Appeal filed as BOC and BOE discuss Tax Assessors issue
Featured Stories, News August 20, 2022
GILMER COUNTY, Ga. – Both the BOC’s special meeting and the BOE’s monthly work session saw discussion after falling median sales ratios in the Tax Assessors Office could set the county up for another state consent order and penalties in fees.
Chief Appraiser, Theresa Gooch stated that if the county’s median falls below a 38, the first consequence comes as the possibility of losing some public utility money or tax revenue. This number comes from the state’s Department of Audits and Accounts (DOAA) studies that occur annually. This means the Audit will look at samples of sales in the year and look at the sale value and compare that to what the county Tax Assessors assessed the value at. Since the state expects the assessors to set there evaluations at 40 percent of the property’s value. The optimum ratio, according to the state, is set between 38 and 42 percent so that there is no major variations.
However, to “pass” the audit, a term presented by BOE Finance Director Trina Penland, the assessed evaluations must fall between 36 percent and 44 percent, allowing for a 4 percent margin of error on either side as some might say. The report of the test samples for 2021 in Gilmer County fell to 35.88 percent, according to Penland’s report.
The study lags, however, according to Gooch who explained that the Department uses 2021 sales to set 2021 values while the county must use 2020 sales to anticipate and set expected 2021 values. The time lag also comes as the county has to have its values set by January 1, 2021. The state, however, comes later as Gooch said in the August 2022 meeting that the county just received the study results. Since the county’s and the states values are at odds, the discrepancy arises. The difference is so stark this year with the rising inflation and market values in just the course of one year.
There is no immediate consequence this year as the county is not under an official review year, Gooch said that will take place next year with regards to the 2022 assessments currently in their final stages. The Tax Assessors will use this information to set the expected 2023 values, but the state will wait until the end of 2023 to set those values based on actual sales.
With the current issue, she urged the county to formally file an appeal to have their concerns on record that Gilmer is “not happy with the findings.” Additionally, Gooch noted that the county could rise up again and make the requirement by next year’s review, but she has concerns if the state continues studies with the time difference allowing major influences to change market values drastically between the county’s anticipatory values from 2022 and the states actuals from 2023.
Not meeting the state required study median causes a fine, County Chairman Charlie Paris noted $174,000. The option is going under a consent order. Paris also noted that the last time the county was under a consent order, “it cost us more than paying the fine.”
In addition to those, Penland reported to the BOE that the Tax Assessors will also have to change their ratios for the digest in coming years, further reducing the money collected for both the Board of Education and the Board of Commissioners budgets.
Gilmer County is not the only county going through this issue currently as Penland showed reports from 2019, 2020, and 2021 audits with more and more counties falling out of compliance each year. In the 2021, the majority of North Georgia along with counties all over the state are facing this same issue of being out of compliance.
Gooch reported that the last time Gilmer County was out of compliance, with a median percentage below 36, was “prior to 2010” and the last time it was out of optimal range, with a median percentage below 38, was 2013.
BOC approves county millage rates for 2022
News August 16, 2022
GILMER COUNTY, Ga. – Set for final approval this week, the Gilmer County Board of Commissioners held a special called meeting approving both theirs and the Board of Educations approved millage rates.
The Board of Education advertised their millage rate at 11.099 mills. Approved by the county, the BOE’s millage rate calculates for a tax levy of $20,123,750. After advertisement and approval from the Board of Education last week, the item must be approved by the Board of Commissioners after as the county government is the official tax collection entity.
After the motion for the BOE, the commissioners moved on to their own rates, originally motioning to approve the rate at 5.541 mills. However, after the motion from Chairman Charlie Paris and a second from Post Commissioner Karleen Ferguson, Post Commissioner Hubert Parker again advocated for a further reduction past the Rollback Rate. Officially advocating for a tax cut, Parker said that with the rising inflation, the county needed to make an effort, even a small one, to relieve some of that stress.
Paris has noted in previous meeting that the inflation is a concern for both the citizens and the county, who is still facing rising costs and contract renegotiations due to inflation. However, he joined discussions and said he had the county Finance Officer, Sandi Holden, look into further decreases. Parker originally spoke about options of going further down to 5,45 mills and later noted the even 5.50 mills would send a good message.
