State Consumer Disputes Redressal Commission
Balbir Singh vs Dlf Pramerica Life Insurance Company ... on 22 January, 2014
STATE CONSUMER DISPUTES REDRESSAL COMMISSION, U.T., CHANDIGARH First Appeal No. : 478 of 2013 Date of Institution : 06.11.2013 Date of Decision : 22.01.2014 Balbir Singh S/o Sh. Rachana Singh R/o H.No.1549, Sector 22-B, Chandigarh. Appellant/Complainant. Versus 1] DLF Pramerica Life Insurance Company Limited, 4th Floor, Building No.9, Tower-B, Cyber City, DLF City, Phase III, Gurgaon-122002 through its authorized representative. 2] DLF Pramerica Life Insurance Company Limited, SCO No.335-336, Sector 35-B, Chandigarh through its authorized representative. Respondents/Opposite Parties. Appeal under Section 15 of the Consumer Protection Act, 1986. Argued by: Sh. Sandeep Bhardwaj, Advocate for the appellant. Sh. Karan Nehra, Advocate for the respondents. First Appeal No. : 477 of 2013 Date of Institution : 06.11.2013 Date of Decision : 22.01.2014 Balbir Singh S/o Sh. Rachana Singh R/o H.No.1549, Sector 22-B, Chandigarh. Appellant/Complainant. Versus 1] DLF Pramerica Life Insurance Company Limited, 4th Floor, Building No.9, Tower-B, Cyber City, DLF City, Phase III, Gurgaon-122002 through its authorized representative. 2] DLF Pramerica Life Insurance Company Limited, SCO No.335-336, Sector 35-B, Chandigarh through its authorized representative. Respondents/Opposite Parties. BEFORE: JUSTICE SHAM SUNDER (RETD.), PRESIDENT SH. DEV RAJ, MEMBER
Argued by: Sh. Sandeep Bhardwaj, Advocate for the appellant.
Sh. Karan Nehra, Advocate for the respondents.
PER DEV RAJ, MEMBER This order shall dispose of two appeals bearing Nos.478 and 477 both of 2013, filed by the appellant (complainant), against the common order dated 07.10.2013, rendered by the District Consumer Disputes Redressal Forum-I, U.T., Chandigarh (hereinafter to be called as the District Forum only), vide which it dismissed two complaints bearing No.201/2013 and No.202/2013, filed by the appellant/complainant.
2. Since, the facts involved in both the complaints, are identical, the same are being culled out from Consumer Complaint No.201 of 2013 - Balbir Singh Vs. DLF Pramerica Life Insurance Company Limited and another.
3. The facts, in brief, are that the complainant, who is an NRI, in the month of March 2010, on visiting India, was approached by his neighbour, namely Pawan Bhatia, who introduced himself to be an agent of the Opposite Parties. It was stated that Mr. Pawan Bhatia, allured the complainant, to invest in the Insurance Policy, a kind of fixed deposit, floated by the Opposite Parties, and introduced him to Ms. Chintan Kaur, Sales Manager of Opposite Party No.2. It was further stated that the signatures of complainant were obtained on blank form and he paid Rs.3 lacs, as premium, to Opposite Party No.2 towards the scheme, by way of two demand drafts. It was further stated that the complainant put his signatures only on one proposal form bearing No.000118489 dated 3.3.2010, and he did not sign any other documents issued by Opposite Parties. It was further stated that the complainant left India on 7.3.2010, where-after, his wife, who was totally illiterate, received two Policy documents, from the Opposite Parties. It was further stated that in August 2010, the complainant visited India, in order to get treatment for his liver and on going through the Policy documents, it transpired that the Opposite Parties illegally issued two Policies bearing No.000019499 and 000022344. It was further stated that after carefully perusing the documents, it was found that the signatures on the documents annexed alongwith Policy No.000019499 were not of the complainant and similarly all the signatures on other Policy No.000022344 were also fake. It was further stated that the present complaint pertained to Policy bearing No.000022344, in which, the Opposite Parties received annual premium of Rs.50,000/-. It was further stated that the complainant immediately approached Opposite Party No.2, which informed that the complainant was supposed to return the Policy document within 15 days of receiving the same and now nothing could be done. It was further stated that in order to usurp the money of the complainant, he was wrongly advised to pay the premium for three years, in order to get his deposited amount with interest. It was further stated that since the complainant was not in India and the Policy documents were not received by him, rather his wife received the same, therefore, the free look period of 15 days was not applicable in his case. It was further stated that the amount was received by the Opposite Parties through their agent by misrepresenting probably because he (agent) gets more commission near about 35-40% of the premium amount, in case of a regular premium unit linked policy than a policy which carried a single premium term. It was further stated that neither the Opposite Parties verified the fact of receiving the Policies by the complainant, nor any effort was made whether the terms and conditions of the Policy were communicated to him. It was further stated that the Opposite Parties had deliberately issued the Policies involving Rs.6 lacs in all as annual premium but no verification was done nor any proof was attached