The main question in Liu is whether disgorgement is permissible in judicial—as opposed to administrative—enforcement actions under Section 21 of the Securities and Exchange Act of 1934, 15 U.S.C. § 78u.  Section 21(d)(5) of the Act provides that, in an action brought by the SEC under the securities laws, “the Commission may seek, and any Federal court may grant, any equitable relief that may be appropriate or necessary for the benefit of investors.”  This statutory provision does not explicitly authorize disgorgement. In contrast, as the petitioners in Liu note, other statutory provisions do expressly enable the SEC to obtain disgorgement in the context of administrative proceedings.

At the heart of the debate in Liu is whether disgorgement is a penalty rather than a proper equitable remedy that may be awarded under Section 21.  

Brent A Levison agrees with the petitioners contention that the purpose of disgorgement is primarily punitive, noting that money disgorged is not necessarily returned to individual consumers, but rather may be paid to the Treasury. The SEC countered that disgorgement awards can be necessary as a deterrent, rather than as a punishment, in cases where compensatory damages may be insufficient to deter future wrongdoing.  

Arguendo, Petitioners are also making compelling arguments that to the extent any disgorgement awards are permitted, such awards should be limited to the defendants’ net gain or profit and allowed to deduct legitimate business expenses from the net gain or profit calculation.  

The Supreme Court’s pending decision in Liu should significantly revisit and reduce the power of disgorgement in the SEC realm—either by prohibiting the SEC from seeking and obtaining disgorgement or by changing and/or implementing limitations upon disgorgement amounts that may be awarded.  The FYC is watching the Liu decision as it should have significant implications as the FTC is currently dealing with a circuit split regarding whether it can obtain equitable monetary relief under Section 13(b) of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. § 13(b)—a provision which, on its face, only authorizes injunctive relief.  Compare FTC v. Credit Bureau Ctr., LLC, 937 F.3d 764, 767 (7th Cir. 2019) (holding that “section 13(b) does not authorize restitutionary relief”) with FTC v. AMG Capital Management, LLC, et al., 910 F.3d 417, 426–27 (9th Cir. 2018), petition for cert. docketed, AMG Capital Management, LLC, et al. v. FTC (U.S. Oct. 21, 2019) (No. 19-508) (holding that FTC can obtain equitable monetary relief pursuant to section 13(b)).  

A favorable ruling in Liu according to Brent A. Levison should strongly support and bolster the argument that courts should follow the Seventh Circuit in Credit Bureau and change the landscape and eliminate FTC’s implied right to obtain equitable monetary relief under section 13(b) of the FTC Act.

The post CORRECTING THE FTC’S AUTHORITY TO COLLECT MONETARY RELIEF UNDER SECTION 13(B) first appeared on Brent Levison.

How Brent Levison Views Terms and Conditions

Merely having website Terms and Conditions does not necessarily create enforceable agreements with site visitors. Terms and Conditions that require users to affirmatively agree and to take proactive steps, such as checking a box and clicking “I Agree” and/or “submit,” also known as “click-wrap” agreements, are far more likely to be upheld in courts of law. To ensure enforceability, just as On Point Global websites prominently displayed links to their Terms and Conditions and prompt all of its visitors to take affirmative action and agree and accept the Website Terms and Conditions.

This material contained herein is provided by Brent Levison and if for informational purposes only and is not legal advice, nor is it a substitute for obtaining legal advice from an experienced attorney. Each website is unique, and not act or rely on any information contained herein without seeking the advice of a lawyer.

The post Terms and Conditions – On Point Global Websites first appeared on Brent Levison.

To give you a quick snapshot, our culture is built on a set of core behaviors that we always aspire to model. These include moving with urgency to get our priorities complete and collaborating across departments to make well-rounded decisions.

One of my favorite core behaviors is that we always keep our pencils sharpened.

This means that we never simply accept success. If we launch an ecommerce website at 10 a.m. and it gives us a 20% conversion rate, we don’t just sit back and relax in our office chairs and call it a day. That same afternoon, our company’s leaders are meeting to discuss steps we can take to double that conversion rate in the next iteration.

The way we do that is through testing. However, as data, marketing and publishing companies across the country are well familiar with – you need to make sure you’re compliant every step of the way. Here’s how.

The On Point Global Testing Process

The first step we take is to gather data on how a website is performing. The specific data we’ll focus on depends on the specific type of website we launch.

