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Government of the Virgin Islands of the United States of America Department of Licensing and Consumer Affairs www.dlca.vi.gov H. Nathalie Hodge Commissioner Testimony Before the 36th Legislature of the Virgin Islands Hon. Avery L. Lewis, Chair Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 Serving Businesses & Assisting, Educating and Protecting Consumers” Golden Rock Shopping Center 3000 Estate Golden Rock, Suite 9 St. Croix, VI 00820-4311 Telephone: 340.713.3522 Administrative Complex “The Battery” St. John, VI 00830 Telephone: 340.727.3303 Property & Procurement Building 8201 Subbase, Suite 1 St. Thomas, VI 00802-5826 Telephone: 340.714.3522 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 2 Good Morning Chairman Lewis, Honorable Senators, Distinguished Members of 1 the 36th Legislature, and the Listening and Viewing Audience. I am Deputy Commissioner 2 Myrna George and I am joined by Matthew Padgett, the Director of Consumer Affairs and 3 General Counsel, Geraldine P. Vaval. Thank you for the opportunity to appear before you 4 today on behalf of the Department of Licensing and Consumer Affairs (DLCA) and 5 Commissioner H. Nathalie Hodge to provide a comprehensive update on the state of 6 DLCA’s ability to provide an update on programs that prevent fraudulent, deceptive and 7 unfair business practices and information to help consumers spot, stop and avoid scams 8 and fraud. Specifically, we will focus on fuel price surveys, the frequency of grocery store 9 price analyses and results, and the status of capital projects. As the agency tasked with 10 protecting the interests of consumers and ensuring fair business practices across the U.S. 11 Virgin Islands, our department remains steadfast in its commitment to enforcing consumer 12 protection laws and providing essential services that promote transparency and 13 accountability in the marketplace. 14 Today, I will outline the consumer protection services that DLCA provides to the 15 public and discuss how these efforts contribute to fair commerce and promote consumer 16 confidence throughout our territory. 17 18 DLCA’s Services for Promoting Fair Business Practices and Consumer Protection 19 Consumer Complaint Resolution and Mediation Services 20 One of the core functions of DLCA is to serve as an intermediary between 21 consumers and businesses when disputes arise. Our Consumer Affairs Division handles 22 complaints relating to deceptive business practices, price gouging (during declared 23 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 3 emergencies and price freeze orders), contract disputes, and other unfair trade practices. 24 Through mediation services provided by our small, but talented and experienced team of 25 Consumer Protection Investigators, we work to resolve conflicts in a fair and timely 26 manner, ensuring that consumers receive appropriate redress while fostering a cooperative 27 relationship with businesses. 28 Over the past year, DLCA has successfully resolved, or forwarded to the 29 appropriate agency, approximately 320 citizen complaints across the territory. In addition 30 to individual case resolutions, we proactively investigate industry-wide concerns regarding 31 business practices and take appropriate regulatory action or make public notifications when 32 necessary. 33 34 Enforcement of Consumer Protection Laws 35 DLCA enforces a variety of laws aimed at safeguarding consumer rights. These 36 include, but are not limited to: 37 1. The Consumer Protection Law. The Consumer Protection Law serves as a 38 safeguard against unfair and deceptive trade practices that could mislead or harm 39 consumers. It establishes guidelines to ensure businesses operate with transparency 40 and integrity, preventing fraudulent claims, false advertising, and 41 misrepresentations about products or services. Through enforcement actions, 42 consumer education, and legal interventions, DLCA actively identifies and 43 addresses violations. By holding businesses accountable for deceptive practices, 44 this law fosters a fair marketplace where consumers can make informed purchasing 45 decisions with confidence. 46 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 4 2. The Price Control Act. The Price Control Act is a critical regulation designed to 47 prevent price gouging, particularly during emergencies such as hurricanes. It grants 48 DLCA the authority to monitor and regulate the prices of essential goods and 49 services, ensuring that businesses do not exploit consumers by imposing unjustified 50 price increases during times of crisis. This act covers necessities such as food, fuel, 51 medical supplies, and building materials, and protecting residents from financial 52 exploitation when access to essential products becomes limited. By enforcing price 53 controls and conducting market surveillance, DLCA upholds economic stability 54 and consumer protection during vulnerable periods. 