South Louisiana Flooding

As we learned during the flooding in South Louisiana in August of 2016, the help of our neighbors and friends in Texas and around the country strengthened us, and allowed our communities to rebuild and flourish. That’s part of the reason Kean Miller donated a total of $25,000 this week to the Greater Houston Community Foundation, the United Way of Greater Houston, and the American Red Cross in lieu of our fall client event originally scheduled for today, September 16th.

Our thoughts and prayers are with our friends, colleagues and peers in Houston and Southeast Texas today, and in the weeks and months ahead.

People First.

By Maureen N. Harbourt

Effective August 25, 2017, the Secretary of the Department of Natural Resources authorized the performance of activities within the Louisiana Coastal Zone necessary to prevent or to mitigate damages associated with Hurricane Harvey.  In the event that new construction is needed for such purposes, an after-the-fact Coastal Use Permit application might be required.  The Secretary’s message can be found here.

The Secretary noted that the emergency use provisions of the Coastal Use Permit Rules and Procedures (LAC 43:I.723.B.3) are activated by his determination that potential damage to energy and other infrastructure in the Louisiana Coastal Zone by Hurricane Harvey may result in an emergency situation and that damage resulting in a threat to life, property, or the environment.  (The Coastal Use Permit rules are available under Louisiana Administrative Code Title 43, Part I here.)  Further, the Secretary has determined that due to the potential threat that Hurricane Harvey may cause impacts of statewide significance, all emergency uses under the jurisdiction of the Louisiana Coastal Resources Program which are necessitated for preparation, response to, and the aftermath of Hurricane Harvey shall be considered uses of state concern (as distinguished from uses of local concern).

The LDNR stated: “Because of the potential for widespread damage associated with Hurricane Harvey, the Department of Natural Resources is temporarily modifying its usual emergency authorization procedures for storm related repair/restoration projects located in the Coastal Zone.  This modification applies ONLY to those activities needed to restore infrastructure.  Unless this notice is renewed, it shall expire on September 15, 2017.”

LDNR requires that those using this emergency authority are to provide the Department with notification via letter, email or fax as soon as possible for documentation purposes.  The notification should include:  the name of the entity undertaking the activity; a description of the work performed; a vicinity map showing the location of the emergency work; and project coordinates (lat/long) if available.  Notifications to LDNR should be directed to:  Karl Morgan, P.O. Box 44487, Baton Rouge, LA 70804-4487 (Fax: 225-342-9439) (E-mail: karl.morgan@la.gov).

By Maureen N. Harbourt

Just a quick reminder that in 2007, the Louisiana State Police (“LSP”) adopted regulations requiring special reporting requirements for persons “engaged in the transportation of hazardous materials by railcars, vessels, or barges, or the temporary storage of hazardous materials in any storage vessel not permanently attached to the ground” if that activity is within “a parish affected, or projected to be affected, by a Category 3 or higher hurricane for which a mandatory evacuation order has been issued.”  LAC 33:V.11103.  Hazardous materials are those materials listed in 40 C.F.R. Part 355, Appendix A.  Temporary storage is defined as storage in a portable container, and excludes any storage in pipelines or any other storage vessel permanently attached to the ground.

At the present time (11 a.m, CST, August 25, 2017),  Hurricane Harvey is a Category 2 storm with maximum sustained winds of 110 mph; but, it is projected that Harvey will strengthen to a Category 3 Hurricane by the time of landfall, which is projected to occur between Corpus Christi and Houston, Texas, late evening on August 25, 2017.  It is also projected that the hurricane will affect southwest and south central Louisiana parishes.  In fact, the Governor of Louisiana has issued an executive order that puts the entire State of Louisiana under a declaration of emergency.  Yesterday evening, Cameron Parish entered a mandatory evacuation order for all areas of the parish south of the Intracoastal Waterway, effective at 6 a.m., CST, August 25, 2017.   We are not aware of any mandatory evacuation orders for any other Louisiana parishes at this time.  The following is a link to all parish emergency response offices which will provide contact information to inquire about any orders issued: http://gohsep.la.gov/about/parishpa.

