claim that the CAD or ARB failed to send the property owner or owner’s agent a required notice. About 41 CADs reported that 781 property owners with properties appraised at about $364 million filed Section 41.411 “no-notice” appeals.
Section 25.25(b) allows the chief appraiser to change the appraisal roll at any time to correct any inaccuracy that does not increase the amount of a taxpayer’s tax liability. Chief appraisers in 79 CADs reported 577 changed properties with a total of about $48 million in value.
Property owners in 59 CADs reported changes under Section 25.25(d), an incorrect appraisal that exceeds the correct value by more than one-third. These CADs reported what is considered a “substantial value error” on 3,948 properties with a total value of almost $1.5 billion.
Tax Code Section 25.25(h) allows for joint motion corrections, requiring both the chief appraiser and property owner (or owner’s agent) to agree to the correction. About 1,068 joint motions in 16 CADs were filed on properties worth about $411 million.
Court action
Property owners who disagree with the ARB’s decision on their property may continue on to district court. As of the 2002/2003 survey reporting date, 107 CADs reported that taxpayers had filed 2,947 lawsuits on their 2002 values, compared to 106 CADs reporting 2,400 lawsuits at the same time in the previous year.
About 1,624 lawsuits were still pending for tax year 2001 and prior years in 133 CADs.
Nine CADs reported 35 lawsuits filed on 2002 issues were resolved through non-binding arbitration.
Geographical information
All CADs must establish and maintain tax maps for property identification. About 56 percent of CADs have developed geographical information systems (GIS). These 150 CADs, the same as last year, have GIS systems for better mapping and information systems. CADS in 44 counties have completed developing their GIS systems.
Freeport exemption
The 2002 & 2003 Appraisal District Operations Report updates the listing of taxing units that tax or retain the right to tax freeport property. The Tax Code defines freeport property as goods, wares and merchandise (other than oil, gas and petroleum products) that leave Texas within 175 days of the date they are brought into or acquired in the state.
Counties, cities, school districts and junior college districts may tax or retain the right to tax freeport property. Other special districts must exempt freeport property.
CADs in 200 districts reported about 1,526 taxing units taxed or retained the right to tax freeport property in 2002, a decrease from 201 CADs and 1,538 units in 2001. Taxing units taxing include: 144 counties, 565 cities, 760 school districts and 57 colleges. (More than one CAD reports some of these college districts.)
For an updated list of these taxing units, call the PTD’s technical assistance hotline at 1-800-252-9121. In Austin, call 512/305-9999. Or you may view the list on PTD’s web site – www.window.state.tx.us/taxinfo/proptax/freeport/index.html.
Personal property
Property Tax Code Section 11.14 allows taxing units to tax non-income producing personal property, after the units follow certain hearing and notice requirements. For 2002, 25 CADs reported that 95 taxing units tax non-income producing personal property, such as private automobiles, boats and airplanes. These units include 14 counties, 22 cities, 36 school districts and 23 special districts.
For 2002, the City of Megargel in Archer County began taxing non-income producing property. The City of Mason and Mason County and Three Way Independent School District (ISD) that consolidated with Sudan ISD in Lamb County discontinued taxing these properties.
A listing of taxing units that tax non-income producing personal property is available by calling the PTD phone numbers listed earlier.
Personal leased vehicles
Property Tax Code Section 11.252 exempts motor vehicles leased for personal use. These vehicles must be passenger cars or trucks with a shipping weight of not more than 9,000 pounds. The law defines “personal use” as using the vehicle more than 50 percent of its use (based on mileage) for activities that do not involve the production of income. A city by ordinance adopted before January 1, 2002, may tax these personal leased vehicles.
In 2003, 75 cities in 39 CADs chose to continue taxing all leased vehicles, both personal and business. In 2002, 68 cities in 35 CADs taxed these vehicles. A listing of these cities is available by calling the PTD phone numbers listed earlier.
Assessing & collecting
Some 147 CADs also perform assessment functions, the same as last year. Assessment functions include calculating effective and rollback tax rates, publishing required notices and preparing and mailing tax bills.
Some 113 CADs also collect property taxes. The number of CADs collecting taxes for taxing units is the same as in 2002. The number of taxing units receiving collection services from CADs increased from 899 taxing units in 2001 to 905 units in 2002.