55 3. Monitoring for Unfair Business Practices. The Unfair Business Practices Act is 56 designed to protect consumers from fraudulent activities, misrepresentation, and 57 contracts that impose unreasonable burdens. This law prohibits deceptive 58 marketing tactics, hidden fees, and unfair terms that businesses may use to take 59 advantage of customers. DLCA plays a vital role in enforcing these regulations by 60 investigating consumer complaints, by taking action against violators, and 61 promoting fair competition. Ensuring that businesses operate with integrity, this act 62 helps maintain consumer trust and prevents financial harm caused by unethical 63 business practices. 64 4. Truth in Pricing Law. The Truth in Pricing Law mandates that businesses provide 65 transparent pricing and uphold their advertised promotions. This regulation ensures 66 that consumers are not misled by hidden costs, unclear labelling, or false 67 advertising. Retailers must display accurate prices on shelves, menus, and 68 promotional materials, allowing consumers to make informed purchasing 69 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 5 decisions. DLCA enforces compliance by conducting inspections, reviewing 70 advertisements, and addressing consumer complaints regarding deceptive pricing 71 practices. This law is essential in promoting honesty in commerce and preventing 72 misleading sales tactics. 73 Through routine inspections, compliance audits, and investigative operations, 74 DLCA actively monitors the marketplace to detect and deter violations of consumer 75 protection laws. These enforcement actions help identify businesses engaging in fraudulent 76 practices, price manipulation, or non-compliance with regulatory standards. Regular 77 oversight ensures that businesses adhere to fair trade principles, fostering a competitive 78 and ethical economic environment. By taking proactive measures, DLCA not only 79 penalizes violators but also educates businesses and consumers about their rights and 80 responsibilities, strengthening overall consumer confidence in the market. 81 82 Price Monitoring During Price Freezes and Emergency Preparedness 83 The Department requires businesses to submit monthly price information on 84 essential goods, including fuel, food, and building materials, to name just a few, to ensure 85 fair pricing across the territory in the event of an emergency order and subsequent price 86 freeze. Once an emergency declaration is issued by the Governor in times of an 87 emergency—such as hurricanes, economic disruptions, or public health crises— DLCA 88 issues a price freeze order and plays a critical role in enforcing price control measures, 89 preventing unscrupulous price hikes or exporting necessary goods that are needed to aide 90 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 6 in recovery or response efforts. If this tedious, but necessary, function did not occur it could 91 result in the exploitation of vulnerable consumers and artificial supply shortages of. 92 By issuing consumer advisories and maintaining price control regulations during 93 times of disaster or economic uncertainty, our efforts help stabilize market conditions and 94 protect residents from financial exploitation during times of crisis. 95 96 Consumer Education and Public Awareness 97 Education is a fundamental pillar of consumer protection. Though, admittedly, our 98 staffing constraints have been a significant impediment to our ability to conduct these types 99 of community engagement activities as regularly as we’d like. Despite this, the DLCA 100 remains committed to empowering consumers, supporting businesses, and protecting the 101 public from fraudulent activities. Through community engagement, educational initiatives, 102 and strategic partnerships, the Department has worked diligently to enhance consumer 103 awareness, promote fair business practices, and provide essential regulatory support. From 104 public awareness campaigns to interactive webinars and community fairs, these outreach 105 activities have strengthened the Department’s role in ensuring transparency, 106 accountability, and consumer protection throughout the Virgin Islands. Over the past two 107 years, the Department of Licensing and Consumer Affairs has actively engaged with the 108 community through a variety of educational initiatives, consumer protection efforts, and 109 business support programs, including, but not limited to the following: 110 July 2023: National Tape Measure Day Educational Tour. The Department 111 celebrated National Tape Measure Day with an educational tour highlighting the history 112 and significance of the tape measure. Stops included St. Croix Christian Academy Summer 113 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 7 Camp and Inner Changes for Girls and Boys Council, Inc. Summer Camp, with the event 114 broadcasted on the