Vanguard CD - Westernbank Closure

[92irish]

Well, the FDIC closed Westernbank (PR) and I bought a couple CDs at Vanguard a while back. The CDs carry very good rates (all relative of course). They were selling lots of CDs at Vanguard.

The FDIC announcement said the deposits were purchased by another PR bank (Banco Popular, or something like that). So, does that mean I get to keep my CDs with the good rates or is the FDIC going to cash me out. This is my first CD from a bank that went under.

Anyone else in similar situation?

[HueyLD]

So, does that mean I get to keep my CDs with the good rates or is the FDIC going to cash me out. This is my first CD from a bank that went under.

Since you have brokered CDs, the FDIC will probably stop paying interest after today and cash you out (up to 250K per bank of course). However, if you purchased those CDs at above 100% of the par value, you will lose the premium.

[dmcmahon]

I'm in the same boat, although not at Vanguard. I bought one of their CDs years ago as part of a 5-year ladder, well before the recent crisis. It paid a decent interest rate and was due to mature later this year. I knew the bank was teetering last year, and I'd been hoping it would skate through to maturity. Sigh. Now I'll find out how well the brokered CD FDIC process works at Schwab.

[dm200]

OUCH!

We are holding Vanguard brokered CDs from Westernbank, RG Premier and Eurobank.

The "good news" is that the total is under $250,000 from each bank.

[dmcmahon]

The "bad" news (for me) is this little goodie at the end of the FDIC web page:

http://www.fdic.gov/deposit/deposits/brokers/index.html


To Deposit Brokers' Investors:

The FDIC must receive the custodial fund information directly from the Deposit Broker who opened the deposit account at the failed FDIC insured institution.


This CD was opened years ago at Smith Barney. In late 2007 I began to get worried about the ultimate solvency of Citi and moved everything to Schwab. Now, I may be in some limbo-land...

[fishndoc]

Darn, another one bites the dust.

This is two Friday's in a row that I have had banks closed where I owned high interest paying CDs.

dmcmahon, the FDIC process worked real smoothly for me last week - Broadway Bank shut down on Friday, and on Tuesday, the principal was added to my Prime MM account.
I understand your concern with having bought the CD at another broker, but the good news is that the FDIC should be really good at this by now, so probably not a new problem for them to sort out.

Do let us know how this works out for you. I also have some older CDs bought back when I was at Merril Lynch - makes me consider selling them on the secondary market if it turns out to be a hassle for you.

[dmcmahon]

Darn, another one bites the dust.

This is two Friday's in a row that I have had banks closed where I owned high interest paying CDs.

dmcmahon, the FDIC process worked real smoothly for me last week - Broadway Bank shut down on Friday, and on Tuesday, the principal was added to my Prime MM account.
I understand your concern with having bought the CD at another broker, but the good news is that the FDIC should be really good at this by now, so probably not a new problem for them to sort out.

Do let us know how this works out for you. I also have some older CDs bought back when I was at Merril Lynch - makes me consider selling them on the secondary market if it turns out to be a hassle for you.

Yeah, I had similar thoughts (of selling) but so far I've toughed it out and skirted disaster twice now. In both of the other cases (Lehman and Advanta) the bank stayed solvent and only the holding company blew up. So, technically, the institution where my CD was invested never actually failed, and they both matured on time with no problem. In one other case, I had an "old" CD with First Federal of California, and I decided to sell that one a few months before it matured, in late 2008. Turns out that one would have been OK, too (it failed quite a while later). This CD is the last of my "old" CDs, thank goodness. Still, ugh!

P.S. Your comment about having back-to-back failures on your CDs hits home - this is why I've given up on brokered CDs in general. I've been parking cash in treasuries. The tiny interest rate differential isn't worth the aggravation. For CDs I stick with directly-opened accounts now. Yes, it's a hassle.

[fishndoc]

For CDs I stick with directly-opened accounts now. Yes, it's a hassle.

Pretty much where I'm at, also. I can still find decent (relatively) rates on shorter term CDs locally (just got 3% at Suntrust for a combination of 2yr & 4yr CDs). I've been pulling some cash out of Vanguard for these <5 yr CDs, and putting my new Vanguard cash into 7-10 year Treasuries and Zero Coupons.

Seems to be the lessor of evils for finding some fixed income return right now.