with regard to the health and income of the complainant. It was further stated that the Opposite Parties also ignored the KYC norms while issuing the said Policies of more than Rs.1 Lac, without obtaining the source of his regular income. It was further stated that the Opposite Parties were bound by the guidelines issued by the Insurance Regulatory Development Authority (IRDA) but they failed to follow the same. It was further stated that the act and conduct of the Opposite Parties, amounted to deficiency, in rendering service and indulgence into unfair trade practice. The Opposite Parties were asked to refund the amount of premium but, to no avail. When the grievance of the complainant, was not redressed, left with no alternative, complaint No.201/2013 under Section 12 of the Consumer Protection Act, 1986 (hereinafter to be called as the Act only), directing the Opposite Parties, to refund the premium amount of Rs.1,50,000/;- alongwith interest @18% per annum from the date of deposit; pay Rs.2,00,000/- as compensation for harassment and mental agony and Rs.50,000/- as costs of litigation, was filed.
4. In the second complaint bearing No.202/2013, the complainant was issued the Policy with annual premium of Rs.5,50,000/- by misrepresentation and he deposited the three years premium in the sum of Rs.16,50,000/-. When the refund was not made, the complainant, in Complaint No.202/2013 claimed refund of premium amount of Rs.16,50,000/;- alongwith interest @18% per annum from the date of deposit; pay Rs.2,00,000/- as compensation for harassment and mental agony and Rs.50,000/- as costs of litigation.
5. Opposite Parties, in their written version, took up a preliminary objection, to the effect that since the contract of insurance was a contract of uberime fide, as such, the complainant was stopped from challenging the contract at such a belated stage. On merits, it was stated that the complainant, after completely understanding the terms and conditions of the product Super Wealth Regular, had voluntarily applied for an Insurance Policy vide application form bearing No.AF000118715 dated 3.3.2010. It was further stated that in the application form, the complainant gave all the relevant details, and informed in the prescribed form, for the sum assured amounting to Rs.10 Lac, for which a premium of Rs.25,000/- was proposed to be paid on half yearly basis for a term of 20 years. It was further stated that alongwith the application form (Annexure OP-1), the complainant provided copies of passport, election card, bank statement etc. It was further stated that the Opposite Parties, in accordance with the approved underwriting guidelines, directed the complainant to undergo medical examination and, as such, he underwent a complete medical examination at Dr. Lavleen Kaurs Health Care Centre, Chandigarh (Annexure OP-2). It was further stated that based on the information, declaration and believing the same to be true, the Opposite Parties issued Policy No.000022344, which commenced from 31.3.2010 (Annexure OP-3). It was further stated that the complainant was bound by the contents/declaration in the application form and, as such, he was estopped from challenging the terms and conditions of the concluded contract. It was further stated that the Policy Document was dispatched on 14.4.2010 to the complainant through courier bearing No.934024710342, which was delivered at his address on 17.4.2010. It was further stated that thereafter as per procedure, the Opposite Parties made a Welcome Call on 26.4.2010 but the complainant did not attend the call for the reasons best known to him. It was further stated that in the said Policy contract, it was clearly informed that the Insurance Company offered 15 days of free-look period, which allowed the Policy owners with the option to return the same, if it did not suit their requirement. It was further stated that despite the said Free-Look option, the complainant never approached the Opposite Parties with any complaint. It was further stated that the complainant paid the renewal premium for Policy, in question, viz. Policy No.000022344 on regular intervals as per premium receipts (Annexure OP-4). It was further stated that the complainant had been paying the renewal premium regularly for the policy despite alleging the same to be issued by forging his signatures. It was further stated that a prudent person would not continue to pay the renewal premium, for the Policy, which he claimed to have been issued by forgery. It was admitted that legal notice from the complainant was received on 21.3.2012 and the same was replied vide letter dated 27.3.2012 (Annexure OP-5). It was further stated that the Policy, in question, was issued in compliance with the applicable IRDA Guidelines, the underwriting and KYC Policies of the Opposite Parties. It was further stated that all charges under the Policy, including surrender charges, were mentioned in the Policy Document sent to the complainant and the same were in accordance with the approved IRDA norms. It was further stated that there was, thus, neither any deficiency in rendering service, on the part of Opposite Parties, nor they indulged into unfair trade practice. The remaining allegations, contained in the complaint were denied.