Government’s Public Access Channel. The initiative culminated in a 115 live broadcast and cash prize giveaway on WJKC Isle 95 FM, engaging the community in 116 a fun and informative way. 117 August 2023: AARP Live Webinar – Fraud in the Aftermath of a Disaster. The 118 Department collaborated with AARP State Offices in the Virgin Islands and Puerto Rico 119 to host an interactive webinar aimed at educating residents on fraud prevention following 120 natural disasters. Expert speakers from FEMA, the FBI, and local consumer affairs 121 agencies discussed common post-disaster scams, including fake charities and unlicensed 122 contractor fraud. The webinar provided attendees with practical strategies, local resources, 123 and insights to protect themselves from fraudulent activities during recovery efforts. 124 September 2023: 2023 Conference on Aging. During the 2023 Conference on 125 Aging, the Department partnered with Legal Services of the Virgin Islands, Disability 126 Rights Center, Women’s Coalition of St. Croix, and other agencies to educate older 127 residents on fraudulent practices, particularly those targeting seniors through unlicensed 128 contractor scams. The presentation emphasized consumer rights and preventive measures 129 to safeguard against financial exploitation. 130 October 2023: Youth Can Make a Difference – World Food Day. As part of the 131 annual World Food Day events, the Department partnered with the University of the Virgin 132 Islands’ School of Agriculture Cooperative Extension Service to facilitate the official food 133 weigh-in station. A DLCA representative and certified scale were stationed under a large 134 tent at UVI’s Albert A. Sheen Campus on St. Croix, ensuring the accurate measurement of 135 locally harvested produce. 136 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 8 November 2023: DLCA Discusses Water Price Freeze on Isle 95’s Big Fat 137 Morning Show. In a continued effort to protect consumers, the Virgin Islands Department 138 of Licensing and Consumer Affairs (DLCA) joined The Big Fat Morning Show on Isle 95 139 to discuss its response to the water contamination crisis. During the segment, DLCA 140 representatives highlighted the price freeze on bottled water and water-related products 141 issued in October 2023. This emergency measure was implemented following Governor 142 Albert Bryan Jr.’s declaration of a state of emergency due to reports of contaminated water 143 from the Virgin Islands Water and Power Authority (WAPA). The price freeze aimed to 144 prevent price gouging and ensure that residents had access to affordable, clean water during 145 the crisis. DLCA urged consumers to report any violations and reaffirmed its commitment 146 to enforcing fair pricing and protecting the community. 147 March 2024: Consumer Protection Week (March 3 – 9, 2024). The Department 148 led National Consumer Protection Week with multiple outreach events aimed at educating 149 the community on consumer rights and fraud prevention. St. Joseph High School’s 12th- 150 grade class participated in an informative seminar, while residents of Flambouyant Gardens 151 and Sunny Isle Housing attended Fraud Protection workshops to learn about common 152 scams. The week concluded with a dynamic Zoom webinar, where industry experts shared 153 insights on safeguarding consumer rights. 154 April 2024: Consumer Education Workshop at Flamboyant Gardens for the 155 Elderly. In April 2024, the Consumer Protection Unit returned to Flamboyant Gardens for 156 the Elderly to engage residents in an informative discussion on pricing transparency and 157 store policies. During the session, the team provided insights into fair pricing practices, 158 common retail policies, and consumer rights when making purchases. Attendees had the 159 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 9 opportunity to ask questions about price matching, refund and return policies, and how to 160 identify potential overcharges. The presentation aimed to equip seniors with the knowledge 161 needed to make informed purchasing decisions and confidently navigate the marketplace. 162 October 2024: FTC Webinar – Fighting Consumer Fraud & Identity Theft. 163 The Department joined the Federal Trade Commission (FTC), AARP, Social Security 164 Administration (SSA), and Better Business Bureau (BBB) for a webinar on consumer fraud 165 and identity theft in the Virgin Islands. The presentation covered unlicensed construction 166 contractor scams, identity theft, data breaches, and credit freezes, equipping attendees with 167 tools to recognize and prevent fraudulent activities. 168 February 2025: The DLCA Goes to the Fair – Agrifest 2025 For the first time, 169 the Department had an official presence at Agrifest 2025, engaging directly with the 170 community. The team provided business licensing assistance, consumer protection 171 education, and regulatory guidance to attendees. The event allowed local entrepreneurs and 172 consumers to learn more about DLCA’s role in supporting businesses and protecting 173 consumer rights in the Virgin Islands. 