When It Might Make Sense to Distribute an IRA Account

Contributed by: Sandra Adams, CFP®

As you might imagine, most financial planners (and most clients) have a preference for stretching the distribution of their IRA (or other qualified retirement) accounts over long periods of time so as to lessen the income tax burden on those accounts over many years.  And, if possible, most clients would prefer the ability to leave dollars in those accounts to their children and grandchildren as a form of legacy/inheritance. However, as life circumstances change, it sometimes makes sense to keep an open mind about how we view the distribution of those accounts. 

In our experience, we have found that it sometimes makes sense to consider accelerating the distribution of IRAs/qualified retirement accounts when the following circumstances are present:

• Owner of the IRA is an older adult (in this context, meaning beyond RMD status)

• IRA/Qualified Retirement Accounts are smaller accounts within the clients overall investment portfolio (i.e. have a $30k IRA and have other investment accounts/bank accounts to draw from)

• Are likely in a lower tax bracket than the heirs they might be leaving the assets to

• May have medical/health care costs to write off to offset the income from the potential income from IRA/qualified account distributions

While these circumstances certainly will not apply to MOST clients, they might apply to a select few. When they do, this strategy can not only save significant tax dollars but can simplify the distribution of an estate long term by avoiding the division of a small IRA amongst multiple beneficiaries.

If you or your family have questions about whether this strategy might apply to you or someone you know, please reach out to our Center Team.  We are always happy to help!

Sandra Adams, CFP® is a Partner and Financial Planner at Center for Financial Planning, Inc.® Sandy specializes in Elder Care Financial Planning and is a frequent speaker on related topics. In addition to her frequent contributions to Money Centered, she is regularly quoted in national media publications such as The Wall Street Journal, Research Magazine and Journal of Financial Planning.

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Any opinions are those of Center for Financial Planning, Inc. and not necessarily those of Raymond James. The information has been obtained from sources considered to be reliable, but Raymond James does not guarantee that the foregoing material is accurate or complete. Any information is not a complete summary of all available data necessary for making a financial decision and does not constitute a recommendation. Please note, changes in tax laws may occur at any time and could have a substantial impact upon each person's situation. Raymond James does not provide tax advice. You should consult a tax professional for any tax matters related to your individual situation.

5 Estate Planning Action Steps to Stay in Control of Your Future

Contributed by: Sandra Adams, CFP®

I recently attended a 2-day training in Elder Mediation.  Coming from a world in which we work with our clients on a regular basis to make sure estate planning documents are in place and up-to-date, I was alarmed to learn that less than 45% of the U.S. adult population has an active will or durable powers of attorney in place (2017 Caring.com Study). Unfortunately, when these documents are not in place, and the adult (at any age) becomes unable to make decisions for themselves, the court must appoint someone...and families aren’t always in agreement.

According to a 2013 AARP report, there was an estimated 1.5 million older adults with court-appointed guardians; record keeping in many constituencies is not accurate nor complete.  A guardian is appointed to make medical and care decisions for someone who is unable to make decisions for themselves; a conservator is appointed to make financial decisions and handle financial affairs for someone who is unable to handle those duties on their own behalf.  And if the family disagrees about who should be appointed to any/either of these roles, they can voluntarily seek mediation to resolve their differences or the court may order mediation.  In many cases, a family member is ultimately appointed to these roles, but in some cases a third party is appointed to serve in these roles as ordered by the court, leaving the fate of the older adult in the hands of someone who doesn’t know them or their wishes well.

Doing the work now to get documents and plans in place can save you and your family unnecessary stress and anxiety in the future, and can help to make sure that the wishes you have for yourself and your future are carried out even if you are no longer the director of those decisions. 

What action steps can you take now to make sure you maintain ultimate control over what happens to you if/when you can no longer make decisions for yourself?

To ensure that you have the ability to name who you wish to make decisions for you when it is time, I recommend taking the following steps:

1. Make sure you have up-to-date estate planning documents and review them often.  The most important documents to have in place during your lifetime are Durable Powers of Attorney — General/Financial AND Health Care (also known as a Patient Advocate Designation).  Additionally, you may want/need to have a Revocable Living Trust and a Will.

