INTERVIEW WITH ARTHUR M. SIMON
An Exercise in Democracy
DAVID ARTHUR WALTERS
The Great Recession has taught us all that banking, securities, and insurance regulation is crucial to the survival and flourishing of the American way of life. Since that way is the way of democracy, and since a successful democracy depends on a well informed people, nothing can be more important to its preservation and advance than the dissemination of knowledge by a free press in the form of fair and accurate reporting
And now, given the near collapse of the credit system and the banking system supporting it, nothing is more obvious to the American people than that they were largely deceived as to the safety of the financial system, hence the security of their livelihoods were put in jeopardy. They depended on public and private sector banking experts, and on the press to watch those experts, and now they feel defrauded.
A great deal of fortune has disappeared, and the watchdogs did not bark until people were robbed blind. The people therefore are critical of the press and banking regulators, and they want to know who is at fault and why, to hold someone responsible for bringing the nation and the world to the brink of absolute ruin, and to see what can be done in the way of effective reform so that they and their progeny can be secure in their financial futures. A democratic people will of course proceed by becoming better informed of the activities of financial and media institutions, no matter how boring the study of those functions may seem at first, until understanding results in keener interest.
Not only do people feel cheated by the System and its elected and unelected chiefs, they know they were deliberately defrauded by the likes of Bernie Madoff, Scott Rothstein, and Allen Stanford. The last fraudster named is most infamous because he used a bank to steal the lifesavings of thousands of small investors all over the world. A third of the money was stolen in Miami and shipped offshore in private airplanes. The Miami Herald told the story in an award-winning series under the rubric "MIAMI HERALD WATCHDOG - ALLEN STANFORD CASE."
The Miami Herald reports accused the State of Florida, via its banking regulators, of aiding Stanford with his criminal scheme. It painted the director of bank regulation at the time, Arthur M. Simon, a distinguished man who had devoted his life to public service, as the villain who created the Stanford disaster, signing a deal with the devil illegally allowing the fiend to open an office in Miami to swindle innocent people.
Arthur M. Simon is an attorney and lecturer at the University of Miami. He began his public service with the United States Marine Corps, serving as an officer from 1968 to 1971. He attended the University of Miami, where he got his law degree and a book award for excellence in constitutional law. Subsequently, he went to Harvard's Kennedy School of Government, where he received his master’s degree in public administration. Years later, he earned a Ph.D. in public administration from Florida State University. His doctoral dissertation was entitled “Hazards in the Dual Banking System: Survival Analysis and Population Ecology of Florida Banks, Thrifts and Credit Unions”. He practiced law with Miami-based law firms for about two decades. He served in the Florida House of Representatives from 1982 to 1994, where he participated in major financial legislation. He joined the Florida Department of Banking and Finance in January 1995, and served as Director of the Banking Division for five years. Then he served as Deputy Comptroller until the end of 2002. He lobbied for Associated Industries of Florida and then his alma mater, the University of Miami. Later he joined the University of Miami, Department of Political Science, as a Fulltime Lecturer. He teaches courses on state and national government, public policy and administration, political analysis, administrative law, and game theory.
After reading the Miami Herald reports, I decided to file a sworn complaint against Dr. Simon with The Florida Bar, the arm of the Florida Supreme Court that regulates the practice of law. I thought it would be best to retrieve whatever documents the Miami Herald had to support its accusations before filing my complaint. The newspaper was uncooperative, so I obtained the documents via public information requests.
The newspaper reports were apparently false, unsubstantiated by the documents, in several respects. I was in shock. I had, along with hundreds of other Internet parrots, spread the defamatory gossip around the world. To rectify my mistake, I decided to do whatever I could to clear Dr. Simon's name, by spreading the truth about his role as a bank regulator in Florida in 1998, when he signed an agreement with Stanford Trust of Antigua to open an international trust company representative office in Florida.
I was surprised when Dr. Simon granted me a personal interview with him at the University of Miami. After all, I had been one of his detractors, and he knew it. It was some time after the interview that it dawned on me that he had brought me in from the cold, so to speak. He actually welcomed my criticism. It soon became obvious to me that he is not one of those petty officials or politicians who complain about complainers and resent criticism. Rather, he has the wisdom to see the profit in criticism, without which civilization by no means would exist or advance. He knows that people who feel wronged have some right in mind, some ideal they believe in, and when they are not right about the wrong, he is willing to patiently show them the wrong until they get it right. Thus is he willing to recognize the virtue in troublemakers and to bring them into the fold. He was unwilling to join my little crusades against lawyers and the press because he believes the professions of law and journalism are essential to democracy and should be given some leeway to err.