174 The Department is actively planning its Consumer Protection Week 2025 (March 175 2–8) and Older Americans Month (May 2025) outreach initiatives, aiming to provide 176 valuable consumer education and community engagement opportunities to empower and 177 protect residents across the Virgin Islands. Through these initiatives, the Department has 178 reaffirmed its commitment to consumer empowerment, fair business practices, and 179 regulatory excellence across the Virgin Islands. 180 We continue to aim to be more engaging with the public, to host workshops and 181 town hall meetings that allow us to educate consumers on these very important topics such 182 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 10 as identifying fraudulent business practices, understanding warranties, consumer contracts, 183 and refund policies and the process for filing consumer complaints and seeking legal 184 recourse when necessary. By empowering consumers with this knowledge, we will 185 enhance their ability to make informed decisions and protect themselves from unfair 186 practices. 187 188 Business Compliance and Licensing Regulations 189 Consumer protection is intrinsically tied to business compliance. DLCA ensures 190 that all businesses operating in the U.S. Virgin Islands adhere to licensing and regulatory 191 requirements. Additionally, our Consumer Protection and Weights & Measures Divisions 192 conduct regular compliance checks to verify that businesses are following established laws 193 regarding product pricing, advertising, and contractual obligations. This creates a business 194 environment that is both fair and competitive while protecting consumers from 195 unscrupulous actors. 196 197 Weights and Measures 198 The Weights and Measures regulations under Title 12A of the U.S. Virgin Islands 199 Code serve as a fundamental consumer protection mechanism to ensure fairness, accuracy, 200 and transparency in commercial transactions. These laws establish standardized 201 measurement practices for goods sold by weight, volume, or count, safeguarding both 202 consumers and businesses from fraud, errors, or misrepresentation. 203 The law mandates that all weighing and measuring devices used in trade—such as 204 fuel pumps, grocery counter scales, and scales used for packaging labels, such as the scales 205 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 11 used in most deli or meat packing applications—must be calibrated and certified to provide 206 accurate readings. This prevents consumers from being overcharged due to faulty or 207 tampered with equipment. The law is particularly crucial in industries such as grocery and 208 fuel, where discrepancies in weight and volume measurements can have significant 209 financial and safety implications. For example, inaccurately measured fuel at gas stations 210 or produce at a grocery store can lead to substantial economic losses for consumers. By 211 using territory specific standards that can be traced back to the National Institute of 212 Standards and Technology, we ensure a consistent quantity, either volume or weight, is 213 being dispensed or sold no matter who is making a purchase or where the purchase is made. 214 In summary, the enforcement of standard weights and measures helps combat 215 fraudulent business practices, such as short weighting, where customers receive less 216 product than they paid for. Regular inspections by DLCA help detect and correct such 217 violations. Through routine inspections and compliance monitoring, the Division of 218 Weights & Measures conducts routine inspections of businesses and their 219 weighing/measuring devices to ensure compliance with Title 12A. Violators can face 220 penalties, fines, and corrective actions to prevent repeat offenses. These inspections serve 221 as a deterrent against fraudulent practices and should give consumers confidence that the 222 products they are purchasing by weight or volume are accurate to an acceptable degree and 223 consistent across every business under our jurisdiction. 224 225 Clearing Up the Misconceptions 226 It is important to clarify that while DLCA does enforce consumer protection laws, 227 its role is limited to regulatory enforcement related to licensed business compliance, and 228 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 12 fair-trade practices. DLCA’s authority includes addressing consumer complaints related to 229 mispricing items, business malpractice, and regulatory violations, but it does not extend to 230 prosecuting criminal offenses such as fraud. The department remains committed to 231 ensuring a fair and transparent marketplace but does not possess the resources or mandate 232 to conduct criminal fraud investigations. 