2. Consider drafting your Durable Power of Attorney documents as “Immediate” rather than “Springing”.  Immediate Powers of Attorney allow your advocate to act on your behalf immediately or at any time that you need them to, while a Springing Power of Attorney generally requires two doctors to declare you incompetent to make your own decisions before your advocate can act on your behalf.

3. Be clear and specific about your wishes for your future medical care, personal care and handling of your financial affairs.  Put things in writing and communicate your wishes to your family members and/or key people in your life.  Consider a family meeting to discuss your future wishes and ensure that everyone is on the same page.

4. Plan ahead.  It is never possible to plan for every contingency, but if you are able to plan for things that might happen (chronic health issues, incapacity, etc.), you and your finances can have a better chance of surviving.  Document your plans and communicate them to those that may be in charge of handling your affairs in the future if/when you cannot.

5. Put a team in place before it becomes necessary.  Make sure your financial planner, CPA, Attorney, any healthcare professionals and your family know your plan and your wishes and know one another so that they can carry out your plan when you might not be able to give clear directions.

If you or your family have questions or would like guidance on how to get these plans in place, please do not hesitate to reach out.  We are always here to help!

Sandra Adams, CFP® is a Partner and Financial Planner at Center for Financial Planning, Inc.® Sandy specializes in Elder Care Financial Planning and is a frequent speaker on related topics. In addition to her frequent contributions to Money Centered, she is regularly quoted in national media publications such as The Wall Street Journal, Research Magazine and Journal of Financial Planning.

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The information contained in this blog does not purport to be a complete description of the securities, markets, or developments referred to in this material. The information has been obtained from sources considered to be reliable, but we do not guarantee that the foregoing material is accurate or complete. Any opinions are those of Sandra Adams and not necessarily those of Raymond James. There is no guarantee that these statements, opinions or forecasts provided herein will prove to be correct. Raymond James and its advisors do not offer tax or legal advice. You should discuss any tax or legal matters with the appropriate professional.

WEBINAR IN REVIEW: SAFE, or Success After Financial Exploitation

Contributed by: Emily Moore

SAFE is a program created by Dr. Peter Lichtenberg, Ph.D., which is being run by LaToya Hall, MSW, of Wayne State University’s Institute of Gerontology.  SAFE was developed to educate seniors on how to protect themselves from fraud and scams, AND how to pick up the pieces after financial exploitation.

During our recent webinar with LaToya, we learned the basics about financial exploitation targeted to seniors: 

1. What to look for.

2. How to protect yourself and your loved ones.

3. What you can do if you have ever been a victim.

The main goals of SAFE:

1. Free education offered to seniors through presentations.

2. Helping seniors take control of their financial health through an educational four-part financial series.

3. Provide one-on-one services to older adults who have been a victim of scams, helping them to get back on their feet.

Key points to take away from the webinar are some common scams and what criminals specifically look for in targeting older adults. 

Criminals look for seniors because they tend to be more vulnerable. They look for people who are typically lonely and socially isolated. They’re also looking for people who have a regular income (such as receiving Social Security), and older adults who are typically more trusting and polite.

Many of the common scams are successful because they represent organizations considered to be legitimate:  Social Security, Medicare and the IRS. A lot of these are done over the phone or by e-mail. It’s important to remember never to give any information over the phone to an incoming caller or respond to an e-mail requesting your personal information.

Another phone scam is called spoofing, where a person calls the senior but looks like they are calling from another number deemed safe (caller ID might identify them as person’s doctor, bank, etc.), so always make sure to double check on a statement. The safest most effective thing to do is to hang up and call the number you have in your records.

These are only a few of the many scams and tactics LaToya goes over in the “Success after Financial Exploitation (SAFE)” Webinar. To learn more and get information along with the free SAFE services listed above, contact LaToya Hall, SAFE Program Coordinator, at L.hall@wayne.edu or 313-664-2608.

Emily Moore is a Client Service Administrator at Center for Financial Planning, Inc.®

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Raymond James is not affiliated with and does not endorse the opinions or services of SAFE, LaToya Hall, or Dr. Peter Lichtenberg.

Caregiver Work/Life Balance

Contributed by: Sandra Adams, CFP®

According to the AARP, of the over 40 million Americans acting as a caregiver for a loved one over the age of 50, 6 in 10 of them are doing so while still trying to earn a living. As we have written about previously, caregiving can take a tremendous financial toll on family members and can cause real issues with caregivers’ own retirement planning. In talking to caregiver clients, it’s not just the financial implications of being a working caregiver that become the biggest issue...it’s the overall impact on one’s life.