My own early circumstances were unsettling to say the least, and I was disposed to distrust and detest authority and to refuse to conform to the herd when I could get away with doing so. Otherwise, I might have been very much like Arthur M. Simon. Although I was a liberal and sometimes wild thinker, I eventually learned to act more or less conservatively. In any event, an interest in the truth led me to Arthur M. Simon, and he won me over. The interview itself, I realized, was an exercise in democracy.
WALTERS: A librarian at Richter Library gave me a pass, and I toured two of the nine floors of stacks. I felt right at home among the over two-million volumes - I saw familiar books when I got off the elevator. I would love to invest a few weeks in that library.
SIMON: I love libraries. They are very important.
WALTERS: They are the arks of civilization. Many people do not understand how I can stand being a bookworm, literally living in libraries, but it’s a rich life as far as I am concerned, and a good library is essential to it.
SIMON: The Library of Congress has the largest collection, and Harvard the second largest. When I was at Harvard, I heard it said that Harvard is the largest collection without cookbooks.
WALTERS: This is a great campus, Mr. Simon. I certainly would like to be put out to pasture here, to do some farming.
SIMON: I feel very fortunate to be here.
WALTERS: I thank you for taking the time for this interview. My associates are suggesting that I am wasting my time writing about your role as bank regulator at the time Allen Stanford was ramping up his fraud unless it is for the Wall Street Journal or the like. No matter how much I try to simplify the subjects involved, they say the whole affair is so complicated that few readers can understand it, and most will not bother to try, that I am wasting my breath, especially when I start talking about the law, because nobody cares to actually read and understand the law except lawyers who can turn a buck on it. And it seems that no one who is not a Stanford victim cares very much about the victims any more, and they could care less about whether the reporting of the newspaper was accurate or not. The Miami Herald gave them the impression that you forged an illegal deal with the devil that allowed billions to be stolen from innocent investors. The bags of money were flown out in private airplanes. Enough said, let's go on to the next scandal - the Rothstein scandal was far more interesting to Floridians. I don't know why, but I don't think the subject matter is too complicated to understand, and I find it fascinating. I want to know what was really going on. I am in it for the truth of it.
SIMON: The more you know about the world and the people in it, the more you understand it, the better. There are a few things that are so complex it is indeed very difficult to understand them. But most things can be understood if you take the time and have the patience to get to the bottom of them. The spread of knowledge is crucial to democracy, and that is what brings the world together.
WALTERS: Mr. Simon, the Miami Herald stated that you, acting for the State of Florida as its banking division director, and against the advice of Richard T. Donelan, chief banking counsel at the time, allowed Allen Stanford to defraud investors by permitting Stanford to operate an office in Florida without any fraud checks or money laundering requirements. Therefore the state violated its own laws and created a financial disaster, said the reports.
SIMON: The reports are patently false, and the Miami Herald should have known that.
WALTERS: But the Herald supports the accusation with testimony of what I've called a peanut gallery of cooperative lawyers, its band of so-called experts.
SIMON: Mr. Walters, I support a free press. Sometimes reporters call you, and you want to be cooperative whenever you can. You pretty much know what the reporters want you to say from their loaded questions, and if that sounds correct, a busy lawyer might answer accordingly instead of offering no comment, or refusing to answer until time-consuming research is conducted. In any event, whatever anyone says to the press, I did not allow nor permit anyone at any time to commit crimes in this state.
WALTERS: Were the Miami Herald reporters rude? Did they ask loaded questions?
SIMON: They were polite for the most part. One of them, Lucy, was somewhat pushy - she was pushing the corruption angle. And at one point, Mike wanted me to say that Governor Bush asked me to sign the agreement, which he had not done - I had no contact with the Governor on the matter at all.
WALTERS: Did anyone else contact you besides the Miami Herald?
SIMON: Only you. You are the only one who has contacted me since the Herald covered the story. Most interestingly, at no time subsequent to the disclosure of Stanford's fraud has anyone from the State of Florida contacted me, or anyone else for that matter, although there are ongoing investigations into the fraud.
