BRIGHTON POLICE BRIGHTON POLICE DEPARTMENTDEPARTMENT

PURSUIT DRIVINGPURSUIT DRIVING

WHY A CHANGE WHY A CHANGE IN POLICY?IN POLICY?

CONCERN OVER CONCERN OVER INJURIES AND DEATHINJURIES AND DEATH

• From 1995 to present, 28% of pursuits ended in an MVA.

• From 1995 to present, 25% of those MVA’s or 1 out of every 30 pursuits ended with an injury or death. Recently the trend is rising.

According to Rochester Police Department figures

PROPERTY DAMAGEPROPERTY DAMAGE

• 28% of pursuits end in MVA’s

• Out of 445 pursuits from 1996 to present, there were 11 police pursuit accidents.

• $63,138 in damage to police vehicles in the past 4 years.

• No calculation on damage to civilian vehicles, buildings, objects, etc.

LIABILITYLIABILITY

• $158,210 paid out in civil claims since 1997. Information not available for 1996 and 1995. The trend shows a steady increase in pay-outs.

• Information not available for cost of medical treatment, benefits and pay for officers injured during pursuits.

NATIONAL TRENDNATIONAL TREND• Courts have held police less culpable (Lewis

vs. Sacramento), but the numbers of injuries and property damage have increased as well as civil liability payments.

• Trend has been to move toward “Limited Chase” policy or “NO Chase Policy”. Our department is adopting a “Limited Chase Policy”.

• LEC and other Monroe County Police Departments are following this model.

BRIGHTON POLICE BRIGHTON POLICE DEPARTMENTDEPARTMENT

THE “DEPARTMENT” IS COMFORTABLE THE “DEPARTMENT” IS COMFORTABLE WITH THE POTENTIAL LIABILITY, WITH THE POTENTIAL LIABILITY,

SCRUTINY AND POTENTIAL LOSS OF SCRUTINY AND POTENTIAL LOSS OF RESULTS BY INSTITUTING A LIMITED RESULTS BY INSTITUTING A LIMITED CHASE POLICY AS OUTLINED IN THIS CHASE POLICY AS OUTLINED IN THIS

TRAINING.TRAINING.

PURSUITPURSUIT

“An attempted apprehension by a police officer operating an emergency equipped police vehicle, of occupant(s) of another motor

vehicle, whose operator refuses to comply with a lawful directive to stop and attempts to flee

or takes other evasive action.”

WHEN DOES A WHEN DOES A PURSUIT BEGIN?PURSUIT BEGIN?

WHEN THE EMERGENCY EQUIPMENT OF WHEN THE EMERGENCY EQUIPMENT OF AN OFFICER’S VEHICLE IS ACTIVATED IN AN OFFICER’S VEHICLE IS ACTIVATED IN

AN ATTEMPT TO STOP THE VEHICLE AN ATTEMPT TO STOP THE VEHICLE

ANDAND THE SUSPECT REFUSES TO STOP THE SUSPECT REFUSES TO STOP

ANDAND ATTEMPTS TO FLEE ATTEMPTS TO FLEE OROR IS IS EVASIVE IN HIS ACTIONEVASIVE IN HIS ACTION

WHAT WHAT ISN’TISN’T A A PURSUIT?PURSUIT?

TRYING TO CATCH-UP TO A VEHICLE THAT HAS NOT ATTEMPTED TO FLEE

FOLLOWING A VIOLATOR WITH EMERGENCY EQUIPMENT WHO DOES

NOT ATTEMPT TO FLEE OR TAKE EVASIVE ACTION

DETERMINE BENEFIT DETERMINE BENEFIT TO THE PUBLICTO THE PUBLIC

HOW IMPORTANT IS IT TO HOW IMPORTANT IS IT TO THE SAFETY OF THE THE SAFETY OF THE

PUBLIC TO APPREHEND PUBLIC TO APPREHEND THE SUSPECT?THE SUSPECT?

