how to overcome the top 7 intercompany accounting challenges in sap...

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How to Overcome the Top 7 Intercompany Accounting Challenges in SAP ERP Financials

David Cohen EY

1

In This Session

• Discuss common issues in intercompany (IC) processes

• Review common design solutions for seven main processes

• Examine project challenges for implementing IC processes

• Consider how existing and future HANA functionality can improve efficiency of IC

processes

• Explore leading practices in the areas of systems, master data, processes, and people

related to IC

2

What We’ll Cover

• Intercompany processes and SAP ERP

• How can HANA improve IC processes?

• Challenges for implementation

• Leading practices – systems, master data, processes, and people

• Wrap-up

3

Intercompany Processes

• Intercompany Product Sales

• Intercompany Charge of Services

• Intercompany Lease of Assets

• Intercompany Accounts Payable and Receivable (AP/AR) Reconciliation

• Intercompany Treasury (In-House Cash)

• Intercompany Profit Elimination

• Intercompany Month-End Closing

4

Common Intercompany Issues

• Top-side, high-level entries

• No ability to isolate Foreign Exchange (FX) impact on IC profit reserve

• Limited ability to analyze gross profit on a consolidated cost basis

• Intercompany profit reserve based on estimates and averages

• Lost goods, goods stuck in transit, Cost of Goods Sold (COGS) without revenue, revenue without

COGS, etc.

• Lack of established policies and procedures driving IC activities

• Not leveraging common processes across multiple countries into one Shared Service Center

Manual processes

Poor visibility

Lack of control

Lack of adherence to a process resulted in unexpected IC write-offs and tedious manual processing

• Long close cycle times and difficult reconciliation of IC processes

• Highly manual and spreadsheet-based process

• No ability to adjust obsolescence, revaluation, Purchase Price Variance (PPV), or consumption

variances for IC profit

• Poor data quality and inconsistencies

• Low accuracy of product costing

5

Why Is Intercompany a Challenge in SAP?

• Strictly from an SAP functional perspective:

Many IC processes are not represented by specific SAP functionality

Sometimes there is no out-of-the-box standard solution

There might be multiple possible designs and solutions for a specific IC process

IC processes are very dependent on company and the industry

• Processes in this presentation are depicted as generic suggestions and not as

specific “unique” solutions with all steps

• Gaps will vary depending on company, industry, processes, and systems

architecture

6





• Intercompany AP/AR Reconciliation




7

Design Principles

• Adopt Stock Transfer Orders (STO)

• Establish Transfer Price agreements harmonized with SAP ERP design

• Use EDI to automate booking of payable upon creation of receivable – no manual

intervention after Goods Receipt

• Handle Invoice Receipt automatically without manual intervention (reduces time required

for month-end closing)

Special care needed for:

• Country taxes (might require implementation of User Exit)

• Additional lines (freight, customs, etc.)

8

Process Flow (Main Activities)

Some potential

issues

regarding

country taxes

and additional

items such as

freight,

customs, etc.

9

Key Enablers: Stock Transfer Order and Goods-in-Transit Functionality

• Stock Transfer Orders (STO) are used to move materials between companies integrating

both processes

• Both companies need to implement Materials Management and Purchasing (MM) and

Sales and Distribution (SD)

• Process is initiated by company that needs to receive the material

• It is necessary to pay attention to fulfilling country statutory requirements. Revenue

recognition, transfer price, and settlement of receivables/payables are usually performed

as if the companies were independent.

• The additional usage of Goods-in-Transit improves the financial controls of inventory

ownership

10

Key Enabler: Goods-in-Transit Functionality

• SAP ERP 6.0 with EHP5 supports full automation of intercompany accounting, including

accruals for stock in transit

Seller location

On hand In transit

Buyer location

On hand In transit

Transfer to

in transit (681)

Issue paired with

receipt (685)

Goods receipt

(101)

Transfer to

in transit (681)

Issue paired with

receipt (685)

Goods receipt

(109)

Logical receipt

(107)

Transfer to

in transit (683)

Goods receipt

(109)

Goods receipt

(107)

Seller ships goods and retains

ownership while in transit. Buyer

confirms receipt, which

automatically books goods issue

and receipt to on hand.

Seller retains ownership for part of

transit time. POD at title transit

point moves inventory to in transit

to buyer. Final receipt moves

inventory to on hand at buyer.