WALTERS: That is strange. Maybe it’s because they can see that you are obviously innocent of any wrongdoing, and don’t want that to be known.
SIMON: I've thought about it. You have to know how these people work. They go around and collect information for some time before they approach you....
WALTERS: So they have all that stuff, and try to get you to say something, to disclose something they want to know, to trip you up or whatever?
WALTERS: But tell me, since I am here, did you in fact permit Stanford to circumvent state and federal money laundering laws when you signed the special agreement for him to operate an international trust representative office in Florida?
SIMON: Certainly not. There was nothing illegal about that agreement, and they might have proceeded without any agreement. What you should know, and what every expert in the field definitely should be aware of, is that the agreement between Florida and Stanford did not in any way exempt Stanford Trust, doing business as Stanford Financial Investors Services, from money laundering laws by recognizing the entity as something other than a "financial institution" under Florida banking law. You see there are two money laundering statutes in Florida, one in Chapter 655 that expressly covers “financial institutions” and another one, in Chapter 896, that covers everything other than “financial institutions”. Chapter 655 is administered by the Office of Financial Regulation - the successor in interest to the former Department of Banking and Finance. In contrast Chapter 896 is administered by the Florida Department of Revenue. Both statutes do essentially the same thing. Arguably, Stanford’s trust representative office was not covered by Chapter 655, because, as a matter of law a trust representative office was never defined as a “financial institution” in the Florida Financial Institutions Codes. If, however, you read the pertinent section of Chapter 655 more carefully, you will note that it covers any entity defined as a “financial institution” under the federal money laundering act, specifically, 31 United States Code, Section 5312. The federal definition, adopted by reference in Chapter 655, covers the usual array of state-licensed financial institutions, such as banks, trust companies, insurance companies, and today also travel agencies, automobile dealers, gambling casinos and a slew of other businesses that might be tempted to engage in illicit money laundering activities. But now, and pay very close attention to this: the federal money laundering law also includes in the definition of “financial institution” any other person who engages in as a business in the transmission of funds, or any network of people who engage as a business in facilitating the transfer of money domestically or internationally outside of the conventional financial institutions system. This statutory language places the prohibition on the activities of any business whatsoever that might act as substitutes for the definitely listed types of businesses, such as banks and trust companies. Moreover, federal law empowers the Treasury Secretary to define by rule any other type of business that the Secretary thinks may have something or the other to do with money laundering crimes, tax evasion, and other regulated conduct. Therefore, in my considered opinion, because the Florida Control of Money Laundering in Financial Institutions Act adopts by reference the broader federal definition of “financial institution,” the Florida act would conceivably cover any trust representative office in Florida which regularly engages in the transfer of currency or monetary instruments from Florida to a foreign country – despite the fact that a trust representative office was not “financial institution” per se (for any other purpose) under Florida law. Moreover, even if for sake of argument, a Stanford trust representative office was not covered by Chapter 655, it was always subject to Chapter 896, Florida's Money Laundering Control Act. As such, Stanford would have to file copies of currency reports with the State Department of Revenue; and the DOR, in turn, was required to provide these reports to the Office of Financial Regulation - much like the analogous arrangement the Florida OFR has with the U.S. Department of Treasury to obtain copies of currency reports filed by state-chartered “financial institutions” with the federal government. So, in conclusion, Florida's agreement with Stanford Trust did by no means violate federal and state anti-laundering laws, or exempt Stanford Trust from those laws. The claim that the agreement circumvented anti-money laundering laws is absolutely false. Futhermore....
WALTERS: I think you have made that perfectly clear. Mr. Simon, I have examined the information you sent to me on your role in the Stanford affair, and it appears to me that you could write an enormously useful book on what happened in Florida from your unique perspective. You were instrumental in the drafting of banking laws for this state. You were the director of the banking division who signed the agreement with Stanford Trust to operate an office in Florida. You have been wrongly cast by the popular press as a villain for signing the agreement. You are an esteemed professor of government at the University of Miami, a highly respected university throughout the world. You have the credentials, the expertise, and the experience. Certainly an academic publisher would print a few thousand copies of your book for distribution to libraries throughout the world, so that professors and students of banking and government could benefit from your knowledge and first-hand experience. Professors are supposed to write books every once in awhile. And in writing this book you would crucify the Miami Herald for the lies it has smeared your good name with.
