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1997 Advocacy Report :  Electronic Benefits Transfer (EBT)


PLEASE NOTE: This 1997 publication is not current, and should be used only as historical information.

Table of Contents

Benefits via cyberspace: the check's not in the mail

Soon there will no longer be checks in the mail for most people who receive government benefits, such as welfare, assistance to the disabled, veterans' benefits, pensions and Social Security. But they'll still get their money.


The wave of the future—and in some cases the present—is Electronic Benefits Transfer (EBT). The program distributes funds electronically to recipients through direct deposit. They withdraw funds using a plastic ATM card and a personal identification number (PIN) at automated teller machines or point of sale (POS) terminals. The federal government and a few states are already using the system—by year's end, 25 states are expected to adopt EBT.

EBT does have its advantages—a potential for cost savings to taxpayers, and the loss of any stigma to users—being chief among them. But consumer advocates raise serious questions about the cost to recipients and predict problems in other areas, such as the inadequacy of training for EBT recipients and the states' failure to extend consumer protections for electronic banking fraud to EBT.

"This is going forward," said Zy Weinberg, director of Public Voice for Food and Health Policy, a nonprofit advocacy group based in Washington, D.C. "There will be no reversal of government policy. EBT is here and it's expanding. Within two years it will be the norm for all federal and state government payments. As advocates, we always have to look out that people aren't getting taken advantage of."

No banking privileges

The original hope for EBT was that recipients without bank accounts would suddenly have the same banking privileges that more affluent people enjoy.

Simple advantages were expected, such as having a checking account, being able to walk up to a bank teller to request account information, and receiving monthly statements. Many advocates were under the impression that these banking privileges would also be provided free or for a nominal cost.

But none of those services is currently offered through state EBT programs and there are no plans pending, said Weinberg.

The Treasury Department is compiling blueprints for the federal electronic funds transfer (EFT) program, which will distribute all federal benefits and payments, except tax refunds. It also has no initiatives planned to help recipients get bank accounts, said Jo Reed of the American Association of Retired People (AARP).

Finding an ideal outcome

"We want to make sure that people who receive federal payments don't assume more of the cost just so the government saves money," said Jean Ann Fox of the Consumer Federation of America. "The ideal outcome of implementing the federal program would be if federally insured deposit institutions found ways to make banking service easily available, very affordable and welcoming to millions of consumers who have no relationships with banks."

Year 2002 food stamp deadline

Federal law requires that states deliver all food stamp benefits electronically by 2002. State programs such as Women, Infants and Children (WIC), unemployment insurance and cash assistance may convert to an electronic program whenever they wish, said Barbara Leyser, a Maryland-based consultant and expert on EBT.

Who benefits?

EBT is seen as a way of providing significant savings to taxpayers. According to Tom McLaughlin, vice president of government services for Deluxe Data Systems in Milwaukee, Wisconsin, disseminating food stamp benefits electronically has been shown to save 10-30% compared to mailing the vouchers.

Deluxe Data is one of the nation's largest processors of ATM and POS transactions. It was recently awarded, along with Citibank and Lockheed Martin, the EBT contract for the Western Alliance of States: Alaska, Arizona, Colorado, Hawaii, Idaho and Washington. Deluxe will also be handling EBT projects on its own in San Bernadino and San Diego counties in California.

While the states are saving money, the financial institutions are already making money from EBT. They make money from transaction fees. Advocates charge that the banks also stand to gain tremendous interest income off the benefits payments between the time they are deposited by the government and the time they are withdrawn by recipients.

According to the Treasury, federal benefits average $240 billion annually. With that kind of money going into banks, advocates say there is no reason that financial institutions should be charging transaction fees to recipients. But that is not the case.

Cost of transactions

So far Maryland is the only state with an EBT program that allows unlimited free transactions of benefits at ATMs and POS terminals. In other states, fees paid by recipients vary from a fee on every transaction (Kansas) to four free ATM transactions per month (Illinois), with additional withdrawals costing between 50 cents and $1 each. (The average recipient uses an ATM about four times a month.)

On top of those fees, some banks that own ATMs add surcharges of their own, so recipients might be charged twice. Two states, Iowa and Connecticut, have banned the double surcharges and at least 12 other states—including California—are considering legislation to prohibit them, said Weinberg.