6. The complainant filed replications, wherein he reiterated all the averments, contained in the complaint, and repudiated the same, contained in the written version of the Opposite Parties.
7. The parties led evidence, in support of their case.
8. After hearing the Counsel for the parties, and, on going through the evidence, and record of the case, the District Forum, dismissed the complaints, vide the common impugned order, as sated above.
9. Feeling aggrieved, the appellant/complainant, has filed the instant appeals.
10. We have heard the Counsel for the parties, and, have gone through the evidence and record of the case, carefully.
11. The Counsel for the appellant/complainant, submitted that the Policies, in question, are Unit Linked Policies and the appellant/complainant is an NRI. It was further submitted that the appellant/complainant appended his signatures on the Proposal Form dated 3.3.2010, and he left India on 7.3.2010 and went abroad. It was further submitted that when he returned to India in August, 2010, the free-look period for surrendering the Policy, in question, was over and he could not opt for the same. It was further submitted that the premium was paid half yearly and in all, the appellant/complainant deposited a sum of Rs.1,50,000/- as premium during the years 2010, 2011 and 2012 in respect of Policy No.000022344. He further submitted in respect of Policy No.000019499, premiums for the years 2010, 2011 and 2012, amounting to Rs.16,50,000/- were paid by the complainant. It was further submitted that under the heading Sales Person/Agent Confidentiality Report at Sr. No.53 (at Page 26 of District Forum file) of the application/proposal form (Annexure C-1), the agent had not signed and the report of Sales Person/Agent was necessary. It was further submitted that the annual income of Rs.20 Lacs in Annexure C-1 was wrongly indicated. It was further submitted that in Annexure C-1, at Page 24 of District Forum file, the growth fund was indicated as 100%. It was further submitted that as per the Guidelines on Anti Money Laundering programme for insurers (Annexure C-4), requirement of Clause 3.1.1 relating to Know Your Customer (KYC) was not complied with. It was further submitted that source of funds was indicated to be verbal. It was also submitted that the provisions of Circular dated 1.1.2008 (Annexure C-6) were not adhered to by the Opposite Parties. It was further submitted that FIR No.209 dated 27.4.2013 under Section 420 IPC was lodged. It was further submitted that the provisions of Clause 14 of Guidelines on Unit Linked Insurance Products (at Page 97 of the District Forum), relating to Furnishing Statements of Accounts was not followed to ensure that the Policy was in compliance with the proposal form. He further submitted that the order of the District Forum, being not legally sustainable, is liable to be set aside.
12. On the other hand, the Counsel for the respondents/Opposite Parties submitted that as per Para 6 of the complaint, the appellant/complainant applied for the Policy, in question, on 3.3.2010, which was issued to him on 7.3.2010. It was further submitted that the appellant/complainant left India for abroad on 7.3.2010 and returned to India in August 2010. It was further submitted that the cause of action, to the appellant/complainant, arose in August 2010 and the complaint having been filed on 8.4.2013, was barred by limitation. It was further submitted that as per Annexure OP-4, the appellant/complainant paid second half yearly premium of Rs.25,000/- on 24.9.2010. It was further submitted that when the appellant/complainant was aware of the deficiencies in August, 2010 by depositing premium on 24.9.2010, his action tantamounted to ratification and acceptance of the terms and conditions of the Insurance Policy. It was further submitted that, in all, the appellant/complainant deposited premium for the years 2010, 2011 and 2012, totalling Rs.1,50,000/- in respect of Policy No.000022344. He further submitted in respect of Policy No.000019499, premium of Rs.16,50,000/- for the years 2010, 2011 and 2012 was paid. It was further submitted that the appellant/complainant cannot say that he was defrauded as fraud tantamounted to voidable contract and he did not exercise this option during three years. Controverting the argument and thrust of the appellant/complainant on fraud and KYC norms, it was submitted that the agent, who allegedly defrauded the appellant/complainant, was not impleaded as a party before the District Forum and he could not be blamed at his back. It was further submitted that Annexure C-4, at Page 79 of District Forum, related to Anti Money Laundering programme for Insurers and no such doubts arose in the instant case. Referring to Page 88 of the District Forum file, which is Annexure II relating to Income Proofs, it was submitted that the list was only illustrative and not exhaustive. It was further submitted that measures, indicated in Circular dated 1.1.2008 (Annexure C-6), relied upon by the Counsel for the appellant/complainant, are not statutory. It was further submitted that fraud had been reiterated after three years.
