Insurer only obligated to mail notice of non-renewal, not required to obtain proof of delivery of notice of non-renewal or lapse of policy

Recently, the Louisiana Supreme Court issued an opinion important to insurers. Specifically the Court held that insurers are required only to mail the notice of non-renewal of a homeowner’s insurance policy to the insured. The insurer is not required to prove receipt or delivery, if the notice is mailed.

Accepting that notice of renewal is the responsibility of the insurer, and not the agent, the agent’s records were nonetheless important in the court’s determination that the insurance policy had lapsed and therefore was not in effect at the time of the event, a house fire.

In the recent case discussed above, the agent received by email an “Agent’s Lapse Letter”, in compliance with the insurer’s customary business practices. The agent received the lapse letter five days after the lapse but before the insured’s house burned down. The agent testified he did not contact the insured until three weeks after he received the lapse letter, which was 11 days after the fire.

The initial notice to the insured was mailed by first class mail, so there was no documentary proof of mailing, such as a mailing receipt from the Post Office. However, the insurer prevailed by convincing the court that it had followed its customary business practices of non-renewal notification. The court cited the emailed lapse letter to the agent as part of the proof that the insurer followed its customary practices.

Practical  Tip:

If you, as an insurance agent, receive notifications from your insurance companies of the non-renewal of or the lapse in a customer’s coverage, you should maintain copies of the notification and the date it was received. Your records could be essential to the insurer’s proof that it complied with the notification laws.

A private out of state company recently mailed official looking documents to Louisiana companies. Media reports reveal that some recipients mailed the form and $125 back to the company erroneously believing they were required to do so.  The Louisiana Secretary of State, however, has specifically disclaimed any affiliation with the mailout.

The form mailed out by the private company appears to only facilitate preparation of company meeting minutes. It does not assist with the filing of the Annual Report with the Louisiana Secretary of State. Sending the form back to the private company is not required; filing the Annual Report with the Louisiana Secretary of State is. The out of state company requires a fee of $125. The Louisiana Secretary of State charges $25 to file the Annual Report.

New procedures for filing the Annual Report with the Secretary of State

Each corporation and limited liability company must file an annual report with the Louisiana Secretary of State; failure to do so for three years can result in revocation of the company charter.

To assist with timely filing of the annual report, the Louisiana Secretary of State mails each company Annual Report Renewal postcard. The actual report is not mailed as a matter of course, but can be obtained by calling the Secretary of State at 225.925.47094 or printing it online from the Secretary of State website.
To fill out the annual report form online, you will need your charter number and renewal id, both of which are printed on the address side of the postcard.  If you do not have your postcard, you can call the Secretary of State at 225.925.4704  to obtain both numbers.

Here is the process to print your annual report, if it is due. Once you have retrieved your charter number and renewal id:  go to www.sos.louisiana.gov/renewal and enter the two numbers. If your report is not due, the website will so indicate. If the annual report is due, a form will display. You can then follow the directions to file it online or print it and mail in a hard copy. Either way the filing must be accompanied by a $25 payment.

Here are some practical pointers on filing out the annual report for companies in good standing:

• The domicile address must be a physical address, but the mailing address can be post office box.  So, if you’d prefer to receive mail from the Secretary of State at a post office box and that information does not appear on the report, then change your mailing address.
• If you want to change your registered agent, his/her signature must be notarized. If you are not changing the registered agent, a notary signature is not necessary on the form.

Best practices: review company info on Secretary of State website

This would also be a good time to review your company profile on the Louisiana Secretary of State website. Here is how you access that information: www.sos.louisiana.gov, then click on Commercial in the left column, then scroll about halfway down the page and click on “Corporations Database” highlighted within the text, then type in the name of your company. At this point, either your company profile will appear or a list of all companies with the words you typed in will appear. If the list appears, find your company and click on “Details”. A copy of your detail report can be printed by clicking on “Print Detailed Record” at the top of the profile.

Here are a few practical pointers for the profile:

• Review the status section to determine if your company is active, which is good, or if the charter has been revoked, which is not good. If the charter has been revoked, there should be a link to click for instructions and forms to reinstate the company.
• Review the Annual Report Status. If it is showing that your company is not in good standing, then click on the link given for instructions to remedy this status.