SIMON: A free press is essential to democracy. The Miami Herald did the public a service with its Stanford series.
WALTERS: But a free press must be held responsible for its free speech - it must be regulated.
SIMON: After a certain point....
WALTERS: Anyone who reads the documents the Herald must have had, and who can think clearly, can see that the Miami Herald maligned you. Are you considering suing the paper for libel?
SIMON: I can say that I have consulted with a panel of outside experts on this issue amongst others, and the consensus right now is to stand by pending further developments. On the other hand....
WALTERS: Why not see if you can have 1st-degree misdemeanor charges brought under Florida's defamation statute? At least you would get a retraction, an apology or sorts.
SIMON: The paper is not going to back down from an accusation it has so adamantly repeated. It will stand by its accusations. In any case, I am not about to write a self-serving J'accuse. [Professor Simon was referring to Emile Zola's open letter published by L'Aurore, accusing the government of anti-semiticism in the case of Alfred Drefus, who was wrongly prosecuted for espionage].
WALTERS: Maybe it would be more appropriate for me to write an J'accuse.
SIMON [reaching for a thick binder, of about two-hundred page]: As a matter of fact, I have been reconstructing the relevant events.
WALTERS: Single-spaced, I see. This is your account of the Stanford affair?
WALTERS [reaching for the file]: May I see it? May I copy it?
SIMON [pulling the file away]: My primary interest here is not in going after the paper or profiting from a book but in serving the public.
WALTERS: Nailing the paper to the wall would serve the public well. I believe the paper recklessly disregarded the truth in its award-winning series, and that the actual malice standard applies. Do you believe the reporters and editors were malicious or just stupid?
SIMON: Stupid. Not to change the subject, but you mentioned my part in drafting Florida's financial code. There is something I have done that no one knows about yet.
WALTERS: Oh? What?
SIMON: I don't mean to brag here, but to bring up a point relevant to my formal responsibility in the Stanford mess.
WALTERS: Please do.
SIMON: I am largely responsible for the scheme that placed banking, securities, and insurance regulation under the purview of appointed directors of two offices, the Office of Financial Regulation and the Office of Insurance Regulation, both being offices of the newly created Department of Financial Services.
WALTERS: You are the father of the new regulatory structure?
SIMON: I was the back-office operator who came up with the scheme and managed to convince my superiors that it was theirs. And they deserved the credit for its realization - the proposal was very controversial at the time, and that got the job done. As a Marine Corps officer I was subordinate in rank to General Milligan, and I would by no means appear to go over his head.
WALTERS: General Milligan?
SIMON: My boss Robert Milligan, he was Florida's comptroller at the time, and he was a Marine Corps general.
WALTERS: I see.
SIMON: Maybe you don't see the point yet, not in the context of the accusations against me. Although I am willing to accept responsibility for any mistakes that I might have made in regards to the agreement with Stanford at that time, you should know that, as the director of the banking division, I was not the ultimate authority over banking regulation. That authority was an elected official. The possibility for corruption is obvious when you have elected officials regulating banks, securities and insurance companies. But under the new regulatory scheme that I came up with – a plan for government reorganization which was nurtured to fruition by the Comptroller, the Treasurer, and the Governor – which is the regulatory structure in place now, the setting of policy is in the hands of the governor and cabinet, sitting as the Financial Services Commission, but the actual regulation, the implementation and enforcement of public policy, is entrusted to appointed officials, experts in their fields. This scheme in effect depoliticized financial regulation in Florida.
WALTERS: One wonders, then, why the Herald did not go up the hierarchy and blame your superiors.
SIMON: I don't think anyone was to blame, however, for the agreement was legal. Keep in mind that I signed it after the lawyers, including Mr. Donelan, had negotiated and agreed on it. In fact, as I remember it, the Stanford agreement was for the most part negotiated over my head, and I attended only a couple of meetings with the counter-party attorneys. I mentioned it in passing to Donelan one day, asked him how the negotiations were going, and he said well, noting a few issues that had been resolved.
WALTERS: But the Miami Herald insists that he objected to it several times, and you signed it anyway - apparently that is what he told the reporters.
SIMON: Nonsense. Donelan is a fine lawyer, and I worked closely with him on many issues. If he had had any objections to the agreement with Stanford Trust, if he felt it was contrary to the public interest, he would have put his objections in writing to his superiors, not only to protect the public, but to....