Federal law prohibits merchants from charging a fee to access food stamps through POS devices. But it does not require merchants to give cash back from POS devices. Nothing prohibits merchants from charging a fee to give cash back.

Sen. Alfonse D'Amato (R-N.Y.) was so outraged by these and other benefits ransaction charges that he held a Senate banking committee hearing in May to denounce a proposed Treasury plan that would allow banks to charge multiple fees to government EBT recipients. (See story below.)

Training recipients

"A basic problem with EBT is that many recipients lack experience with banking," said Cher McIntyre, director of advocacy for Consumer Action. "Yet we are turning them loose with ATM cards and not paying much attention to what happens after that. In-person training is definitely called for."

She noted that many states mail written materials to recipients to explain the mechanics of EBT. Some states are also sending an EBT card and a preselected PIN in the mail to recipients. "The potential for massive fraud and theft of benefits is obvious," said McIntyre.

"We as advocates are unanimous in our belief that people need to have hands on, in-person training," said Weinberg. "You can't mail out training materials. We're finding that a lot of the mailed materials do not contain a full rendering of the user's rights and responsibilities. For people with limited English or literacy skills, mailing materials just won't work."

No Regulation E coverage

McIntyre noted that it is especially important for recipients to understand how things work because "needs based" EBT programs, when administered by the states, are not covered by the usual protections afforded electronic fund transfers.

Under federal Regulation E, users of ATM and debit cards who follow the rules have limited liability for losses from fraudulent use ($50 or, in certain cases, $500).

This, however, does not apply to state-administered benefits such as food stamps, cash assistance and the WIC program.

States lobbied against affording recipients consumer protections under Reg. E--and won. As a result, recipients of state-administered benefits—with the exception of unemployment insurance—are responsible for any and all losses of funds disseminated through EBT.

Recipients could lose money

McIntyre explained that if the card is lost or stolen, it should be reported immediately so that a stop can be put on the card. If money is taken from the account before the card is reported missing, then the recipient suffers the loss.

"A sympathetic case worker may try to make someone whole, but no state has policies or procedures to cover losses," said Leyser. "The only thing that states have in place is a fair hearing process. If you're wiped out, it's tough to wait 45 days for a hearing. There has to be a state obligation to make them whole."

Regulation E protection of federal benefits such as Social Security, SSI and veterans' pensions, however, is still legally intact. "The House essentially sanctioned a parallel system of justice for EBT recipients," said Karen Drew of The National Consumer Law Center in Boston.

In case of emergency

While some states have a 24-hour toll-free number for emergencies, others have created potentially untenable situations that may leave clients without access to food or funds in an emergency situation. For instance, Connecticut obtained a waiver from the U.S. Department of Agriculture allowing it to take up to three days to issue a replacement for a lost or stolen EBT card. Clients temporarily without cards have no access to benefits in the interim.

"EBT systems are designed on a state-by-state basis. That gives us advocates a huge opportunity to impact the process while states are adopting their own designs and testing their own systems," said Drew.

From state to state

EBT distribution systems are not being developed as one national system, but rather by state, or regional, decree. Unless efforts are made now to make all state systems compatible, EBT experts fear that recipients who live in one state but need to shop for food in another state might be stranded. With a paper-based system—food stamps, for example—the benefits could be used in any state.

Something needs to be done to ensure access to cash benefits when a recipient is out of state, say advocates. Alliances of states—like those formed in the North, South and West—will have at least the possibility of designing compatible systems. (EBT experts refer to this as interoperability.)

Independent states, however, have not done much on the issue. New Mexico and Texas are the only two adjacent states so far that have worked to ensure that recipients who cross state lines can access their benefits.

The question of who will pick up the tab for out-of-state EBT transactions is blocking progress.

Weinberg said, "Our assumption is if you use an out-of-state ATM, you will be assessed a charge."

EBT's upside

Despite the many concerns, most consumer advocates see the advantages of EBT. Perhaps chief among them is that the stigma of using food stamps disappears when recipients are paying for their groceries with a plastic card indistinguishable from an ATM, debit or credit card.

EBT also has the potential to reduce fraud by eliminating the chance that welfare checks and food stamps will be lost or stolen in the mail.

And, because most recipients pay to cash their checks, there's the possibility that fees may be eliminated or at least lowered.