REASONS TO INITIATE REASONS TO INITIATE A PURSUITA PURSUIT

WHEN AN OFFICER HAS WHEN AN OFFICER HAS

ARTICULATABLE ARTICULATABLE REASONABLE REASONABLE SUSPICIONSUSPICION TO BELIEVE THAT AN TO BELIEVE THAT AN

OPERATOR AND/OR PASSENGER(S), IN A OPERATOR AND/OR PASSENGER(S), IN A VEHICLE, WAS ATTEMPTING TO COMMIT VEHICLE, WAS ATTEMPTING TO COMMIT

OR HAS COMMITTED ONE OF THE OR HAS COMMITTED ONE OF THE OFFENSES LISTED IN APPENDIX AOFFENSES LISTED IN APPENDIX A

REASONABLE REASONABLE SUSPICIONSUSPICION

CIRCUMSTANCES AND/OR INFORMATION TO FORM A BELIEF IN THE MIND OF A

REASONABLE PERSON THAT AN INDIVIDUAL MAY HAVE ATTEMPTED TO

COMMIT OR HAD COMMITTED AND OFFENSE.

THIS IS NOT THE SAME AS PROBABLE CAUSE.THIS IS NOT THE SAME AS PROBABLE CAUSE.

AT THIS TIME, AN OFFICER MAY NOT HAVE ENOUGH AT THIS TIME, AN OFFICER MAY NOT HAVE ENOUGH INFORMATION FOR AN ARREST, AN OFFICER MAY ONLY INFORMATION FOR AN ARREST, AN OFFICER MAY ONLY

SUSPECT THEY ARE INVOLVED.SUSPECT THEY ARE INVOLVED.

APPENDIX “A”APPENDIX “A”• Murder/Manslaughter

• Forcible Rape/Sodomy

• Robbery

• Kidnapping/Unlawful Imprisonment

• Felony Assault

• Burglary in progress or immediate flight therefrom (not to include Burglary 3rd)

• Arson

• Felony Criminal Possession or Use of a Weapon or Menacing with a Firearm

• A-1 Drug cases

• “Wanted People” if they are wanted for any of the above crimes

• Fleeing the scene of an MVA with personal injuries

*An exigent circumstance involves an incident where the

apprehension of a fleeing suspect, while not falling into a

listed crime category, is of an equally serious nature and the

apprehension of the suspect outweighs the risks associated

with the pursuit. A supervisor/command officer must

clearly document the exigent circumstance that lead to

permission to pursue.

. . . or, . . . or, Exigent Circumstances, Exigent Circumstances, with the with the permission of a supervisor/command officerpermission of a supervisor/command officer

A PURSUIT IS NOT A PURSUIT IS NOT AUTHORIZEDAUTHORIZED

When an officer does not have When an officer does not have reasonable suspicion to believe a reasonable suspicion to believe a person has attempted to commit person has attempted to commit or has committed those offenses or has committed those offenses

listed in Appendix “A”listed in Appendix “A”

WHAT ABOUT?WHAT ABOUT?• VEHICLE AND TRAFFIC LAW VIOLATORSVEHICLE AND TRAFFIC LAW VIOLATORS If there isn’t If there isn’t

any reasonable suspicion to believe that they were attempting to any reasonable suspicion to believe that they were attempting to commit or have committed an offense in Appendix “A” and all commit or have committed an offense in Appendix “A” and all the officer has is V&T, a pursuit will not be authorizedthe officer has is V&T, a pursuit will not be authorized::

– 58% of Pursuits are for V&T only58% of Pursuits are for V&T only

– 29% of those pursuits end in MVA’s29% of those pursuits end in MVA’s

– Risk of the chase outweighs the benefitRisk of the chase outweighs the benefit

• STOLEN VEHICLESSTOLEN VEHICLES If there is no reasonable suspicion to link If there is no reasonable suspicion to link the operator or occupant(s) of the stolen vehicle to a crime or the operator or occupant(s) of the stolen vehicle to a crime or attempted crime contained in Appendix “A”, a pursuit is not attempted crime contained in Appendix “A”, a pursuit is not authorized:authorized:

– A lot of reported stolen vehicles are due to “Geeker” dealsA lot of reported stolen vehicles are due to “Geeker” deals

– Almost 36% of pursuits involving a stolen vehicle end in an Almost 36% of pursuits involving a stolen vehicle end in an MVAMVA

WHAT ABOUT?WHAT ABOUT?• PEOPLE WITH OUTSTANDING WARRANTSPEOPLE WITH OUTSTANDING WARRANTS. If . If

the warrants are for offenses in Appendix “A”, a the warrants are for offenses in Appendix “A”, a pursuit may be considered. If not, it will not be pursuit may be considered. If not, it will not be authorized.authorized.