Acquiescing to the option of 5.50 mills, the board voted down the original motion of 5.541 mills. Then, a new motion by Paris came for approval of 5.50 mills. Seconded by Parker, the motion passed unanimously. In addition to the millage rate, Post Commissioner Parker suggested a letter to constitutional officers and department heads in the county to hold in mind the rising inflation in the final months of this budget and entering the budget process for next year.
Parker read a suggestion for that later stating, “As you are aware, the county is operating a tight budget and unusually high inflation has caused it to be even tighter. This may be a good time to review your budget for the current year and adjust accordingly.”
Additionally, the county continued its 1 mill General Obligation Bond Millage Rate.
County advertises Rollback Rate for 2022 Millage Rate
News July 28, 2022
GILMER COUNTY, Ga. – With a special called meeting today, July 28, 2022, the Gilmer County Board of Commissioners advertised their Rollback Millage Rate at 5.541 mills.
This is down 0.681 mills from last year’s 6.222 mills. According to calculations from Gilmer’s Finance Department this represents a growth of $1.3 million that the rollback rate covers.
The five year history of the digest shows that the millage has decreased since 2018 when the millage rate was kept at 6.983 from the previous year. Post Commissioner Hubert Parker voiced an opinion to provide a further decrease past the Rollback Rate in the Special Called Meeting.
Gilmer County’s Five Year History of the Tax Digest and Levy
With a motion from Chairman Charlie Paris seconded by Post Commissioner Karleen Ferguson, discussion opened for the commissioners to discuss the topic. Parker proposed the further decrease siting inflation as a real issue that citizens are facing. Paris responded that the county has also been feeling the pressure of inflation noting several increases the county is already dealing with through changes from prices originally bid to the county in January and its new solid waste management company, Waste Pro, currently under renegotiations of their contract due to rising costs of gasoline. Ferguson agreed with Paris saying that this was also her thinking when considering the rollback rate.
Paris noted that further reductions past the Rollback could see the county using its operational reserves as rising prices are continuing to grow. Paris noted that even with the Rollback Rate he has concerns over creating the 2023 budget and funding the county’s services. The 5.541 mills is estimated to levy $11 million in property taxes from the $2 billion 2022 Net Digest. This Net Digest has nearly doubled since 2017 when it sat at $1.2 billion. Even with the 5.541 mills Rollback Rate, the county is estimating over $600,000 added to the county budget.
Calculation of the Rollback Rate with the 2022 Tax Digest for Gilmer County.
Yet, the county is already looking at rising costs affecting the current 2022 budget. Chairman Paris stated, “I’m very much concerned that we’re going to have to dip into our reserves in our 2022 budget, nevermind the 2023.
Not reaching a full consensus, the board said that advertising at 5.541 mills would be the first step, but they could decrease it at a later date before the final approval. The only thing they couldn’t do is increase it before then. With that they unanimous approval came for the Rollback Millage Rate. The Board of Education will hold a meeting to approve advertisement of their Millage Rate and then another Special Called Meeting will see the school give final approval of their rate before the county approves their own and the school’s millage rate together.
Currently, the county said they are expecting to hold their meeting for final approval of the rate on August 15, 2022, at 2 p.m. with the assumption that the Board of Education will hold their meeting for final approval on August 11, 2022.
Hotel/Motel Tax receives final approval with start date change
News June 14, 2022
ELLIJAY, Ga. – A topic that that began last December when the Board of Commissioners heard options of potentially raising the county’s Hotel/Motel Tax will see its final stages of adoption in the next 30 days before the start date.
June saw the final adoption of the change and implementation will move forward with a ratification of the contract, implementing the Chambers change in percentage, and the actual start date of the tax change. To that end, County Attorney David Clark noted that there may be a Special Called Meeting to formally ratify that before the start date.
In January 2022, the official motion and approval came to begin a change in the Hotel/Motel Tax from five percent to eight percent and included tourism product development (TPD) Projects. Then, in April 2022, when t he county began advertising the change, another change was introduced as Clark stated that stays up to 30 days can be considered “short term rentals.”
The Commissioners held discussion this month, June 2022, during their Regular Meeting as to the official start date. Since last month, that date has been set to July 1, 2022. However, discussion upon the wording in the Official Code of Georgia Annotated (OCGA), and its reference to earliest implementation being the second month following adoption. the county questioned whether to postpone the start date to August to be sure.