Intercompany sale recognized

immediately at time of goods

issue. Buyer holds inventory in

transit until physical receipt, which

moves inventory to on hand.

Intercompany invoicing is automatically triggered

when title transfers between companies

Inventory location by status, ownership, and movement

User task performed in SAP

Title transfer point that triggers billing

1. Ship goods

1. Ship goods

2. Create proof of delivery 1. Ship goods 3. Receive goods

2. Receive goods

2. Create proof of delivery

11









12

Design Principles

• Use Intercompany Charge of Services process to create and charge a variety of expenses

between Company Codes

• Accumulate charges either by direct posting or with periodic assessment into Work

Breakdown Structures (WBS)

• Calculate and post invoices (AP/AR) at month-end or ad hoc

• Use EDI and IDoc integration to automatically create the Accounts Payable invoice,

booking it at the same time as Accounts Receivable

• Consider each type of process carefully; as this is not a standard process in SAP, there

are several alternatives on how to trigger the process or how to deal with specific

charges (IT fees, HR ex-pat charges, training, etc.)

13

Process Flow

14

Design Principles

• Consider the creation by the Buyer of a blanket Purchase Order (PO) authorizing the

charges while seller creates a Sales Order for automatic billing:

The reference PO is used to post charges to the receiver cost object

Other types of POs can be considered depending on specific business process

• Based on the WBS charges, the sales price is calculated and the following documents are

created: Billing, Accounts Receivable Invoice, and Accounts Payable Invoice

Charges are collected on a WBS by direct posting or by allocation of

expenses from Cost Centers or other objects

15

Design Principles (cont.)

• Trigger Billing and Invoicing periodically and automatically – it is possible to add an ad

hoc billing event as well

• Activate Extended Withholding Tax (WHT) functionality for all countries – you will need it!

• Resolve issues with billing through Dispute Management − do not hold back month-end

closing

SAP GAPs:

• Full processing of WHT in receiver side

• Posting payable invoice to the correct cost object

16

Key Enabler: Resource-Related Billing (RRB)

• RRB allows for the summarization of data based on Project, Sales Order, Service Order,

and other cost objects in order to calculate COGS and Revenue (Sales Price)

• RRB is powerful, but requires standardization and rationalization of different business

processes and scenarios

• There are several standard possibilities for billing: Cost-Based Billing, Quantity-Based

Billing, Fixed Price, Surcharges, and any combination of these. They are used when

simple Milestone or Periodic Billing are not enough.

• RRB has extensive possibilities for configuration with the possibility of custom logic by

using User Exits

17

Example: Usage of WBS and RRB

Service Charges

Labor – $2,000

Fringe – $1,000

Other Costs – $3,000

IT Cost Center

WBS 123

Country A

Charges

Labor – $2,000

SAP – $5,000

Support – $8,000

Transferred to WBS 123

Labor – $500

Fringe – $100

Other Costs – $300

WBS 123

Labor – $500

Fringe – $100

Other Costs – $300

Allocated to WBS 123

IT Charges – $1,000

Allocated from IT

IT Charges – $1,000

Month-End

Billed – $1,900

COS – $1,900

A/R – $2,000* Revenue – $2,000

*Difference between COS and A/R is due to markup and surcharges

18









19

Design Principles

• Leverage the key design principles from IC Sales of Products and IC Service Charges

processes

• Use a zero-dollar value PO (STO) to request rental equipment or an asset

• Match Asset or Equipment to a Non-Valuated Material through Serial Number

• Enhance SAP solution through user exits to handle all scenarios of Withholding Tax and

other Fees

Most prevailing technology nowadays:

Excel spreadsheets!

20

Process Flow

21

Key Enablers

• Link Assets, Equipment, and Non-Valuated Material by serial number

• MM/SD are the drivers for shipping the asset and creating the documentation

• For some scenarios, Cost Centers can be used as an indirect assignment of the

location (country) of the equipment in order to derive invoice and tax charges (e.g.,

IT charges to different countries)

• It will probably be necessary to develop custom reports to manage end of lease

and other management information

• Potential gap for different country taxes

Use combination of Vendor, Country, and other Sales Orders/Billing

characteristics to derive correct tax calculation

• There is a need to keep synchronization between AM and MM modules for quantity

(i.e., asset disposal)