Currently, the average check cashing fee is about 2% of the check amount, said Stephen Wolf, chairman of the National Check Cashers Association. On a $500 check that fee is $10. To withdraw $500 from an ATM machine or POS terminal should cost no more than $1 or $2, and maybe less in states that enact limits on fees for EBT withdrawals.

The nuts and bolts of EBT

The Advocacy Report interviewed Barbara Leyser, a Maryland-based consultant. She has been involved for close to a decade in researching and planning the most efficient and consumer-friendly ways to deliver public benefits electronically. In this interview, Leyser describes how EBT is likely to take place, and raises some concerns for consumer advocates to consider.

Q: What is electronic benefits transfer, or EBT?

EBT is the electronic delivery of public benefits [such as Social Security or welfare] by a government agency. These benefits can be accessed using a debit card and a personal identification number (PIN) at an automated teller machine (ATM), most often found in banks, or a point-of-sale (POS) machine, usually found in grocery stores.

Q: How are the states that use EBT distributing assistance payments to recipients?

The money is in a pooled bank account held by the welfare department or another state agency. The recipient has access only to the benefits she or he is entitled to, and those benefits are drawn using a card that looks just like a bank card. The recipient has the authorization to withdraw X amount of dollars, but there is no individual account per se.

Q: How are federal benefits handled?

Right now EBT participation for Social Security, SSI and Veteran's Benefits is not available as an option for all states, but the Treasury is working on it. In January 1999 all federal benefits will have to be distributed electronically. The exact way it will be done is not certain.

In the Southern Alliance of States, the Treasury creates an individual account for the recipient. The account has no check writing privileges—it's a debit-only account that is drawn on by using a card and a PIN. The recipient pays a fee of about $2 a month and gets one free ATM transaction and unlimited free POS transactions. Monthly statements are $1 a month more. However, federal EBT has the full protection of Regulation E [which regulates electronic transactions], which state EBT recipients do not get.

People applying for Social Security, SSI and/or Veteran's Assistance benefits must have their own bank account so that funds can be directly deposited. Otherwise, they have to certify that they don't have an account and benefits checks will be mailed to them.

Q: When will the federal government know specifically how it will use EBT?

In June 1997 the Treasury is expected to spell out everything about the way they envision the world looking in January 1999. Then there will be an opportunity for public comment, with the final rule due this fall.

Q: Is there a deadline for states to enact EBT systems?

By this fall, over half the states will have at least started delivering benefits electronically. There is a federal requirement that all food stamp benefits be delivered electronically by 2002. But I've heard that U.S. Department of Agriculture officials say they expect EBT to be nationwide by 1999.

Q: Must recipients pay fees to obtain their state benefits via EBT?

It varies from state to state. In the Southern Alliance, it's two free transactions per month and 85 cents for each additional transaction. The profit goes to the contractor of the system and the state saves money because it doesn't have to pay the contractor that money.

There could also be surcharges [by financial institutions that own the ATM and POS terminals] on top of those fees. In Missouri, the retailers are being encouraged to charge surcharges, but some states have taken a hard stance against it. The Northeast Coalition of States has prohibited surcharges on EBT transactions by and large.

Q: What about fees pertaining to food stamp benefits?

When EBT was first proposed it was supposed to be unlimited free access. Whether that's indefinitely, or people will have to fight to maintain it, I don't know. But I guess there will be a fight.

For example, a couple of years ago, Sen. Patrick Leahy (D-Vt.) wanted to allow charging two cents for each EBT transaction. Some said, why not, it's only a few cents. But once the door is opened, they could charge anything. The ante will be upped every day. Advocates need to be vigilant in watching EBT fees.

Q: Are POS terminals used only for food stamps?

Food stamp rules require the government to supply POS equipment to authorized food stamp retailers, to enable them to participate once a state converts to EBT. States have discretion in deciding whether the equipment can be used for cash EBT transactions. States can also decide whether they will pay for POS devices at other locations to afford greater access to cash benefits.

Q: Can POS devices be used to access state and federal benefits in cash?

It depends on the equipment and fees. The government is supposed to provide merchants with a POS device, pay for processing fees and train the merchants for free. Some states are now saying that if retailers want a government terminal, it can only be used for food stamps EBT.