Favored rights granted to condominium associations

Only a few types of creditors in Louisiana are granted the right to lien a debtor’s property prior to a judicial confirmation that a debt is in fact owed. This is a valuable right and should not be taken lightly.

Creditors afforded this preferred status include condominium associations, homeowners associations, general contractors and subcontractors.

Amounts to include in lien

For condominium associations, the lien amount includes at least:

• all unpaid assessments, including any amounts that have been accelerated,

• fines in excess of $250,

• late fees in excess of $250,

• interest at the rate proscribed in the condo documents, or if no such provision, then at the legal rate of interest, and

• reasonable attorney’s fees incurred by the association in collection of the assessment or enforcement of the privilege.

Arguably, if the condo documents provide for additional amounts of recovery, such as court costs, then the association can also recover those amounts as well.

 Criteria for content of lien

The condo lien must:

• be in the form of an affidavit,

• be signed and verified by an officer or agent of the association,

• include the legal property description for the condo unit,

• include the name of each record owner,

• include the amount of the delinquent or accelerated amount,

• include the date on which the assessment became delinquent,

• disclose any fines in excess of $250,

• disclose any late fees in excess of $250, and

• be recorded in the mortgage records in the parish where the property is located.

Once recorded, the condo lien will prime all other liens and encumbrances except (1) mortgages recorded before either the condo declaration or condo lien, (2) property taxes and (3) government assessments in which the unit is specifically described. To preserve this ranking, a notice of the filing of a lawsuit must be recorded in the land records within one year of the recordation of the condo lien.

Failure to give the required 7 day advance notice of the filing of a lien can result in cancellation of the lien.

Louisiana law requires that seven days prior to the filing of a lien, the condo association must serve on the unit owner a statement that:

1.  details the amount of the delinquent or accelerated assessment,

2. discloses the date the assessment became delinquent or accelerated, and

3.  is executed before a notary public.

The condo association must  serve the statement on the unit owner either by personal delivery or registered or certified mail.  A court recently invalidated a lien because the unit owner was not given the seven day advance notice.

However, the mere cancellation of the lien does not mean the debt is extinguished. Whether a lien can be re-recorded depends on how much time has lapsed from the date the date of delinquency.

Contractors and subcontractors are two of only a few creditors that are granted the right to obtain a secured right in property prior to a judicial confirmation of the debt. Other creditors afforded this right include condominium and homeowners associations.

This is a favored position and should not be taken lightly.  Careful review should be given to certify that the contractor lien meets all statutory requirements.

For example, a materialmen’s lien was judicially canceled because it did not adequately describe the materials. The lien stated it was for “materials supplied”. The Court held that this was insufficient. The types of materials supplied should be described, such as doors, windows, cabinets or other building components.

In 2011, the Louisiana legislature passed two new condo laws on fidelity insurance and late fees. Both laws mandate notifications to each unit owner. Why not combine the notices?

 The combined notice should state:

1. that the condo association has procured fidelity insurance or a fidelity bond
2. that the owner has a right to inspect proof of the fidelity bond or insurance
3. the amount of the assessment due by the unit owner
4. the due date of the assement due by the unit owner
5. that the assessment is due within ____days of the due date. The blank should be the greater of 10 days or the deadline stated in the condo documents.

The notice can be given either in writing or by electronic means. This is yet another reason to create a database of the email addresses for unit owners.

Be sure to keep copies of the notices delivered.

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In 2011 the Louisiana legislature passed a new law that sets parameters for condominium late fees. Under the new law, late fees cannot be charged within ten days of the due date and cannot exceed thirty percent of the monthly assessment. As with the new law requiring condo associations to carry fidelity insurance discussed in a prior blog, this new law on condo late fees also requires that notices must now be given to unit owners and specific information must be included in the notices.

Practical Tips:

1. Determine if the delinquency period for your Association is less than 10 days.
2.  Determine if the late fee charged by your Association is 30% of the monthly assessment or greater.
3. Give the proper notification to your unit owners. See the post to this blog on the notice requirements.

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With the passage of a new Louisiana state law on condo fidelity insurance, condo associations in Louisiana must now satisfy the requirements in both the state law and HUD regulations, just as the associations must also be mindful of both state and HUD requirements for its other insurance coverages.