13. It is clearly evident that the appellant/complainant, applied for purchase of the following Insurance Policies, which were the subject matter of Consumer Complaints bearing Nos.201/2013 and 202/2013 filed by him, before the District Forum:-
Details Complaint No.201/2013 Complaint No.202/2013 Insurance Policy No. 000022344 000019499 Date of purchase of Policy.
06/04/2010 06/03/2010 Coverage Term 20 years 20 years Coverage commencement date 31/03/2010 05/03/2010 Maturity date 30/03/2030 04/03/2030 Policy installment premium Rs.25,000/-
Rs.2,75,000/-
Premium frequency Half yearly Half yearly Total premium paid Rs.1,50,000/-
Rs.16,50,000/-
In complaint No.201/2013, the first premium was paid by the appellant/complainant at the time of submitting his proposal form and, in all, he paid six half yearly premiums totaling Rs.1,50,000/-. Similarly in Consumer Complaint No.202/2013, against Policy No.000019499, six half yearly premiums totalling Rs.16,50,000/- were paid by the appellant/complainant.
14. The first question, which arises for consideration, is, as to whether, the appellant/complainant exercised his option, accepting or rejecting the terms and conditions of the Policy, in question, within the free-look period of 15 days. The Insurance Policy No.000022344, Annexure C-1 (Colly.), as per admission of the appellant/complainant, was received by his family when he was not in India.
When the Policy, in question, was received by the appellant/complainant, the proposal form formed part of the same as is evident from Annexure C-1 (Colly.). The Insurance Company was required to send the Policy Document at the address given by the appellant/complainant and the same was rightly sent at the correct address. The contention that the Policy was received during the absence of the complainant when he was abroad and he came to know about the same only in August 2010, is of no significance. Not only this, his contention that the terms and conditions of the Policy were not acceptable to him, gets negated, from the fact that even after knowing the entire terms and conditions in August 2010, he chose to pay the next half yearly premium on 24.9.2010 and, thereafter, paid four half yearly premiums during the years 2011 and 2012. Thus, in all, he paid a sum of Rs.1,50,000/- in respect of Policy No.000022344. He paid six half yearly premium during the years 2010, 2011 and 2012 amounting to Rs.16,50,000/- in respect of Policy No.000019499. Since, the appellant/complainant did not exercise the option within the free-look period of 15 days, no deficiency, therefore, could be fastened upon the respondents/Opposite Parties. In these circumstances, the appellant/complainant was estopped from finding fault with the respondents/Opposite parties on one or the other ground.
15. The next question, which falls for consideration, is, as to whether there was any deficiency on the part of the respondents/Opposite Parties in issuing the Policy, in question, without verifying the source of funds as envisaged in Clause 3.1.5 of guidelines pertaining to Anti Money Laundering programme for insurers (Annexure C-4) (at page 80 of the District Forum). Clause 3.1.5, aforesaid, being relevant, is extracted below:-
3.1.5 Sources of Funds:
It is imperative to ensure that the insurance being purchased is reasonable. Accordingly, customers source of funds, his estimated net worth etc., should be documented properly and the advisor and/or employee shall obtain income proofs as in Annexure III, to establish his need for insurance cover. Proposal form may also have questionnaires/declarations on sources of fund, and details of bank accounts. Large single premiums should be backed by documentation, to establish source of funds.