22









23

Leading Practices

• Use automatic Intercompany Reconciliation Process (ICR)

• Periodically process (during the month) the reconciliation of IC payable and receivable –

no need to wait for month-end closing

• Implement Dispute Management process for issues about price, quantity, or quality

• Reconcile the documents and afterwards deal with the dispute:

Subsequent debit and credit memos derived from the dispute resolution will also be

reconciled

Dispute does not interrupt month-end closing

The automatic creation of payable (in buyer’s General Ledger) upon the

creation of the receivable (in seller’s GL) should reduce the number of

discrepancies to a minimum

24

Process Flow

25

Option 1: SAP ICR (Intercompany Reconciliation) Tool

• Solution collects data from Accounts Receivable and Payable invoice-level detail and

enables matching analysis during the month. It can accommodate non-SAP data.

• There is an opportunity to correct before month-end close, reducing differences at

month-end. Nevertheless, it is a batch process.

• There is a process for automatic and manual matching with standard or customized rules

for reconciliation and matching

• ICR is an analysis tool. It does not correct the problem at the source, but it can initiate a

dispute.

ICR works better in an SSC environment (centralized processing)

26

Option 1: SAP ICR (Intercompany Reconciliation) Tool (cont.)

Navigation tree with differences to

reconcile by Company and Partner

Company unassigned

documents Partner unassigned

documents

Matched documents

27

Option 1: SAP ICR (Intercompany Reconciliation) Tool (cont.)

Communication (email)

Workflow (custom)

Dispute Case

28

Option 2: SAP BusinessObjects IC Reconciliation Tool

• Easier to include mixed ERP data

• Good integration with Consolidation (BPC module)

• Good functionality for mixed currencies

• Works well in decentralized environment

• It can force agreement by generating adjustment posting

• More complicated integration to Dispute Management

How does it compare to SAP ERP ICR?

29

The total of the invoices is equal

to the balance in the child account

The total of the invoices differs

from the balance in the child

account

Matched invoices

(in black font)

Unmatched invoices

(in blue hyperlink)

Matching takes place based on

invoice reference created by

ERP System

Uploaded data

Amount not matched

Option 2: SAP BusinessObjects IC Reconciliation Tool (cont.)

The declaring company’s invoices are compared to the partner’s. The invoices are matched automatically:

• Have the same transaction reference

• Contain the same transaction amount

30









31

In-House Cash Concepts

• Simulate an internal bank and use it to fulfill financial services to group companies

• It can provide services such as: Provision of FX, Interest Rate Calculation, Liquidity Management, Intercompany Liability, Funding Management, Centralized Management of Payables and Receivables

• Two scenarios for payables and receivables:

External incoming and outgoing payment via In-House Cash (IHC):

All incoming and outgoing payment with external entities is processed through the In-House Cash Center of the parent company

Internal payments:

The In-House Cash Center is used to manage all payments between company units and thus keeps cash resources within the group and optimizes how they are applied

32

Example: Vendor Payment Process Flow

33

In-House Cash

• Principles:

IHC is set up at the group headquarters

IHC is a virtual bank where subsidiaries have current accounts

Technically, it is a separate engine. That is the reason for the complex ALE/IDoc

configuration and the multiple steps in processing.

Accounts can be maintained in any currency

The handling of intercompany payments is fully automated within IHC. On the due

settlement date, the IHC accounts and the general ledgers of the paying and recipient

intercompany counterparties are updated automatically with the relevant postings.

34

In-House Cash: How Does It Help?

• Benefits:

Centralized payment and receivable transactions on a regional or global level

Reduced cost and number of payment transactions, bank account numbers, and

bank fees

Can use surplus cash for financing purposes; keep cash resources within the group

Better control of financial interest of subsidiaries

Processes internal payment transactions on a cost-effective basis

Reduce the number of external banks and associated interfaces

35

Additional Points

• Critical configuration: ALE and IDocs. Functionality makes extensive usage of IDocs.

Users might have to be trained in troubleshooting them.

• Accounts Payable has two steps (instead of one)

• SAP ERP functionality works well, but additional custom management reports and

interfaces might be required

• Plan enough time to test with banks

• IHC cannot be implemented for certain countries (e.g., China)

Difficult to have 100% adherence to IHC (country regulations, external systems, etc.)