Post Commissioner Hubert Parker questioned the postponement saying that he felt like the county might be confusing or causing issues with changing the dates again. The date was at one point discussed at August as was a segmented start date revolving around reservation times versus the actual date of stay but this changed to July last month after cabin owners pushed for a single hard start date and said they were agreeable to July.
Now, as commissioners discussed the OCGA wording, Commission Chairman Charlie Paris said that he would prefer August just to be absolutely sure the comply with the code. Advice from attorney Clark said that he felt July would be in compliance, but also agreed that August would be the safer option as he has seen litigation over minute wordings.
Parker said that since the July 1 start date hasn’t passed, he felt they wouldn’t cause major harm with the change and so he “could live with it.”
Official motion came from Chairman Paris to approve the final adoption of the Hotel/Motel Tax increase on August 1, 2022. The county is still likely to hold a special meeting for the ratification of the contract but official adoption has been approved and is in motion with a concrete date.
County adjusts Hotel/Motel tax dates as cabin owners speak
News May 17, 2022
GILMER COUNTY, Ga. – With the Hotel/Motel tax change well underway, May saw cabin owners requesting adjustments to the change with the public hearing and first reader in the BOC meetings.
Questions arose among speakers asking the board to not go fully to eight percent right away, but instead staging a smaller increase and potentially returning to the increase later if still needed. Another request saw different speakers telling the board about added stress from having to go back to people who have or will make reservations before the change takes place. The date of implementation became the main focus of discussions from the county’s work session to public hearing to the regular meeting in Citizen’s Wishing to Speak.
Originally, the board looked to have the change begin a soft implementation this week that would see rentals informing those making reservations for a stay after August 1 about the tax increase and the charge would be added to their stay as it occurs after the August 1 implementation date. This idea came out of the county’s work session on May 11, 2022. However, during the Public Hearing and Regular Session on May 12, 2022, rental owners returned to oppose the implementation and the county asking them to “collect a tax that isn’t implemented yet.”
Debates continued over the official implementation of the tax and a specific date rather than implementation in stages or the possibility of retroactive implementation. Speakers also debated the difficulty of including Airbnb and VRBO into the collection so quickly.
Post 1 Commissioner Hubert Parker noted that the tax has been discussed and information has been going out since December and implementation is not coming as a surprise to the county.
Board of Commissioners Chairman Charlie Paris said in the public hearing, “I would be sympathetic to the idea that this hasn’t been approved yet and it’s not a tax yet and perhaps we need to do that first.” Paris called for some give on both sides so that everyone could feel it was implemented properly and be able to walk away “not mad.”
Parker also said he would be agreeable to a set date. With the presumption of a final reader in the June meeting, the BOC looked at implementation on July 1, 2022.
Instead of stage implementation looking at reservation made date and the date of the stay, speakers looked for a single hard date to say any reservations made before this date follow the past rule and those made after that date follow the eight percent tax. The noted concerns of trying to follow two different rules at once depending on when the stay date is.
The official motion to approve the first reader came in the regular meeting supporting the implementation of a single date, July 1, 2022, to impose the tax increase on all reservations made on July 1, 2022, and after, regardless of the actual date of the stay.
Gilmer begins process to change hotel/motel tax
News April 17, 2022
GILMER COUNTY, Ga. – With the information made available in December 2021, and the decision to move forward made in January 2022, the Board of Commissioners officially approved a motion this month to authorize County Attorney David Clark to begin revisions to the Excise Tax on Rooms, Lodging’s and Accommodations Ordinance.
The motion comes with new information on the change as the final process begins for changing the tax. However, even that won’t be the final step as Clark said the Governor will need to sign this as well. With final county approval potentially occurring in June, Clark said that July 1, 2022, could likely be the actual change date of the tax depending on when the Governor signs. In January’s meeting, it was stated that the approval in the county’s meeting is for the resolution to be sent for approval in state legislation. This was included in the formal motion and approval of a change in the Hotel/Motel Tax came in January as the county was looking into the concept.
Going from five percent to eight percent and including tourism product development (TPD) Projects, this change is also bringing along a change in stay length. Clark reported to the board that Chief Financial Officer (CFO) Sandi Holden noticed a change needed for the updated ordinance.