After gathering data for one to two weeks and giving everyone a chance to review, we set up a meeting with the On Point Global Miami leadership team. We’ll use this meeting to discuss the different departments’ ideas for optimization.

Some ideas will relate to adjusting copy. Others will be associated with layout and user experience. All ideas are considered and prioritized. The first test idea that we select will be based on what our team believes will have the biggest impact – based on their experience.

After all, our managers have been implementing tests on our web properties for years now. They have a good understanding of what changes will have positive impacts and what factors may be affecting our rankings or conversion rates.

Next, after selecting a test idea, we implement the change and immediately begin gathering data on how users are interacting with the new iteration of the website.

Oftentimes, we can quickly determine if the test had the desired result. If we see a noticeable decrease in some or all key metrics within a day or two, we may move on to test #2. Otherwise, if the numbers are trending in the right direction, we could let the test run for a week to 10 days.

Then, finally, each successful test’s results are logged so that we can consider them for future sites.

But that’s just half of the process.

In addition to considering possible changes, implementing them step by step and following the metrics for a certain period of days, we also have established checks to ensure that we are being compliant with FTC legislation.

How Brent Levison Combines Compliance Culture With Testing

As I’ve discussed in another post, creating and maintaining a compliance culture is key to your success in 2020 and going forward. The Federal Trade Commission’s (FTC) role is to protect consumers in all aspects of trade. This includes online consumers.

Throughout the testing process, the team members of On Point Global Miami do not lose sight of FTC requirements. We train our project managers and department leaders – as well as all other employees within the company – on the importance of compliance and the steps that we all must take in order to meet federal requirements.

From the brainstorming process to laying out each test idea and the steps we’d need to take, our team is checking to make sure (at each stage of the process) that each proposed change would be considered compliant.

If there is any doubt, we consult our compliance counsel. Then, based on their thoughts, we either move forward with testing the concept or we scrap that idea to focus on other tests.

To ensure that On Point Global websites are compliant, we have a team dedicated to quality assurance (QA), which is also trained on compliance. This team is instrumental during the testing process. Working in tandem with project managers and our other company leaders, our quality assurance team checks to make sure that each step our team is taking during the testing process will not have any issues related to
compliance, among other things.

Final Thoughts on Compliance & Testing

Optimizing your websites through testing is the only way to make sure that your users are having a positive user experience. Checking on compliance requirements each step of the way is the only way to make sure that you’re providing products and services to consumers in a way that is considered legally compliant by the FTC.

Today and going forward, there is no way to separate the two and be successful. All businesses need to prioritize both of these elements at all times. However, if you do have to choose between the two, you must always choose compliance.

The post Pencils Always Sharpened: How On Point Global Balances Testing With Compliance first appeared on Brent Levison.

The Telephone Consumer Protection Act (TCPA) is one of the most important laws that you need to know in and out in order to effectively – and legally – market to your audience.

Hello, I’m Brent Levison of On Point Global. Today I’m going to be talking about the TCPA and how our team complies with the regulation at scale.

What is the Telephone Consumer Protection Act (TCPA)?

We’ve all gotten calls from telemarketers before. And while the script may vary from time to time, what often doesn’t change is customer interest:

Customers who are interested in hearing about offers will listen, and those who are not interested will not listen.

Unfortunately, a lot of marketing companies in the past were not so keen to take cues from consumers, and they continued to make unsolicited calls. Years later, in 1991, the Federal Communications Commission established the TCPA as a way to protect consumers from these unwanted communications.

The TCPA restricts the ability of telemarketing companies to make calls or robocalls and send messages that are not specifically consented to by consumers.

If you want to send any such messages to your audience, you need to follow the guidelines established by this act.

Throughout the last 30 years, this act has undergone a number of major changes. Some of the most notable updates include the following:

• In 2003, the FCC worked together with the Federal Trade Commission (FTC) to create a Do-Not-Call Registry. This registry was and still is national in scope, applying to calls that are made between states and within states. The FTC is still responsible for the management of this list.
• In 2012, the Federal Communications Commission implemented additional rules for telemarketers to follow, including the need to get “prior express written consent” from consumers before autodialing them, regardless of whether they had already communicated with those customers in the past. The 2012 update also mandated that telemarketing companies give users the chance to essentially remove themselves from the marketing list during every call they receive. This was an effective way for people to start controlling who could and could not call them about offers.