• OTHER “WANTED PERSONS.”OTHER “WANTED PERSONS.” If the package is for If the package is for offenses in Appendix “A”, a pursuit may be considered. offenses in Appendix “A”, a pursuit may be considered. If not, it will not be authorized. If not, it will not be authorized.

• POSSIBLE DWI VIOLATORSPOSSIBLE DWI VIOLATORS. If there is no . If there is no reasonable suspicion that an offense in Appendix “A” reasonable suspicion that an offense in Appendix “A” has been committed, a pursuit will not be authorized.has been committed, a pursuit will not be authorized.

• PEOPLE WHO COMMIT DOMESTIC LAW PEOPLE WHO COMMIT DOMESTIC LAW OFFENSES OR ARE SUBJECT TO CRIMINAL OFFENSES OR ARE SUBJECT TO CRIMINAL CONTEMPT CHARGESCONTEMPT CHARGES. If there isn’t an offense . If there isn’t an offense listed in Appendix “A” (like a felony assault listed in Appendix “A” (like a felony assault ANDAND Criminal Contempt) a pursuit will not be authorized.Criminal Contempt) a pursuit will not be authorized.

WHAT ABOUT?WHAT ABOUT?• ““DETAILS”,DETAILS”, the ones where officers are searching for suspects the ones where officers are searching for suspects

who are committing multiple crimes. If there is articulable who are committing multiple crimes. If there is articulable reasonable suspicion to believe that the person being pursued reasonable suspicion to believe that the person being pursued was about to commit or has committed an offense in Appendix was about to commit or has committed an offense in Appendix “A”, then the pursuit may be considered.“A”, then the pursuit may be considered.

• OFFENSES NOT LISTED IN APPENDIX “A”.OFFENSES NOT LISTED IN APPENDIX “A”. Not Not authorized.authorized.

• BURGLARY CHARGESBURGLARY CHARGES, , such as a “Wanted Package”.such as a “Wanted Package”. If If there is a charge like Robbery or Felony Assault along with it or there is a charge like Robbery or Felony Assault along with it or there is reasonable suspicion to believe that it was being there is reasonable suspicion to believe that it was being attempted or had been committed and/or the perpetrator is in attempted or had been committed and/or the perpetrator is in flight therefrom, then a pursuit may be considered. If not, it is flight therefrom, then a pursuit may be considered. If not, it is considered a property crime and it will not be authorized. considered a property crime and it will not be authorized.

A PURSUIT IS NOT TO BE A PURSUIT IS NOT TO BE CONTINUED WHEN:CONTINUED WHEN:

THE RISKS OUTWEIGH THE THE RISKS OUTWEIGH THE BENEFITSBENEFITS

Serious Physical Crime Serious Physical Crime

Physical CrimePhysical Crime

PropertyProperty CrimeCrime

Non-serious OffenseNon-serious Offense

Aggravating or Aggravating or Mitigating Mitigating

Circumstances will Circumstances will determine whether to determine whether to continue or terminate continue or terminate

the pursuitthe pursuit

HIGH BENEFIT

LOW BENEFIT

Active ViolentActive Violent

Pursuit will not take Pursuit will not take placeplace

PURSUIT CONTINUUMPURSUIT CONTINUUM

UNAUTHORIZED USEUNAUTHORIZED USE

MINOR V&TMINOR V&T

““DOESN’T SEEM RIGHT”DOESN’T SEEM RIGHT”

DWI’sDWI’s

NON-SERIOUS OFFENSES NON-SERIOUS OFFENSES (includes stolen vehicles) (includes stolen vehicles)

MVA H&R with INJURIESMVA H&R with INJURIES

PHYSICAL CRIME PHYSICAL CRIME

SUSPECTED OR WANTEDSUSPECTED OR WANTED

SERIOUS VIOLENT CRIMESERIOUS VIOLENT CRIME

A-1 DRUG CRIMESA-1 DRUG CRIMES

ACTIVE VIOLENT CRIMEACTIVE VIOLENT CRIME

or HOSTAGE SITUATIONor HOSTAGE SITUATION

Very Very

High High

HighHigh

Medium Medium

MildMild

LowLow

Doesn’t matter, risk Doesn’t matter, risk to the public to the public

outweighs the benefit outweighs the benefit of apprehensionof apprehension

Extreme or tExtreme or too oo MANY, not worth it at MANY, not worth it at

any costany cost

BENEFIT RISK

The risk to the police The risk to the police and public must not and public must not