No doubt, Annexure-III (at page 88 of District Forum file), appended to Circular dated 31.3.2006 (Annexure C-4), relating to Guidelines on Anti Money Laundering programme for Insurers, gives list of income proofs but the note below the same, also indicates The list is only illustrative and not exhaustive, meaning thereby that the income, indicated by the appellant/complainant in the proposal form, was also a proper source.
16. Insofar as the contention of the appellant/complainant that the Policies, in question, were issued in violation of Clause 3.1.1 of guidelines pertaining to Anti Money Laundering programme for insurers (Annexure C-4) is concerned, once the Policy alongwith the proposal forms, which were furnished by the appellant/complainant himself, were received by him, and he was afforded opportunity to return the Policy within free-look period of 15 days, in case, the terms and conditions were not acceptable to him, he could very well return the Policy, in case, either the terms or conditions were not acceptable to him or, if, he felt that the respondents/Opposite Parties violated any guidelines. Therefore, the contention that the respondents/Opposite Parties violated guidelines pertaining to Anti Money Laundering programme for insurers (Annexure C-4) is an afterthought besides being directly not relevant.
17. The next question, which falls for consideration, is, as to whether, the Insurance Regulatory and Development Authority (Treatment of Discontinued Linked Insurance Policies) Regulations 2010 (hereinafter to be referred as IRDA Regulations 2010) have its application to the instant case or not. No doubt, the IRDA Regulations, 2010 came into force w.e.f. 01.07.2010, yet the same are in respect of Unit Linked Policies. However, in the instant case, the Policy, in dispute, was purchased by the appellant/complainant on 6.4.2010, with coverage commencement date as 31.03.2010. Therefore, the provisions of IRDA Regulations 2010, could not be applied to this case. The Counsel for the appellant/complainant placed reliance on Glorious Plastics Ltd. Vs. National Insurance Co. Ltd. & Anr. IV (2008) CPJ 44 (N.C.) in support of his contention that the aforesaid Regulations were applicable to the instant case. The facts of the aforesaid case are clearly distinguishable from the facts of the instant case. Regulation 1(2) of the aforesaid Regulations clearly states that these Regulations shall come into force on the date of their publication, in the official Gazette and shall apply to all products of linked life insurance, cleared by the Authority thereafter. These Regulations were published in the official Gazette on 01.07.2010. Thus, these Regulations came into force on 01.07.2010, whereas the dates of commencement of the policies in these cases were 31.03.2010 and 05.03.2010 respectively. No help, therefore, can be drawn by the Counsel for the appellant/complainant, from the aforesaid case. The submission of the Counsel for the appellant/complainant, therefore, being devoid of merit is rejected.
18. The next question, which arises for consideration, is, as to whether, any surrender value against the aforesaid Policies, has accrued to the appellant/complainant or not. Provisions regarding Failure to Pay Regular Premium after the first 3 Policy Years and Clause 5 of the terms and conditions of the Policy, in question, at Pages 44 and 49 of the District Forum file, are extracted below:-
Failure to Pay Regular Premium after the first 3 Policy Years:
i) If the company does not receive the Regular Premium due after the first 3 consecutive Policy Years from the Policy Commencement Date, Regular Premium due for the first 3 consecutive Policy Years has been paid, then:
i) The Policyholder will be allowed a Grace Period to pay the Regular Premium.
ii) If the Regular Premium due is not received within the Grace Period, the Policy will remain in force with all Policy Benefits under Article 3) and any applicable Rider benefits during the Revival Period. During the Revival Period the charges specified in the Schedule will continue to be deducted.
iii) However if during the Revival Period, the Surrender Value becomes equal to or less than one full years premium then this Policy shall automatically terminate, at which time the Surrender Value as on date of termination as per Article5) will become payable.
j) During the Revival Period, the Policyholder may:
i) Revive the Policy in accordance with Article 2)l) and 2)m) below, or
ii) Surrender the Policy in accordance with Article 5), after which the Policy shall automatically terminate and the Surrender Value will become payable, or
iii) Continue the Policy beyond the Revival Period without paying further Regular Premium, as long as the Company receives a written request in advance for continuation from the Policyholder before the expiry of the Revival Period. If the Company agrees to the continuation request, then the Policy will continue with the benefits as per Article 3) being in force and all Policy charges will continue to apply. The Policy shall automatically terminate when the Surrender Value as per Article 5) reaches one full years premium, at which time the Surrender Value will become payable.