If a mandatory evacuation order is issued for any Louisiana parishes due to a Class 3 or higher category hurricane, the rules (LAC 33:V.11105) require the following:

  • Notification shall be given to the DPS, via electronic submittal, to the 24-hour Louisiana Emergency Hazardous Materials Hotline email address at emergency@la.gov within 12 hours of a mandatory evacuation order issued by the proper parish authorities.
  • For persons engaged in the transportation activities noted above, the report must include the following information:
    • the exact nature of, and the type, location, and relative fullness of the container (i.e., full, half-full, or empty) of all hazardous materials that are located within a parish subject to the evacuation order;
    • the primary and secondary contact person’s phone, e-mail, and fax number; and
    • whether the facility will be sufficiently manned such that post-event assessments will be performed by company personnel (as soon as safely practicable) and that any releases and/or hazardous situations will be reported in accordance with existing Louisiana Department of Environmental Quality (LDEQ) and State Police reporting requirements.
  • For those materials that are stored, it shall be necessary to only report those hazardous materials that were not reported in the annual SARA inventory report (40 CFR Parts 312/313) and those that are in excess of what is typically stored at the facility.

In addition to the notification to the LSP, “within a reasonable period of time” persons subject to the rule “shall perform a post-event assessment of those hazardous materials that were actually present in the affected area and to what degree, if any, those materials were compromised by said event and their current condition.”  Such information must be available for review by both the LSP and the LDEQ shall have access to this information.

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By Trippe Hawthorne

One of the activities regulated and licensed by the Louisiana State Licensing Board for Contractors is Mold Remediation.  Any person engaging in or holding herself/himself out as engaging in mold remediation must have a mold remediation license issued by the Louisiana State Licensing Board for Contractors.  Persons violating that prohibition are subject to administrative and criminal sanctions.

One of the requirements for a mold remediation license is completing four hours of instruction in Louisiana’s Unfair Trade Practices and Consumer Protection Law, given by a board-approved provider. Kean Miller is a board approved provider, and one of the ways Kean Miller is helping the region recover from the 2016 flooding is offering this training on an on-demand basis.  If you are interested in Kean Miller’s board approved four hour course on Louisiana’s Unfair Trade Practices and Consumer Protection Law, please contact Steve Boutwell at (225) 389-3736 or steve.boutwell@keanmiller.com

 

 

Amanda Wynn looks over historical court documetns that were rescued from the flooded basement of the Milwaukee County Historical Society Friday morning. Whynn, a curator at the Old World Third St. facility, staff and volunteers layed out wet records and artifacts that had been stored in the facilities basement. JOHN KLEIN/JKLEIN@JOURNALSENTINEL.COM

By Ben K. Jumonville

For several businesses in the Baton Rouge area, one of the many implications of the recent flooding is the loss of business records that are subject to retention requirements under various state and federal laws. In light of the destruction of many such records in the flood, a question arises as to the applicability of these retention requirements and the steps a business should take to maintain compliance with the law.

Under federal laws, businesses generally remain subject to their record-keeping obligations, but the IRS and the Department of Labor have provided some guidance in the past on how businesses who have lost records in a natural disaster can comply with the law.

With respect to records required to substantiate business losses and other tax deductions, the Internal Revenue Code addresses the loss of records due to circumstances beyond the taxpayer’s control. Specifically, Treasury Regulation § 1.274-5T provides that “[w]here the taxpayer establishes that the failure to produce adequate records is due to the loss of such records through circumstances beyond the taxpayer’s control, such as destruction by fire, flood, earthquake, or other casualty, the taxpayer shall have a right to substantiate a deduction by reasonable reconstruction of his expenditures or use.”

When claiming this exception, the taxpayer must be diligent about the reconstruction of records. Corroborating records or testimony regarding the specific expenses incurred is required, and a deduction will be denied if a business makes no attempt to recreate its destroyed records. Similarly, if the reconstruction is uncorroborated or perceived as unreliable, the deduction can be denied for lack of substantiation.

According to the Disaster Resource Guide published by the IRS, a business seeking to create a “reasonable reconstruction” of its lost business records should obtain copies of invoices from its suppliers, copies of bank statements, and copies of the last year’s federal, state and local tax returns, including payroll tax returns and business licenses, as these will reflect gross sales for a given time period.

In addition to reconstructing destroyed records, the Tax Court has indicated that it is necessary to document the extent of the destruction at the facility where the records were stored and the extent of the records that were lost. For instance, where the taxpayer did not provide evidence as to flood water damage at his record-keeping facility, the Tax Court denied the deduction, observing that it was not obligated to accept a taxpayer’s “unverified and self-serving testimony.” Darling v. C.I.R., 89 T.C.M. (CCH) 1334 (Tax 2005).

