FINAL DECISION 

 
ANDREWS, Attorney-Advisor: 
 
 
This is a proceeding under the provisions of section 1552 of title 10 and section 
425 of title 14 of the United States Code.  The BCMR docketed this case on January 7, 
1999, upon receipt of the applicant’s completed application. 
 
 
appointed members who were designated to serve as the Board in this case. 
 

This  final  decision,  dated  December  9,  1999,  is  signed  by  the  three  duly  

RELIEF REQUESTED 

DEPARTMENT OF TRANSPORTATION 

BOARD FOR CORRECTION OF MILITARY RECORDS 

 
Application for the Correction of 
the Coast Guard Record of: 
 
                                                                                        BCMR Docket No. 1999-042 
 
 
   

 
 
The  applicant,  a  xxxxxxxxxxxx  on  active  duty  in  the  Coast  Guard,  asked  the 
Board  to  correct  his  military  record  to  show  that  on  July  16,  1996,  he  extended  his 
enlistment for two years instead of reenlisting for six years.  The correction would allow 
the applicant to receive a maximum Zone B selective reenlistment bonus (SRB) for the 
six-year reenlistment contract he signed on August 4, 1998, prior to his ten-year active 
duty anniversary date.   
 

APPLICANT’S ALLEGATIONS 

The applicant alleged that when he reenlisted for six years on July 16, 1996, the 
Coast  Guard  failed  to  counsel  him  concerning  the  effect  of  the  reenlistment  on  his 
future  entitlement  to  an  SRB.    He  alleged  that  if  he  had  been  properly  counseled, he 
would  have  extended  his  then  current  enlistment  for  only  two  years,  rather  than 
reenlisting for six years, to preserve his eligibility to receive a maximum Zone B SRB on 
the tenth anniversary of his active duty date.  He alleged that because he was not prop-
erly counseled, on his tenth anniversary, he had almost four years of obligated service 
left to serve.  Therefore, he could receive an SRB for only two years of additional service 

under  ALDIST  046/98,  instead  of  for  all  six  years  of  the  new  enlistment  contract  he 
signed on August 4, 1998.  The applicant alleged that this was unfair because the Coast 
Guard was required to counsel him properly, but did not.  

 
The applicant submitted with his application a letter from his commanding offi-
cer, who stated that there was no administrative entry (page 7) in the applicant’s record 
documenting SRB counseling prior to his reenlistment on July 16, 1996.  

VIEWS OF THE COAST GUARD 

 

 

 
 
Board deny the applicant’s request.   

On October 6, 1999, the Chief Counsel of the Coast Guard recommended that the 

 
The Chief Counsel argued that the Board should deny relief because the Coast 
Guard  had  no  duty  to  counsel  the  applicant  regarding  the  effect  of  his  1997  reenlist-
ment1 on a potential future SRB.  The Chief Counsel alleged that Coast Guard regula-
tions do not require that a member’s SRB counseling include “a discussion of the effect 
of  either  an  extension  or  reenlistment  on  a  future  SRB  eligibility.”    He  alleged  that 
regulations require only that members be counseled concerning the SRB multiple cur-
rently applicable for their ratings; the number of years for which they may reenlist; and 
the number of months of newly obligated service upon which their SRBs will be calcu-
lated.  The Chief Counsel argued that because there is no statute mandating SRB coun-
seling, the Board should defer to the Coast Guard’s determination of what constitutes 
proper  SRB  counseling.    Furthermore,  the  Chief  Counsel  argued,  the  Coast  Guard’s 
regulations “were not intended to create any personal rights” and “neither government 
agents,  nor  the  BCMR,  can  create  entitlements  or  rights  that  are  not  provided  for  by 
statute.  Therefore, the internal counseling procedure, based on Coast Guard policy to 
encourage reenlistments, is not a right that the BCMR may independently impose on 
the Coast Guard as it is within the discretion of the Coast Guard to decide how to man-
age its workforce policies.” 

 
The  Chief  Counsel  also  argued  that  the  Board  should  deny  relief  because  the 
applicant’s record contains a page 7 entry dated March 15, 1997, which indicates that he 
was  counseled  in  accordance  with  Article  12.B.4.  of  the  Personnel  Manual.    Article 
12.B.4.,  the  Chief  Counsel  stated,  requires  members  to  be  counseled  concerning  their 
SRB  eligibility.    “Hence,  under  the  presumption  of  regularity  afforded  his  military 
superiors,  the  Applicant  can  be  presumed  to  have  received  such  counseling  in  the 
absence of substantial evidence to the contrary.” 