outweigh the benefit of outweigh the benefit of capture. This must be capture. This must be continuously evaluated continuously evaluated by weighing aggravated by weighing aggravated

and mitigating and mitigating circumstancescircumstances

AGGRAVATING AGGRAVATING CIRCUMSTANCESCIRCUMSTANCES

• Firearm involved

• Known violent history

• Violent crime will continue

• Mental state of suspect (suicidal or homicidal)

• Extenuating suspicious condition

• Destruction of evidence in a violent crime

• Vehicle used in a violent crime

• Known suspect unable to be located

MITIGATING MITIGATING CIRCUMSTANCESCIRCUMSTANCES

• Suspect known or unknown

• Will the suspect be able to be located later

• Suspect unarmed

• Uninvolved passengers

• Children on board

• Crime will not continue

• Resources available

““RISKRISK to the PUBLIC to the PUBLIC””

What level or risk does the What level or risk does the pursuit present to public pursuit present to public

safety?safety?

RISK VARIABLES RISK VARIABLES

• SPEEDSPEED

• THE AREA or NEIGHBORHOODTHE AREA or NEIGHBORHOOD

• SUSPECT’S VEHICLE CONDITION/TYPESUSPECT’S VEHICLE CONDITION/TYPE

• PEDESTRIAN VOLUMEPEDESTRIAN VOLUME

• TRAFFIC VOLUMETRAFFIC VOLUME

• WEATHER/ROAD CONDITIONSWEATHER/ROAD CONDITIONS

• SUSPECT’S DRIVING BEHAVIOR/CONDUCTSUSPECT’S DRIVING BEHAVIOR/CONDUCT

• OFFICER’S DEMEANOROFFICER’S DEMEANOR

• POLICE VEHICLE CONDITIONPOLICE VEHICLE CONDITION

UNMARKED VEHICLES UNMARKED VEHICLES WILL NOT BE USED IN WILL NOT BE USED IN

PURSUITSPURSUITS• Marked Patrol Units may not be able to Marked Patrol Units may not be able to

differentiate between the unmarked police unit and differentiate between the unmarked police unit and the suspect vehiclethe suspect vehicle

• Unmarked vehicles are not designed for chasesUnmarked vehicles are not designed for chases

• Pursued person has a defense that he didn’t know Pursued person has a defense that he didn’t know it was the policeit was the police

• Civilians cannot differentiate or be alertedCivilians cannot differentiate or be alerted

• Sometimes unmarked units do not carry radiosSometimes unmarked units do not carry radios

CONTINUE TO MAKE VEHICLE CONTINUE TO MAKE VEHICLE STOPS.STOPS.

IF A PURSUIT BEGINS, BE ABLE IF A PURSUIT BEGINS, BE ABLE TO ARTICULATE WHY YOU ARE TO ARTICULATE WHY YOU ARE

PURSUING THE VEHICLEPURSUING THE VEHICLEIF YOU CAN’T ADVISE YOUR SUPERVISOR WHY IF YOU CAN’T ADVISE YOUR SUPERVISOR WHY

YOU’RE PURSUING IT, THEN IT WILL BE:YOU’RE PURSUING IT, THEN IT WILL BE:

TERMINATEDTERMINATED

““7”7” CRITICAL TASKSCRITICAL TASKS of of POLICE POLICE PURSUITPURSUIT

1. 1.

2. 2.

3. 3.

4. 4.

5. 5.

6.6.

7.7.