 As creatures of Louisiana law, it goes without saying that condominium associations in Louisiana must comply with state laws concerning various types of insurance and bonds. And, to attract unit owners, the same condo associations must also comply with insurance regulations by the U.S. Housing and Urban Development (HUD). HUD guarantees many mortgages and has issued regulations on the terms under which it will do so, including mandated insurance requirements.

The following discussion integrates the insurance requirements under Louisiana state laws with the HUD regulations. Compliance with one or the other is not acceptable; condo associations must choose insurance coverages that comply with both standards. 

Practical Tips

 A list of practical tips related to the insurance considerations is set out at the end of this bog.

List of insurance condo associations must maintain

 As will be discussed below, all Louisiana condo associations must maintain each of the following:

• a fidelity bond
• hazard (property) insurance
• flood insurance, if it is in a flood hazard area
• general comprehensive liability insurance

 Fidelity Bonds

HUD has for some time required that condo associations maintain fidelity bonds or insurance. Louisiana now also requires this coverage. In both instances, this bond protects against missing or stolen money, property or securities by persons handling or responsible for these association assets.

As announced in our newsletter earlier this month, Louisiana’s new law on fidelity bonds goes into effect on August 15, 2011.  What will be different on August 15, 2011 is that all condo associations must follow these rules and there is a minimum coverage requirement of $10,000.

Applicable to all Louisiana condo associations

Both new and established condominium projects, no matter the number of units, must obtain fidelity coverage. Some of you may be aware that HUD requires only condo developments of 20 units or more to obtain fidelity coverage. The new Louisiana law does not have a size minimum. Therefore, all condo associations in Louisiana, regardless of size, must be covered by a fidelity bond.

Coverage amount of fidelity bond

Louisiana requires a minimum coverage of $10,000 and a maximum amount of $1,000,000. HUD has no minimum or maximum limits.  Applying the most restrictive terms of both standards, all condo associations in Louisiana must maintain minimum coverage of $10,000, but there is no maximum coverage.

So, the bottom line in applying both standards is:  All Louisiana condo associations must maintain fidelity coverage that

• covers all officers and directors and
• covers employees and third parties (such as property managers and employees of property managers) that are responsible for or handle the association’s money; and
• is in an amount equal to the association reserves plus 3 months of aggregate assessments, but not less than $10,000.

Can the association satisfy the fidelity bond requirements through coverage provided by others?

Louisiana directly answers this in the affirmative; specifically Louisiana law provides that condo associations can satisfy the bond requirement as an “additional insured” under its property manager’s insurance, so long as the manager’s policy satisfies all of the statutory requirements for direct coverage. While HUD is silent on this, it would seem logical that the HUD requirements would be satisfied by coverage as an “additional insured” on the manager’s policy or bond. To be sure, your insurance agent should confirm that there is no difference in coverage for a named insured and an additional insured in this instance.  

Between Louisiana law and HUD regulations, Louisiana condo associations must obtain other types of insurance, as follows:

Hazard (Property) Insurance

Both Louisiana and HUD require that condo associations carry hazard or property insurance. However, the calculation of the amount of coverage differs.

The state law calculation is: after application of any deductible, the amount of coverage must be 80% of the actual cash value of the insured property. The HUD calculation is: 100% of the current replacement cost of the condo development. The Louisiana condo association should purchase coverage in an amount that would satisfy both standards.

Both standards exclude land, foundations, excavations and other items normally excluded from property policies.

HUD also provides that unit owners cannot make up the “gap” in coverage if the association does not maintain 100% coverage in its hazard/property coverage. Therefore, the association is the only party that can maintain this insurance.

HO-6 Insurance-Interior/”Wall to Wall” coverage

Individual unit owners must obtain their own coverage for the interior if the condo policy does not include this coverage.

Under this policy, unit owners may also purchase Loss Assessment coverage, which is additional coverage to pay for assessments imposed by the association on unit owners to cover the deductible or costs by the association when an insured loss is suffered. Following Hurricane Katrina, condominiums must now absorb very high deductibles.  In some instances, condo associations impose an assessment on the unit owners to cover the deductible for the claim. These assessments can be substantial. Unit owners with the Loss Assessment coverage can look to their the HO-6 insurer to pay all or part of the assessment. Check with your insurance agent for complete details on this coverage.

Liability Insurance

Combining the provisions of Louisiana law and HUD regulations, Louisiana condo associations must maintain comprehensive general liability coverage that

• insures against death, bodily injury and property damage arising out of or in connection with
• the use, ownership or maintenance of
• common elements, commercial space owned and leased by the association and public ways of the condo project,
• including medical payments insurance.