                                                 
1  The Chief Counsel stated that the applicant was mistaken in alleging that he had reenlisted for six years 
on July 16, 1996, through July 15, 2002.  In fact, the Chief Counsel stated, the applicant reenlisted for five 
years on July 15, 1997, through July 14, 2002. 

The Chief Counsel stated that this case is similar to the case in BCMR Docket No. 
1999-014 in which the Board denied relief.  He further stated that this case involves a 
significant issue of Coast Guard policy.  Therefore, if the Board decides relief should be 
granted, the decision must be reviewed by the Secretary’s delegate. 

 
APPLICANT’S RESPONSE TO THE VIEWS OF THE COAST GUARD 
 
On October 7, 1999, the BCMR sent the applicant a copy of the Chief Counsel’s 
advisory opinion and invited him to respond within 15 days.  On November 3, 1999, the 
applicant responded, stating that the case was ready for decision. 

SUMMARY OF THE RECORD 

 
 
On  August  15,  198x,  the  applicant  enlisted  in  the  Coast  Guard  for  four  years, 
through August 14, 199x.  On June 16, 1992, he was discharged and immediately reen-
listed for a term of three years, obligating himself to serve through June 15, 1995.  On 
April  20,  1995,  the  applicant  extended  his  enlistment  for  two  years,  through  June  15, 
1997.  In May 1996, the applicant received PCS (permanent change of station) orders.  
To accept the orders, he had to obligate himself to serve for at least one full year at the 
new station.  Therefore, on May 8, 1996, the applicant extended his enlistment for three 
months, through September 15, 1997.  Both the June 15, 1995, and May 8, 1996, exten-
sion agreements signed by the applicant indicate that he was provided a copy of “SRB 
Questions and Answers” and fully understood the effect of his extensions on his current 
and future SRB eligibility. 
 
 
On March 15, 1997, six months prior to the end of his enlistment, the applicant’s 
command made a page 7 entry in his record stating, “reenlistment interview conducted 
this date per Article 12-B-4 Personnel Manual … .”  Four months later, on July 15, 1997, 
the applicant reenlisted for five years, through July 14, 2002.  His reenlistment contract, 
DD Form 4/1, did not provide any information concerning SRBs.2 
 
On March 2, 1998, the Commandant of the Coast Guard issued ALDIST 046/98, 
 
which allowed members to receive an SRB if they reenlisted or extended their current 
enlistments between April 1, 1998 and September 30, 1998.  ALDIST 046/98 provided 
that  members  in  the  xx  rating  who  extended  their  enlistments  or  reenlisted  would 
receive an SRB calculated with a multiple of one. 
 

On August 4, 1998, the applicant reenlisted for six years, through August 3, 2004, 
for  the  purpose  of  receiving  a  Zone  B  SRB  with  a  multiple  of  one.    Under  ALDIST 
046/98, the applicant’s reenlistment made him eligible to receive an SRB for any addi-
tional  service to which he obligated himself.  Because the applicant had already obli-
                                                 
2  No copy of this reenlistment contract was in the applicant’s record received from Coast Guard head-
quarters.  However, upon inquiry by the BCMR staff, the Coast Guard Personnel Command confirmed 
the date, duration, and form of the reenlistment contract. 

gated himself to serve through July 14, 2002, his six-year enlistment on August 4, 1998, 
qualified him to receive an SRB for only 24 additional months of obligated service, from 
July 15, 2002, to August 3, 2004.   
 

APPLICABLE REGULATIONS 

 
 
Article  12.B.4.b.1.  of  the  Personnel  Manual  requires  each  member  to  have  a 
predischarge  interview  approximately  six  months  before  the  end  of  his  or  her  enlist-
ment.    Article  12.B.4.b.3.  provides  that  during  predischarge  interview,  a  petty  officer 
“must inform each potential reenlistee eligible for a Selective Reenlistment Bonus (SRB) 
of  that  eligibility  and  the  SRB  program’s  monetary  benefits.”    The  petty  officer  is 
required to discuss the amount of the SRB for which the member is eligible; “SRB flexi-
bility and possible changes that might increase or decrease the bonus amount to which 
the member is entitled at reenlistment”; any limiting factor that could negatively affect 
the SRB payment; the advantages of reenlisting under the current ALDIST as opposed 
to waiting for new SRB multiples to be issued; and how SRBs are paid out. 
 