5) Surrender Value a) At any
time after the commencement of the 4th Policy Year, and as long as the Regular Premium due for at least the first Policy Year has been received by the Company, the Policyholder may surrender the Policy and the Surrender Value as on the date of surrender will be payable.
b) The Company may in its sole and absolute discretion, in case of Force Majeure circumstances, or if so directed by the IRDA defer the payment of Surrender Value or partial withdrawal under this Policy for a period not exceeding 30 days from the date on which payment would usually have been made.
19. Vide the order dated 8.1.2014, the Counsel for the respondents/Opposite Parties was asked, as to whether the Policy, in question, had acquired surrender value or not. He, submitted that as on 07.01.2014, the surrender value of the Policies, in question, viz. 000022344 and 000019499, was Rs.45,271/- and Rs.14,17,965/- respectively.
20. The appellant/complainant paid premium for three years (six half yearly premiums) and the Policies, in question, entered the fourth year on 1/4/2013 and 6/3/2013. Thus, the appellant/complainant was clearly entitled to the surrender value of Rs.45,271/- as on 7.1.2014 in respect of Policy No.000022344 and Rs.14,17,965/- in respect of Policy No.000019499. In fact, when the Policies, in question, lapsed, the respondents/Opposite Parties ought to have, on their own, sent the surrender value of the said Policies to the appellant/complainant. By not sending the surrender value, the respondents/Opposite Parties were deficient in rendering service.
21. Thus, the District Forum erred in dismissing the complaint and, as such, the order of the District Forum, being illegal and perverse, is liable to be set aside.
22. For the reasons recorded above, both the appeals bearing No.478 of 2013 and 477 of 2013, filed by the appellant/complainant, are accepted with costs. The order of the District Forum is set aside. Both the Consumer Complaints bearing No.201 of 2013 and 202 of 2013 are partly accepted and the respondents/Opposite Parties, are directed in the following manner:-
Consumer Complaint No.201 of 2013.
(i) to pay Rs.45,271/- to the appellant/complainant, being the surrender value of the Policy bearing No.000022344, in question, as on 07.01.2014;
(ii) to pay Rs.5,000/- as cost of litigation to the appellant/complainant.
This order shall be complied with, by respondents/Opposite Parties, within a period of 45 days, from the date of receipt of its certified copy, failing which, they shall be liable to pay the amount (Rs.45,271/-) mentioned in Clause (i) of Para No.22 alongwith interest @9% p.a. from the date of default, till the date of actual payment to the appellant/complainant, besides paying the litigation costs, as aforesaid.
Consumer Complaint No.202 of 2013.
(i) to pay Rs.14,17,965/-
to the appellant/complainant being the surrender value of the Policy bearing No.000019499, in question, as on 07.01.2014;
(ii) to pay Rs.5,000/- as cost of litigation to the appellant/complainant.
This order shall be complied with, by respondents/Opposite Parties, within a period of 45 days, from the date of receipt of its certified copy, failing which, they shall be liable to pay the amount (Rs.14,17,965/-) mentioned in Clause (i) of Para No.22 alongwith interest @9% p.a. from the date of default, till the date of actual payment to the appellant/complainant, besides paying the litigation costs, as aforesaid.
23. Certified copy of this order be placed in First Appeal No.477 of 2013.
24. Certified Copies of this order be sent to the parties, free of charge.
25. The file be consigned to Record Room, after due completion.
Pronounced.
January 22, 2014.
Sd/-
[JUSTICE SHAM SUNDER (RETD.)] PRESIDENT Sd/-
[DEV RAJ] MEMBER Ad STATE COMMISSION (First Appeal No.478 of 2013) Argued by: Sh. Sandeep Bhardwaj, Advocate for the appellant.
Sh. Karan Nehra, Advocate for the respondents.
Dated the 22nd day of January 2014.
ORDER Vide our detailed order of the even date, recorded separately, this appeal and the connected appeal No.477/2013, arising out of the common order dated 7.10.2013 passed by the District Forum, have been accepted, with costs. The order dated 7.10.2013 has been set aside. Both the Consumer Complaints bearing No.201 of 2013 and 202 of 2013 have been partly accepted with costs.
(DEV RAJ) MEMBER (JUSTICE SHAM SUNDER(RETD.)) PRESIDENT Ad