233 DLCA’s Division of Consumer Protection does not conduct investigations or 234 provide advisement in cases involving fraud as fraud is classified as a criminal offense, and 235 complaints or reports concerning fraudulent activities fall outside of DLCA’s limited 236 jurisdiction. Instead, complainants who wish to report fraud are directed to the appropriate 237 enforcement authorities, primarily the Federal Trade Commission (FTC) or, in some 238 instances, the White-Collar Crimes Unit of the Virgin Islands Police Department (VIPD). 239 This distinction is important, as DLCA’s primary role focuses on regulatory oversight and 240 consumer protection within the framework of business compliance, rather than criminal 241 investigations. 242 When a consumer submits a complaint to DLCA that appears to involve fraudulent 243 activities—such as identity theft, credit card fraud, or any form of willful misrepresentation 244 aimed at securing unlawful gains, the Department refers the complainant to the FTC or 245 other local resources that have the jurisdiction and authority to investigate, pursue and 246 prosecute these criminal allegations. The FTC specializes in addressing fraud-related 247 consumer issues and has the authority to investigate deceptive trade practices on a federal 248 level. The FTC provides consumers with the necessary resources to report fraud, conduct 249 inquiries, and take appropriate legal actions against perpetrators. DLCA does not have 250 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 13 investigative authority or enforcement capabilities in these matters, making the FTC the 251 most appropriate agency to handle such cases. 252 In situations where fraud appears to have been committed within the Virgin Islands 253 and has a criminal element that requires local law enforcement intervention, complainants 254 are instead directed to the White-Collar Crimes Unit of the VIPD. This unit is equipped to 255 handle financial crimes, including embezzlement, wire fraud, and other forms of economic 256 deception that require forensic analysis and legal prosecution. Since fraud cases often 257 involve criminal intent and potential prosecution under Virgin Islands law, DLCA ensures 258 that these matters are promptly forwarded to the relevant law enforcement authorities for 259 further investigation. 260 In addition to clarifying DLCA’s stance on fraud investigations, it is also necessary 261 to address public misconceptions regarding DLCA’s role in price monitoring and market 262 analysis. While DLCA provides a "Shopping Basket" that reflects current pricing of goods 263 at a given time, it does not conduct a "Market Basket Survey" intended for long-term 264 economic analysis. The Shopping Basket is designed to offer consumers insight into the 265 cost of selected goods at specific points in time, but it is not structured for month-over- 266 month or year-over-year comparative analysis. 267 The purpose of the DLCA’s Shopping Basket is to provide transparency in pricing 268 and to inform consumers of the cost of everyday essential goods at various retailers. 269 However, the items included in the Shopping Basket are rotated and changed regularly, 270 which means that the data collected does not allow for direct price comparison across 271 different time periods. This flexibility in selection is intentional, as it enables DLCA to 272 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 14 highlight a diverse range of consumer goods and ensure that pricing information remains 273 relevant to current market conditions. 274 For those seeking Consumer Price Index (CPI) information or a formal Market 275 Basket Survey that tracks economic trends over time, the Bureau of Economic Research 276 (BER) is the designated agency responsible for compiling such data. BER conducts 277 structured analyses that account for inflation, cost-of-living changes, and other economic 278 indicators that impact the financial well-being of consumers in the Virgin Islands. These 279 reports provide an official measurement of economic trends and are the appropriate 280 resource for individuals or organizations interested in understanding long-term pricing 281 fluctuations. 282 It is crucial for consumers and businesses alike to understand the distinction 283 between DLCA’s Shopping Basket and BER’s Market Basket Survey. While DLCA 284 remains committed to consumer advocacy and price transparency, its role does not extend 285 to producing long-term economic data or CPI reports. Misinterpretation of DLCA’s 286 Shopping Basket as an economic indicator can lead to misunderstandings about price 287 trends and market stability. For precise statistical analysis and comprehensive price 288 comparisons, BER’s data should be referenced. 289 DLCA remains committed to its mission of ensuring fair business practices, 290 consumer protection, and pricing transparency. However, its functions are clearly defined, 291 and any inquiries or concerns that fall outside its jurisdiction, including fraud investigations 292 and long-term economic analysis, are appropriately redirected to the relevant agencies. 