Enclosure (1) to Commandant Instruction 7220.33 (Reenlistment Bonus Programs 
Administration), Section 2 states that “[a]ll personnel with 14 years or less active service 
who  reenlist  or  extend  for  any  period,  however,  brief, shall be counseled on the SRB 
program.    They  shall  sign  a  page  7  service  record  entry,  enclosure  (3),  outlining  the 
effect that particular action has on their SRB entitlement.” 
 
 
Enclosure (3) to the SRB Instruction states that during the three months prior to 
the end of an enlistment or any time a member reenlists, he or she must be counseled 
concerning his or her eligibility for an SRB, and the counseling must be memorialized in 
the member’s record with a page 7 signed by the member.  The format for the required 
page 7 is reproduced below: 

 
 
 
 
 
 
 

(DATE):  I have been provided with a copy of enclosure (5) to Commandant 
Instruction 7220.33 (series) entitled “SRB Questions and Answers.”  I have been 
informed that: 
 
My current Selective Reenlistment Bonus (SRB) multiple is ____ and is listed in 
ALDIST _______, which has been made available for my review. 
 
In accordance with article 12-B-4, CG Personnel Manual, I am eligible to 
reenlist/extend my enlistment for a maximum of ____ years.   
 
My SRB will be computed based on _____ months newly obligated service. 
 
The following SRB policies were unclear to me, but my SRB counselor provided me 
with the corresponding answers: (list specifics) 
 
 
______________________________ 
(signature of member/date) 

____________________________ 
(signature of counselor) 

 

 
 
 
 
 
 
 
 
 

 
 
 
 
 
 
Enclosure (5) to the SRB Instruction, “SRB Questions and Answers,” explains that 
previously  obligated service reduces an applicant’s SRB.  It further advises members, 
“[w]hen coming up on your end of enlistment, carefully consider the advantages/dis-
advantages of reenlisting vice extending.” 
 
 
Section 3.d.(9) of Enclosure (1) to the SRB Instruction states that “[c]ommanding 
officers are authorized to effect early discharge and reenlist members within 3 months 
prior to their 6th, 10th, or 14th year active service anniversary dates (not to be confused 
with the normal expiration of enlistment), for the purpose of qualifying for a Zone A, B, 
or C SRB respectively.  In such cases, SRB payments will be reduced by any portion of 
unserved service obligation.” 
 
 
Article 1.G.14.a. of the Personnel Manual provides that an extension of an enlist-
ment requested by a member must normally be of at least two years’ duration unless 
the member is required to extend his or her enlistment for a particular purpose, such as 
to accept transfer orders, complete a cruise, attend school, or be promoted. 
 

BCMR DOCKET NO. 1999-014 

 
 
In BCMR Docket No. 1999-014, the applicant asked the Board to change a four-
year reenlistment dated March 1997 to a two-year extension  in order to maximize an 
SRB he received for reenlisting for six years on his tenth anniversary in July 1998.  There 
was no page 7 in the applicant’s record indicating that he had been counseled concern-
ing SRBs prior to signing the four-year reenlistment contract.  However, an extension 
contract signed by the applicant in March 1996 stated that he had been given the chance 
to  review  the  SRB  Instruction,  including  “SRB  Questions  and  Answers,”  and  that  he 
understood the effect of his extension on his current and future SRB eligibility.   
 

The Board denied the applicant’s request, in accordance with the recommenda-
tion of the Coast Guard.  The Board found that the Coast Guard had erred by failing to 
counsel the applicant when he reenlisted in 1997, but concluded that  

 
the  applicant’s  present  contention  amounts  to  a  retrospective  review  of  his  military 
record  based  on  a  later  opportunity  that  the  applicant  could  not  have  known  about  in 
1997. … [S]ince there was no SRB multiple for the applicant’s rate in 1997, and the appli-
cant is not alleging this, any error that occurred at that time was harmless. …  The Board 
is not persuaded that if the applicant had received a page 7 entry in 1997, he would have 
extended for two years rather than reenlisting for four years. …  The applicant’s reenlist-
ment  history  suggests  that  he  would  have  reenlisted  for  four  years  in  1997  (as  he  did) 
because he had previously enlisted for four years both in 1988 and 1992. … Additionally, 