SECURE THE RADIO FREQUENCYSECURE THE RADIO FREQUENCY

IDENTIFY DIRECTION/PURSUING VEHICLE IDENTIFY DIRECTION/PURSUING VEHICLE

ESTABLISH REASON/BENEFIT OF PURSUITESTABLISH REASON/BENEFIT OF PURSUIT

IF CONTINUE, CONSIDER RISK VARIABLESIF CONTINUE, CONSIDER RISK VARIABLES

OFFICERS AND SUPERVISORS ASSESS TO OFFICERS AND SUPERVISORS ASSESS TO EITHER CONTINUE OR TERMINATEEITHER CONTINUE OR TERMINATE

CONTINUE TO EVALUATE PURSUIT AND/OR CONTINUE TO EVALUATE PURSUIT AND/OR EMPLOY OTHER TACTICS/STRATEGIESEMPLOY OTHER TACTICS/STRATEGIES

SUPERVISOR ACKNOWLEDGE MONITORINGSUPERVISOR ACKNOWLEDGE MONITORING

SECURE THE SECURE THE FREQUENCYFREQUENCY

Advise OEC that you either are trying to Advise OEC that you either are trying to “catch up to”, “following with failure to stop”, “catch up to”, “following with failure to stop”,

or you’re “in pursuit” and to hold the airor you’re “in pursuit” and to hold the air

THE PURSUIT WILL STAY ON THE MAIN THE PURSUIT WILL STAY ON THE MAIN FREQUENCY UNTIL/UNLESS OEC DIRECTS FREQUENCY UNTIL/UNLESS OEC DIRECTS

OTHERWISEOTHERWISE

ARTICULATING THE ARTICULATING THE INITIATIONINITIATION

• Identification of car number and direction of travelIdentification of car number and direction of travel

• Vehicle color, model, style, type, and plate if known Vehicle color, model, style, type, and plate if known and number of occupants and descriptions, if knownand number of occupants and descriptions, if known

• Reason for pursuit - give some information to allow Reason for pursuit - give some information to allow supervisors to hear/understand the reasonable supervisors to hear/understand the reasonable suspicion or more (like known offender) of driver or suspicion or more (like known offender) of driver or passengers who attempted to commit or have passengers who attempted to commit or have committed offenses in Appendix “A” committed offenses in Appendix “A”

• Weapons, if anyWeapons, if any

• Speed, vehicle and/or pedestrian traffic densitySpeed, vehicle and/or pedestrian traffic density

• The pursued person’s driving behavior (good or bad)The pursued person’s driving behavior (good or bad)

SUPERVISORSSUPERVISORS• ASSUME RESPONSIBILITY PRIOR TO ASSUME RESPONSIBILITY PRIOR TO

OEC “VOLUNTEERING” YOUOEC “VOLUNTEERING” YOU

• OEC WILL ASSIGN A SUPERVISOR IF OEC WILL ASSIGN A SUPERVISOR IF YOU DON’T TAKE CHARGEYOU DON’T TAKE CHARGE

• ADVISE OEC PROMPTLY AND ADVISE OEC PROMPTLY AND CLEARLY - “I’M MONITORING THE CLEARLY - “I’M MONITORING THE CHASE”CHASE”

• ASSESS SITUATIONASSESS SITUATION

ASSESSING THE ASSESSING THE SITUATIONSITUATION

• Determine reason of pursuit, if not articulated in the beginning, try to ascertain by asking the officer. If the officer doesn’t know or can’t identify a reason - TERMINATE!TERMINATE!

• Terminate if it does not comply with General Order 0002 and direct alternate options, if possible.

• If it complies, confirm or determine RISK VARIABLES.

• If it complies, determine if there are any aggravating or mitigating circumstances and continuously evaluate whether to continue with the pursuit or terminate.

• Attempt to direct other tactics (ie-spikes, shutting off main streets, etc.) without taking up too much air time.

RESPONSIBILITIES OF RESPONSIBILITIES OF SUPERVISORSSUPERVISORS

THE SUPERVISOR WHO ADVISES THEY ARE THE SUPERVISOR WHO ADVISES THEY ARE “MONITORING THE PURSUIT” HAS “MONITORING THE PURSUIT” HAS

RESPONSIBILITYRESPONSIBILITY FOR IT’S MANAGEMENT UNLESS FOR IT’S MANAGEMENT UNLESS RELIEVED BY A HIGHER RANKING AUTHORITY. RELIEVED BY A HIGHER RANKING AUTHORITY.

ANY BRIGHTON POLICE SUPERVISOR MAY ANY BRIGHTON POLICE SUPERVISOR MAY TERMINATE A PURSUIT IF THE RISKS OUTWEIGH TERMINATE A PURSUIT IF THE RISKS OUTWEIGH

THE BENEFITS.THE BENEFITS.

