PodcastHero_web_2020

Episode 41: Jason Wheeler of Elevator’s Cut

Jason Wheeler, co-host of Elevator’s Cut and grain merchandising specialist at White Commercial, stops by to talk with Rodney on how a strong, local grain buyer can be so important to a town’s economy. When the buyer makes more money, the farmer makes more money, too. It may sound counterintuitive at first, but join this conversation for a closer look at the process.

 

Rodney Connor: Hey, today on the podcast we have Jason Wheeler with White Commercial.

Jason Wheeler: Yeah, thanks. I'm glad to be here and chat with you.

Rodney Connor: So I know Jason actually just through his podcast, so I've been listening to The Elevator's Cut podcast I think since its inception, Jason. I don't know if I was your first listener, but I caught that one pretty early. I think there was only maybe a couple episodes at the time. Didn't know each other actually what I was on your podcast back in August, something like that.

Jason Wheeler: Yeah, it's been a couple months. I don't know, time runs together these days, weird.

Rodney Connor: That's right, yeah. So I'll tell you just personally, man, not knowing you before that, hearing you on the podcast and stuff, we've had a few conversations since then, and man, we just had a couple of conversations about how a strong agricultural community really affects that local community. That's the thing that I'm super interested in, I could tell by our conversations that you were super passionate about it, so that's why I wanted to get you on the show today.

Jason Wheeler: Yeah, I am passionate about that. So I've been with White Commercial for 15 years and that's really what White Commercial was built about. So what we do is we work strictly with commercial grain elevators, or I guess you could say also large farmers that have become grain elevators by accident, but eventually, over time, your neighbors start like, "Hey, you got all these bins. You mind if I use some?" So that happens and so those are our customers. We help them with merchandising. And yeah, you're right what you said, what you see is a strong merchandiser at a commercial in a town helps everybody strive. And that's really what Mr. White saw when he started our company in the '70s was back then, hedging and basis trading wasn't really a common practice like it is now, and it was government storage, and collect and checks. That's what grain elevators did, from what I understand. I wasn't alive, so you have to bear with me, but this is what I've been told.

Jason Wheeler: And anyways, if a merchandising grain elevator hedges and just strictly makes their money off basis, and managing their spreads, and that sort of thing, if they're doing that well, they're going to help all the farmers in their community, they'll help the end users in their community, because they can be neutral to price and buy corn for $5, sell it for $3, and still make money. And when you tell that that don't either understand the grain business, or merchandising and hedging, and stuff, that doesn't make any sense, but I promise you it is. So that's what we do. We teach people how to do that. And in a perfect world, the elevator, since they are price neutral, can help a farmer really manage their price risk pretty well.

Rodney Connor: I've been working with farmers long enough that a lot of farmers think the buyer is trying to pick their pocket all the time. It's a zero sum game. Every penny I can squeeze out of my buyer makes me a better, more profitable farmer. I am certain you don't think it's quite that simple. Just curious your thoughts, where do you see that money evaporate? What kinds of behaviors make that money evaporate from that local community from the buy side?

Jason Wheeler: From the elevator side?

Rodney Connor: Yeah.

Jason Wheeler: And I'll tell you, so what you just said is true in not all cases, but a lot of farmers think ... You take this year. Beans were $11 not too long ago, now they're 15. And, "You elevator, you guys must've made a fortune off my bean that I sold you $11." They didn't, I promise you. They sold them either in the cash market or they hedged them, and they paid a bunch of margin calls and wish you hadn't had sold at $11. I'm here to tell you. So they didn't, and a lot of guys know that in general, but it's frustrating when the markets run up after you sold, I get it. So that happens, so one of the things you said was hey, it comes down to we're arguing over pennies. I'm a farmer, I'm selling to the elevator. I'm trying to get all I can. They're trying to get us. And that's I mean true in the spot market. You're selling today and you're bringing the grain in, if everything's happened in the spot market, there's no margin left at that point, for anybody.