 

 

the required page 7 counseling entry does not mandate a discussion of the effect of either 
an  extension  or  reenlistment  on  a  future  SRB.[3]  …    The  Board  notes  that  just  a  year 
before  his  1997  reenlistment,  the  applicant  acknowledged  on  his  1996  extension  agree-
ment that he had been informed about his SRB eligibility (although one was not available 
for him) and that he understood the effect that the extension would have on his current 
and future SRB eligibility.  Yet, he reenlisted in 1997 without asking any questions.  The 
Board finds that even with SRB counseling in 1997, the applicant would have probably 
reenlisted for four years. …  ‘The Board is only obligated to grant enough relief to correct 
what  it  sees  as  an  injustice.’  Reale  v.  United  States,  208  Ct.  Cl.  1010,  1011  (1976).    The 
Board does not find that any corrective action is necessary in this case. …  [T]he Board’s 
job is not to perfect records but to correct harmful errors and remove injustices. 

BCMR DOCKET NO. 1999-059 

In BCMR Docket No. 1999-059, the applicant alleged that he had not been prop-
erly counseled concerning SRBs before he signed a four-year reenlistment contract on 
February 11, 1998.  There was no page 7 in his record documenting the required coun-
seling.  No SRB was authorized for members in the applicant’s rating in February 1998.  
However, the applicant alleged that, if he had been properly counseled, he would have 
extended his enlistment and reenlisted later when an SRB became available.  
 
 
The  Chief  Counsel  of  the  Coast  Guard  recommended  that  the  Board  grant  the 
applicant’s request in Docket No. 1999-059.4  He stated that “[a]lthough there is suffi-
cient legal basis to deny relief in this case, the totality of the circumstances indicate that 
it would be proper for the Board to grant relief in this case by voiding the Applicant’s 
11  February  1998  reenlistment  contract  and  replacing  it  with  a  third  extension  of  ten 
(10) [sic] months.”  The Chief Counsel stated that the Board should grant relief because 
the applicant could have extended his enlistment for less than four years and because 
he was willing to sign a new long-term reenlistment as consideration for the SRB. 
 

The  Board  granted  the  applicant’s  request  because  the  lack  of  a  page  7  in  the 
applicant’s record indicated that the Coast Guard had erred by failing to counsel him 
properly  concerning  SRBs.    Given  the  applicant’s  statement  that  he  would  not  have 
reenlisted for four years if he had been properly counseled, and with no evidence to the 
contrary,  the  Board  found  that  the  preponderance  of  the  evidence  indicated  that  he 
would  have  extended  his  enlistment  for  nine  months  rather  than  reenlisting  for  four 
years if he had been properly counseled. 
 
                                                 
3  But see Section 3.d.(6) of Enclosure (1), Enclosure (3), and Enclosure (5) to the SRB Instruction, COMDT-
INST 7220.33. 
 
4  The Chief Counsel also recommended that relief be granted in BCMR Docket Nos. 1999-015 and 1999-
031.  The applicants in those cases, like the applicants in this case and in Docket Nos. 1999-059 and 1999-
014, asked the Board to shorten the terms of previous reenlistments/extensions because they had not been 
properly counseled and the extra years of obligated service were reducing their SRBs. 
 

FINDINGS AND CONCLUSIONS 

 
 
The  Board  makes  the  following  findings  and  conclusions  on  the  basis  of  the  
applicant's military record and submissions, the Coast Guard's submissions, and appli-
cable law: 
 

The Board has jurisdiction concerning this matter pursuant to section 1552 

of title 10, United States Code.  The application was timely. 
 

3. 

The  record  supports  the  Chief  Counsel’s  statement  that  the  applicant 
reenlisted for five years on July 15, 1997, rather than for six years on July 16, 1996, as 
alleged  by  the  applicant.    The  applicant  alleged  that  he  was  not  properly  counseled 
about  SRBs  and  the  effect  of  obligating  service  on  potential  future  SRBs  prior  to  this 
reenlistment.5  He alleged that, had he been properly counseled, he would have extend-
ed his enlistment for only two years, so that on his tenth anniversary on active duty,6 he 
would have had no remaining obligated service and therefore would have been eligible 
to receive the maximum possible SRB for his rating.  
 
