Keep Politics Out of University Investment Decisions

by James A. Bacon

I didn’t see this one coming, but I’m delighted to hear of it: Secretary of Education Aimee Guidera and Secretary of Finance Stephen Cummings have written the presidents of Virginia’s public universities asking them to verify that their endowment investments are not influenced by political considerations.

Aimee Guidera

The state wants to ensure higher education institutions “invest in a manner that prioritizes risk-adjusted investment returns independent of social, political or ideological interests,” wrote Guidera and Cummings, according to Cardinal News, which obtained a copy of the letter.

The query follows a conversation between Gov. Glenn Youngkin and the state Council of Presidents in March that was prompted by calls of pro-Palestinian groups on college campuses to divest university assets tied to Israel, according to the letter.

Stephen Cummings

I’ve followed this issue closely for the Jefferson Council as it has played out at the University of Virginia, and I refer Guidera, Cummings and Bacon’s Rebellion readers to this article: “Board Shows No Interest in Israel Divestment.”

President Jim Ryan and the Board of Visitors have ignored a resolution passed by the student body to divest companies doing business in Israel from UVA’s endowment.

However, UVA’s investment arm, UVIMCO, does have an ESG (environmental, social, governance) policy, and it maintains an Advisory Committee on Investor Responsibility. UVIMCO’s primary ESG focus has been mitigating systemic risks of climate change.

Does that count?

Meanwhile, Cardinal News reports a remarkable response from state Senator Mamie Locke, D-Hampton, and chair of the Senate higher education subcommittee. Said she: “This is another case of the administration dipping its political toe into higher education where it shouldn’t be.”

Let me get this straight: Team Youngkin is being “political” by asking universities to keep political considerations out of their investment decisions?

Yeah, right.

Locke’s further comments only confused the issue. Here’s how Cardinal News summarized them:

Locke, a retired Hampton University political science professor, said that while endowments are typically aligned with a university’s goals for education and research, they’re often also tied to strict specifications from donors regarding how those donations are invested and spent. 

She said she doesn’t see how the state retirement system’s investment policies could be applied to education endowments and foundations. “They have separate purposes which have been established. You can’t make them one and the same.” 

She later added: “You can’t make the square peg fit into that round hole.”

Locke is conflating different things. Yes, many gifts to universities are dedicated to specific purposes that are political or ideological in nature. Team Youngkin is not questioning the right of donors to endow a professorship of Hegemonic Beauty Standards or an institute dedicating to saving democracy from MAGA fascists. But that’s not what Guidera and Cummings are asking about. They want to know if there are strings are tied to how that money is invested. They want to ensure that endowments generate the maximum risk-adjusted return and aren’t hijacked to advance a crusade that most donors never signed up for.

We’re talking about a lot of money. UVA’s endowment exceeds $14 billion. As of a couple of years ago, according to an AI search, Virginia Tech’s endowment surpassed $2.6 billion and Virginia Commonwealth University’s $2 billion. Both are probably larger today.

Once the precedent has been established that universities can use their endowments to promote for political and ideological goals, what’s to stop Boards of Visitors from using endowments to advance conservative goals — divesting companies whose health care plans pay for abortions, say, or hospitals that conduct transgender surgeries, or corporations that trade with leftist regimes beloved by progressives?

Do we really want to open that Pandora’s box? Do we really want to launch another front in our culture wars? Aren’t we exhausted enough already?

James A. Bacon is contributing editor of the Jefferson Council. The views expressed here are his own.


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54 responses to “Keep Politics Out of University Investment Decisions”

  1. Lefty665 Avatar
    Lefty665

    Good for them. Keep political statements out of endowment investments. They can start by shedding Israeli investments that support Israeli Genocide in Gaza. Those investments are profoundly political statements.

  2. Randy Huffman Avatar
    Randy Huffman

    Re Ms Locke's statement: "while endowments are typically aligned with a university’s goals for education and research, they’re often also tied to strict specifications from donors regarding how those donations are invested and spent."

    UVA has a policy on how endowments are managed and invested, plus they have a large unrestricted endowment. With the possible exception of some mega donations, most endowments are not going to specify anything other than they are managed in accordance with UVA policy. Their policies that I saw online are here, last listed as updated 10/2023 (there may be others, but this seems comprehensive):

    https://uvapolicy.virginia.edu/policy/EXT-009

    I noticed this following statement in the policy

    "Named endowment funds are usually pooled for investment with the University’s general endowment funds and the individual funds are credited with their pro rata share of the earnings at the annual rate as adopted by the BOV."