How can a working caregiver have a balanced life with so many roles and responsibilities? 

1. Take advantage of any paid caregiver time off or flexibility that you may have with your job. Make sure you have open and honest conversations with your employer about what is going on in your life and your caregiving duties so that they can help you make your job and caregiver duties work for you.

2. Seek out community resources and information that will help connect you with needed services - you don’t have to do it all alone! Agencies, community and faith-based are available to help you meet your loved one’s needs and allow you to continue to have a career.

3. Seek the help of professionals that you can delegate responsibilities for financial planning, investments, bill paying, taxes, care management, etc.

4. Determine your eligibility for various programs that could give you more support and receive all the benefits to which your loved one is entitled at BenefitsCheckUp.org.

5. Keep yourself organized. Coordinate and organize your time, activities and paperwork. Find a system that works for you (paper, electronic, etc.). i.e., schedule appointments all on the same day, at the end or beginning of days to make things work better with your work and family schedule.

6. Find time for yourself. As a caregiver, if you don’t have time to enjoy time for yourself and de-stress, things will only become more chaotic, stressful and out-of-balance. Find our Working Caregiver Bill of Rights here. After all, if you aren’t taken care of, you can’t take care of the one you love!

As impossible as it often seems, there is a way to have some balance in your life if you are a working caregiver.  It takes careful planning, organization, communication, and use of resources.  If you are a working caregiver and would like assistance in planning for your balanced life, give us a call.  We are always happy to help!

Sandra Adams, CFP® is a Partner and Financial Planner at Center for Financial Planning, Inc.® Sandy specializes in Elder Care Financial Planning and is a frequent speaker on related topics. In addition to her frequent contributions to Money Centered, she is regularly quoted in national media publications such as The Wall Street Journal, Research Magazine and Journal of Financial Planning.

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Opinions expressed are those of Sandra Adams and are not necessarily those of Raymond James. All opinions are as of this date and are subject to change without notice. The information has been obtained from sources considered to be reliable, but we do not guarantee that the foregoing material is accurate or complete.

New Legislation is Hoping to Help Caregivers

Contributed by: Sandra Adams, CFP®

Being a caregiver for a family member presents real-world challenges from an emotional and financial perspective.  The National Alliance for Caregiving reports that there are over 40 million Americans acting as family caregivers providing over 37 billion hours of unpaid assistance to loved ones.  As I wrote in a previous blog “Family Caregiving — The REAL Long Term Costs”, family caregiving can take a toll on caregivers’ health and future retirement goals if the right plans and tools are not utilized.

Recent legislation is attempting to help the millions of Americans serving as caregivers:

RAISE Family Caregivers Act

In early 2018 the president signed into law the Recognize, Assist, Include, Support and Engage Family Caregivers Act.  The act directs the Department of Health and Human Services to create an advisory council charged with making recommendations on the strategy to support family caregivers.  The strategy, which must be developed within 18 months, will address financial and workplace issues, respite care and other ways to support caregivers.

Employer Tax Credit for Paid Family Medical Leave

A little publicized addition in the recent Tax Cuts and Jobs Act of 2017 that took effect on January 1st, 2018, was the Employer Tax Cut Credit for Paid Family Medical Leave Time.  Under the Family & Medical Leave Act (FMLA), employers must provide certain employees with the option for up to 12 weeks of unpaid, job-protected leave per year (and must maintain group health benefits during the leave).  To incentivize employers to further support FMLA, the recent Tax Act provides employers with a business credit equal to 12.5% of wages paid to employees during leave (as long as the employee is paid at least 50% of their normal wages) and the credit phases in as much as 25% of wages if the employer provides 100% of continuing wages (up to the 12 week maximum).

Employers and the government are recognizing the deep impact of family caregiving on the financial futures of caregivers and are beginning to offer some support.  How significant the results of these recent legislative changes will be remains to be seen.  We will continue to keep you updated.  In the meantime, if you are a caregiver and need additional resources, information, or need assistance in designing strategies for yourself or for your loved one, please give us a call.  We are always happy to help!