There is somewhat less guidance with respect to a business’s obligations to maintain records related to employees and employee benefit plans under applicable federal laws such as ERISA or COBRA. Generally speaking, these laws do not anticipate how to apply the record-keeping rules when a natural disaster occurs and records and businesses are destroyed.

Although there is no statutory guidance on the record-keeping requirements under these laws after a natural disaster, the Department of Labor has previously considered this issue in advisory opinions and in rules published in the Code of Federal Regulations. According to the DOL, the loss or destruction of records required to be maintained under ERISA does not discharge the business from its statutory duty to retain such records. 29 CFR Part 2520.

The DOL has also indicated that there is a general duty to reconstruct the records required to be retained under ERISA. That said, whether lost or destroyed records can, or should be, reconstructed and whether the persons responsible for the retention of records are, or should be, personally liable for the cost incurred in connection with the reconstruction of records is “necessarily dependent on the facts and circumstances of each case.” DOL Advisory Opinion 84-19A (April 26, 1984).

For instance, if reconstruction cannot be accomplished without excessive or unreasonable cost, a company would not be under a duty to reconstruct or attempt to reconstruct the lost or destroyed records. Further, if a company has access to other documents from which the lost or destroyed records could reconstructed and such other documents would be available to the company for the remainder of the requisite retention period, reconstruction of the destroyed records would not be required, provided that the company “make such agreements and arrangements necessary” to ensure that such other documents would remain available. DOL Advisory Opinion 84-19A (April 26, 1984).

In sum, if you or your business lost records in the flood which were subject to retention requirements, the best course of action is to undertake reasonable efforts that demonstrate good faith compliance with the law. Such steps include documenting the destruction done to the building in which your records were stored, the types of records that were kept prior to the flood, and the measures taken to remediate the problem. To the extent reasonable, make a good faith effort to reconstruct the lost records. Ultimately, if a business can show that it took the most reasonable and appropriate steps to comply with its record-keeping requirements, it may be able to persuade the IRS or other governmental authority to waive applicable sanctions.

For more helpful information on record reconstruction, the Disaster Resource Guide published by the IRS contains specific steps that individuals and businesses can take to reconstruct their records.

 

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By Devin Ricci

The City of Baton Rouge and the surrounding areas have been struck by devastating floods.  Thousands were stranded. The roadways to their homes are flooded and most impassable.  Flooding is not new to Louisiana.  Just over ten years ago, the state experienced one of the most devastating natural disasters on record with Hurricane Katrina.  Since then, numerous other storms have taken swipes at the state –  Gustav, Rita, Isaac, to name a few. 2016 has been the year of unnamed storms thus far for the citizens of Louisiana. Alexandria, Monroe, Shreveport, and Lake Charles each flooded in the months preceding the “Great Flood of 2016” currently affecting Baton Rouge.

Storms are uncontrollable, but as a patent attorney, I turn to technology that we can control for assistance in the aftermath. There is a glimmer of hope that we are not alone, that similar events throughout the world have resulted in great innovations some of which are currently being implemented throughout Baton Rouge to speed the recovery and rescue stranded citizens.  These innovations are far and wide, including solar technology, mobile cell phone towers, power stations, water filtration apparatuses. Even the oft-hated drones are being used to locate people and assess flooding from vantage points that would have previously been limited to helicopters.

One of the more popular examples of these innovations is the Aqua Dam by Layfield, which is being used across the area to block water from roadways.  We have all heard the moniker that you cannot fight fire with fire; the Aqua Dam is proof, however, that you may be able to hold off water with water.  Patented as U.S. Patent nos. 8,840,338 in 2014 and 9,297,133 in 2016, the Aqua Dam is a portable reservoir body apparatus comprising a plurality of interior bladders contained within an exterior housing (the outer tube).  The interior bladders are filled with fluids causing them to expand and fill the cavity of the outer tube.  The unit further comprises a series of fasteners to maintain its shape, thereby creating a displacement dam which prevents the passage of water.  These units are being used on the interstate, major highways and bridges.  In most instances, the flood water is being pumped straight from the road into the dam being formed to keep the water at bay, opening the roadways.