    Hence, it is NOT correct that most endowment agreements specify how the assets are invested.

    1. walter smith Avatar
      walter smith

      Yes. Just typical D against anything Youngkin.

    2. DJRippert Avatar
      DJRippert

      More gaslighting from the left. If you don't like something, just make things up.

      “This is another case of the administration dipping its political toe into higher education where it shouldn’t be.”

      But the administrators of public colleges and universities (state employees) should be able to dive headfirst into any half-baked political slant they want?

      1. walter smith Avatar
        walter smith

        Yes! Racist!

  3. Dick Hall-Sizemore Avatar
    Dick Hall-Sizemore

    This is just political posturing by the administration. There has been no indication or allegation that any institution of higher education in Virginia has been using political motives to guide its investments. Indeed, as Jim indicated, Pres. Ryan of UVa. ignored calls for the university to divest in companies doing business in Virginia. As for the request by the administration to "verify" how university foundations are investing their funds, the governor's press secretary could not cite any provision of law that gave the governor any jurisdiction over the management of the universities' private endowments.

    It seems to me that it is the administration that is trying to drag politics into this area.

    1. walter smith Avatar
      walter smith

      Well, here's your evidence that an institution of higher learning uses political motives to guide its investment decisions.
      https://uvimco.org/responsibility/

      1. Dick Hall-Sizemore Avatar
        Dick Hall-Sizemore

        OK. Good point. The Board of Visitors can change that, if it wishes.

        1. walter smith Avatar
          walter smith

          I really think AG Miyares needs to step in on whether the fiduciary standard applies to all public investment funds. I think it should. I imagine as an ex-State employee, you are a participant in the pension (which has been discontinued or just cut back?).

          1. Dick Hall-Sizemore Avatar
            Dick Hall-Sizemore

            These endowment funds are not public funds.

            I am indeed a member of VRS and receive a monthly pension check. I am a member of the "old" system. That is a fixed benefit system. Employees hired after about 2010-2012 participate in a hybrid system, some of whose benefits are dependent on 401Ks. The VRS is an independent trust, governed by a Board of Trustees. The standard of investment is set out in law: "the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims. The Board shall also diversify such investments so as to minimize the risk of large losses unless under the circumstances it is clearly prudent not to do so."

          2. walter smith Avatar
            walter smith

            I knew there was some modification on the pensions…
            So I think the AG needs to interpret that standard of care as prohibiting ESG/sustainability.

            And I would say the endowments are public funds because all of the UVA (and I would assume, Tech, etc) foundations have language with a "savings" clause that the funds would go to the Commonwealth of Va…

            Maybe we need an AG opinion there, too!

        2. Nancy Naive Avatar
          Nancy Naive

          Can they? The word advisory in no way implies control. I’ll bet they can change the investment company, but cannot change how the money is invested.

      2. Nancy Naive Avatar
        Nancy Naive

        Nice brochure, Walt. Keyword: advisory. UVIMCO is governed by whatever document established the endowment, and by fiduciary rules and tax laws. Ultimately UVIMCO decides how to invest the money responsible to “in perpetuity” goal and the endowment trust document.

        The students, faculty, president, BoV, janitors, etc., have only an advisory position. UVIMCO can simply ignore them.

        Example, if in their capacity in that brochure, the BoV said, “sell everything and buy bitcoin” what do think UVIMCO will do?

        1. walter smith Avatar
          walter smith

          Have you read the documents? I have. Meanwhile, if you have a commitment to achieve the goals, and since UVIMCO can’t establish governance on its own, it establishes an advisory committee to virtue signal to the world that it will do woke investing. Why else have the committee unless you intend to do it? Or, are you saying it is all just window dressing to fool the gullible wokies? Now who’s the conspiracy theorist?

          1. Nancy Naive Avatar
            Nancy Naive

            read it again. Copy the phrase that you think gives anyone other than UVIMCO and its investment managers control of investments.

            https://uvimco.org/wp-content/uploads/2024/06/Investor-Responsibility-Framework-2024.pdf

          2. walter smith Avatar
            walter smith

            The investment committee makes the decisions, but has established an advisory committee to ignore its advice, while at the same time committing to its “Responsibility” goals…
            And I bet you believe SlowJoe is compos mentis, don’t you?