Currently, the ordinance applies to stays up to ten days, however, with changes in the state, Clark stated that stays up to 30 days can be considered “short term rentals.” The county will also be adding this change alongside the increase in percentage.
As for the application of these changes, Paris clarified in the county’s regular meeting after questioning the county attorney. Any rentals scheduled after July 1 will be subject to the new changes. This means that even reservations made before July will fall under the new changes if the stay occurs after the change date.
While the July 1 date is still currently an estimate due to potential delays either from the state or local governance or if the process delays with citizens input, the county only used that date as the assumption for the clarifications. The TPDs listed for the county to pursue in 2022 include Parks, Trails, Wayfinding Signage, and Recreation facilities. However, Clark estimated that with the collection beginning in July, it could be September before the county starts realizing that change in their financial reports. Meaning it could be fall before the county could begin working on those projects.
Hotel/Motel Tax raised in Gilmer BOC special meeting
News January 30, 2022
ELLIJAY, Ga. – A special called meeting of Gilmer’s Board of Commissioners saw the official motion and approval of a change in the Hotel/Motel Tax from five percent to eight percent and included tourism product development (TPD) Projects.
The meeting saw the continued discussion of the topic that was brought up last year after Gilmer Chamber President and CEO Jennifer Grimmer responded to Post Commissioner Karleen Ferguson’s request for information. Grimmer had already provided information to the cities at their request and delivered similar to the BOC.
In December 2021, Grimmer said that going above five percent in the tax opens up tourism product development (TPD) options. Grimmer explained that this fund could be used to build or improve things like river access, signage, parking lots, public bathrooms, and other projects. Gilmer is currently 100 percent marketing and does not use any of the funds for tangible or “brick-and-mortar” improvements.
With this approval, certain areas have to be listed for general guidance on projects for the county to pursue. The board stated that the project list can change from year to year, but the county is to disclose the general ideas where they will use the TPD options to fund. They noted that approval in the county’s meeting is for the resolution to be sent for approval in state legislation. In fact, Post Commissioner Hubert Parker’s motion for approval included submitting the request to Speaker David Ralston.
These stated projects were labeled as Parks, Trails, and Recreation facilities. Though throughout the meeting, the board’s exploration of projects lead to additional funding for the pool and wayfinding signage. Additionally, 18% of the funds collected must be used for the TPD projects.
Recently, the county’s pool project has failed to see real progress as bids for the project have not received any submissions. The board discussed that some questions to those interested said the addition of a diving well had some affect on their decisions. The diving well would increase project costs and liability costs for the county. Brief discussions still saw interest from board members to pursue the diving well if possible.
Additionally, in the special meeting’s Citizens Wishing to Speak section, the board heard a presentation from Robert Ferguson about his recent attendance of the Gilmer Chamber’s “Leadership Gilmer” course. Robert said that part of the course was to find a project to work on to improve the county. He went on to add that his project that he worked on with a group of people in the course was wayfinding signage. Providing handouts and extra documentation, Robert noted the abundance of signage in Ellijay for different things including a large portion of real estate signage. He also noted a lack of signage for visitors to utilize in increasing tourism guidance.
The addition of more wayfinding signage would help visitors quickly navigate to sites like local businesses, vineyards, the downtown area, and even historic places like the Tabor House. Though not a part of this same project, it is something the Chamber has noted as helpful and important for those unfamiliar with our county. Having inspected signage on their own, the Chamber recently updated signage on the Highway 515 Welcome Center and main office in the last year.
These two projects were a current focus for the Board of Commissioners with TPD, but they also discussed future possible projects briefly. Ultimately, with the project list updated annually, they elected to focus on the 2022 projects and push discussion for 2023 to a later date. Additionally, sending the resolution to state legislation requires the current project list and County Attorney David Clark noted that this change would not be finalized and implemented until Georgia’s Governor signs the bill into law. This could occur in May or later.
After signing, Clark said there is a notification period as well. If the signing is delay, the change could occur as late as September of 2022.
Grimmer also returned to speak at the Special Meeting offering information. She noted that TPD funding could have doubled in 2021 according to projections. She reasserted to the BOC that the Gilmer Chamber was a point of information on the subject with no financial interest as the increase would lower the Chambers percentage received in order to balance out to the same collection.
It was noted that while the Parks, Trails, and Recreation facilities denoted as projects are considerations and the county is not bound to complete projects in all the areas. However, they cannot work on projects outside of those areas until added to the list during the annual discussions.