[TOM1964]

My son's trust had a large 2-year CD there, opened just 6 weeks ago.

I guess trust-registered accounts can be a pain to redeem through the FDIC? Or is that just directly-opened CD's? Ours was in a Vanguard Brokerage account, so I guess that's "fiduciary?" Will the trustee (not me, I'm a "grantor") have to fill out some special forms and wait?

I do my homework on my at-risk investments, but am I expected to evaluate banks before I open a CD? I'd have thought Vanguard might help us not step on a land mine with something that obvious, if the bank was in fact "shakey" as others have said.

Cheers, Tom

[fishndoc]

My son's trust had a large 2-year CD there, opened just 6 weeks ago.

I guess trust-registered accounts can be a pain to redeem through the FDIC? Or is that just directly-opened CD's? Ours was in a Vanguard Brokerage account, so I guess that's "fiduciary?" Will the trustee (not me, I'm a "grantor") have to fill out some special forms and wait?

I do my homework on my at-risk investments, but am I expected to evaluate banks before I open a CD? I'd have thought Vanguard might help us not step on a land mine with something that obvious, if the bank was in fact "shakey" as others have said.

Cheers, Tom

Tom,
I know little about Trusts, but if the CD was purchased through Vanguard brokerage, I see no reason it would be handled differently from an individual investor - as I noted above, with the failure of Broadway last week, the principal was in my money market on Tuesday, and the interest owed showed up there today. Nothing was required from or by me, it just happened.

[dmcmahon]

My son's trust had a large 2-year CD there, opened just 6 weeks ago.

I guess trust-registered accounts can be a pain to redeem through the FDIC? Or is that just directly-opened CD's? Ours was in a Vanguard Brokerage account, so I guess that's "fiduciary?" Will the trustee (not me, I'm a "grantor") have to fill out some special forms and wait?

I do my homework on my at-risk investments, but am I expected to evaluate banks before I open a CD? I'd have thought Vanguard might help us not step on a land mine with something that obvious, if the bank was in fact "shakey" as others have said.

Cheers, Tom

Mine's also a trust, but it's revocable so it's my SSN. Still, it's a possible extra complication, espeically if you have a large claim. In theory, the trust structure gives me 5x the coverage because of the number of qualified beneficiaries. I never put that to the test though - I always keep any individual FDIC investment below the individual maximum.

Alas, yes, you do need to "do your homework" on any investment these days, including bank CDs. I bought mine years ago, before the crisis, and selected this bank based on size (large) and the rate (high enough). Now there are web sites where you can get unofficial ratings on banks. That's where I found out this bank was sub-par. Unfortunately, the mere fact that a bank is trying to get brokered deposits is correlated with a greater-than-average need for deposits. Given the number of failures we're working through, it seems as if extra vigilance is sadly needed.

All that said, you should be fine if you bought the CD through the broker that now holds it - the back-office process should be well-greased now, at least at the major institutions. The fact that I switched brokers is what makes my situation potentially nasty. FWIW the FDIC responded to my email and said in essense "talk to your broker on Monday".

[dm200]

We have CDs at three of the failed banks, all in Puerto Rico - Westernbank, Eurobank and RG Premier. The FDIC transferred assets of each to a different other bank in Puerto Rico.

For brokered CDs, I do not think we know yet how this will be handled and what options, if any, we have. I think it is possible we may just get a payout from the FDIC or we might get an option to keep the CD (probably at a lower rate) at the acquiring bank.

We shall see.

[dmcmahon]

dm100, you should get your money, ultimately. My situation is more like the one described in this lovely gem:

http://www.fdic.gov/deposit/deposits/brokers/4documentationreq.html

We recognize that the insurance of a brokered deposit can be somewhat complicated. For this reason, as an example, we have prepared the following case involving “Apple Brokerage.” Please refer to [ur]http://www.fdic.gov/deposit/deposits/brokers/4exhibit1.html[/url] (Exhibit 1) located at the end of this section, which represents a brokered deposit account ownership “tree.” The tree reflects that Apple Brokerage deposited $5,000,000 with a failed insured depository institution. The FDIC notifies Apple Brokerage that the institution has failed and they have funds on deposit for which they are acting in an agency capacity. The failed institution’s records do not reflect the level of ownership represented in the tree. Thus, sub-tier notification must originate with the first-tier broker. The first order of business for Apple Brokerage is to notify the sub-tier brokers of the closing, to cease all trading activity on the account and restore the account relationships to those in effect on the closing date. In our example, Apple Brokerage would notify Banana Brokerage and the four investors of the closing and request specific documentation from them to prove ownership of their funds. Banana Brokerage would in turn notify Coconut Brokers, Inc., Kiwi Brokers and the investor. Coconut Brokers would have to notify the Newport Family Trust and Mango Financial who in turn would notify its customers – the nine investors. Kiwi Brokers would notify its investor and Fourth National Bank who would notify its customers – the four investors.