TCPA Compliance Tips From Brent Levison of On Point Global

The TCPA is a strong regulation, and as marketing means and approaches continue to evolve so too will federal protections provided by the FTC and FCC.

As marketers, the TCPA holds us to a high standard. We can’t be harassing to consumers. In fact, we never want to be.

At On Point Global Miami, we want to be guests, not pests.

That’s how you get into the proverbial door and match your audience with the products and services that they want and need.

Also, just like with every other business practice, the best way to optimize is to listen to your customers. So if someone says they don’t want calls, acknowledge their request and comply. It’s the law.

Keep in mind, customers don’t need to write out their consent revocation. The FTC and FCC will accept a spoken request, and you will need to abide by it to be legally compliant.

Another important tip is to follow the federal government’s example. Not only should you have your own do-not-call list (which is a requirement of the TCPA), you should also maintain it and verify that the information you have is accurate. After all, TCPA laws are still in place even if you end up dialing or autodialing a wrong number. You want to make sure that you are always only marketing to consumers who have provided their consent.

Finally, possibly the most important piece of advice is to know when you need legal help. Just as the TCPA has evolved over the last 30 years, it will continue to change and have new provisions added. An effective way to stay informed about these updates and how your business will need to adjust with each change is to seek counsel regularly.

As I’ve mentioned in previous posts, it’s important to have another set of eyes (or more) looking at the same details that you are from a different perspective. It can mean all the difference in an industry where you need to be compliant in order to succeed.

TCPA Litigation Today

In the years since the establishment of the TCPA, there has been no shortage of related lawsuits. As I mentioned before, while many telemarketing companies are taking the necessary steps to be compliant in their business practices, others are not.

Some common examples of TCPA cases include companies marketing to consumers immediately after they receive a phone number but without getting prior express written consent, as well as marketers who continue to robocall consumers even after they have requested to be removed from their calling list.

It’s because of these occurrences that TCPA laws continue to receive updates and additional specificity so that consumers can receive upgraded protections just as marketing models continue to evolve each year.

Today, cases related to the Telephone Consumer Protection Act have some of the highest numbers of filings in the federal court system.

Simply put, those businesses that are trying to get around TCPA compliance requirements are facing penalties. And when it comes to statutory damages, these have been set by federal law as follows:

• $500 for each penalty
• Up to $1,500 for each willing violation

The main difference here is that telemarketers who willingly and relentlessly robocall consumers – to the tune of countless times per day or week – will receive more severe penalties.

The post How On Point Global Complies With the TCPA first appeared on Brent Levison.

However, this new currency doesn’t come without challenges for the party whose job it is to regulate it.

Hello again. I’m On Point Global Chief Administrative Officer Brent Levison and the FTC and its challenge to manage data security and storage is the topic I’m going to discuss with you today.

The Role of the Federal Trade Commission (FTC) in Data

In many instances, data is something that people want to provide access to. They want to see products and services that are relevant to them and that will help them in their daily lives. At the same time, companies want to match people with these offers.

But then there’s the challenge: How do you ensure that all transactions that involve data are done in a safe way?

After all, we’re talking about personal identifying information like a customer’s name, their credit card number and even their Social Security Number in some instances. This is information that needs to be protected in every circumstance.

That’s where the FTC comes in.

Their main job is to protect the interest of the consumer across all data businesses. They can establish new processes in order to ensure that consumers are safe from fraudulent business and that their information remains secure.

Recent data breaches from companies big and small have made the Federal Trade Commission’s role clear as it relates to keeping consumers safe.

Recent Data Breaches – How the FTC Responds

In the last two decades, there have been thousands of data breaches, which have released countless pieces of vital consumer data. A number of these breaches involved large companies, such as Target and Capital One.

Hundreds of millions of consumers were affected in many of these individual incidents, with some or all of the following information being leaked:

• Names
• Social Security Numbers
• Birth dates
• Residential addresses
• Bank numbers
• Email addresses
• Passwords

Following the leaks, the FTC worked to ensure that these companies would not experience data breaches again. The Commission does this by ensuring that the companies take necessary steps to prevent leaks in the future by way of upgrading their data security and storage practices.