County hears option to raise Hotel/Motel Tax
News December 15, 2021
ELLIJAY, Ga. – Having prepared presentations for the two cities upon request, Gilmer Chamber President and CEO Jennifer Grimmer spoke to the Board of Commissioners in December on Hotel/Motel Tax after being questioned on the subject by Post 2 Commissioner Karleen Ferguson.
Grimmer had prepared a presentation for the City of Ellijay, she said that she examined both cities and the county along with the study she did. Grimmer also prepared the comparisons to provide the information to the Board of Commissioners according to Ferguson. The county has made no motions or even had an agenda item to discuss changing the Hotel/Motel Tax as this topic came after a report to the board during its monthly meeting.
Grimmer had reported on the Chamber’s year and on the budget looking into next year as they continue marketing plans for the county. Set as an update and discussion item, Ferguson asked Grimmer to explain the comparisons and what it would mean if Gilmer County raised its Hotel/Motel Tax.
Ferguson called the numbers “pretty dramatic” and said they could help the county’s general fund in accomplishing some projects that the county has been unable to do yet.
Grimmer told the board that the topic came up as the City of Ellijay asked for her expertise on the topic. While the Chamber did not initiate the conversation, they do have several tools and resources monitoring rentals, rooms, and similar lodging and their effects on the community. As part of her original report, before the question of the tax arose, Grimmer had just discussed with the county averages such as how much an average cabin owner can make and tracking for how much of the county’s lodging capacity is being used or estimated to be on certain weekends.
Gilmer Chamber President and CEO Jennifer Grimmer
But moving to the topic on the tax itself, Grimmer said that going above five percent in the tax opens up tourism product development (TPD) options. Grimmer explained that this fund could be used to build or improve things like river access, signage, parking lots, public bathrooms, and other projects. Gilmer is currently 100 percent marketing and does not use any of the funds for tangible or “brick-and-mortar” improvements.
The county could go up to eight percent tax in Georgia. Grimmer explained that at six percent tax, the funds are split between the DMO (Destination Marketing Organization, i.e. the Chamber), the county, and TPD. Grimmer explained that the state sets the Chambers portion doesn’t change from 5 percent to 8 percent so they are virtually unaffected, but increasing the total tax increases the portion of TPD up to 15 percent.
Grimmer reported that Blue Ridge is at 8 percent tax with Fannin at 6 percent. Currently Ellijay and Gilmer are at 5 percent. East Ellijay is at 3 percent.
As for whether the county is actually moving forward on the subject, Post 1 Commissioner Hubert Parker said he wanted to know more about what the county might run into if they move ahead with adjusting the tax. With plans to revisit the topic on future agendas, the county is set to look deeper into the topic before making its official decision.
Tax Tips With Beth Bennett: Delays in Tax Returns
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Board lowers Bond Millage with final approval of rates
News August 25, 2020
ELLIJAY, Ga. – A unanimous vote on Monday, August 24, 2020, saw the Gilmer County Board of Commissioners follow up on statements from last year where they discussed lowering the Bond Millage Rate in the county.
While they did not approve lowering the rate in 2019, many citizens have continued discussing and pushing for the reduction this year. A few have very vocally called for the reduction of the “extra half mill” that was put on the Bond Millage rate raising it from 1 to 1.5 mills. Additionally, the viral outbreak and subsequent shutdowns of counties and states cast a dark shadow on local economies and doubt for the financial future of Gilmer.
The Commissioners halted capital spending and major projects as they watched and waited to see just what kind of impact it would have, even delaying their pool project that has been underway for over a year now. The pool was closed at the beginning of May in 2019.
However, the last two months have shown quite the difference. Despite the cancellation of major events in the county and increasing numbers from the virus, recent reports show an increase in collections from tourism and SPLOST.
Whether this played a role in their decision, the commissioners did not say, but they did approve a drop in the bond millage rate by .25 mills, taking it from 1.5 to 1.25 mills.
The School-Board-approved millage rate of 13.963 was approved to be implemented by the Board of Commissioners. This is the Rollback Rate calculated for Gilmer County Schools as they have advertised over the past month since the July meeting. The Board of Education approved this rate last week during their regular August meeting.