    2. Marty Chapman Avatar
      Marty Chapman

      Dick, surely the Governor and relevant state officials can request information from state universities. Note: " UVa. ignored calls for the university to divest in companies doing business in Virginia." Did you mean "Israel" rather than "Virginia" here?

      1. Dick Hall-Sizemore Avatar
        Dick Hall-Sizemore

        Good catch. I have amended my mistake.

        Requesting information is different from "veryifying" that the investments have been made in accordance with standards preferred by the governor.

        1. Marty Chapman Avatar
          Marty Chapman

          I am prone to the same sort of error!

    3. Nancy Naive Avatar
      Nancy Naive

      The school may not even have the authority or ability to control investments. If they were smart, they don’t.

  4. walter smith Avatar
    walter smith

    This is long overdue, and I wish AG Miyares would join in on the fiduciary aspect of ESG.
    Funds should be invested for maximum long term gains. Period. No "stakeholder" capitalism. No "sustainability." Similarly, the ESG/sustainability against corporations needs to be stopped. The sole duty of the directors should be maximization of shareholder return. Not the appropriate virtue signaling to the virtue overlords in the "proxy advisory" services (conform your policies to what we say or we'll tell the investment firms to vote against your directors). Normies have no idea how corrupted THAT process has gotten.
    Of the same piece is institutional neutrality.

    Let's sum it up here – Make Colleges Boring Again!
    (in other words, get back to education)

  5. Nancy Naive Avatar
    Nancy Naive

    Some dozen years back, some in the GA called to seize UVa’s endowment and spread it around all the other state schools and were promptly told that it was private funds. Moreover, those endowments are not “owned” by UVa. They are trusts set up “for the benefit of” UVa.

    As such, I doubt UVa has any control over how the funds are invested. The school is the beneficiary, not the fiduciary. Now, generally a trustee would submit to the beneficiary’s wishes, but they don’t have to. The trustees have a fiduciary responsibility to protect the funds.

    I suppose you could get a copy of the trust document to see how much control UVa may have, but generally speaking, they are very limited. About the greatest control held by a beneficiary (or the grantor) is the ability to change trustees. This is smart because it shields the money from lawsuits.

    It’s why the Goldman family couldn’t get OJ’s retirement money. It didn’t belong to him.

    FWIW, there are a clear ton of different kinds of trust and trust-like arrangements, all of which are covered by state and federal laws. A good trust will allow you to control your children — forever.

    1. Randy Huffman Avatar
      Randy Huffman

      As I outlined above taken from the UVA website, endowment investments are managed as a part of the University policy.

      https://uvapolicy.virginia.edu/policy/EXT-009

      Per the Uvimco annual report, they look to be technically independent, but clearly part of the University

      1. Nancy Naive Avatar
        Nancy Naive

        That doesn’t say anything about the ownership of the endowments. It’s the policy on how donation funds are handled coming to the University.

        Here’s a clue. If the endowments have an TIN/EIN that differs from the University EIN, they’re independent. There is a magic word for which you can search, “irrevocable”. If it’s present in the endowment document, then it’s independent from the university. It’s absence, however, says nothing. Similarly, the word “revocable”.

        “Endowment funds are initially invested by donors for certain charitable purposes. They are usually established as trusts, which keep them independent of the organizations that they support. Endowment funds consist of cash, equities, bonds, and other types of securities that can generate investment income.”

        https://corporatefinanceins… .

        “Trusts are people, too, my friend”. No really, they are legally treated as people.

        An important example is Sweetbriar. There the trustees illegally attempted to terminate the trust by distributing the entirety of the principal.

        1. Randy Huffman Avatar
          Randy Huffman

          Nuts. UVIMCO stands for University of Virginia Investment Company, UVA logo is on their door. UVA hires their management, the COO of UVA and some BOV members sits on their board. Only thing I don’t know is who appoints the rest of their board.

          The advisory committee who helped create their lovely ESG policies came from UVA, sorry but I can’t get the link to paste in while on my I pad. Does anyone in their right mind not think all of that was not dictated by UVA?