There is pressure for retailers to go out and pay for the equipment themselves so that when someone comes into the store with food stamps, they can also access their cash benefits to buy toilet paper and diapers at the same time. The food stamp-only terminals are troubling, especially for Mom-and-Pop stores in low-income neighborhoods.

Q: Can recipients use their cards in different states?

Not yet. There are national operating guidelines for compatibility. But not all states are going along with the guidelines, which suggest using a logo—the Questmark—to indicate that the card can be used anywhere in the country that the logo is displayed. You can use paper food stamps anywhere. If a recipient leaves her state to tend to a sick relative and doesn't have access to her food stamps, what does she do? She needs to eat.

Improving your state's EBT system

Experts on electronic benefit transfer (EBT) programs agree that this is a good time for welfare rights and consumer advocates to get involved in EBT planning at the state level. These are some of their suggestions for making EBT programs more user-friendly:

  • Contact the EBT agency in your state to say that you are opposed to surcharges for withdrawing benefits at ATM and point-of-sale (POS) terminals.
  • Urge your state representatives to require that state EBT contractors allow four free ATM transactions per month.
  • Find out if there are any ATM or POS terminals in your area that do not charge for cash withdrawals. Let your clients know they can save money by using them.
  • Ask that recipients be trained in person to use the EBT card, and that they select their own PIN during the training. Suggest that trainings be available in other languages besides English.
  • Encourage special training programs to reach homebound, elderly and disabled recipients.
  • If your state insists on sending EBT cards and pre-selected PINs through the mail, ask that a phone call be required to activate the card. Suggest that training materials be translated into the languages used by non-English speakers in your state.
  • Urge your state representatives to extend the liability limitations of federal Regulation E to cover EBT recipients.
  • Push for a 24-hour toll-free hotline that recipients can use to report lost or stolen EBT cards. Propose that the people answering the phone have the ability to issue new cards and/or PINs right away.
  • Press for a system that will allow EBT recipients to withdraw benefits and purchase food in other states. This could be accomplished by linking EBT accounts to major electronic networks such as Cirrus, Plus or Star.

D'amato assails EBT fees - Criticizes Treasury Department

By Dawn Frankfort

At a May hearing held by the U.S. Senate Banking Committee, Chairman Alfonse D'Amato (R-NY) blasted the Treasury Department's plans for electronic benefits transfer (EBT) programs. The proposal would allow EBT recipients to be charged two or even three times on the same transaction when withdrawing their benefits from ATMs and point-of-sale (POS) terminals.

For recipients without bank accounts, monthly benefits will be deposited into a central EBT account at a bank chosen by the government.

The Treasury Department estimates that more than 10 million recipients of federal payments do not have bank accounts. The electronic delivery of all government benefits and payments, except for tax refunds, will be compulsory on Jan. 1, 1999.

D'Amato lambasted a provision that allows recipients to be charged up to three times for each withdrawal. These fees include:

  • An access charge by the assigned bank.
  • The ATM operator's surcharge.
  • A non-customer charge for using another bank's ATM.
High stakes banking

D'Amato pointed out that the central banks chosen by the government will have "free use" of $7-$8 billion in Social Security benefits each month. "It is an outrage that under the administration's plan, the banks will not have to pay any interest or provide regular customer services on these accounts, but they will be permitted to charge multiple fees each time a senior citizen uses an ATM to access his or her benefits."

D'Amato, a critic of ATM fees and the sponsor of legislation to limit them, noted that the average user of ATMs pays $155 in ATM fees yearly. Under the proposed Treasury plan, federal recipients could pay more than $300 in ATM fees.

Consumer protection needed

D'Amato and his GOP colleague from North Carolina, Sen. Lauch Faircloth, stressed that an allowance be made for recipients with special needs, such as disabilities, advanced age or illiteracy, who may not be able to adapt to the new system easily.

Marcy Creque of the American Association of Retired Persons (AARP) spoke efore the committee, calling on the government to protect recipients from "unreasonable banking fees and other unfair or abusive practices."

"While direct deposit may offer several cost advantages to the government, fundamental consumer protections must be in place by the time this takes effect. We must not overlook the interests of the most vulnerable in society in favor of banks and potentially predatory financial operations."

She testified that older people make up a significant proportion of people without bank accounts and are vulnerable to financial fraud and abuse. Many seniors without bank accounts live on less than $10,000 per year, she said.