They also moved forward with approval of the county’s M&O (Maintenance and Operations) Millage Rate of 6.783 mills. This is also a Rollback Rate calculated for the Board of Commissioners and advertised for the past month since their July Meeting.
BOE approves Millage Rate and Budget
News August 21, 2020
EAST ELLIJAY, Ga. – The second month of posting and readings for the Millage Rate from Gilmer’s Board of Education saw no public comments before Thursday night’s meeting.
With no comment, the board continued forward with a recommendation from Superintendent Dr. Shanna Downs to adopt the Rollback Rate dropping the Millage Rate from 14.248 to 13.963. Advertised since last month’s meeting, the board spoke on finances with the Millage Rate, this month, alongside the budget meetings after delays from the state due to COVID-19.
This week also saw the board‘s last public comments meeting for the 2020-2021 budget, also with no comments from the public. No longer needing monthly spending resolutions, the board will finally be moving forward with the remaining 10 months of the fiscal year with an established budget as the item received unanimous approval during Thursday’s meeting.
Discussions have gone on over the last few months over this budget and Millage Rate, the board has discussed needs and funding in the budget with cuts, changes, and shortfalls coming from the state funding. Some in the public expected increases in the Millage Rate to make up for the difference in the state funding.
This week saw the rollback rate agenda item return with very little discussion from the board and short review of the tax history. The board moved to adopt the rollback to keep in line with collections.
The budget also slightly decreased through its estimate compared to June’s Financial Summary that saw the final month of the FY 2019-2020 budget with expenditures at $44,732,231. The tentative budget that has now been approved as the 2021 Budget indicates and estimation of $41,575,332 total expenditures.
The budget is set for the school system, but the Millage Rate will now move on to a special called meeting of the Gilmer County Board of Commissioners who are currently expected to approve the Millage Rate as approved by the school along with their own Rollback Rate Monday, August 24, 2020. Being held at 10:00 a.m., the Board of Commissioners are also considering a rollback to their Debt-Service-paying “Bond Millage Rate” by 0.25 mills.
While the Bond Millage is expected to provide a reduction in many citizens property taxes, Tax Assessments are individual to the property. Rollback Rates also look to collect the same taxes as the entity, be it the county or the school system, did last year despite increases in property values.
Commissioners advertise Millage Rate and Bond Millage
News July 27, 2020
ELLIJAY, Ga. – Gilmer’s Board of Commissioners discussed their Millage Rate in a Special Meeting this July without one of its members.
Having contracted COVID-19, the board’s third commissioner, Karleen Ferguson, was absent from the meeting for health and safety. The two remaining commissioners discussed accepting the rollback rate versus not accepting it.
Very early, Gilmer Commission Chairman Charlie Paris voiced his opinion to accept the rollback rate saying, “My personal position would be that we should take the rollback rate. It’s not going to hurt us terribly and I don’t think this is the year to be trying…”
Post 1 Commissioner Hubert Parker agreed saying that he was good with the Rollback as well.
The worksheet showing the preparation of the 2020 Digest and formula calculating the Rollback Rate for Gilmer County.
However, additional discussions turned to the Bond Millage Rate for the county. With discussions last year on reducing the rate, the Commissioners ultimately decided against it, keeping the 1.5 mills, but promising to revisit the idea in 2020. Now, Parker and Paris began discussions by immediately moving to a debate on whether to reduce it by .25 or .15 mills. Paris noted that work still needs to continue in capital projects and expenditures coming in the Road Department as well. Having the Bond Millage pay off part of the bond debt service allows more SPLOST funds for those expenditures.
Parker offered his opinion on the Bond Millage saying, “I would be fine going with .25.” However, he did mention a desire to look at it again later. Looking at the decreases, Paris said he didn’t have a problem with reducing it by .25 mills to a Bond Millage Rate of 1.25 mills.
The rates were approved by two separate motions as Paris made a motion to approve advertising, it came to accept the Rollback Rate of 6.783 mills. The rate was approved by the two present commissioners.
Then came another motion from Paris to have “the Bond Millage Rate be reduced from 1.5 mills to 1.25 mills.” The rate was approved by the two present commissioners.
Moving forward, the Commissioners are looking for another Special Called meeting towards the end of August to formally adopt the Millage Rate. They have to wait for the Board of Education to adopt their rate in August before the County can formally adopt both rates.