The information provided does not purport to be a complete description of the developments referred to in this material, it has been obtained from sources deemed to be reliable but its accuracy and completeness cannot be guaranteed. Neither Raymond James Financial Services nor any Raymond James Financial Advisor renders advice on tax issues, these matters should be discussed with the appropriate professional.

Sandra Adams, CFP® is a Partner and Financial Planner at Center for Financial Planning, Inc.® Sandy specializes in Elder Care Financial Planning and is a frequent speaker on related topics. In addition to her frequent contributions to Money Centered, she is regularly quoted in national media publications such as The Wall Street Journal, Research Magazine and Journal of Financial Planning.

Webinar in Review: Carepartners Passage Through Dementia

Contributed by: Sandra Adams, CFP®

More and more of our clients and families are being impacted by dementia.  What is it and how does it impact those diagnosed and those who are caring for them?

Dementia is a general term for a decline in mental ability severe enough to interfere with daily life. While it is believed there are over 50 different types of dementia, Alzheimer’s disease is the most prevalent type, with more than 5 million people currently living with this specific type.  1 in 9 seniors has Alzheimer’s disease, but half don’t know it.  There are currently medications available to slow the progression of dementia, but there is no cure.

Most individuals with dementia are being cared for by family caregivers.  Having knowledge about the signs and progression of different types of dementia can be extremely helpful to both the person with the disease and the caregiver.  Planning ahead to make sure that the appropriate legal and care plans are in place in advance can relieve a tremendous amount of stress from everyone involved.

Realizing that the person with dementia is still the same person, just with a disease, is essential.

Dr. Paula Duren shared with us the 5 Foundational Care Concepts for Caregivers of individuals with dementia:

1. Everyone has basic human needs

2. You are the one with the healthy brain

3. Be a good detective

4. They may not remember your words but they will remember your spirit/energy

5. Know that every behavior is an effort to communicate

Dr. Duren of Universal Dementia Caregivers also teaches care strategies for caregivers about how to work effectively with those they are caring for.  She also works with caregivers to care for themselves.  After all, if caregivers are not healthy and strong, they cannot care for their loved ones with dementia fully. 

Listen to the replay of our webinar “Carepartners Passage Through Dementia” for additional tips and information AND watch for information about our May workshop for caregivers being facilitated by Dr. Duren.

Sandra Adams, CFP® is a Partner and Financial Planner at Center for Financial Planning, Inc.® Sandy specializes in Elder Care Financial Planning and is a frequent speaker on related topics. In addition to her frequent contributions to Money Centered, she is regularly quoted in national media publications such as The Wall Street Journal, Research Magazine and Journal of Financial Planning.

This information has been obtained from sources deemed to be reliable but its accuracy and completeness cannot be guaranteed. Raymond James is not affiliated with Dr. Paula Duren.

How Do You Want to Be Remembered?

Contributed by: Sandra Adams, CFP®

On a recent flight, I took the opportunity to browse the movie selection and found a film I had never heard before, but that peaked my interest.  “The Last Word” with Shirley MacLaine, while not the greatest movie from the view of a film critic, was on point with some lessons about how we live our lives and how we want to be remembered once we are gone.  Having been touched with a handful of recent deaths in my personal and professional life, this touched a nerve with me.

The movie “The Last Word” tells the story of a woman facing the end of her life.  As someone who has always felt the need for control and brutal honesty, she finds herself wanting to craft her own obituary.  Realizing that the keys to any great obituary are: the person is deeply loved by their families (she is divorced with a non-existent relationship with her only daughter), the person is respected by co-workers (she realizes she alienated many of the people she worked with by the way she treated them in her working life), and the person has somehow touched an unexpected person in a profound way (something she has never done).  With her time running out, she sets out to find a way to “fix” what has gone wrong in the past and make her life worthy of a great obituary.  On her journey to improve her life in the memory of others, she reminds us to make a difference in people’s lives, to make every day count, and to take risks.  After all, she says, “When you fail, you learn.  When you fail, you live.”

Many of us are so busy doing the day-to-day things that we need to do that we never really consider what we are doing with our lives or what impact we want to have on others during the course of our lives.  Working with clients on their path to, through and after retirement, we have conversations about making sure that financial goals are tied to things that make their life most fulfilling and meaningful — it’s not just about the money.  As my partner Matt Chope, CFP© likes to say, “We try to help clients make the most out of the one life they have to live.” 