The European Union currently has a very strong set of protection rules on data, courtesy of 2018’s General Data Protection Regulation (GDPR). However, the United States doesn’t yet have a similar overarching law when it comes to data protection.

Despite that, we are getting closer to the EU’s higher level of data regulations. The first sign of this is the California Consumer Privacy Act that has been signed into law.

The California Consumer Privacy Act (CCPA)

California is now giving residents the legal right to look into the information that companies have legally gathered on them. While this act is only effective in this one state as of writing (Brent Levison on 2/4/2020), it is very likely a sign of laws to come and a small step toward larger online data regulation.

As such, we were quick to update all our websites with CCPA requirements so that we here at On Point Global are FTC compliant.

Currently, the CCPA has the following provisions for residents of California:

1. They can request information about the data that has been compiled on them from businesses with $25 million+ in revenue each year and companies that collect data on 50K+ people per year.
2. They can find out about the different types of information that companies have gathered from them, such as the locations of their phones, websites they visit, audio clips they’ve recorded and even face recognition points.
3. They can also get information about any predictions the businesses have made related to their buying habits, interests and more.
4. Consumers can find out who their information has been bought from or traded to. They can also select to be kept off of all data sale transactions with marketing partners and other businesses.
5. Users can make requests to these businesses to have all the information that has been gathered about them deleted.

Whereas the FTC has placed a high level of priority on data security and the way that it is stored, the Federal Trade Commission is also working to ensure that consumers data is only existing in places where customers want it to.

Customers are now more informed than ever on data practices and how their information is stored and shared. They also have the deserved right to play their own part in the regulation of their personal data. It’s just a matter of ensuring that all new consumers enter the market with the same level of understanding.

In addition to keeping customers safe, the FTC also helps to keep them informed by providing information online on subjects like how to handle a data breach, customer rights during these instances and more.

How Brent Levison of On Point Global Strives for FTC Compliance

Here at On Point Global Miami, we are always striving to be compliant with the FTC and the latest regulations. Looking to establish the same standards within your organization? The key is to look outside of your company walls.

New laws are being established with a newfound regularity since the creation of data business models. To ensure that you are keeping up with the trends and understanding their requirements correctly, you need to constantly seek expert advice.

Invest in compliance help now to avoid unnecessary risks.

Seek counsel and ask about the latest updates. Ask what your company could be doing more of, as it relates to compliance and these new regulations. After all, it is very possible that the CCPA in California is only the beginning of state-specific (or even federal) laws that relate to the security and storage of data.

The specific legal changes that will occur in 2020 and beyond are still to be written, but you can be sure of two things.

1. The FTC will become even more involved in the data business to ensure the safety of consumers.
2. The companies that place a high level of importance on instilling a compliance culture will be the ones that succeed.

The post The Legal Challenges Data Presents to the FTC first appeared on Brent Levison.

]]> https://brentlevison.com/how-on-point-global-manages-compliance-at-scale/ Mon, 10 Feb 2020 18:29:24 +0000 https://brentlevison.com/?p=641 One thing I’m asked about often is how we manage compliance. As a company that has grown exponentially in the last 5+ years, compliance is an element that is always at the forefront of what we do. Here’s why. The Importance of Compliance for Your Business Being compliant is making sure that you are meeting […]

The post How On Point Global Manages Compliance at Scale first appeared on Brent Levison.

]]> One thing I’m asked about often is how we manage compliance.

As a company that has grown exponentially in the last 5+ years, compliance is an element that is always at the forefront of what we do.

Here’s why.

The Importance of Compliance for Your Business

Being compliant is making sure that you are meeting the requirements established by the government. This is something most know, but fewer understand the various steps involved in the process and the importance of investing in it.

Reviewing these requirements and being aware of any changes to them are both crucial steps to take before beginning any business venture.

Not confirming your compliance creates risk that could result in serious consequences.

The consequence can come in the shape of a fine, but it can come in the form of a tarnished business reputation. Of course, you don’t want either of these associated with your company.

Brent Levison Establishes a Compliance Culture in On Point Global Miami

One thing that I always tell fellow business owners is that you need to know your strengths – and you need to know where you need help.

With a fair amount of knowledge in the area of compliance, I understand its importance. But I know that On Point Global requires more insight than mine alone. After all, you can never be too compliant.

That’s why I like to surround myself with teams of individuals who know everything there is to know about compliance in data and other aspects of On Point’s business model.