          Very importantly, UVA determines their distribution policy. You cannot argue UVIMCO is steadfastly independent when their customer tells them how much and when to send funds to them annually.

          Yes, there are legal guardrails, but UVA controls UVIMCO.

          1. Nancy Naive Avatar
            Nancy Naive

            I may not be able to guarantee much, but however much UVa, its endowment, and UVIMCO are incestuously bound, it’s far enough removed to keep any combination from being named co-defendants in a lawsuit against any other, which makes them doubly immune to BR, and TJC hit pieces.

            Yep, grantors and beneficiaries do have some control, but only as much as given by the endowment documents and state/federal law permits. UVIMCO’s first responsibility is to the endowment and its trustees. Beneficiary-trustees trusts do exist, and a lot of people get wrapped around the legal axel if the IRS determines it to be an “abusive” trust.

            Someplace is a document titled something akin to “The Irrevocable Charitable Trust F/B/O The University of Virginia” and THAT is the trump card. All of these UVa policy documents on handling donations, etc., and UVIMCO’s forward-looking, and “is committed to” statements are just flowers.

            Need to find the “shall” statements, not the “is, will” statements, e.g., “UVIMCO (or trustee) shall distribute all income in addition to 5% or $5,000 of principal…” and not “UVIMCO is committed to investing in sustainable….”

            BTW, there are two UVIMCOs. U. of Vermont has an identically named trustee/investment company.

          2. walter smith Avatar
            walter smith

            You do not know as much as you think. UVA has $14 billion in UVIMCO. Some is unrestricted. Most comes from affiliated foundations, all for the benefit of some aspect of UVA, all with a savings clause that if UVA disappears, the money is for the Commonwealth. In each of the Foundation’s pots of money there are likely pots with some restrictions on how to be used, but I sincerely doubt there are any trust instruments saying “no woke social justice investing” because you Marxists had not yet polluted that.
            All of these Foundation Boards are insular and self selecting. They pick their new Board members…No risk of clubbiness there, huh? On top of that, the integration with UVA fund raising apparat really means there is not the true “independence.” The Foundations have a different EIN, but that’s about it. How come all of the “independent” foundations use UVIMCO as the asset manager? Asking for a friend…
            And then to top it off, Jim Ryan required all “UAO”s (University Affiliated Organization) to sign a new affiliation agreement. He gets to appoint a member to each Foundation’s Board, and so does the BOV. These members are “super” members. They even have the duty to “rat” on the “independent” Foundation. In a self selecting clubby Board of almost 40, is it possible the UVA appointees exercise effective control of the “independent” Foundation? Again, just asking for a friend…

          3. walter smith Avatar
            walter smith

            You do not know as much as you think. UVA has $14 billion in UVIMCO. Some is unrestricted. Most comes from affiliated foundations, all for the benefit of some aspect of UVA, all with a savings clause that if UVA disappears, the money is for the Commonwealth. In each of the Foundation’s pots of money there are likely pots with some restrictions on how to be used, but I sincerely doubt there are any trust instruments saying “no woke social justice investing” because you Marxists had not yet polluted that.
            All of these Foundation Boards are insular and self selecting. They pick their new Board members…No risk of clubbiness there, huh? On top of that, the integration with UVA fund raising apparat really means there is not the true “independence.” The Foundations have a different EIN, but that’s about it. How come all of the “independent” foundations use UVIMCO as the asset manager? Asking for a friend…
            And then to top it off, Jim Ryan required all “UAO”s (University Affiliated Organization) to sign a new affiliation agreement. He gets to appoint a member to each Foundation’s Board, and so does the BOV. These members are “super” members. They even have the duty to “rat” on the “independent” Foundation. In a self selecting clubby Board of almost 40, is it possible the UVA appointees exercise effective control of the “independent” Foundation? Again, just asking for a friend…

          4. Nancy Naive Avatar
            Nancy Naive

            UVa has no money with UVIMCO. The endowment does. Money in an endowment belongs to the endowment, not the beneficiary. That’s what insulates it from lawsuits against UVa.

            For example, you do not own the money in your IRA. The IRA is a separate entity.

          5. walter smith Avatar
            walter smith

            UVA does have money in UVIMCO. It is called the Strategic Investment Fund. Additionally, UVA is the beneficiary of a pile of money from all of the affiliated foundations. And don’t kid yourself…UVA controls the UVIMCO Board, one way or the other, just like it controls all of the affiliated Foundations.