When you look back on your life, what do you want to be remembered for?  What impact do you want to have on the world?  On others?  Are you being intentional about living that life?  If not, start now.  And work with your financial planner to make sure those life goals are incorporated into your overall plan.

Sandra Adams, CFP® is a Partner and Financial Planner at Center for Financial Planning, Inc.® Sandy specializes in Elder Care Financial Planning and is a frequent speaker on related topics. In addition to her frequent contributions to Money Centered, she is regularly quoted in national media publications such as The Wall Street Journal, Research Magazine and Journal of Financial Planning.

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Any opinions are those of Sandra Adams and not necessarily those of Raymond James.

Why it’s Time to Start Asking More Questions

Contributed by: Sandra Adams, CFP®

I recently took a week-long family trip with my husband and son (a senior in high school).  This was a rare occasion for the three of us to spend some time together and communicate — away from the TVs, devices and to actually get my son out of his room and away from his Xbox. Getting information out of teenagers — especially boys — about what is going on in their lives is like “getting blood out of a turnip” as they say. 

As with many of our family members, friends and co-workers that we may have difficulty communicating with, rather than become frustrated that we are not getting the information we are looking for, or find that we are “stuck” trying to help or plan for someone that is not helping in the process, we took a different path on our trip.  We decided that I would try to open the door by asking some open ended questions...and then try being quiet.  We just listened and gave space.  It took several days into our trip for our son to start opening up, but once he started, the results were amazing — he talked to us about things that he had never spoken about, asked our advice about some things that were going on at school, and began taking part in “adult” conversations right before our eyes.

Such conversations can and need to take place in many circumstances in our lives.  Whether it be our aging parents that we are beginning to assist, and we aren’t sure of their future desires for their own aging futures; our children as they transition into adulthood; or conversations with ourselves as we determine our next steps in life (transitioning into retirement, transitioning into a new career, figuring out what life looks like after divorce or the death of a spouse).  All of these conversations start with asking the right questions...and then listening...to others or ourselves.  Spending time on this process is important and does not happen overnight, but the results can be life changing.

Start the New Year by committing to start asking questions of those people you want to communicate more clearly with, or about those situations you want to move forward on.  If you are not sure what questions you need to be asking or how to start this process, please feel free to reach out for our help!

Sandra Adams, CFP® is a Partner and Financial Planner at Center for Financial Planning, Inc.® Sandy specializes in Elder Care Financial Planning and is a frequent speaker on related topics. In addition to her frequent contributions to Money Centered, she is regularly quoted in national media publications such as The Wall Street Journal, Research Magazine and Journal of Financial Planning.

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Any opinions are those of Sandra Adams, CFP®, and not necessarily those of Raymond James.

Helping Older Relatives? How to Help Without Jeopardizing Your Own Finances

Contributed by: Matthew E. Chope, CFP®

Helping elderly family members with financial issues can be tricky.  In many cases, you may feel an obligation to assist, especially if the older adult is on a fixed budget and has limited financial resources. In fact, a recent MetLife study found that 68% of American caregivers have been found to spend their own money to support the needs of their older adult relatives, which drained funds that they had planned to use for their own financial independence. If you sense that an elder you care about is on a trajectory for financial ruin, what can you do to help? 

How do you step in and assist without putting your own financial security in jeopardy? 

The first thing to do is to gather some information to get a better sense of your loved one’s financial picture.  You’ll want to have an understanding of their assets and debts, and their budget:  their sources of income and their expenses. With the understanding of what income and what bills and expenses the older adult is dealing with, you can better connect with resources that may be able to assist them.

A client (let us call him John) told me a story recently about how he helped his older sister in-law (let us call her Bonnie) make some difficult decisions.  Bonnie was not a high-income earner in her working years. Although she was able to purchase her home and pay off her mortgage; she didn’t save much, and she had now depleted her savings.  At age 75, the reverse mortgage that Bonnie had put in place, in addition to her minimal Social Security income were not enough to keep up with her rising costs for health care (Medicare premiums and prescription drug co-pays), property taxes, insurances and utilities.