To the folks at Layfield, we salute you and appreciate your innovative contributions.  The Aqua Dam structures have and will continue to open our roadways, allowing evacuees to escape and rescuers to enter flooded areas. To others, and particularly the citizens of Louisiana, please keep innovating.  We cannot prevent all future flooding, but we can help diminish their impact with innovations like these.

 

Leslie Andermann Gallagher surveys the flood damage to her home on August 17, 2016 in Sorrento, Louisiana. Last week Louisiana was overwhelmed with flood water causing at least twelve deaths and thousands of homes damaged by the flood waters. Joe Raedle, Getty Images

By Carrie Tournillon

If your home has been damaged by the recent floods in southeast Louisiana, you will need to submit a flood claim, if you have flood insurance.  Steps for submitting the claim and reaching agreement with an adjuster on the dollar amount for the covered loss or appealing denial of payment can be found here.

However, for the many homeowners who do not have flood insurance or are under-insured, financial assistance is available through FEMA’s Individuals and Households Program (“IHP”).  The IHP provides financial assistance and direct services, such as temporary housing, to those who have necessary expenses and serious needs as a result of a disaster or emergency, if they are unable to meet the needs through other means (like flood insurance).

Financial assistance through the IHP can be used to repair damage to a primary residence caused by disasters or to replace a disaster-damaged home that is uninsured or under-insured.  Examples of items covered for repair include:  foundation and roof; windows and doors; floors, walls, and ceilings; septic or sewage system; well or other water system; heating, ventilating, and air conditioning system; electrical, plumbing, and gas systems; and entrance and exit ways from the home, including privately owned access roads.

The IHP also offers Other Needs Assistance that can be used to provide financial assistance to replace or repair essential household items, such as furnishings and appliances.  Miscellaneous items purchased or rented to assist with recovery or cleaning efforts, such as dehumidifiers, can be covered as well.

Additional information on FEMA’s Individuals and Households Program and eligibility can be found here.

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By Daniel Stanton

By emergency declaration issued August 18, 2016, the Commissioner of the Louisiana Department of Insurance adopted Emergency Rule 27. Emergency Rule 27 allows the Department of Insurance to suspend certain statutes in the Louisiana Insurance Code and the rules and regulations promulgated under those statutes that may affect families and business affected by the current flood crisis in Louisiana.

While Emergency Rule 27 suspends many provisions of the Louisiana Insurance Code, most of the suspended provisions affect the ability of an insurer to cancel, terminate, non-renew, or non-reinstate a policy of insurance. One of its most significant provisions provides that an insurer may not terminate, cancel, or non-renew a policy of insurance as a result of the “inability of an insured . . . from complying with any policy provisions,” this includes non-payment of premiums. Insurers are further forbidden from imposing any interest, penalty, or other charge as a result of the enactment of Emergency Rule 27. Furthermore, the rule extends to September 10, 2016, any deadline for the submission of evidence or the completion of any act related to any claim for coverage under a policy of insurance made prior to August 12, 2016.

Emergency Rule 27 currently applies to policy holders residing in the following parishes: Acadia, Allen, Ascension, Avoyelles, Cameron, East Baton Rouge, East Feliciana, Iberia, Iberville, Jefferson Davis, Lafayette, Livingston, Point Coupee, St. Helena, St. James, St. John the Baptist, St. Landry, St. Martin, St. Tammany, Tangipahoa, Vermillion, Washington, West Baton Rouge, and West Feliciana. Emergency Rule 27 applies to any policy of insurance in effect as of 12:01 a.m. on August 12, 2016, and will remain in effect through September 10, 2016.

Additional information and a copy of Emergency Rule 27 may be found on the Louisiana Department of Insurance’s website.

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By Alan J. Berteau

President Obama has declared 20 parishes in Louisiana to be Major Disaster Areas.  The presidential declaration recognizes the obvious, grim reality of the tragedy in Louisiana, but more importantly enables flood victims in these parishes to apply for federal disaster assistance from the Federal Emergency Management Authority.  A previous article on the Kean Miller Louisiana Law Blog addressed this issue.