It's enough to drive you bananas!

[dmcmahon]

Calculated Risk (a well-known financial blogger) just put out his updated unofficial problem bank list:

http://cr4re.com/PBLApril302010.html

For reference, here's an older one where you can see Westernbank PR listed:

http://cr4re.com/PBLJan0110.html

This is provided for entertainment purposes only, and is best enjoyed while wearing a tinfoil hat. I also look at the bankrate.com rating. I try to get as much information as I can about an institution before putting any money into it, FDIC insurance nonwithstanding.

[dm200]

dm100, you should get your money, ultimately. My situation is more like the one described in this lovely gem:

http://www.fdic.gov/deposit/deposits/brokers/4documentationreq.html

We recognize that the insurance of a brokered deposit can be somewhat complicated. For this reason, as an example, we have prepared the following case involving “Apple Brokerage.” Please refer to [ur]http://www.fdic.gov/deposit/deposits/brokers/4exhibit1.html[/url] (Exhibit 1) located at the end of this section, which represents a brokered deposit account ownership “tree.” The tree reflects that Apple Brokerage deposited $5,000,000 with a failed insured depository institution. The FDIC notifies Apple Brokerage that the institution has failed and they have funds on deposit for which they are acting in an agency capacity. The failed institution’s records do not reflect the level of ownership represented in the tree. Thus, sub-tier notification must originate with the first-tier broker. The first order of business for Apple Brokerage is to notify the sub-tier brokers of the closing, to cease all trading activity on the account and restore the account relationships to those in effect on the closing date. In our example, Apple Brokerage would notify Banana Brokerage and the four investors of the closing and request specific documentation from them to prove ownership of their funds. Banana Brokerage would in turn notify Coconut Brokers, Inc., Kiwi Brokers and the investor. Coconut Brokers would have to notify the Newport Family Trust and Mango Financial who in turn would notify its customers – the nine investors. Kiwi Brokers would notify its investor and Fourth National Bank who would notify its customers – the four investors.

It's enough to drive you bananas!

At the time of the failure of Indymac, we had the then-limit of $100,000. it took 3 weeks, but we got the full amount and accrued interest to date of failure (but nothing between failure and when we got the money).

[dmcmahon]

At the time of the failure of Indymac, we had the then-limit of $100,000. it took 3 weeks, but we got the full amount and accrued interest to date of failure (but nothing between failure and when we got the money).

Yep - so did my mom. That's why I think you'll be fine. My situation is different since the CD was moved between brokers - my claim has to go through the hierarchical flow described on the FDIC's web page (linked above). Doubtless a less-frequently-exercised process, and with many more opportunities to fumble the ball.

[mike10]

This is a real bummer. My wife and I opened separate IRA brokered cd's two years ago. After the first year the bank in Georgia was closed and the account was moved to WesternBank PR and now a year later this one is closed to. The first bank failure was not a big deal so I hope this will go just as smooth.

The worst part is I have to tell my 83 year old mother who also opened a CD at the same time we initially did two years ago. She got a little excited last year with the first bank failure. Everyone is out to get her.

[Puakinekine]

This is not a criticism but a question. Is all this aggravation in a taxable account worth the 1 or 2% extra yield over a bond fund or a CD from a more stable bank?

[dm200]

This is not a criticism but a question. Is all this aggravation in a taxable account worth the 1 or 2% extra yield over a bond fund or a CD from a more stable bank?

If you have $1,000,000 - then 1.00% = $10,000 per year and 2.00% = $20,000 per year.

[dmcmahon]

This is not a criticism but a question. Is all this aggravation in a taxable account worth the 1 or 2% extra yield over a bond fund or a CD from a more stable bank?

