Rather than conduct due diligence into those valuations and distribution irregularities to determine that they were reasonable and that the Apple REITs were suitable, DLA accepted the valuations and continued to record them on customer account statements.

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Company officials created false documents, such as invoices, customer checks and account statements to verify business activity that never occurred or existed.

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It recommended that customers' annual statements explain the amount of "interest foregone" by a customer.

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With respect to these forward-looking statements, management has made assumptions regarding, among other things, customer and network usage, customer growth and retention, pricing, operating costs, the timing of various events and the economic and regulatory environment.

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Raise your hand if you have heard one of the statements above from someone in leadership in response to a call for better customer understanding.

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Part of a new customer relations initiative called "Total Merrill, " the new format added information to single monthly statements that customers were craving.

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