Jason Wheeler: And you're right, everything you can argue and get, he loses and vice versa. But the beauty of the commercial grain deal is trying to manage stuff into the future and out of the spot market for months down the road, whether it's purchases or sales, and maybe they buy something for a few months out and then they do execute in the spot market the other side. So I'm going to say never be in the spot market, but one side, at least, you want to be out of the spot market on from the elevator side. So that's one thing that does, I think, hurt margins for grain, or you see money evaporate is we just get down, the elevator hadn't bought and sold anything, you're bringing your grain in, the market's inverted, everything's screaming up, the elevator doesn't want the risk, it's just get it out of here as soon as I can. And in the spot market, everybody knows what the market is and who's been what in that area for the most part is public bids. And so it's like I'm not pulling the wool over anybody's eyes.

Jason Wheeler: So that happens. The other thing that really happens that I see that evaporates money out of everybody's pocket is just bad policies by the elevator. So a lot of people like to kick farmers or whatever, occasionally just get frustrated with farmer selling habits and things, and how, "Well, farmers always want the price to go up and they never do this." And guys, as you know, anybody listening to this podcast, if they're honest with themselves, it's a next to impossible job marketing grain off the farm. I mean you can do one of two things, you can sell too early or you sell too late. That's it. That's all you can do because nobody's going to sell the perfect number. And you wake up every day and you can look at the market, it's changing by the second, so it's very difficult. So don't get me wrong, so I think a lot of it is policy driven on the commercial side as far as when it gets ... I mean because honestly, that's where I come at it from anyway.

Jason Wheeler: So I see what we can do better. And what we can do better is a policy thing. And one thing I was thinking, I think I shared this with you last time we talked, but you think about out West, like Western Kansas, where they had the huge wheat carries and everything, and they would just pile it on the ground. And you see it out there now. From a commercial standpoint, I know huge carry markets, if you bought a bunch of grain and are carrying it with this stuff, because they put in the VSR and all that fun stuff, and it drove massive carries. And so that's a huge amount of money a grain elevator can merchandise and make. And in that case, there are co-ops for the most parts. I mean this is money getting paid back into the community when they make it, so it's great. And so I see these, I just drive out there and I was just like God, I'd never seen piles.

Rodney Connor: Just money everywhere, right.

Jason Wheeler: I'm like this is great. But then you go in and talk to the merchandiser. You're like all right, what's a ... And I mean they were carrying two years worth of crops, as you know, the carryovers year to year was 75% at one point on wheat, I think. So it was just crazy the amount of grain. Multi-years worth of grain. And I'm like this is great for them. They're finding a place to hold it and take advantage of those carries. But anyways, getting back to our evaporations, you go in, you talk to the merchandiser and they're like, "No, we don't actually own any of that. It's all on storage." And I'm like, "Well, at least you're charging a bunch for storage, right?" "Oh no. By God, we're the cheapest in the four county area. We're charging two and an eighth cent a bushel, and that undercuts our competition by eight." I'm like, "Are you serious?" So meanwhile, there's dollar 50 a bushel type carries from year to year, and they carry it that long, and they're getting 2 cents a bushel.

Jason Wheeler: Meanwhile, the price is not getting any better, the farmer is just sitting there waiting on a price that's not getting better, a lot of cases getting worse, mostly was getting worse. So farmer's price is going away, the elevator's not making any money off of it, and I don't know what the quality is going to do sitting out there, but it just evaporates. Yeah, so it's heartbreaking because one, the farmer could have sold a good price early. He didn't, so he missed that. Elevator missed tons of margin on that side. And then, of course, the community missed out because in the case of most of those are co-ops, it's just gone. So it's heartbreaking.

Rodney Connor: Yeah, I think I told you the story about where I see the other ... So you talked about a carry market, the other one is an inverted market, where huge inverses and, as a buyer, you're thinking man, how do I sell this? I need ownership. I want to own this. So the answer, obviously I'll let you fill in the blank here what's the answer to that is an elevator. I need ownership in an inverse.

Jason Wheeler: Yeah, I got to get some DP.