No. However, I wasn't yield-seeking without regard to risk. In fact, the opposite, I look at every bank to the extent I can. This CD was opened in 2005 - who knew? Re. the bond fund, my psychology would have me hating it every time the NAV dropped. I prefer to directly own my fixed income instruments, that way I (usually) know what I'll be paid, and when my principal will be returned.

[vst]

Brokerage CDs require lots of record keeping and really good brokers in order for the FDIC pass through insurance to pay out correctly and efficiently. If someone screwed up the titling on the CD, then quite frankly, you are out of luck. So says the FDIC who looks very closely at how the CD is/was titled at the time of failure.

This is called "Custodial risk" which essentially affects brokered deposits which are held in street name.

The average investor doesn't have a clue as to how complex a brokered cd really is.

[dmcmahon]

Brokerage CDs require lots of record keeping and really good brokers in order for the FDIC pass through insurance to pay out correctly and efficiently. If someone screwed up the titling on the CD, then quite frankly, you are out of luck. So says the FDIC who looks very closely at how the CD is/was titled at the time of failure.

This is called "Custodial risk" which essentially affects brokered deposits which are held in street name.

The average investor doesn't have a clue as to how complex a brokered cd really is.

Well, if "someone" screwed up the titling of my CD then "someone" can expect a lawsuit. The product was sold as FDIC insured by Smith Barney. I asked specifically that the titling be checked carefully after the move to Schwab. It's been listed as FDIC insured in all my statements. So, it damned well better be insured. For $90k you bet I'm getting a lawyer if it comes to it.

[vst]

Brokerage CDs require lots of record keeping and really good brokers in order for the FDIC pass through insurance to pay out correctly and efficiently. If someone screwed up the titling on the CD, then quite frankly, you are out of luck. So says the FDIC who looks very closely at how the CD is/was titled at the time of failure.

This is called "Custodial risk" which essentially affects brokered deposits which are held in street name.

The average investor doesn't have a clue as to how complex a brokered cd really is.

Well, if "someone" screwed up the titling of my CD then "someone" can expect a lawsuit. The product was sold as FDIC insured by Smith Barney. I asked specifically that the titling be checked carefully after the move to Schwab. It's been listed as FDIC insured in all my statements. So, it damned well better be insured. For $90k you bet I'm getting a lawyer if it comes to it.

Not to create unnecessary fear, but here's a cautionary tale from the state of MN which details how one govt. entity lost 2 million due to "custodial risk".

http://www.auditor.state.mn.us/other/columns/SafekeepingCountyInvestments_0409.pdf

Custodial risk is real. Since SEC and SIPC are asleep at the wheel sometimes (i.e. Stanford & Madoff), we as investors need to be fully awake and alert when it comes to our investments.

I like brokered cds a lot. I think they make for some great and safe investments, but I do NOT like how the burden is on us (the investor) to make sure the custodians are doing their jobs. I also do NOT like how difficult it seems to get them out of street name and into investor name (i'm not aware of any cases in which this can be done at the moment).

[tfb]

Not to create unnecessary fear, but here's a cautionary tale from the state of MN which details how one govt. entity lost 2 million due to "custodial risk".

http://www.auditor.state.mn.us/other/columns/SafekeepingCountyInvestments_0409.pdf

That's really a different case, isn't it?

When Rate Search went out of business, the entity discovered that a large number of their CDs held by Rate Search could not be found.

It's not like a broker screwed up the title. They just didn't buy the CDs. Are you saying VBS, Fidelity, or whichever broker you buy the brokered CDs from may be outright fraudulent? If you suspect so, don't buy anything from them, not just brokered CDs.

[fishndoc]

Brokerage CDs require lots of record keeping and really good brokers in order for the FDIC pass through insurance to pay out correctly and efficiently. If someone screwed up the titling on the CD, then quite frankly, you are out of luck. So says the FDIC who looks very closely at how the CD is/was titled at the time of failure.

This is called "Custodial risk" which essentially affects brokered deposits which are held in street name.

The average investor doesn't have a clue as to how complex a brokered cd really is.

Well, if "someone" screwed up the titling of my CD then "someone" can expect a lawsuit. The product was sold as FDIC insured by Smith Barney. I asked specifically that the titling be checked carefully after the move to Schwab. It's been listed as FDIC insured in all my statements. So, it damned well better be insured. For $90k you bet I'm getting a lawyer if it comes to it.