          6. Nancy Naive Avatar
            Nancy Naive

            You are correct, the SIF is UVa money, and how it is invested is most probably within the purview of the State Government and the governor. Maybe.

            How endowment and the foundations money is invested is most assuredly NOT within State purview and moreover is none of their business.

          7. walter smith Avatar
            walter smith

            Oh, really? Tell me why. Using Obama language, can the Foundations “invest” in pro-life causes? Or, pro baby-killing causes? A private endowment can invest how it wants. That depends on the trustor/testator/governing docs. However, the endowments for UVA have a public use. UVA IS a “public institution of higher learning.” That’s a fact. It is also a fact that every single foundation is a 501(c)(3) organization. Further, every single Foundation’s charter has a savings clause with the Commonwealth of Virginia as the last resort. Then, add in fiduciary duties of the Board (in reality controlled by UVA) to act in a fiduciary manner. ESG investing – “stakeholder capitalism” – is just Marxism for corporations and investment advisors – it is inherently political. Maximizing returns to the beneficiaries, just like maximizing returns to the shareholders of a corporation, should be the sole duty of the fiduciaries/ Board…not virtue-signaling with other people’s money. Many States are catching on and insisting on fiducairy duty excluding virtue signaling investing. AG Miyares can simply issue an advisory opinion. If we had a sane legislature (hypothetical, obviously!), the statute would be amended to so specify.

          8. Nancy Naive Avatar
            Nancy Naive

            To make money. The taxes I pay have public use too, but it’s not the government’s business as to how I invest.

            Prove that they are not maximizing income.

            BTW, income is generally what belongs to the beneficiaries. Capital gains in trusts are additions to principal, and not income. So, buying and selling adds only to the endowment. Just an interesting fact.

          9. Nancy Naive Avatar
            Nancy Naive

            For both our benefits:
            1) The Endowment and the Foundations are separate legal entities governed by founding documents, like trusts. They are NOT owned by the university; the assets held by an endowment/foundation belong to the endowment/foundation.
            2) UVa is the beneficiary of all of these entities, the State is the follow-on beneficiary. Money has to go somewhere.
            3) UVa does have Short Term Reserves. Money owned by the university that comes from various sources including tuition and state funds.
            4) UVIMCO is a private company that provides investment services to the endowment and the foundations and UVa.
            5) The SIF is an investment vehicle managed by UVIMCO to invest UVa reserves less tuition and state appropriations. The income from SIF funds various endeavors, e.g., research projects, while the principal remains intact for its “reserve” purposes.
            The SIF is managed by UVIMCO.

            https://hac.virginia.gov/subcommittee/2016_Subcommittee/higher_education/files/8-26-16/Key%20Considerations%20SIF%20(2).pdf

          10. walter smith Avatar
            walter smith

            Now you are actually correct. Next you need to see the MOU (Memorandum of Understanding) each UAO (University Affiliated Organization) had to sign. All Foundations had to sign. While they have separate EINs and separate Boards, the UAOs are not by any means truly independent. UVA controls this money in reality. Hence the “Responsibility” tab on the UVIMCO site. As to trusts within the Foundations, if any, there is no way to really know how compliant with the Trustor’s wishes they are. Particularly if the Trustor is long deceased.

          11. Nancy Naive Avatar
            Nancy Naive

            Yes they are. They are independent entities in the eyes of the law, and they’re private. They are no more a part of UVa as is NNSB&DD, and neither the governor, nor the AG have an legal reason to know how they or the shipyard invest their money. In fact, even though the SIF is UVa money, it is mostly donor funds and it is questionable if the State has authority to request how it is invested.

            The grantor at Sweetbriar was long dead too.