WALTERS: Cover his own ass?
SIMON: Correct. That is first-year law school.
WALTERS: But why would he tell the Miami Herald that he objected to the agreement on multiple occasions, and that you signed it anyway?
SIMON: Believe me, if that is what he said to the reporters, I cannot explain it. When I read the newspaper report on the scandal, I said something is wrong here. Donelan did not object. He's the counsel that approved it before it was sent to me. That was almost a dozen years ago, so I wondered to myself: Was there some email, something I have forgotten, something the paper has that they think is their smoking gun on this?
WALTERS: The Herald's executive editor did not respond to my request for any information that would support their claim.
SIMON: That speaks loudly. And the Office of Financial Regulation told you just a few days ago that there is no record of any memorandum written by attorney Donelan objecting to the Stanford trust representative office or the Stanford Memorandum of Agreement. Indeed, the OFR now acknowledges, after a diligent search of Department records, that no such memo was ever issued. Also, it is noteworthy that the respective House and Senate bill analyses for the new law the Florida Legislature enacted this year in response to the massive Stanford financial fraud both indicate clearly and unequivocally that the Department of Banking and Finance did not have any regulatory authority over international trust company representative offices. As such, Stanford Trust Company could lawfully open a representative office in this state without any prior approval or regulatory oversight from the Division of Banking and Finance. Obviously, then, the office was not illegal; and neither was the Memorandum of Agreement.
WALTERS: You know I asked you this before, but let me ask again because you did not answer, weren't you indignant or angry or even enraged by the Miami Herald reports that scapegoated you, cast you as a villain?
SIMON: Well, when the news first broke about Allen Stanford's fraud, I thought to myself, Gee, I signed that agreement with the Stanford Trust. And when I heard Stanford was using CDs on an Antigua bank to forward his Ponzi scheme, I thought, What? Selling CDs on an Antigua bank? And then, Why in the world would people want to buy CDs on an Antigua bank?
WALTERS: But weren't you pissed off, or hurt when the paper implicated you personally?
SIMON [avoiding the question]: Look, I take full responsibility for any mistakes I may have made, and having the benefit of hindsight, I would not sign that agreement with Stanford Trust now.
WALTERS: But without that benefit, would you sign it again?
SIMON: Yes, I think so. Stanford Trust could have proceeded without the agreement, anyway, as the Greenberg Traurig lawyer - I think it was Carlos Loumiet although it was unsigned - argued in a memorandum in the first place.
WALTERS: I received a copy of that memorandum from someone in Antigua, and when I read it, with its supporting citations of our federal and state supreme courts, I was persuaded Stanford did not need that state banking division's approval.
SIMON: Greenberg Traurig has expert lawyers.
WALTERS: If the State had refused to permit the trust to open an international representative office in Florida, could it had gotten a mandate from a court?
SIMON: Good question. Greenberg Traurig is a powerful law firm. In one meeting a Stanford attorney was indignant that the Department lacked statutory jurisdiction prevent the opening and operation of a trust representative office, and said he would take the matter higher. I wondered what he meant by higher.
WALTERS: If Stanford Trust could have done business in Florida without getting permission from the banking division, how did it come to the division's attention in the first place? Why did it do the tango with banking?
SIMON: Because Stanford Trust applied to the Department of State to register as a foreign corporation under the name of Stanford Trust Company Limited, and the Department automatically kicked back the application because it had the word "trust" in it. Florida law prohibits the use of the word trust, which would suggest to the public that the entity is a regulated trust company. Actually, there is way that the word might be used providing that the company using it does not engage in a certain kind of activity.
WALTERS: So Stanford Trust could have registered a corporation here under some name without the word trust in it, gotten under the Secretary's radar and perpetuated whatever scheme it may have had?
SIMON: Correct. But they wanted to use the word 'trust.'
WALTERS: Why? Marketing reasons? Because it signifies trustworthiness?
WALTERS: But what about the trust functions, aspects such as secrecy, sequestering assets, avoiding probate and other taxes?
SIMON: That too. Although there was a way they might have used the word 'trust' in the name, apparently the functions they had in mind moved them to suggest another name, 'Stanford Fiduciary Investor Services.'
WALTERS: But “fiduciary” services suggest "trust services," although fiduciary services could mean something other than trust services.