CADs that collect establish a separate collection budget. These CADs budgeted an average of $123,534 to perform the 2002 collection function, about a 1 percent increase from the preceding year. CAD collection budgets ranged from as low as $2,600 to $896,382, with an average cost per parcel to collect of 39 cents.
In 2002, eight CADs also collected property taxes for multi-county taxing units for which they did not appraise these taxing units’ property.
The survey also asked CADs to report on other taxing units that offer consolidated collection services in their districts. The tables Taxing Units Served by a Consolidated Tax Collection Office, 1986-2002 and Who Collects and For Whom show consolidated collections with the type of collecting unit and the number of taxing units receiving the service.
Some 165 county tax offices collect for 1,817 taxing units.
Some taxing units used private companies to collect taxes. In 2002, there were 48 private companies collecting for 486 taxing units, compared to 48 companies collecting for 481 units in 2001.
Consolidation of all property tax collections for all taxing units into one office occurred in 114 CADs — five more than 2001. The single collecting office in these CADs included 59 CAD offices, 54 county tax offices and one city that collected for all taxing units in that county.
Only about 382 taxing units still collect only their own taxes as more taxing units move to consolidated collection offices. In 2001, 425 units collected their own taxes.
Taxing Units Served by a Consolidated Tax Collection Office, 1986-2002 Type of Collection Office Year CADs Counties ISDs Cities Special Districts/Private Total 1986 732 720 124 59 305 1,940 1987 780 837 134 58 293 2,102 1988 813 854 126 74 4 1,871* 1989 839 955 105 69 7 1,975* 1990 867 1,048 106 56 434 2,511 1991 1,031 1,199 870 47 461 3,608** 1992 1,077 1,261 781 79 488 3,686** 1993 952 1,215 126 60 497 2,850 1994 940 1,311 124 60 470 2,909 1995 922 1,393 121 60 472 2,968 1996 924 1,450 121 51 481 3,027 1997 915 1,484 126 51 450 3,026 1998 918 1,576 127 41 462 3,124 1999 907 1,636 135 41 472 3,191 2000 906 1,692 128 37 464 3,230 2001 899 1,751 128 31 484 3,293 2002 905 1,817 120 30 489 3,361 *Does not include taxing units served by private firms.
**Includes County Education Districts.
Who Collects and for Whom 2001 Collecting Office and Units Served 2002 Collecting Offices and Units Served 167 counties for 1,751 taxing units 165 counties for 1,817 taxing units 113 CADs for 899 taxing units 113 CADs for 905 taxing units 4 cities for 31 taxing units 4 cities for 30 taxing units 42 school offices for 128 taxing units 42 school offices for 120 taxing units 1 special district for 3 taxing units 1 special district for 3 taxing units 48 private firms for 481 taxing units 48 private firms for 486 taxing units 375 offices collecting for 3,293 units 373 offices collecting for 3,361 units Report available
The 2002 & 2003 Appraisal District Operations Report also contains information on ARB compensation, CAD office space, software companies, computer facilities, appraisal firms, electronic data submission, tax rate rollback activity and more. Many CADs also mailed the Comptroller’s office a copy of their 2003 appraisal budget, and some CADs that collect taxes provided copies of their 2003 collection budgets.
To request any CAD’s survey, appraisal budget or collection budget, please send an e-mail to the Property Tax Division at ptd.cpa@cpa.state.tx.us, or call the PTD’s technical assistance hotline at 1-800-252-9121. In Austin, call 512/305-9999.
CAD directory
From the CAD surveys, the PTD also updates names and addresses of CAD directors, ARB members and chief appraisers. This information is contained in the 2003 Appraisal District Directory.
The PTD sent each appraisal district and county tax office a copy of the 2002 & 2003 Appraisal District Operations Report and 2003 Appraisal District Directory.
Anyone may purchase either book by sending a check or money order for $10 each to the Comptroller’s Property Tax Division, P. O. Box 13528, Austin, Texas 78711-3528.
For the past 22 years, CADs have completed the Appraisal District Operations Survey. Texas Comptroller Carole Keeton Strayhorn thanks the districts for their time in completing the survey and welcomes the districts’ good advice at any time.
Statement
October 2003
October 2003