36









37

Accounting 101: Intercompany Profit Elimination

Intercompany sales has a

profit of $200.00

Overall inventory is overstated

by $200.00

Inventory must be adjusted (by

eliminating IC Profit) and taxes

deferred (30% of ICP, as an

example)

What is Intercompany Profit Elimination?

38

Accounting 101: Intercompany Profit Elimination (cont.)

• It looks simple until you add:

Balances from previous years

Purchase Price Variances (PPV)

Exchange Rate differences

Currency Adjustment Translation (CAT)

Production variances

Price adjustments and rebilling

Legal, Group, and Functional Currency

Billing currency

Daily and Monthly Exchange Rates

Complex production and supply chains (such as tolling)

39

Leading Practices

• Keep in mind that there are two processes that must be addressed:

Determination of Actual Costing across Company Codes

Determination of Company Uplift (or Delta Profit, ICP)

• Use the latest SAP functionality in this area:

Parallel Valuation in Material Ledger (Legal and Group Management) with single and

multi-settlement

Implementation of STOs for intercompany sales

Actual Company Uplift (EHP 5 and 6 – business function LOG_MM_SIT)

Companies must be in the same Controlling Area

40

Option 1: Parallel Valuation Material Ledger Solution

• Currency Types set up for Material Ledger Solution with Parallel Valuation:

Currency Type 10 for Local Currency (Legal Valuation)

Currency Type 30 for Group Currency (Legal Valuation)

Currency Type 31 for Group Currency (Group Valuation)

Intercompany Delta Profit is the difference between Currency Type 30 and 31

• IC Inventory Profit is reported, revaluating inventory and goods movement

based on Management View: Inventory at hand, Good Issue (for relieve of IC

Profit), Returns, Scrap, and so on

41

Currency 10 Currency 30 Currency 31

Option 1: Parallel Valuation Material Ledger Solution (cont.)

Parallel Group Valuation (currencies 31 and 32) is NOT available in SAP S/4HANA

42

STO (Stock Transfer Order) Updating ICP (Intercompany Profit)

• IC Profit (Delta Profit) is recorded in Legal Valuation as a Non-Valued Cost Component

• Delta Profit is updated based on STO information

Purchase Price Value – Sender’s COGS (KW00) or

Transfer price – COGS selling Plant

Invoice $1,100 Invoice $1,300

STO updates IC Profit STO updates IC Profit

43

Option 2: Alternative Material Ledger Solution Without Parallel Valuation

Currency 10 Currency 30

• Currency Types 10, 30 are set up in the

Material Ledger, which enables two

currencies to be maintained in the

Material Master

• Delta Profit is stored as a cost

component in both the currencies

• Delta Profit is automatically updated

by STO and any subsequent material

movement

• Variances in multi-level settlement are

forwarded to receiving plants and

update Delta Profit

• External Sales or transfer of goods

decrease Delta Profit in the

material/plant

44

Option 2: Alternative Material Ledger Solution Without Parallel Valuation (cont.)

• In this solution we get:

Local Currency Group Valuation Actual (CT10 minus Intercompany Profit)

Consolidated Currency Group Valuation Actual (CT30 minus Intercompany Profit)

Local Currency Legal Valuation Actual (Currency Type 10)

Consolidated Currency Legal Valuation Actual (Currency Type 30)

• Sanjeev Walia, EY, “Key Design Considerations for Legal and Group Valuation in

SAP’s Material Ledger” (SAPinsider Financials 2015, Las Vegas)

45









46

Leading Practices

• Implement one of the two SAP options for managing month-end closing

SAP Closing Cockpit − standard SAP tool to monitor and control the entire period-end

closing cycle

SAP Financial Closing add-on

• Genco Odevci, “I Implemented Closing Cockpit in SAP ERP 6.0 – Now What?”

(SAPinsider Financials 2015, Las Vegas)

47

Key Enabler: SAP Closing Cockpit

• SAP Closing Cockpit works through the definition of templates and tasks lists executed

during period end

• The key design elements are:

Defining organizational hierarchy for closing

Defining period close template

Assigning tasks to template

Defining task dependencies

Creating and releasing a task list – ongoing each period

48

Key Enabler: SAP Closing Cockpit (cont.)

• It provides a structured list of financial activities that occur periodically

• The single-screen layout presents a period-close-centric view

• The purpose is to replace spreadsheet-based close checklists. Embedded task

dependencies can help prevent timing issues.