SIMON: When I first saw the name 'Stanford Fiduciary Investor Services,' the word 'fiduciary' stood out, but even more so did the word 'investor.' I had my doubts about what was meant, about the nature of the business the words signified, but the more I thought about it, I could see nothing wrong with the use of those words in the context of what a international trust representative office could do, which would be to represent a foreign trust company by providing its customers with conveniences, but not operate as a trust company in the state.
WALTERS: There certainly is much ado over words. Until the new legislation was passed, there were no specific words in the law prohibiting international trust representative offices from being set up in Florida, so anyone could have set one up, because the law does not prohibit what it is silent on.
WALTERS: I guess that answers the question: What's in a word? Apparently everything. Professor Simon, were you hoodwinked by Greenberg Traurig lawyers into signing an agreement with a shifty character? If Donelan and you had reservations in the back of your minds, why not just refuse to go along?
SIMON: I don't know if we were hoodwinked. Stanford counsel presented strong legal grounds. You have to understand that what we do is governed by law. Any refusal would have to be supported by law and put in writing.
WALTERS: You mean you couldn't refuse because you didn't like someone's looks or your intuition told you he might be a crook?
WALTERS: Is Greenberg Traurig a crooked law firm? Didn't its lawyers deliberately perpetuate a fraud?
SIMON: I have seen no indication of that. Many highly regarded people were fooled by Stanford, and even praised his activities, including President Clinton and President Bush.
WALTERS: But they were not so close to him. I suppose the lawyers were doing what lawyers do, playing the lawyer game, presumably according to the rules, so I guess a prosecutor would have to prove they actually knew their client was stealing or were helping him break laws....
SIMON: Before I forget, I want to emphasize that the Stanford fraud was based on his marketing of securities, his brokerage operations, and not on his representative trust office activities in Florida. He already had a brokerage operation in Florida, and in any event his licensed brokers could have sold the CDs.
WALTERS: The trust was irrelevant?
SIMON: The legal action is for fraud in reference to securities.
WALTERS: But the Herald made a big deal over the trust's Miami office, and reported that it was his inroad into the perpetuation of his fraud throughout the United States.
SIMON: The trust per se was not the issue; the issue was securities fraud, wherever it was committed, no matter what office was used.
WALTERS: So it would not matter if a licensed broker sold a CD in a trust office or a brokerage office, or if one office doubled as the other, the employees changing hats?
SIMON: No, I don't think so.
WALTERS: So the big deal over the trust's office in Miami and the agreement you signed is a red herring?
SIMON: As I said, the issue is securities fraud.
WALTERS: Were you in charge of securities regulation?
SIMON: No, I was the banking director. I am not an expert on securities, but I know my banking. The director of the securities division, since 1986, was Don Saxon, one of the most distinguished state securities experts in the country. Incidentally, about 25% of the nation's securities brokers and investment advisors, I think, are registered to do securities business in Florida. As a matter of fact, Don Saxon was appointed in 2003 to be the first director of the newly created Office of Financial Regulation I told you about.
WALTERS: Maybe he should have been scapegoated. But they saw your signature on the agreement with Stanford Trust, so they went for you, painted you as the villain if not a lax regulator.
SIMON: You go ask anyone I regulated if I was a lax regulator during my five years as banking director. They will tell you I was a tough regulator. As a matter of fact, I dealt with international bank agencies and representative offices then, and even with one foreign owned or controlled trust company, which we determined was originally approved based on false, misleading, or incomplete information. Also, when the banks in foreign countries were having difficulties, no deposits in their Florida agencies were lost on my watch, deposits which were uninsured, incidentally, and that's because I took immediate and decisive action. Likewise, no state-chartered commercial banks in Florida failed on my watch. I worked very closely with the Fed, and on one occasion the Fed called me in the middle of the night from Washington, D.C. to take emergency action against an international agency in Miami before it opened for business the next morning, because it had too much red tape to deal with and I could get there first, and I did, and I resolved the situation. I wish I could give you a few examples, but I'm not sure whether or not I would be violating confidentiality laws.
WALTERS: I had better end the interview here before you start charging me for the education.
SIMON: It's not like I have nothing else to do - I'm preparing for the next semester.
WALTERS: This is a beautiful university, and you certainly have beautiful students here.
SIMON: That we do.
WALTERS: Thank you very much.