Editor's note: A staff member in the senator's Washington, D.C., office aid that the banking committee will continue to keep an eye on federal EBT policies as they develop. At press time, he said that no legislation had been proposed by D'Amato to limit EBT fees. If you would like to support his opposition to EBT fees, you can write to Senator D'Amato, 520 Hart Senate Office Building, Washington, DC 20510, or e-mail him: .(JavaScript must be enabled to view this email address)

Utah's EBT program is a "win-win situation"

By Dawn Frankfort

Utah's system easy for clients

When the state of Utah decided to adopt electronic benefits transfer (EBT), it set out to make the paperless system an improvement for recipients as well as for the state.

Making the system easy for the client to use was paramount, said L. Clyde Terry, EBT manager for the Utah Department of Human Services and Office of Family Support. "Most others look at EBT for what it can do for the state," said Terry. "Our focus was whether it was a plus for the client to access their benefits this way. We felt it was.

"The safety, security, anonymity, ease of access, ability to have the benefits restored if necessary, avoiding all the lost check problems—that was what was most important," he said. "The next area we looked at was misuse of benefits. Lastly, we looked at the potential for cost savings. We ended just about cost neutral, with a slight savings."

The state program, known as Horizon, has been in place since last year. Currently, Utah EBT is used for some 38,000 food stamp clients and about 18,000 cash assistance clients, said Terry.

Training for clients

Recipients go to a local benefits office, where they are shown an EBT training video and given a 20-page instructional booklet. While there, they select a PIN number and practice using the plastic EBT card—identical to an ATM or debit card. A counselor goes over the material with them until they are comfortable.

"We do not distribute cards by mail or send a pre-selected PIN in the mail because it is difficult to ensure that only the intended client receives the card and PIN that way," said Terry. "But when they are given out in the office, we can be sure."

For disabled, elderly, or other clients who find it tough to get around, the training and the selection of a PIN number can be done at their homes. Up to two separate "alternate payees" may be issued different PINs. (This is usually someone who assists the homebound client with grocery shopping and other tasks.)

The training video is available in Spanish and sign-language for the hearing impaired. The booklet is available in Spanish, too. The state tries to hire multilingual staff trainers, said Terry.

Benefits can be withdrawn at ATMs that use the Zion and national Star ATM networks, allowing for out-of-state use. Under the system three free ATM transactions per month are allowed, with a 50-cent charge for each additional transaction. The ATMs can dispense up to $500 per day.

Benefits may also be used in grocery stores with point-of-sale (POS) machines, which allow clients to pay for groceries directly with their food stamps benefits, as well as to receive cash. All POS transactions are free. Horizon EBT logos are displayed in windows of participating grocery stores.

In case of an emergency, such as a lost or a stolen card, a client can go to a local benefits office and get a new card and PIN for immediate use. Use of the replacement automatically invalidates the old card. If the office is closed, clients can call a live, 24-hour toll-free number that can help them access their benefits by the next morning. The toll-free system also features automated information on account balances.

Fine-tuning needed

"We've had to replace a lost card or a stolen card," said Terry. "But we've never had to replace any benefit funds."

He said the state is always in the process of fine-tuning the system. To help achieve success in their states, Terry advised consumer and welfare rights advocates to get involved at the earliest stages. "Contact EBT management and share your thoughts," he said. "Things are not always set in concrete. Some adjustments may be made to create a win-win situation."

Making a difference: working behind the scenes for low income consumers

(Editor's note: "Making a Difference," a regular feature of The Advocacy Report, is a series profiling organizations that are active in consumer advocacy.)

NCLC background

The National Consumer Law Center (NCLC), with headquarters in Boston, Mass., is a nonprofit legal organization which represents the interests of low income consumers. Since 1969, it has provided its substantial expertise nationally to legal services organizations and volunteer attorneys whose mission it is to protect the poor from predatory pricing by the so-called "poverty industry"—pawnshops, check-cashing outlets, rent-to-own stores and high-interest lenders.

The NCLC began as a support center of the national Legal Services Corporation network. In 1971 it became an independent, nonprofit corporation.

The NCLC today

Today the Center specializes in utilities, banking and finance, warrantees, and harassment by bill collectors as well as other aspects of consumer law.

"Our attorneys are leaders in their fields," said Willard P. Ogburn, the Center's executive director. "Our staff members have on average 20 years of specialization. They provide expert opinions on how proposed changes will impact low income people."