 
Under  Section  2  of  Enclosure  (1)  and  Enclosure  (3)  to  Commandant 
Instruction 7220.33, the applicant had a right to be counseled concerning SRBs within 
three months prior to his enlistment. Such counseling must be documented by a signed 
page 7 entry.  There is no evidence in the record indicating that the Coast Guard coun-
seled the applicant about SRBs within three months of his enlistment on July 15, 1997.   
 

The Chief Counsel argued that the page 7 entry made in the applicant’s 
record on March 15, 1997, proves that he received proper SRB counseling in accordance 
with  Coast  Guard  policy  and  regulations.    However,  the  page  7  entry  made  in  the 
applicant’s  record  on  March  15,  1997,  does  not  meet  the  requirements  of  the  Coast 
Guard’s regulations in Commandant Instruction 7220.33.  It was made more than three 
months before his enlistment, and it was not signed by the applicant.  Moreover, it did 
not indicate that the applicant was provided a copy of “SRB Questions and Answers” as 
required  by  Enclosure  (3)  of  the  Instruction.    “SRB  Questions  and  Answers”  informs 
members of the effect of obligated service on potential future SRBs and advises them to 
consider  carefully  the  advantages  and  disadvantages  of  extending  versus  reenlisting 
with respect to future entitlement to SRBs.   

4. 

1. 

2. 

 

                                                 
5  The Board assumes that the applicant’s claims concerning lack of counseling apply to his reenlistment 
dated July 15, 1997, although he was mistaken about the date and duration of this reenlistment. 
  
6  The Board notes that the applicant alleged he would have extended his contract for two years to remain 
eligible for a maximum SRB on his tenth anniversary because he thought he had reenlisted in July 1996, 
two years before his tenth anniversary on active duty.  In fact, however, the applicant reenlisted just one 
year before his tenth anniversary. 
 

5. 

The page 7 entry in the applicant’s record dated March 15, 1997, indicates 
that he had a predischarge interview conducted “per Article 12-B-4 Personnel Manual 
…  .”    However,  under  Article  12.B.4.b.3.,  a  member’s  predischarge  interview  must 
include a discussion of SRBs only if the member is eligible for an SRB at the time of the 
interview.  Because the applicant was not eligible for an SRB at the time of his predis-
charge interview, it is unclear whether he was informed about SRBs.  Furthermore, Arti-
cle 12.B.4.b.3. does not specifically require the petty officer conducting a predischarge 
interview to inform the member of the effect of previously obligated service.  Therefore, 
because the requirements of Article 12.B.4.b.3. do not ensure that members receive the 
counseling that is required by the SRB Instruction, the Board finds that the page 7 entry 
made  in  the  applicant’s  record  on  March  15,  1997,  does  not  prove  that  the  applicant 
received proper SRB counseling.   

7. 

There is no page 7 entry meeting the requirements of Enclosure (3) to the 
SRB  Instruction  in  the  applicant’s  record.    Had  proper  counseling  occurred,  such  an 
entry should appear.  Therefore, the Board finds that the applicant has proved by a pre-
ponderance  of  the  evidence  that  the  Coast  Guard  failed  to  counsel  him  properly  in 
accordance with the terms of the SRB Instruction, COMDTINST 7220.33. 
 

The Chief Counsel argued that the regulations created no right or entitle-
ment to counseling on the part of the members.   He also argued that the Board should 
defer  to  the  Coast  Guard’s  determination  of  what  constitutes  proper  SRB  counseling 
and that the Coast Guard had decided that counseling concerning the effect of a reen-
listment on a potential future SRB was not required.  However, the provisions for SRB 
counseling in COMDTINST 7220.33 are not permissive but mandatory.7  The Board was 
established by Congress in part to correct the injustices that arise when the Coast Guard 
fails to follow its own regulations.  The Board will not defer to a Coast Guard determi-
nation that it may ignore the mandatory language in its own regulations. 

 
6. 

  
8. 