PURSUING UNITSPURSUING UNITS

THERE SHOULD ONLY BE A THERE SHOULD ONLY BE A PRIMARY AND SECONDARY UNIT PRIMARY AND SECONDARY UNIT

IN DIRECT PURSUIT OF THE IN DIRECT PURSUIT OF THE SUSPECT VEHICLE.SUSPECT VEHICLE.

““NO TRAINS”NO TRAINS”

ASSISTING UNITSASSISTING UNITS“What can you do?”“What can you do?”

• Parallel side streets.

• Calculate where chase may be heading and attempt to restrict non-involved traffic.

• Anticipate direction of chase and deploy “spikes” and advise officers involved.

• Determine locations, if known, where suspect(s) may go and respond.

• Advise all units and supervisors of potential hazards or RISK VARIABLES.

““TERMINATE”TERMINATE”IT MEANS TO CEASE OR STOP IT MEANS TO CEASE OR STOP

THE PURSUIT THE PURSUIT IMMEDIATELYIMMEDIATELY

TURN OFF YOUR EMERGENCY TURN OFF YOUR EMERGENCY LIGHTS, SLOW YOUR LIGHTS, SLOW YOUR

VEHICLE DOWN, AND RETURN VEHICLE DOWN, AND RETURN TO NORMAL DRIVING.TO NORMAL DRIVING.

WHEN TO TERMINATE?WHEN TO TERMINATE?

• When risks outweigh the benefits that may be gained. Your life or the life of another means more than a V&T ticket or a minor offense arrest.

• The pursued vehicle is only wanted for V&T violations.

• For any offense not covered by Appendix “A”

WHEN TO TEMINATE? WHEN TO TEMINATE? (cont’d)(cont’d)

• There are mitigating circumstances that allow later apprehension.

• A direct order by a Supervisor to terminate.

• An order by another supervisor of another jurisdiction that the pursuit extends to.

• It is no longer known where the suspect is

• When radio contact is lost.

• When officer doesn’t know where they are.

ACKNOWLEDGE THE ACKNOWLEDGE THE TERMINATE ORDERTERMINATE ORDER

Similar to acknowledging a “35” from the Similar to acknowledging a “35” from the dispatch on a routine assignment. dispatch on a routine assignment.

““Brighton 772, 10-4, I’m terminating.”Brighton 772, 10-4, I’m terminating.”

UNACCEPTABLEUNACCEPTABLEDO NOT “KEY THE MIKE”. If you’re keying the DO NOT “KEY THE MIKE”. If you’re keying the

“mike” then there are only two reasons for it:“mike” then there are only two reasons for it:

You are in the “BLACK” zone and you are You are in the “BLACK” zone and you are “white knuckling” the microphone - very “white knuckling” the microphone - very dangerous for you, other officers, and the dangerous for you, other officers, and the

public, orpublic, orYou are doing it intentionally and trying You are doing it intentionally and trying to keep a supervisor from terminating a to keep a supervisor from terminating a

chase that you probably shouldn’t be chase that you probably shouldn’t be involved in.involved in.

WHAT IF ANOTHER WHAT IF ANOTHER JURISDICTION COMES JURISDICTION COMES

INTO BRIGHTON?INTO BRIGHTON?

BRIGHTON POLICE WILL GET INVOLVED BRIGHTON POLICE WILL GET INVOLVED ONLY IF IT FITS BRIGHTON POLICE ONLY IF IT FITS BRIGHTON POLICE

DEPARTMENT POLICYDEPARTMENT POLICY

IF IT DOESN’T, WE CAN STILL ASSIST BY PARALLELING, BLOCKING OFF MAIN THOROUGH-FARES, ANTICIPATING

ACTION, ETC.

POST PURSUIT REPORTPOST PURSUIT REPORT• MUST be filled out by a supervisor.

• ALL officers involved in the pursuit will complete an addendum to document their actions in the chase.

DOCUMENT “WHAT YOU DID”

• What roads you paralleled on

• Streets you blocked

• Spikes you utilized

• Other significant actions

WHAT HAPPENS AFTER WHAT HAPPENS AFTER A “TERMINATE”?A “TERMINATE”?

• If there are ANY solvability factors that could lead to the apprehension of the individual who fled, Officers are encouraged to follow those leads in order to apprehend the violator and “Make an arrest”. This can be documented on a Crime report to follow-up like any other crime.

• If there are no solvability factors, then an FIF may be appropriate.