While you may obtain financial assistance from FEMA, a federal declaration of disaster does not suspend the payment of your mortgage note, rent, car payments, student loan payments, credit card payments, or payments on open accounts. Many lenders and creditors are offering assistance to victims of the flood but there are five important general rules to bear in mind:

  1. The assistance is not automatic; you must apply for it. If you ignore and fail to pay a debt, you will probably not be able to avoid the consequences of the non-payment later by claiming inability to pay due to flooding.
  2. You should work directly with the lender or creditor on the debt in question. Avoid third-party intermediaries. You and your creditor share an interest in avoiding default on your obligation. Third parties do not share that interest. You need to be sure you know exactly what information the creditor gets from you, and exactly what the creditor is offering to you.
  3. Save all records associated with your request for assistance, including all correspondence, e-mails, forms and, if possible, a log of telephone conversations.
  4. Once you have applied for assistance, do not hesitate to follow up with the creditor on a recurring basis.
  5. You should be sure that you completely understand what your future obligation will be on the debt in question. For example, at the expiration of a grace period, will you owe a balloon payment to cover payments deferred? Will your payments increase in the future to cover temporary reductions? Will your deferred obligation include interest or fees incurred during the grace period? You should get, in writing, from your creditor a clear explanation of what you will owe, and when you have to pay what you owe, after the expiration of the relief period.

Both Freddie Mac and Fannie Mae have implemented disaster relief guidelines.[1]  You can determine if your loan is a FHLMC or FNMA loan by visiting the “look-up” pages on the Freddie Mac and Fannie Mae websites.  To apply for relief, however, you must contact your loan servicer (the bank or other entity to which you make your mortgage payments).  FHLMC and FNMA essentially direct the loan servicer to help you; the servicer will follow that directive. The specific assistance rendered will be decided by the loan servicer. The assistance may include forbearance (i.e., giving you additional time to catch up on late payments), reduction in your payments, and waiver or reduction of late fees, penalties. If the modification to your loan obligation is temporary, you must be sure you understand what your obligation will be upon the completion of that time (probably 12 months, or less).  The loan servicer is obligated to tell you what you need to know.  Your loan servicer is not required to provide you any specific relief; just because a neighbor received help of a certain kind does not mean you will receive the same help.  Freddie Mac and Fannie Mae websites offer an overview of the types of assistance available.

The Federal Housing Administration (FHA) is a government agency which insures millions of home loans.  On August 18, 2016, FHA directed the lenders who hold mortgage notes insured by FHA to help flood victims in the disaster areas:

HUD (U.S. Department of Housing & Urban Development) has instructed FHA lenders to use reasonable judgment in determining who is an “affected borrower.” Lenders are required to reevaluate each delinquent loan until reinstatement or foreclosure and to identify the cause of default. Contact your lender to let them know about your situation. Some of the actions that your lender may take are:

  • During the term of a moratorium, your loan may not be referred to foreclosure if you were affected by a disaster.
  • Your lender will evaluate you for any available loss mitigation assistance to help you retain your home.
  • Your lender may enter into a forbearance plan, or execute a loan modification or a partial claim, if these actions will help retain and pay for your home.
  • If saving your home is not feasible, lenders have some flexibility in using the pre-foreclosure sales program or may offer to accept a deed-in-lieu of foreclosure.

HUD Disaster Resources

Even if your home loan is not owned by Freddie Mac or Fannie Mae, or insured by FHA, you should contact your lender to see if it offers disaster assistance. Regions Bank, for example, has announced its intention to assist its customers who were victims of the flood. You can check Regions’ Disaster Resource Center for details. JP Morgan Chase announced that it is “automatically waiving late fees for mortgage, credit card, business banking and auto loans as well as overdraft, ATM and monthly service fees on deposit accounts through August.”  Other banks offering assistance include Whitney Bank and Iberia Bank.

You should assume that your lender or other creditor will offer you some type of assistance if you reside in the disaster area IF you contact the lender and qualify for the assistance. Lenders and other creditors may also offer assistance to individuals who work in the disaster area, even if they don’t live there.  You will only find out the assistance available to you by contacting your lender.

Farmers may be entitled to targeted financial assistance through various disaster relief programs administered by the Farm Service Agency of the U.S. Department of Agriculture.

Vehicle lenders are stepping up to offer relief as well.  Toyota Financial Services announced on August 16, 2016, that it is offering payment relief options to flood victims, including extensions and lease deferred payments.  Although we have not found specific announcements from other major vehicle lenders, it is reasonable to assume that others offer disaster relief.