Close to 30 employees—14 of them lawyers—work at the Center's offices in Boston and Washington, D.C. Funding comes from project-by-project grant contracts, private donations, foundation and public agency grants, legal consulting fees and the sale of the Center's legal practice manuals.

The Center has had a hand in some of the most important consumer law issues of this century, including the Fair Debt Collection Act, the Truth in Lending Act and the Consumer Leasing Act.

The Fair Debt Collection Act broadly prohibits once-commonplace abusive tactics by collection agencies. "We drafted much of that legislation," recalled Ogburn. "The language we recommended was to ensure that consumers had effective remedies."

Rather than taking center stage on issues, the Center often acts as a sporting player by lending its expertise, Ogburn said. He added that sometimes the most important influence the Center has on legislation is in stopping detrimental amendments at the committee level or through informal discussions with key players off the House and Senate floors.

"We carefully evaluate new issues and where our intervention can have impact on the greatest number of people," said Ogburn. "We're a real behind-the-scenes organization."

In the early 1990s, the Center identified high interest rate mortgage refinancing as a major problem in low income communities, helping lay the groundwork for federal protections passed in 1995.

High-rate home equity loans, frequently marketed in poor, illiterate and immigrant neighborhoods, charge exorbitant loan-shark interest rates and often have enormous balloon payments due in just a few years. Sometimes it is desperation that leads people to agree to the loan terms—sometimes it is because of outright misrepresentation and fraud by lenders and contractors.

"We saw from our contacts around the country that the number of high-rate mortgages was beginning to rise and the impact on consumers was very dramatic," said Ogburn.

Second mortgages related to debt consolidation or home repairs may contain outrageous terms. In many communities across the nation, poor and elderly homeowners were being turned out of their homes when they could not meet the draconian loan requirements.

Despite lawmakers' attempts to protect consumers, problems with rip-off second mortgages continue today. Many unsuspecting homeowners who believe they are refinancing with better terms are actually agreeing to increase their principal debt because of outrageous closing costs charged by the lenders.

Consumers under siege

Willard P. OgburnThe 1970s were heady times at the Center, said Ogburn. Congress was in the mood to grant sweeping changes that protected the rights of people, particularly low income Americans. "In the '70s, the federal government stepped in and provided consumer protection in a wide range of areas," recalled Ogburn.

The last few years have not been good for consumers, said the University of Chicago Law School graduate, who joined the Center in 1975. "By the '90s, efforts had been made to withdraw some of those important protections," said Ogburn. "Our work more often than not is to maintain consumer protection. The pendulum has clearly swung and the very standard of consumer protection is being attacked."

He mentioned the "wholesale attacks on the Truth in Lending Act" (TILA) in recent years. TILA provides protection for consumers in at least two of the abuses on the Center's list of 10 most common consumer law violations. These include sellers who jack up cash prices for high-risk borrowers—amounting to illegal finance charges—and car leasing companies that withhold interest on security deposits.

"Recently, we worked to have the consumer protection laws extended to cover electronic benefits transfer (EBT), yet we were unsuccessful in the last Congress."

Ogburn cited rent-to-own businesses and auto pawn shops as prime offenders in "financial abuses that just shock the conscience. They charge any interest rate they can get away with," says Ogburn. "We see truly outlandish and offensive interest rates—often in three digits."

Hidden costs also continue to plague the unwary consumer, Ogburn said. When consumers purchase financial services, they may unwittingly agree to other services such as credit life insurance.

Ironically, said Ogburn, it is all too often low income consumers, who cannot afford to pay for useless extras, who get saddled with unnecessary debt because they are the targets of deceptive sales practices.

But far from being discouraged, Ogburn and the Center's staff believe hat the pendulum will swing the other way—back in favor of consumers. "In the future, we will inevitably see more consumer protection legislation, especially in low income communities."

The National Consumer Law Center is located at 18 Tremont St., Boston, MA 02108; (617) 523-8010.

Consumer Actions's Advocacy Department

  • Hotline: Nancy McAdoo, Nelson Santiago, Barbara Sieh
  • Community Consumer Advocates: Guadalupe Aguilar, Josephine Shaw, Darcy Ting
  • Executive Director: Ken McEldowney
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  • Writer: Dawn Frankfort

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