The CFPB’s Final Report on Pre-Dispute Arbitration Clauses

by Davis Wright Tremaine LLP

CFPBFeb10v2On March 10, 2015, the CFPB issued its long-awaited Arbitration Study analyzing the use of pre-dispute arbitration provisions in connection with consumer financial products or services. In the 728-page report, as well as during a field hearing held the same day, the CFPB was critical of the use and effect of pre-dispute arbitration provisions in credit card agreements and other consumer financial contracts, particularly when compared to class-action lawsuits. In the coming months, the CFPB will likely use this report as the basis to adopt regulations restricting, if not entirely banning, the use of pre-dispute arbitration clauses in connection with consumer financial products and services. In the face of this potentially game-changing regulatory effort, industry representatives have quickly raised questions about the data underlying the CFPB’s report to undermine the agency’s conclusions, and will undoubtedly continue to scrutinize the report’s data and highlight any flaws as the CFPB considers issuing arbitration-related regulations.


Many contracts for consumer financial products and services include a “pre-dispute arbitration clause” that requires any dispute related to the contract be resolved through private arbitration rather than litigation. In addition, many arbitration clauses include “class waivers” that prohibit consumers from banding together with other similarly situated persons to file claims as a class rather than an individual. Consumer advocates have challenged these pre-dispute arbitration clauses as unfairly restricting basic consumer rights, such as the right to sue, while industry representatives have argued that arbitration represents a better, faster, and cheaper means of resolving disputes.

Section 1028(a) of the Dodd-Frank Act requires the CFPB to study and provide Congress with a report on the use of pre-dispute arbitration clauses in contracts for consumer financial products and services. The Dodd-Frank Act further authorizes the CFPB to issue regulations prohibiting or imposing conditions on the use of pre-dispute arbitration provisions in connection with consumer products or services, provided that such regulations are in the public interest and consistent with the findings of the CFPB’s study. See 12 U.S.C. 5518.

As we discussed in a previous post, the CFPB initiated a public inquiry in 2012 as a “preliminary step” in its study of consumer arbitration, seeking comments on the appropriate steps, methods, and data sources for the required study. The CFPB released preliminary results of its study on December 12, 2013, focusing on three types of consumer financial services contracts: cardholder agreements for credit cards, deposit account agreements for checking accounts, and cardholder agreements for general purpose reloadable prepaid cards. The preliminary report included findings with respect to the incidence and substance of arbitration provisions (including their complexity and inclusion of class action waivers), and the incidence and types of consumer disputes filed with the American Arbitration Association and in small claims courts. In that report, the CFPB indicated that it would conduct additional empirical research, including a telephone survey of consumers, to assess the use of litigation and arbitration to resolve disputes about consumer financial services and products, and the impact of pre-dispute arbitration clauses on the price of consumer financial services and products, among other things.

CFPB’s Final Arbitration Study

The CFPB’s recently released study is based on an empirical assessment of:

  • 850 consumer financial product or service agreements, including credit cards, checking accounts, general purpose reloadable prepaid accounts, private student loans, storefront payday loans, and mobile wireless third-party billing;
  • 1,847 consumer finance arbitration disputes;
  • 562 consumer finance class action lawsuits filed in federal or state courts;
  • 3,462 individual lawsuits in federal court;
  • Over 42,000 small claims court filings related to credit cards;
  • 419 consumer finance class action settlements in federal court; and
  • 1,150 state and federal regulatory and enforcement agency actions.

The CFPB has highlighted the following key findings from the gathered data:

  • Arbitration agreements affect a large number of consumers, including 80 million consumers in the credit card market alone;
  • Consumer understanding of arbitration is significantly lacking—three in four consumers did not know if they were subject to an arbitration provision and only 7 percent recognized such a provision meant they could not sue their card issuer in court;
  • Consumers are reluctant to bring small individual claims against companies, while roughly 32 million consumers on average are eligible for relief through consumer financial class action settlements each year; and
  • Arbitration clauses have not produced lower prices for consumers.

The CFPB’s study attempts to compare aggregate arbitration outcomes with aggregate class action outcomes. It concludes that, over a five-year period, at least 160 million consumers were eligible for relief in consumer class actions, and that settlements in those cases totaled $2.7 billion in cash, in-kind relief, expenses and fees. By contrast, over a two-year period, consumers obtained relief in only 78 arbitrations (out of 1,060 filed with AAA), and obtained less than $400,000 in relief and debt forbearance in those cases, which was outweighed by the $2.8 million consumers were ordered to pay companies in some 263 other arbitrations where decisions were reported.

The CFPB separately highlighted a few additional findings regarding the use of arbitration clauses:

  • 90 percent of arbitration provisions expressly prohibit class arbitrations;
  • Credit card issuers attempted to invoke arbitration provisions to block 65 percent of class action lawsuits, compared to less than 1 percent of individual lawsuits; and
  • Only two class arbitrations were filed with AAA between 2010 and 2012, neither of which resulted in a favorable resolution for consumers.

CFPB Field Hearing

The CFPB held a field hearing on March 10, 2015 in Newark, New Jersey, to announce the results of its study, moderate a discussion on the topic between consumer and industry advocates, and receive public testimony. CFPB Director Richard Cordray gave scripted introductory remarks and industry representatives and consumer advocates were each given an opportunity to present their respective positions.