We  have also found no specific announcements of assistance of credit card issuers, but if you anticipate difficulty in staying current on credit card obligations, contact the issuer and ask for disaster assistance.

The LSU College of Agriculture’s website offers an excellent compendium of disaster-related resources and links useful for any victim of flooding.

The Louisiana Office of Financial Institutions Website contains, among other resources, a list of agencies to contact for assistance.  Any third party entity listed on the LOFI webpage can be trusted (notwithstanding my general warning against reliance upon third parties in obtaining disaster assistance).

Your lenders and creditors are generally not required by law to offer disaster assistance. But lenders and creditors want to help flood victims manage their obligations while they cope with the more immediate challenges of safety, food, shelter, electricity, and medical needs. There is no guarantee that you will receive assistance from a given creditor, but you may rest assured you will not receive assistance if you don’t apply for it.

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[1] The Federal Home Loan Mortgage Corporation (“Freddie Mac”) and the Federal National Mortgage Association (“Fannie Mae”) are government-sponsored entities which together own or guarantee payment on approximately 60% of the home mortgage loans in the United States. There is a very good chance that your home mortgage note is owned by one of these “government-sponsored enterprises.” The entity to whom you actually pay your note is servicing the loan; it no longer owns the loan, if it ever did.

 

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By Kevin C. Curry and Carey J. Messina

Many employers have a number of employees who were affected by the August 2016 flooding event in Louisiana.  These employers are looking for means to assist their employees in recovering from this significant disaster.  Employers have a number of options for providing disaster relief assistance to their employees.

A number of employers are simply collecting funds internally or raising funds through gofundme™ or similar online fundraising platforms.

These types of internal or private fundraising methods are generally simple to set up and operate.  For tax purposes, these types of fundraising efforts are generally treated as non-deductible gifts to the employees from whoever makes the contributions to the funds.  Generally, true gifts are not treated as taxable income to the employees.  However, under certain circumstances, an employee may not be taxed on payments that are considered “qualified disaster relief payments” received from employers or other sources under Section 139 of the Internal Revenue Code.

Qualified disaster relief payments within the meaning of Section 139 include payments received (regardless of source) for the following expenses:

  1. Reasonable and necessary personal, family, living, or funeral expenses incurred as a result of a qualified disaster;
  2. Reasonable and necessary expenses incurred for the repair or rehabilitation of a personal residence due to a qualified disaster (a personal residence can be a rented residence or one owned);
  3. Reasonable and necessary expenses incurred for the repair or replacement of the contents of a personal residence due to a qualified disaster.

Qualified disaster relief payments do not include payments for expenses otherwise paid for by insurance or other reimbursements.  Furthermore, qualified disaster relief payments do not include income replacement payments such as payments for lost wages, lost business income or employment compensation.  Generally, a qualified disaster includes several types of disasters, one of which is a Presidentially declared disaster.  The August 2016 flood has been declared a qualified disaster in East Baton Rouge, Livingston and Ascension Parishes and several other surrounding parishes.

Often, donors wanting to make gifts to assist in relief situations will want to contribute to a charitable organization to obtain the benefit of an income tax charitable deduction or for other reasons (for example some private foundations or other charities can only make gifts to other charities).  In the disaster relief context, an employer can establish its own charitable organization under Section 501(c)(3) of the Internal Revenue Code to provide qualified disaster relief payments to its employees.  However, this requires the establishment of a non-profit organization that will qualify as either a private foundation or a public charity depending upon the funding source.  Furthermore, the qualification of the organization as a Section 501(c)(3) charity must be recognized with the IRS which requires some time (although the qualification can often be obtained on an expedited basis) and requires some costs to establish the charitable organization.

For those employers desiring to set up a charitable entity to make qualified disaster relief payments and give the donors the benefit of a charitable deduction, the Baton Rouge Area Foundation (a Section 501(c)(3) charity) will set up a fund as part of the Baton Rouge Area Foundation which can provide qualified disaster relief payments for an employer’s employees.  This allows an employer to set up a relief fund for which the contributions are deductible without incurring the costs and taking the time necessary to set up its own stand-alone fund.  The fund is administered by the Baton Rouge Area Foundation.  Anyone interested in establishing a fund with the Baton Rouge Area Foundation can contact Elizabeth Hutchison at ehutchison@braf.org or 225-381-7080 and can read more information about this option at www.employees1st.org.