The Chief Counsel argued that the Board should deny relief for the rea-
sons stated in its final decision in BCMR Docket No. 1999-014.  Like the applicant in that 
case, this applicant learned when he received proper SRB counseling prior to his tenth 
active duty anniversary date (a) that his SRB would be reduced because of the length of 
his last enlistment; (b) that the last time he reenlisted, he should have been counseled 
concerning and in accordance with the provisions of the SRB Instruction, COMDTINST 
7220.33; (c) that if he had been properly counseled the last time he reenlisted, he would 
have learned that reenlisting for many years of service might reduce any future SRB for 
which he might become eligible and that he would have an opportunity to reenlist on 
his tenth anniversary if an SRB was authorized for his rating.  Also like the applicant in 
Docket No. 1999-014, this applicant alleged that if he had been properly counseled and 
                                                 
7    Moreover,  the  Deputy  General  Counsel,  acting  as  the  delegate  of  the  Secretary,  has  determined  that 
Coast Guard regulations require members to be “fully advised” of their SRB opportunities.  See BCMR 
Docket Nos. 1997-123, 1997-069, 1997-062, 1997-054, and 121-93. 

This applicant’s case is also very similar to the cases in BCMR Docket Nos. 
1999-059, 1999-031, and 1999-015.  In those cases, as in Docket No. 1999-014, the appli-
cant was not properly counseled and learned the advantages of a shorter extension after 
he  had  already  enlisted  for  several  years.    However,  in  these  other  cases,  unlike  in 
Docket No. 1999-014, the Chief Counsel recommended that the Board grant relief, and 
the Board granted relief.  The Board concludes that it is difficult if not impossible to rec-
oncile  the  Chief  Counsel’s  recommendations  in  this  case  and  in  Docket  No.  1999-014 
with his recommendations in Docket Nos. 1999-059, 1999-031, and 1999-015.  Nor is it 
possible for the Board’s decision in this case to be entirely consistent with its decision in 
Docket No. 1999-014 and its decisions in Docket Nos. 1999-059, 1999-031, and 1999-015. 
 
 
10.  Under Article 1.G.14.a. of the Personnel Manual, members who voluntar-
ily  extend  their  enlistments  must  normally  extend  them  for  at  least  two  years.    The 
applicant has not proved by a preponderance of the evidence that he would have been 
permitted in July 1997 to extend his enlistment for less than two years had he requested 
to do so. 
 

11. 

The  Coast  Guard  erred  in  failing  to  counsel  the  applicant  in  accordance 
with the requirements of COMDTINST 7220.33 when he reenlisted for five years on July 
15, 1997.  Had the Coast Guard properly counseled the applicant, he would have been 
given the SRB Instruction with Enclosure (5) to read and thereby been informed of (a) 
the negative effect a long reenlistment would have on possible future SRBs and (b) the 
fact that he could reenlist to receive an SRB the next year if one was authorized for his 
rating  during  the  three  months  prior  to  his  tenth  anniversary,  August  15,  199x.  
Whether the applicant would have acted on this information and chosen to extend his 
enlistment for only two years in hope of receiving an SRB on his tenth anniversary is 
necessarily  a  matter  of  speculation.    However,  given  that  SRBs  involve  thousands  of 
dollars,  the  applicant’s  allegation  that  he  would have chosen to extend only until his 
tenth anniversary, his history of short-term extensions, and a lack of any evidence to the 
contrary, the Board finds that if the Coast Guard had properly counseled the applicant, 
he  would  have  extended  his  enlistment  for  two  years  so  as  to  remain  eligible  for  a 
maximum SRB on his tenth anniversary. 

 
12.  Accordingly,  relief  should  be  granted  by  correcting  the  applicant’s  five-

year reenlistment dated July 15, 1997, to a two-year extension. 

learned  the  advantages  of  extending  his  enlistment  until  his  tenth  anniversary,  he 
would not have reenlisted for so many years.  

 
9. 

 
 
 
 
 
 

[ORDER AND SIGNATURES APPEAR ON NEXT PAGE]

 
 

The application for correction of the military record of XXXXXXXXXX, USCG, is 

ORDER 

 

hereby granted as follows.   

 
His  record  shall  be  corrected  to  show  that  on  July  15,  1997,  he  extended  his 
enlistment  for  two  years,  from  September  16, 1997, through September 15, 1999.  His 
five-year reenlistment contract dated July 15, 1997, shall be null and void.   

 
The Coast Guard shall pay the applicant the amount due him as a result of this 

 
 

correction. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 

 
 
Mark A. Holmstrup 

 

 

 
 
Pamela M. Pelcovits 

 

 

 
David M. Wiegand