Director Cordray focused much of his remarks on the comparison of arbitration as an alternative to class action litigation, and the evidence the CFPB has relied on to conclude that arbitration clauses “restrict consumer relief in disputes with financial companies by limiting class actions that provide millions of dollars in redress each year.” He noted that only a small number of consumers bring arbitration claims each year, despite tens of millions of consumers being covered by contracts containing arbitration provisions, and highlighted the significant monetary recoveries and non-monetary relief produced by class actions, including unquantifiable benefits stemming from changed practices and deterrent effects.

Consumer advocates called on the CFPB to use the report as a basis to ban pre-dispute arbitration provisions, which they characterized as “litigation avoidance” tools that companies use to insulate themselves from class-action liability. Pressing the point that the majority of consumer claims disappear rather than proceed in arbitration, plaintiffs’ attorneys claimed they regularly turn away potential clients whose contracts include arbitration provisions and class action waivers because they are not economically feasible to pursue.  One consumer advocate argued that arbitration has stunted the development of consumer protection law because all arbitration decisions are confidential and common law doctrines are therefore not being created or modified based on application of the law to various facts and circumstances.

Industry representatives argued that arbitration offers consumers and companies a more efficient and less expensive alternative to the judicial system, and criticized the CFPB for not surveying consumers on their satisfaction with arbitration. They noted that the arbitration system is still in its infancy and evolving, and called on CFPB to better educate consumers about arbitration and other aspects of the contracts they are signing. In addition, the CFPB was criticized for failing to note the limited, small-dollar relief individual consumers often obtain in class action settlements, as well as the number of frivolous class action claims that end up being dismissed or abandoned and the costs companies incur in defending those cases.

Our Initial Assessment

The CFPB’s report has wide-ranging implications for the consumer finance industry, as it sets the stage for the CFPB to issue regulations that will restrict or prohibit pre-dispute arbitration clauses in consumer financial services contracts. Based on the CFPB’s report and the tenor of its comments at the public hearing, it likely will conclude that pre-dispute arbitration clauses (or at least class arbitration waivers) have a very limited place—or no place at all—in consumer financial services contracts. As any arbitration regulations the CFPB issues must be “consistent with” this study, its depth and extensive citation to empirical evidence give proponents of pre-dispute arbitration clauses a high bar to challenge any future regulations.

If the consumer financial services industry is to persuade the CFPB to adopt a different or more limited approach than an outright ban on pre-dispute arbitration clauses, it will need to rebut or convincingly respond to the study’s findings, and the CFPB’s interpretation of those findings. Some initial thoughts on ways the industry can focus this effort include the following:

  • Identifying flawed or missing data. In its report, press release and testimony at the public hearing, the CFPB framed the empirical data as strongly supporting its central conclusion that pre-dispute arbitration clauses “restrict consumer relief in disputes with financial companies by limiting class actions that provide millions of dollars in redress each year.” That underlying data will need to be scrutinized for accuracy, particularly with respect to the CFPB’s comparison of class action litigation and arbitration outcomes, including their respective costs and benefits. Based on our initial review of the report, some data points the CFPB does not appear to have fully considered include:
    • Collateral consequences of class actions. The coercive effects of class actions, including the significant legal costs borne by providers of consumer financial products and services in defending baseless actions.
    • Individualized costs and benefits. The individual consumer costs and benefits of class actions as compared to the individual consumer costs and benefits of arbitration. The CFPB’s conclusions appear to be focused primarily on the aggregate data; the individual data may tell another story.
    • Effectiveness of other dispute resolution mechanisms. Many consumer complaints can be easily resolved through customer service departments, government-facilitated complaint mechanisms (e.g., the CFPB’s complaint portal), and third party services (e.g., the Better Business Bureau). The limited set of consumers who file arbitrations may reflect the resolution of numerous disputes through such informal means, while representative class action plaintiffs, selected and influenced by plaintiffs’ class action lawyers, and purporting to act on behalf of millions of consumers, are unlikely to avail themselves of informal dispute resolution mechanisms.
  • Developing additional relevant information. If flawed or missing data is identified, the consumer financial services industry should consider conducting its own studies to develop alternative data points. Given the CFPB’s claim to be a data-driven agency, strong data will be needed to rebut the CFPB’s data and conclusions and to support any policy arguments in favor of arbitration. Anecdotal experience, such as the actual experience of consumers who have participated in arbitrations and class action litigation, can be converted to empirical data through controlled satisfaction surveys.
  • Focus on policy arguments. While careful and detailed analysis of the empirical data will be a vital aspect of any challenge to the CFPB’s conclusions, strong policy arguments that support arbitration will also need to be advanced. For example, the CFPB noted at the field hearing that the Dodd-Frank Act specifically banned pre-dispute arbitration clauses in mortgage agreements, and queried how or why it should approach other financial products or services differently. Developing nuanced differentiators between products and services, and identifying the varied impact of arbitration and class actions, may be necessary.
  • Highlighting tension with FAA. Depending on how the CFPB crafts any proposed regulations regarding pre-dispute arbitration provisions, those regulations could come into conflict with the Federal Arbitration Act, 9 U.S.C. § 2, and the liberal federal policy favoring arbitration, which the Supreme Court strongly affirmed in AT&T Mobility LLC v. Concepcion, 131 S. Ct. 1740 (2011). Highlighting the long history in favor of arbitration, and how regulations against arbitration might conflict with that precedent, may bolster the case for arbitration.

We will be continuing to assess the data in the CFPB’s report, and to monitor the CFPB’s follow-up actions in this area over the coming months.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Davis Wright Tremaine LLP | Attorney Advertising

Written by:

Davis Wright Tremaine LLP

Davis Wright Tremaine LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.