From previous experience with Schwab customer service, I bet you will be OK. (much better than Vanguard). Also, you have the option of going to one of their local offices to meet with a rep in person, and I find this always helps with a difficult problem.

[dmcmahon]

From previous experience with Schwab customer service, I bet you will be OK. (much better than Vanguard). Also, you have the option of going to one of their local offices to meet with a rep in person, and I find this always helps with a difficult problem.

Thanks, Doc. That's exactly what I intend to do on Monday. Actually I have complete confidence in Schwab - it's the link between them and SB that's got me worried.

[adrift]

http://www.marketwatch.com/story/popula ... _news_stmp

[dmcmahon]

http://www.marketwatch.com/story/popular-inc-assumes-deposits-acquires-assets-of-westernbank-puerto-rico-from-federal-deposit-insurance-corporation-2010-04-30?reflink=MW_news_stmp

http://www.fdic.gov/bank/individual/failed/westernbank-puertorico.html

All deposit accounts, excluding certain brokered deposits, have been transferred to Banco Popular

(Empahsis mine.)

[Big Al]

Information about continued interest rate on existing CDs can be found here :

http://www.popular.com/westernbank/faq-en.html#intRate

If the above starts you at the beginning, scroll down to section, "VII Interest Rates, Charges and FDIC Coverage"

Good luck, Al

[dm200]

Information about continued interest rate on existing CDs can be found here :

http://www.popular.com/westernbank/faq-en.html#intRate

If the above starts you at the beginning, scroll down to section, "VII Interest Rates, Charges and FDIC Coverage"

Good luck, Al

I think it is possible that the "rules" may be different for brokered CDs. We shall see.

[dmcmahon]

Update on mine: Schwab says not to worry, should be settled this week. I dug up the original trade confirm from SB, as well as my transfer docs, just in case. I sent the CUSIP number to the FDIC for clarification (remember, mine's a lot older than y'alls). Here is the FDIC's email response word-for-word:

The CUSIP number you listed below is one that was excluded from the
transfer (to the acquirer) and will be paid out by FDIC to DTC at 100%
of the closing principal and interest (through 4/30), this week.

There is no need for your broker to make a claim on your behalf, because
this was an ALL deposit transfer and insurance determinations are not
required on this closing.

[dmcmahon]

And the beat goes on...Schwab on-line now lists the position as:

WESTERNBANK P R
4.65XXX
**IN RECEIVERSHIP** EFF: 04/30/10

The "value" is marked down to $90k (from $92k which reflected the interest that was due in a month). So it looks like it's slowly being digested by the process, and I should be fine.

P.S. From now on, I'm doing all my Caribbean banking in the Caymans with all the other high rollers!

[jimlandis]

I own six VG Brokerage CDs. Three of them went upside-down last week....RG Premier, Euro Bk. and Western Bank. How lucky is that?
And, I didn't bet on Super Saver, either. I only deal with VG Brokerage CDs. I trust them and it's really easy to order on-line. And, the tele reps are great.

Jim

[92irish]

Well, its been three days and my Westernbank CDs still are showing in my VBS account. The stated values are down slightly, but still above par. I have received no notices and there is nothing noting that the CDs are in receivership, etc.

I am beginning to wonder whether my CDs are not being liquidated. It seems that maybe some CDs are being cashed out and others are not. The ones I have pay 1.9% (due 2011); 2.3% (due 2012); and 2.85% (due 2013). Better than market rates, but not grossly so.

Any other holders seeing action in their VBS accounts yet?

[dm200]

We hold Vanguard Brokered CDs in all three of the failed (but FDIC insured) banks in Puerto Rico. Today, I inquired (using online chat feature) of Vanguard what should I expect, do I need to do anything, and are there any choices. The clear answer from Vanguard is that brokered CDs from all 3 banks (Westernbank, RG Premier and Eurobank) will be cashed out by the FDIC.

[tfb]

I have a CD thru Fidelity. No movement yet. Not worried. Just waiting.

[brainstem]

I talked with a Flagship rep on Monday --- I was told to wait and the CD will be redeemed by FDIC automatically --- there was nothing for me to do at this time -- the process should be on autopilot --- given current rates, not exactly a major event if things cash out in the near future

[92irish]

For anyone who is interested, one week down and no money from the FDIC.