293 Consumers who require assistance in these areas are strongly encouraged to contact the 294 appropriate authorities to obtain accurate information and proper resolutions. 295 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 15 Status of Capital Projects and Upcoming Initiatives 296 In addition to our enforcement and consumer protection initiatives, the DLCA 297 remains committed to improving its infrastructure and operational capabilities through 298 strategic capital projects and initiatives. These efforts are essential to enhancing service 299 delivery, increasing efficiency, and ensuring that our facilities and technology meet the 300 needs of our employees, businesses and consumers across the U.S. Virgin Islands. 301 Facility Upgrades and Expansion – DLCA is exploring opportunities to expand its 302 office footprint to improve operational efficiency and accommodate growing service 303 demands. The modernization of office spaces will support increased staffing needs and 304 facilitate more effective consumer engagement, particularly for the DLCA and the Office 305 of Cannabis Regulation (OCR) staff. 306 Digital Transformation & IT Infrastructure Enhancement. The DLCA recently 307 selected a vendor to redesign its website and implement an upgraded Business Licensing 308 Portal. This enhanced system will streamline application processing, improve turnaround 309 times, and expand the consumer complaint tracking system to provide real-time updates 310 and faster resolution of disputes. 311 Food, Fuel, and Housing Study: Cost of Living Analysis. As part of the Department 312 of Licensing and Consumer Affairs’ (DLCA) commitment to consumer protection and 313 economic transparency, we are actively engaged in research efforts to analyze market 314 conditions affecting the affordability of essential goods and services. One such initiative is 315 the Food, Fuel, and Housing Cost Analysis, which aims to provide a comprehensive 316 assessment of cost trends in these critical areas. 317 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 16 A Food and Housing Cost Analysis began in the Virgin Islands in April 2017, but the 318 "First Report" lacked thoroughness due to the unavailability of certain data. Recently, 319 funding has been secured to resume the analysis, with a new performance period beginning 320 on December 31, 2024, and concluding on December 31, 2026. 321 This renewed analysis will not only focus on the cost of food and construction materials 322 but will also delve into the fuel price trends and costs of other essential goods and services 323 that impact the cost of living, such as labor and energy costs in the territory. By expanding 324 the scope and ensuring the availability of necessary data, the analysis aims to provide a 325 comprehensive understanding of the factors influencing the cost of living in the Virgin 326 Islands. 327 328 Conclusion and Legislative Considerations 329 I want to thank you for allowing our team to clear up these common 330 misunderstandings, by maintaining a clear distinction between its regulatory functions and 331 the responsibilities of other agencies, DLCA ensures that consumers receive accurate 332 guidance, and that fraud cases or economic research inquiries are handled by the 333 appropriate organizations. This approach helps prevent misinformation and ensures that 334 consumers can access the right resources for their specific needs. 335 I’d like to close with the following, we understand that effective consumer 336 protection is a shared responsibility, not only with the legislature and the executive 337 branches of government, but with every individual consumer throughout the Territory. 338 Whether you reside here or are here on business or leisure, we all share in the responsibility 339 of understanding our rights as consumers and reporting any activity that you feel may be 340 Testimony before Committee on Government Operations, Veterans Affairs, and Consumer Protection February 24, 2025 17 in violation of the laws of the US Virgin Islands. DLCA remains committed to working 341 alongside the Legislature to enhance our existing laws and improve enforcement 342 mechanisms. As we look ahead, we welcome discussions on strengthening consumer 343 protection policies, increasing funding for enforcement initiatives, and leveraging 344 technology to streamline complaint processing and market monitoring. 345 We appreciate the support of Governor Albert Bryan Jr., the Bryan/Roach 346 Administration and the Legislature in these efforts and stand ready to provide any 347 additional information necessary to advance consumer rights in the U.S. Virgin Islands. 348 Thank you for the opportunity to testify today. We are happy to answer any questions you 349 may have. 350