This means that I’m always speaking with counsel and getting their opinions on every aspect of our websites. Additionally, I’m asking about recent law changes and requesting that I be updated whenever there is a new change.

Oftentimes, a new law is introduced that requires us to make some changes. So it’s crucial that we learn about it as soon as possible so that we can make the necessary adjustments.

I may not be the one who handles every element of it, but as my colleagues will tell you, “Brent Levison is always checking on compliance.” But more than just making sure that everyone I work with grasps the importance of adhering to government requirements, I’ve also made sure the appropriate training is provided so that employees know what to look out for.

Compliance Training at On Point Global

After bringing the concept of compliance to the forefront at On Point Global Miami, the next step was to sit down with our team to discuss it. There were two main points that myself and our legal advisors covered:

• What compliance is and why it matters
• How we can maintain a compliance culture on a daily basis

By discussing these two main areas, we could take this idea that often starts out as a confusing concept and turn it into a practice that we can engage in every single day.

When discussing why compliance matters, the literature that you get from advisors or that you can find online is clear. If you’re meeting government requirements, your business can flourish risk-free. If you’re not, then you’re likely to face consequences.

The area that required a bit more explanation was how we were establishing (and going to maintain) a culture of compliance through daily practice. On my end, this was simple. It meant staying up to date on changes to relevant laws and seeking out advice on how we could modify our owned domains to meet all compliance laws.

For the rest of the team, adopting a compliance culture meant changing the way that they approached each project, albeit slightly.

It meant that project managers, content writers, designers and developers needed to ask these questions before each major decision:

1. How would I perceive this website if I weren’t an employee of On Point Global?
2. How would I interpret the content, design and overall user experience?
3. How clear is our messaging?
4. Does our website fully inform the user of their protections?
5. How can we improve upon existing templates based on a new law?

But asking these questions and ensuring we could provide the right answers to them was only part of the equation. After all, one thing that we’ve all learned at On Point Global is that compliance is not a matter that is black and white. There is a significant amount of gray area.

That’s where the legal help comes in.

If ever any of our team members feels like there is confusing gray area in the language of a new law as it relates to our operations, I make sure to seek counsel.

Confusion or any kind of doubt is the first cue that you need professional advice – and it’s crucial that you be attuned to these cues whenever they present themselves. You can’t operate from a place of assumptions, because that leaves you open to the worst kind of surprises.

Given various types of new legislation like the CCPA, I’ve been seeking counsel often to make sure that On Point Global websites are compliant and that users know everything they need to about our business.

Furthermore, as we get advice from other legal professionals, I make sure to establish company-wide standards that everyone must adhere to for meeting compliance.

2 Key Standards of On Point Global Compliance

One such standard is continuous self-assessment. Not only myself but all of our managers and team leads who are in a position to make business-impacting decisions must continually assess whether or not our website(s) are being compliant based on current and new legislation.

Another key standard is injecting our compliance culture into the quality assurance process for all site launches. By that I mean making compliance checks an established step that each team member on our QA team needs to complete as they review sites for user experience and more.

By establishing internal standards for government compliance and making sure that these standards pervade all of our business activities, we can eliminate risk and ensure that our company is following best legal practices in the short run as well as the long run.

The post How On Point Global Manages Compliance at Scale first appeared on Brent Levison.

]]> https://brentlevison.com/how-on-point-global-came-to-be/ Mon, 10 Feb 2020 18:11:56 +0000 https://brentlevison.com/?p=638 Today I wanted to talk a little about beginnings and to tell you the story of On Point Global. This isn’t uncommon with most companies. They establish a vision, and their story is basically how they got from Point A to Point B. Cliché as it may be, On Point Global isn’t most companies. This […]

The post How On Point Global Came to Be first appeared on Brent Levison.

]]> Today I wanted to talk a little about beginnings and to tell you the story of On Point Global. This isn’t uncommon with most companies. They establish a vision, and their story is basically how they got from Point A to Point B.

Cliché as it may be, On Point Global isn’t most companies.

This is a company whose story we all created along the way. I do mean “all” of us, from the executive
team to content, design, tech, HR and more. In fact, it’s a story we’re still creating even today.

As many of my colleagues would say: We proved the model before we even put our name on the door.