Vanguard account still shows the CDs in my account, but they did mark the values down to par yesterday (they had been listed with a premium prior to the bank failure).

I thought it would have only taken a couple days. Not worried - just waiting.

[fishndoc]

For anyone who is interested, one week down and no money from the FDIC.

Vanguard account still shows the CDs in my account, but they did mark the values down to par yesterday (they had been listed with a premium prior to the bank failure).

I thought it would have only taken a couple days. Not worried - just waiting.

Same here.
Wonder if the bank being located outside the US might contribute to the delay?


For anyone interested, this week I did find a pretty good deal on a local CD: Suntrust is doing 3% on a combined double CD of 26 months and 49 months. Equal amounts must go into each CD, so you end up with 3% for an average maturity of just over 3 years. I don't think this is just limited to GA.

[tfb]

After the market closed, Fidelity now shows a pending payout for my CD from R-G Premier. I expect it to clear completely on Monday. They are getting there.

EDIT on Sat. 5/8/2010: Fidelity now shows the payout with accrued interest as completed as of 5/7/2010.

[dmcmahon]

I got an email from Schwab indicating that the FDIC claim was in progress and that I would be notified if further action was required on my part, though no action was required at this time. There's been no change in what I see in the account.

[dm200]

Wonder if the bank being located outside the US might contribute to the delay?

Last I knew, Puerto Rico is US territory and those born there are US citizens.

[dm200]

Today, Vanguard showed the Eurobank CDs as redeemed into the linked MM fund, and the RG Premier redeemed but the transfer of the money "pending".

I expect to see Westernbank CDs redeemed into the MM fund any day.

As a comparison, Indymac took about 3 weeks several years ago. Indymac was in California.

[vst]

Today, Vanguard showed the Eurobank CDs as redeemed into the linked MM fund, and the RG Premier redeemed but the transfer of the money "pending".

I expect to see Westernbank CDs redeemed into the MM fund any day.

As a comparison, Indymac took about 3 weeks several years ago. Indymac was in California.

That may have had something to do with Indymac being taken over the the FDIC vs these other banks which had most of their deposits transferred.

Which leads me to ask, what would have happened if the bank(s) had been taken over by the FDIC? Would the broker(s) have to provide more documentation to the FDIC to have the funds released? Is that when the titles to the CDs have to be examined? If so, then how long would all of this taken?

[dm200]

Today, Vanguard showed the Eurobank CDs as redeemed into the linked MM fund, and the RG Premier redeemed but the transfer of the money "pending".

I expect to see Westernbank CDs redeemed into the MM fund any day.

As a comparison, Indymac took about 3 weeks several years ago. Indymac was in California.

That may have had something to do with Indymac being taken over the the FDIC vs these other banks which had most of their deposits transferred.

Which leads me to ask, what would have happened if the bank(s) had been taken over by the FDIC? Would the broker(s) have to provide more documentation to the FDIC to have the funds released? Is that when the titles to the CDs have to be examined? If so, then how long would all of this taken?

In this case, these banks were taken over by the FDIC, BUT most accounts were then transferred to other banks. The brokered CDs were not, and are being paid out by the FDIC. I think (could be wring) that in these cases, the FDIC does need to compile a consolidated list before paying out the brokered CDs - in case someone has brokered CDs from the same bank at different brokers and that puts you over the limit.

[92irish]

For anyone who is interested...

Westernbank CDs are now gone from my account and funds are available in my cash account. That's eleven days from closure - not too bad I guess.

For what it is worth, I held them in a trust account not in my personal name. Some had wondered if that might hold things up, but it did not appear to.

[dmcmahon]

Sheila Bair came through for me. Schwab's system processed the claim last night and I have my money back. Thank you FDR, wherever you are!

[fishndoc]

I received credit in my Vanguard MM today as well. Interesting that dm's refund was just as fast as mine, considering I had purchased the CD as a new issue through Vanguard, and yours was a more convoluted purchase.

For all the complaints we hear (mostly deserved) about the financial system regulators, the FDIC seems to quietly and efficiently do its job. As you said, thanks Ms Blair!

[TOM1964]

My son's trust received the money on Tuesday the 11th as well. No additional forms were required because of the trust registration, despite the information on the FDIC's site.

Tom