The amount of coverage for this insurance is whatever amount the executive board determines, but cannot be less than any amount specified in the condo declarations.

Flood Insurance

Louisiana has no legal requirement for flood insurance, so each Louisiana condo association in a Special Flood Hazard Area must follow HUD requirements, which are:

• The insurance must cover the individual condo units and the common elements.
• The coverage amount is the LESSOR of  (1) the replacement cost of the project less land costs or (2) up to the National Flood Insurance Program (NFIP) standard of $250,000 per unit.  
• For residential condo buildings in a regular program community, maximum coverage is $250,000 times the number of units in the building (not to exceed the replacement cost).

The association, not the unit owner, is responsible for obtaining the flood insurance on the development. However, this insurance may not cover certain claims for interior damage, so unit owners should discuss this with their insurance agent.

Miscellaneous

Insurance policies carried pursuant to the above must provide that:

(1) Each unit owner is an insured person under the policy with respect to liability arising out of his ownership of an individual interest in the common elements or membership in the association.

(2) The insurer waives its right to subrogation under the policy against any unit owner or members of his household.

(3) No act or any omission by any unit owner, unless acting within the scope of his authority on behalf of the association, will void the policy or be a condition to recovery under the policy, and

(4) If, at the time of a loss under the policy, there is other insurance in the name of a unit owner covering the same property covered by the policy, the policy is primary insurance not contributing with the other insurance.

Condo Declarations

The condo declarations should be reviewed for additional insurance requirements.

Practical Tips

1.  Go over this information with your insurance agent.

2.  Determine if your condo development is in a Special Flood Hazard Area and if so, make sure you have flood insurance.

3.  If your association is covered through your property manager’s fidelity bond,

• make sure the association is named as an “additional insured”
• tickle the anniversary date of the bond to obtain a new declarations page or proof of the bond each year. Keep this dec page in a handy place so it is easily accessible when mortgage companies, selling unit owners or prospective new owners request it

4.  If the association increases its assessments, be sure to determine if the fidelity bond should likewise be increased. 

5.  Keep copies of all of the insurance dec pages in a handy place so they are easily accessible when mortgage companies, selling unit owners or prospective new owners request copies of them.

Sources

• HUD Mortgage Letter 2009-46B, dated November 6, 2009.
• State Law:  La. R.S. 9:1123.113

Sign up for condo newsletter

Over the past few months we have published several condo newsletters, including one in July 2011 that announced these fidelity bond changes and the new condo law regulating late fees.  If you would like to receive future newsletters, sign up at the top of this page.  For past issues, send an email to lydia@alfordlegal.com and referemce “past condo newsletters” in the subject line.

Before signing a lease, follow the R-A-N rule:  Read, Ask and Negotiate.

1.  Read the lease, no matter the length or the small print.

2.  Ask. If you do not understand certain terms, ask for clarification.

3.  Negotiate.  Depending on supply and demand, some terms may be negotiable.

The following are some common provisions in commercial leases and the signifance to the tenant.  It is not an exhaustive list or explanation. Look for a followup post for an analysis of terms for the landlord’s benefit, plus two practical reasons why landlords should carry their own insurance even if the tenant also carries casulty and liability insurance.

Who is the tenant? 

It is commn for the named tenant to be a corporation or limited liability company. However, in this instance it is also common for the landlord to also require that an individual personally guarantee the lease. For small businesses, that usually means that the owner of the company. So, whether the business owner is the named tenant or the personal guarantor, it is important to know that his or her personal assets are at risk if there is a default on the lease. Wishful thinking that the landlord will walk away from unpaid rent is not a realistic business plan and jepoardizes the guarantor’s home, bank account and other assets.

Premises

The rent may be constant throughout the lease or it may increase each year. The increase may be a stated amount or may be calculated based on a standard of measurement such as the Consumer Price Index. 

Monthly rent may be a flat rate, or may also include a percentage of the tenant’s sales. 

It is also common for the tenant to contribute monthly a prorata share of the insurance, property taxes and/or common area maintenance expenses. Sometimes this obligation is set out separate and apart from the base rent. In that instance, the tenant must combine the base rate and all additional monthly charges to determine the total monthly expense. No matter the rent structure, each tenant should carefully review the lease before signing for a clear understanding of the total financial commitment.