Here at the On Point Global office in Miami, we are and always have been focused on the work, on the data and on winning every day of the week. We prioritize innovation, collaboration and moving with urgency so that we can accomplish our motto:

“We assist, enable and empower people to accomplish tasks and achieve goals.”

This is how we got there.

On Point Global Miami as a Lead Generation Company

Like many others in 2014, we were focused on lead generation. The difference between us and our competitors? We were 100% focused on one thing – learning about customers.

The goal was to get better every day, and there were no shortcuts.

After a couple of years, we realized that we could do more for consumers.

That’s when we decided to shift our focus to publishing.

Brent Levison Increases Involvement & On Point Becomes a Publisher

Now it’s 2016 and online publishing is booming. We decide that this is where our focus should be and put in 110% effort to make our mark and positively impact the lives of users around the country.

I encourage our team to experiment with new types of articles. We add newsletters to our sites. We look at our competitors to see how they’re succeeding and determine areas where we can improve upon existing models.

Creating rich and valuable content becomes our #1 priority, and the whole company embraces it. Everything we do is to provide a better experience for our end user.

Here’s how we did it.

First, we reviewed the data:

• How were customers interacting with our sites?
• What pages were they reading and not reading?
• What were they interested in?
• What were they not interested in?

Second, we kept up with all the key trends in the publishing space, from those in search engine marketing to best practices for optimization and more.

After two more years, we had developed such a strong understanding of our audience that we realized we needed to change our focus again.

Once more, we discovered there was a way we could have a bigger, more helpful impact on our readers.

In fact, there were two ways.

On Point Global Adds Services

For years, we had been offering rich content across various verticals. We still do, in fact. On Point Global provides content on:

• Automotive.
• Financial services.
• Home & communities.
• Marketplaces.
• Recreation & travel.

And that’s just a few examples.

In any case, even though we were already assisting millions of people to accomplish tasks with the time-saving information and tips on our sites, we weren’t satisfied with stopping there.

We wanted to provide services for our audience. We wanted to provide the means by which they could accomplish their goals online.

So we did.

Rather than refocus our priorities, we continued to create rich content and added fulfillment services to our product offering. Soon enough, our sites were reaching far and wide to help users with both detailed information and DIFM (do it for me) concierge services in various areas.

On Point Global as a Data Company

Remember all those learnings I mentioned before? At this point, we didn’t just know which automotive topics our auto audience was interested in. With 21 million first party data records, we knew what financial services our audience wanted to know about. We knew which travel destinations they were considering and more.

With that information, we began to connect them with the products and services they needed at the exact time they needed them.

By 2018, our understanding of our audience surpassed any expectation we could’ve had when we started the company back in 2014. Simply put, On Point Global went from being a lead generation company to a business that helps its ever-growing audience at every stage of the funnel.

That ever-growing audience consists of 11 million unique visitors every month across our 2,000+ domains on various popular verticals.

But we’re not done yet.

Now the challenge is to see how we can continue to help people – through Data SaaS. It’s not enough that we’ve been able to help millions of consumers every day to accomplish their tasks and achieve their goals… because there are tasks and goals that our sites don’t cover yet.

That’s why we’re working to establish partnerships with third-party companies so that they can learn more about their audiences and be able to help them with valuable content just like we do.

Brent Levison Fosters a Culture of Development

In 4+ years, our company has come so far and changed so much. On Point is now a Data company that provides eCommerce services, and it operates in 4 offices across 3 countries.

A lot of the original team jokes that we connected the dots backwards, achieving success and then building a brand around those wins.

But I like to think that it was all part of a plan. We just didn’t know it yet.

In any case, one thing that has never been in question is the importance of developing our team members.

Like I mentioned before, On Point Global is a company that all of us worked to build. It wasn’t just Brent Levison and the executive team. It wasn’t just content or just design or just tech. It was the coming together of all these specialties to put everything we had toward one goal.

And just as everyone at On Point has given everything they have to build this company into what it is today, I’ve always prioritized giving back everything I can.

From providing leadership training to our managers and implementing company-wide feedback meetings in every department to establishing company volunteering days at Camillus House and working to develop students at local magnet high school iTech, one of my top priorities will always be the development of those around me.

This is a culture that I foster every day. And as we continue to grow and to help the millions of people who reach our sites each month, I’ll always strive to do my best in helping my team members and my community.

The post How On Point Global Came to Be first appeared on Brent Levison.

]]>