• Once a task is being worked on, its status will be visible to all

• Support documentation or a note can be attached to tasks

• Auditors accept completed task list printout as proof of close completion

• SAP transactions or custom T-Codes can be directly called from the Closing Cockpit.

Task execution captured with a time snapshot.

Source: Genco Odevci, “Expert Techniques for Making the Most of the SAP Financial Closing Cockpit” (SAPinsider Financials 2014).

49

Additional Option: Usage of SAP Financial Closing Add-On

• It requires a separate license agreement

• It connects to multiple SAP ERP systems for remote runs

• It offers automated closing tasks, even in remote system. All task types (transactions,

programs, jobs, workflow, CPS (Central Process Scheduling by Redwood) tasks) are

available for the local and remote systems.

• It has reusable task groups

• Tasks can automatically start when predecessors are done (e.g., run transaction in test

mode; if successful, run in production mode; if errors, send mail using workflow)

• It offers collaboration, notifications, and workflows

• It offers better real-time insight into the closing status

50

What We’ll Cover





• Wrap-up

51

How Can HANA Improve IC Processes?

• ICR (Intercompany Reconciliation):

ICR works directly on the open items in AP/AR (central ERP instance)

Always ready to reconcile – no batch loading or matching

New Management Dashboard

• Material Ledger:

Side-car solution implemented in several clients

Accelerated closing runs:

Material selection

Single and Multi-Level Settlement

Post-closing

In-memory computing increases speed of tasks due to almost instantaneous

fetching of data from the virtual “hard-disk”

52

SAP S/4HANA Finance (Optimized Financial Data Architecture)

Legal/External

Accounting (FI)

Documents

Legal/External

Accounting (FI)

Totals tables

Management

Accounting (CO)

Documents

Management

Accounting (CO)

Totals tables

ERP Financials

Market Segment

Data

Legal/External

Accounting (FI)

Documents

Legal/External

Accounting (FI)

Totals tables

Management

Accounting (CO)

Documents

Management

Accounting (CO)

Totals tables

Profitability Analysis

(COPA)

Documents

Market Segment

Data

• No Data Redundancy

• Easy Reconciliation

• High Flexibility

• Less Data Volume

• High Performance

• One-stop shop for all operational financial reporting

• Drilldown to atomic detail

One Unified Accounting Document

• Data Redundancy (Totals tables, Data Warehouse)

• High Reconciliation effort

• Low Flexibility

• Higher Data Volume

• Performance issues

Physical Data

Virtual HANA views

Reports

Reports

Reports

Profitability Analysis

(COPA)

Documents

Data

Warehouse

SAP S/4HANA Finance*

*SAP S/4HANA Finance, formerly known as SAP Simple Finance

53

Central Journal

• Finance data copied from source systems onto a Central

Journal instance – source systems can remain in place

and continue with local transaction processing

• Real-time harmonized global financial information on a

HANA platform with atomic detail, allowing flexible

reporting using robust reporting tools

• Single Uniform Global Data Model for external (FI), internal

(CO), and Profitability/Market Segment (COPA) accounting

• No reconciliation across instances

• Central Journal is an adoption scenario that enables implementing SAP S/4HANA Finance with minimum disruption

to existing systems

• It provides real-time replication of financial information from diverse instances that are harmonized into a Central

Journal

• Can provide consolidated financial and management reporting, central process execution and transaction, planning,

consolidation, and reporting based on the same (single source of truth) data set

Consolidation Reporting

SAP ERP 6.0 SAP ERP 6.0 SAP R3 4.6 Non-

SAP

Central Journal SAP Instance with SAP

S/4HANA Finance

54

What We’ll Cover





• Wrap-up

55

Project Perspective

• IC processes are frequently an afterthought

• Seen as only an integration issue instead of a process

Integration: Communication or connection between modules (e.g., account

determination for material movements)

Process: Series of connected steps accomplishing a goal (e.g., P2P, O2C, R2R)

• IC processes frequently “break” during integration tests or after go-live

• Create a specific project work stream to deal with IC processes

• In a phased rollout, think about interim stage

• Give the team the right resources (business and functional)

56

Interim Stage Challenges

• Projects frequently think in terms of to-be processes of final design

• This works fine with big-bang-style implementations, but most Global implementations are phased by business and/or geography