Security Deposit

Just as with residential leases, commercial leases also generally require a deposit equal to one month’s rent.

Term

Commercial leases are usually 3-5 years. If you want a shorter term, ask for it. In addition there may be an option exercisable by the tenant to extend the lease.

Be careful though, some leases have an automatic renewal clause that puts the burden on the tenant to give the landlord considerable advance notice that it will NOT renew the lease. If the lease you sign has an automatic renewal clause, make sure you tickle the notice deadline so that you can timely terminate the lease, if that is  in the best interest of your business. Otherwise, inaction may lead to an automatic renewal of the lease.

Hold Harmless and Insurance

The parties usually agree to hold each other harmless for liabilities arising from the negligence of just one of them. For example, if a customer slips and falls on the premises due to negligence of the tenant, this clause says that the tenant will indemnify the landlord for any sums the landlord may be called upon to pay arising from the accident. 

The lease will likely require that you carry insurance to cover yourself and the landlord in these types of accidents.  You should consult with an insurance agent to find out what insurance is available and which best suits your needs.

The lease should also include a waiver of subrogation for the protection of the tenant and the landlord. With this provision, the insurance policies will cover the damage and the paying insurance company cannot seek reimbursement from the party at fault.

Tenant Default

The most common ground for default is non-payment of rent. However, the grounds for default are broader; violation of almost any requirement of a lease is an actionable default. Whether the landlord would seek to terminate the lease is a different issue.

Some leases require that before the landlord can take action on a default, notice of and time to cure the default must be first given to the tenant. If the proposed lease does not include a cure provision, this may be an item subject to negotiation. For example, the lease may provide that before the landlord can declare the tenant in default for not paying rent, the landlord has to give notice of the default to the tenant and give the tenant 5 days to cure the default, or in other words, the tenant gets another 5 days from the notice of default to pay the delinquent rent. This may not be an unlimited right; some leases cap the number of times the landlord has to extend the notice and cure period.

Attorney’s Fees

Generally attorney’s fees are not awarded in contract disputes unless the contract says so. Leases generally include this clause, but sometimes it is only in favor of the landlord. So, if the landlord files a lawsuit alleging a default and is successful, the tenant will also be cast to pay the landlord’s attorney’s fees and court costs.  The tenant should make sure the attorney’s fees provision goes both ways.

Recordation of Leases

Inherent in each lease is a promise by the landlord that the tenant will not be dispossessed of the premises, assuming the tenant is not in default.  However this promise of peaceful possession is not binding on new owners of the property, unless the lease is recorded in the land records. So if the landlord sells the property, the new owner is technically not obligated to honor the lease, UNLESS the lease is recorded in the public records.

Recording the lease or a memo of it puts all third parties on notice that a lease exists and any future owner must honor the recorded lease.

In practical terms, many new owners purchase the property based on the leases in hand. But if you have any concerns, you will need to record a memorandum of the lease and make sure the lease gives you the right to do so.  Recordation of the lease also protects the tenant’s trade fixtures from becoming an improvement to be owned by the landlord.

Repair and Maintenance

Perhaps the most significant difference between commercial and residential leases is that commercial tenants are responsible for a considerable portion of the repairs and maintenance. Generally, the landlord is responsible for making repairs only to the roof, foundation and other structural parts of the building, and the tenant is responsible for all other repairs. For example, that means the tenant is responsible for repairing the air conditioner when it fails.  Furthermore, if the pipes burst and damage your property or inventory in the leased space, the landlord is not responsible for replacing furniture, replenishing inventory or remedying any other damages.

In essence the tenant accepts the premises in its current condition, accepts responsibility for keeping it in good condition and is obligated for making repairs when the condition fails.

Therefore, before signing the lease, it is important that the tenant make inquiries as to the age of such things as the air conditioning and heating systems, plumbing and roof.

Ownership of Improvements

If you make improvements to the premises, the improvements will become those of the landlord.  Sometimes, tenants invest substantial funds preparing the premises for occupancy, all to the ultimate benefit of the landlord.

Conclusion

While the lease may look like a daunting document, many pages in length and containing a lot of small print, it is essential that tenants read and understand it before signing.  That’s a true axiom for any contract.