Here are the actions John took to help Bonnie with her situation:

1. John discovered that the county would allow her to apply for a reduced or total removal of real estate taxes through the property tax poverty exemption. As a result, Bonnie received a full exemption from her property taxes. Each county has a program for low-income folks - you need to complete an application and appear before a board of review annually. Here is a link with more information: https://www.michigan.gov/documents/treasury/Bulletin7of2010_322157_7.pdf

2. John contacted low-income home energy assistance (LIHEAP) and received a reduction in electricity and heating costs for Bonnie. https://www.benefits.gov/benefits/benefit-details/1545

3. John contacted Human ARC Premium Assist about receiving a significant reduction in Medicare Part B premiums; as an added bonus, they also provided assistance with Bonnie’s prescription drug costs. https://screening.humanarc.com/PremiumAssist

4. While online at the premium assistance site, John found more information about special coverages for things like medical alert, ambulance/transportation assistance, and a 1.25% copay for prescriptions.

5. John contacted Social Services about food stamps and Bonnie is now receiving about $97 more a month through a program called SNAP. http://www.feedingamerica.org/need-help-find-food/

6. For Bonnie’s auto insurance, John pays the whole year upfront and Bonnie pays John back monthly so she can take advantage of the discount for paying the premium annually.

7. John pays Bonnie’s utility bills via automatic payments from his account to avoid late fees, which in the past were a wasteful and unnecessary expense. Bonnie also reimburses John monthly for this.

8. To save money on her cell phone bill, John added Bonnie’s phone line to his plan as an additional line.

9. Bonnie was willing to give up cable TV – John found that an inexpensive antenna works fine and they were able to rid Bonnie of her monthly cable bill.

With a little bit of creativity and resourcefulness, John was able to assist Bonnie while also preserving his own financial resources.  If you or someone you know is in the position of assisting an older adult and needs help putting together a strategy, please let us know.  We are here to help!

Matthew E. Chope, CFP ® is a Partner and Financial Planner at Center for Financial Planning, Inc.® Matt has been quoted in various investment professional newspapers and magazines. He is active in the community and his profession and helps local corporations and nonprofits in the areas of strategic planning and money and business management decisions.

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This information has been obtained from sources deemed to be reliable but its accuracy and completeness cannot be guaranteed. The case study provided is hypothetical and has been included for illustrative purposes only. Individuals cases will vary. Links are being provided for informational purposes only. Raymond James is not affiliated with and does not endorse, authorize or sponsor any of the listed websites or their respective sponsors. Raymond James is not responsible for the content of any website or the collection or use of information regarding any website's users and/or members. Neither Raymond James Financial Services nor any Raymond James Financial Advisor renders advice on tax, legal, or mortgage issues, these matters should be discussed with the appropriate professional. 

Sandy’s Spring Teaching at Schoolcraft College

Contributed by: Sandra Adams, CFP®

I am excited to let you know that for a second semester am going to be teaching courses for Schoolcraft College as part of the Continuing Education and Professional Development Program.  As always, the opportunity to share my knowledge and passion in the areas of financial planning and gerontology is exciting for me. 

The classes I will be teaching again, in April are:

Serving as a Financial Fiduciary: 
April 2nd, 2018, from 6-9pm

Being responsible for someone else’s finances can be a huge weight to carry. Learn what it means to serve in the role of a financial fiduciary — persons required to always act in the best financial interest of those they are serving.  Learn where to find guidance and resources, avoid scams, and how to establish sound, long-term planning.

Long Life Planning:
Mondays for three weeks starting April 9th, 2018, from 6-8pm

Go beyond traditional retirement planning and tackle topics such as long-term care planning, difficult conversations with family, aging, and end-of-life planning.  Discuss resources, downsizing, housing and care options, legal and financial guidance and more.  Plan now for your later long life.

If you or someone you know might be interested in attending one of these or other courses offered by the Schoolcraft Continuing Education and Professional Development program, find more information here:  www.schoolcraft.edu/cepd

Sandra Adams, CFP® is a Partner and Financial Planner at Center for Financial Planning, Inc.® Sandy specializes in Elder Care Financial Planning and is a frequent speaker on related topics. In addition to her frequent contributions to Money Centered, she is regularly quoted in national media publications such as The Wall Street Journal, Research Magazine and Journal of Financial Planning.

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Raymond James is not affiliated with Schoolcraft College. Links are being provided for information purposes only. Raymond James is not affiliated with and does not endorse, authorize or sponsor any of the listed websites or their respective sponsors. Raymond James is not responsible for the content of any website or the collection or use of information regarding any website's users and/or members.