• The key decision is whether or not to integrate the IC processes in the interim stage

• Unless the company works with two or more disconnected systems in terms of IC processes, there is a need to link all systems from day one:

The design for the interim stage can absorb significant resources from the project team (up to 30% to 40% of work)

To-be processes might need to be adjusted to work together with the interim design (need for compromise)

The Key Decision is whether or not to integrate the IC processes in

the interim stage

57

Interim Stage Challenges: Integrating All Companies

• In a phased rollout, a design decision to integrate companies that have not migrated to

the new environment into the IC processes has advantages and disadvantages:

• Immediate benefit to IC processes by implementing

leading practices

• Better management reports

• Faster closing

• Alleviates issues with communications

• Easier transition in future rollouts

• Early work on master data harmonization

Advantages

• Complexity of implementation

• Consumption of project resources

• Potential issues with differences in business

processes (e.g., transfer prices, material valuation)

• Need to compromise a few to-be design decisions

Disadvantages

58

Interim Stage: STO Integration

• Integration through custom development (Intercompany Data Transfer)

• Need to customize IC Data Transfer for each IC process

59

What We’ll Cover





• Wrap-up

60

Leading Practices

• Single instance with consistent global template

• Leverage dual posting (seller AR and buyer AP)

• Use the matching and reconciliation functionality for AR/AP and GR/IR

• Use ERP (SAP In-House Cash) netting functionality

• SAP ERP 6.0 since Enhancement Pack 5 – provides Goods-in-Transit visibility

• Use workflow and IDocs where possible

• Single-point consolidation (avoid sub-consolidation) and leverage a tool (HFM, BPC, etc.)

Systems

Master Data Management and Governance

• Establish a governance policy to manage strategic changes to master data

• Establish master data policies and procedures for change management

• Involve master data team in all projects that impact systems

• Assign full responsibility of master data to individuals for maintenance

61

Leading Practices (cont.)

• Establish materiality thresholds for posting of IC transactions

• Establish a detailed monthly calendar for IC tasks

• Establish a Dispute Resolution Policy with a committee that arbitrates disputes

• Establish up-front approvals

• Consider tax needs (provisioning, transfer pricing) when establishing timing of billing (monthly, quarterly, annual) for

corporate pass-downs

• Establish policy on currency for transactions between entities with different currencies for reconciliation and

settlement

• Document and communicate IC policies and procedures

Processes

People

• Centralize IC accounting (where possible) but maintain a single point of contact for IC transaction inquiries for each

company

• Document and train for specific roles and responsibilities, including handoffs

• Train and provide job aids/contact information for all personnel involved in IC transactions

• Document review/approval/escalation points for IC transactions

62

What We’ll Cover





• Wrap-up

63

Where to Find More Information

• Sanjeev Walia, “Key Design Considerations for Legal and Group Valuation in SAP’s

Material Ledger” (SAPinsider Financials 2015, Las Vegas).

• Genco Odevci, “I Implemented Closing Cockpit in SAP ERP 6.0 – Now What?”

(SAPinsider Financials 2015, Las Vegas).

• Prem Ramlal, “Manage Cash Flows and Reduce Bank Costs with an Integrated Treasury

System” (SAPinsider Financials 2014, Orlando).

• Financials Expert (http://sapexperts.wispubs.com/Financials):

Janet Salmon, “Calculate Actual Costs Across Multiple Company Codes Using a New

Business Function in SAP Enhancement Package 5 for SAP ERP 6.0” (Financials

Expert, December 2010).

http://sapexperts.wispubs.com/Financials/Articles/Calculate-Actual-Costs-Across-Multiple-Company-Codes-Using-a-New-Business-Function-in-SAP-Enhancement-Package-5-for-SAP-ERP-6-0?id=B189B381C44F4F23A95E366E81D128B5.Vri_kvkrLIU

64

7 Key Points to Take Home

• Consider IC processes as a project work stream

• Automate transactions and postings across company codes

• Use a formal process of Dispute Resolution to avoid interruptions in the IC processes

• Standardize IC processes and manage the necessary change to accomplish them

• Review policies to support the implementation of leading practices

• Do not forget about the interim stage with a phased rollout

• Be bold – you will live with the system for the next 15 years!

65

Your Turn!

How to contact me:

David Cohen

Email: [email protected]

Please remember to complete your session evaluation

66

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