          12. walter smith Avatar
            walter smith

            You have read the MOUs? The Foundations are not independent. They are controlled and the separateness is a fiction.
            Even so, the legislature already has the authority to regulate fiduciary standards, and does. There is also common law and a body of trust law on fiduciary standards. ESG investing violates those standards. And they aren’t telling them how to invest. They are prohibiting investment decisions based on politics. Can’t wait to see your new opinion when Republicans are in control of the legislature and the Dems hold the executive spots. Political investing violates fiduciary duty. Period. No matter who is in charge.
            Some trusts have the ability to invade principal. There are all sorts. And the trustees there are bound by fiduciary duty. The only legit way to do ESG investing for such trustees would be if it was a spoiled rotten heir who wanted to virtue signal green or ESG investing with his own money. And no one is telling you how to invest your money. Do what you want. But you do continue to ruin the inherent value by voting D, so it is obvious you don’t care. Besides, you’ll be long dead when everything blows up from DUtopia…

          13. Randy Huffman Avatar
            Randy Huffman

            Just got back to this and read Walter’s comments too. UVIMCO decided to issue their ESG oriented investor responsibility guidelines for what reason? Why did they commit themselves to transitioning their endowment to a net zero by 2050 objective? The answer is simple, because their “beneficiary “ – UVA asked them to. No independent investment manager would have implemented such a policy otherwise.

            ESG mandates have no place in a University endowment, that’s the whole point.

          14. Nancy Naive Avatar
            Nancy Naive

            As the beneficiary, UVa does (and should) have sway over the way the endowment is invested. As the investment company, UVIMCO has a responsibility to increase principal and income despite the beneficiary. Saying “by 2050” is comfortable compromise. “Okay Mom, I’ll take the trash out after I get home from the Mall.”

          15. LarrytheG Avatar
            LarrytheG

            Interesting, the idea that we want politicians to be in charge of deciding what is acceptable "politically" in the investment fund or not .. depending of course of who the politicians are at any point in time. No surprise where these "ideas" are coming from either!

          16. Nancy Naive Avatar
            Nancy Naive

            The problem isn’t political appointees making investment decisions, it’s companies that make money from politically unpopular products.

          17. LarrytheG Avatar
            LarrytheG

            unpopular products or unpopular businesses?

  6. Thomas Dixon Avatar
    Thomas Dixon

    If they can't keep politics out of the Department of Health, they won't with universities.

  7. Nancy Naive Avatar
    Nancy Naive

    UVa has kept politics out of their endowment investing the best way they possibly could. They gave absolutely ZERO control over the investments to the BoV.

    1. walter smith Avatar
      walter smith

      Not true. See above.

      1. Nancy Naive Avatar
        Nancy Naive

        What above, Walt? What above? Wouldn’t that involve how we each sort and display our posts?

        1. walter smith Avatar
          walter smith

          I had just finished composing a lengthy description of reality, which you still are blathering about on a fiction.

  8. Nancy Naive Avatar
    Nancy Naive

    is that Tom Brokow?

  9. LarrytheG Avatar
    LarrytheG

    Didn't this sort of start way back when some folks were concerned that some public investments were being made in "blood" diamonds and gold, etc?

    Are we now saying that the investments should be totally without regard to anything along these lines , i.e Russian companies, or Companies said to be using "slave" labor, etc?

    Seems to me that once you DO cross "A" line, it opens up the whole thing.

    1. Nancy Naive Avatar
      Nancy Naive

      And when Republicans get involved, money is lost…

      http://www.cnn.com/US/9807/10/texas.disney/

      1. LarrytheG Avatar
        LarrytheG

        wow…….July 10, 1998

        1. Nancy Naive Avatar
          Nancy Naive

          That was the year of the “gay cruise”. Disney chartered their cruise ship to an organization that sold the cabins to LBG couples. When the Southern Baptists found out they stomped their feet and sold all their stock and urged “all good Christians” to do the same.

          The “virtue signaling” cost them tonnes of money. Disney was on a tear and their shares were snapped up like wedding dresses in a bargain basement.

  10. Nancy Naive Avatar
    Nancy Naive

    ”what’s to stop Boards of Visitors from using endowments to advance conservative goals — divesting companies whose health care plans pay for abortions, say, or hospitals that conduct transgender surgeries, or corporations that trade with leftist regimes beloved by progressives?”

    Because endowments and foundations and their money is private?

    For Republicans, the lack of understanding of private ownership is shocking.

  11. Nancy Naive Avatar
    Nancy Naive

    as a note on a similar vein …. The 2nd dumbest thing the State of Connecticut ever did was exempt insurance companies from paying State taxes. The dumbest was exempt them from filing tax returns.

    As a result, not only did they lose revenue, they had no idea how much revenue they were losing.

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