Practical tips before signing a lease

1. Read it
2. Ask questions about provisions you do not understand
3. Negotiate terms
4. Ask for the personal guaranty to be waived
5. Ask for an accounting of the prior year’s property taxes, insurance and common area expenses
6. Be mindful that investments in the buildout will be to the landlord’s benefit
7. Find out the age of the roof, air conditioning and heating systems, plumbing, etc.
8. Consider requesting a non-compete clause
9. If the lease has an automatic renewal clause, tickle a reminder date to let the landlord know you will not be renewing the lease.
10. Consider recording a memorandum of the lease
11. Ask for a default cure period
12. Make sure there is a waiver of subrogation clause

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Here’s how a creditor can collect on a Louisiana judgment:

Record the judgment in the land records and keep it up to date

The first thing a creditor should do after obtaining a Louisiana money judgment is to record it in the land records in all parishes where the debtor owns real property. The recorded judgment then acts as a lien against all currently owned and later acquired real property in that parish.

The recordation of the judgment, however, is good for only 10 years.  To continue as a lien against the property, the judgment must be renewed before the end of the ten years.  Therefore, the creditor should calendar a renewal reminder date at least 9 1/2 years after recording the judgment.

Court compels the debtor to divulge wages and all assets to the creditor

Creditors may also be interested in seizing the debtor’s personal or movable property.  However, information on the debtor’s personal property will likely be private and not accessible by the public. So, the law allows the creditor to question the debtor about assets, income and debts.

This process is called a Judgment Debtor Examination. It is a legal proceeding, initiated by the creditor, in which the debtor is summoned to appear in Court to answer inquiries by the petitioning creditor. The debtor can also be compelled to produce copies of  documents such as payroll checks, cancelled checks and income tax returns.

Generally, the judge swears the debtor in and the parties then go outside the courtroom where the creditor then asks the debtor about such things as:

• the debtor’s social security number and driver’s license number
• identification and value of all assets owned
• information on all bank accounts and balances in the accounts
• the name of the debtor’s employer and contact information for the employer
• the amount of the debtor’s net and gross wages and how often the wages are paid
• list of stocks, bonds and investment accounts owned and the value of each
• identification of automobiles owned and the value of each
• past or future inheritances
• current monthly expenses
• list of all debts

Seizure of assets and/or garnishment of wages

Following the debtor examination, the creditor usually has a better picture of the debtor’s financial situation and better able to determine if it is worthwhile to execute on the judgment. The creditor may garnish wages or seize bank accounts and/or real property, depending on circumstances such as the balance in the account(s), prior ranking liens or garnishments and the amount of legal fees and court costs to pursue collection.  It is these legal expenses and court costs that businesses covered by the open accounts law can now recover by statute.

Restrictions on seizures

Not all assets are subject to seizure. For example, retirement accounts, certain amounts of life insurance and tools of the debtor’s trade are exempt from seizure.

Furthermore, the debtor may file bankruptcy after a judgment is obtained. If this occurs, the creditor must cease and desist all collection efforts and seek permission from the bankruptcy court to proceed with collection.

Open Accounts law

Businesses covered by the Louisiana open accounts law have long been able to collect pre-judgment attorney’s fees and court costs. In 2010 the Louisiana open accounts law was amended to grant post-judgment attorney’s fees and court costs as well. This is a right not granted to all creditors; so if the open accounts law applies to you, make sure to take advantage of it.

Summary of practical steps to collect on Louisiana judgment:

1. Record the judgment in parish land records
2. Tickle date to renew judgment
3. Determine the assets, income and debts of the debtor through a Judgment Debtor Examination
4. Request that the debtor bring documents to the Judgment Debtor Examination
5. Determine if the cost to pursue seizure of assets is a practical worthwhile endeavor
6. Initiate seizure actions

Visit our website to learn more about the services offered by Alford & Alford, LLP.

The purpose of this blog is to provide plainly stated, practical applications
of Louisiana laws that can be immediately implemented by individuals and
businesses.

The mission of our law firm is to provide each existing and potential
business and individual client with a high quality, well reasoned, forward
thinking and realistic course of action to transform opportunity to reality, at
a fee that is fair to the client and recognizes the value, effort and experience
of our firm.

Individuals and businesses retain the services of Alford & Alford, LLP because
we are attentive and responsive to their needs, strive to provide service in a
timely manner and offer a philosophy of ‘practicality’ in our approach.