Rodney Connor: Free DP, man. Give it to the farmer all day. Farmer loves free DP. But what happens, so this is a specific example, I don't know when that big bean inverse was that I remember.

Jason Wheeler: I think it was '12.

Rodney Connor: Somewhere around 2013 or '12, yeah.

Jason Wheeler: Was it '12, '13?

Rodney Connor: And I had a guy, local facility, small town. And the guy says he's got 150,000 bushel of old crop beans sitting there, and it was a dollar inverse. So the money on the table right now. So I go to him and say, "Hey, you should do a basis contract. We should consider a basis contract." So a basis contract lets that farmer lock in that good basis, sells that basis premium, and then his futures are open. Long story short, he didn't want to sell cash because he felt like the market was going to go higher. And he's like, "Oh no, man. I lose on basis contracts every single time. Every time I do a basis contract, the market goes down." And I'm like, "Perfect, that was first option. Second option, how about you just give them to me on free DP? But I'm like I'm going to make a buck a bushel on these. Just so you know. I want you to know I'm going to make a buck a bushel on these."

Rodney Connor: And he's like, "Well, I'm not giving you a buck a bushel. No way am I doing that." I'm like, "Great, then just do the basis contract so you can have the buck a bushel. I really don't care who gets it." Didn't do it, man. Did not do it. The lack of trust. And I just don't understand. I guess it kills me to see that money evaporate. That year sticks out for me as a year I saw, we're talking $200,000 worth of value literally up in smoke. Nobody got it. I didn't get it, the elevator didn't get it, the farmer didn't get it. Those are the things. And that's the reason I love listening to your podcast, Jason. I think you guys talk about teaching these buyers how to not let that happen, and all my time is spent talking to growers about how not to let that happen. So if we can get that message out there, I think it leads to better communities.

Jason Wheeler: Yeah, it's definitely those inversions, which is what we're in now. I mean being in corn, we've got strong prices, but you look at new crop and it's a lot less. And it's a tough time, but we like to draw pictures, the basis and the spreads, and show it out visually, because if we just have to do math in our heads again, Arkansas, so it's tough. So we draw it out, but I've had guys that'll go to their farmers, this situation you were saying, and they'll draw it out and say, "Look, that bean inversion year, it inverted over $3 from old crop to new crop."

And they're like, "Look, we are staring at this. We know this is here. We're about to have to roll into this. If we're in the right position, we're going to make that." And he just tried to explain the best he could to the farmer and then said, "If you don't want this, can I have it? Because this is about to happen. But the only way anybody can make money is if we've sold the basis." And that's a mentality out there that it's frustrating to me that a lot of farmers, you just hit it perfect, they don't want to do something even if it is in their best interest because somebody might make money off of it.

Rodney Connor: Or they've been burned or it didn't work out. So the other thing is-

Jason Wheeler: I understand that.

Rodney Connor: ... being burned in the past. So back to this basis thing, let's lean into that. He says, "The basis contract has screwed me every time I've done it." Well, the basis contract didn't do anything. The futures market fell. I mean maybe he lost a few cents on basis because he did it too early sometime, but but it's the cash price that he wasn't happy with.

Jason Wheeler: Well yeah, in those basis contracts, I mean this is a hard ... Like I said, our business is simple but there's a few things you got to understand, and not everybody does at the beginning, but it's easy to learn, but one thing is basis contracts do, to borrow a term, screw a lot of farmers.

Rodney Connor: Yeah, sorry about that.

Jason Wheeler: No, that's fine. So the reason is because a lot of them do it in carry markets. So you set your basis and then you keep rolling it. And you roll into carry markets with the basis, and it's just going to get lower and lower, and you definitely see that happen. But in this environment, you flip it around and say no, this is an inverted market. You roll into that, your basis is going to get better and better, really. But yeah, they've got that history of that. But the mentality that just gets me is the, "I don't want you guys making money." Well, do you want us to be here at all? Because you know we're a business and we're not a 501(c)(3), or a nonprofit, or something, we have to make a margin. But the other thing is long term, not only do you have to make a margin in your business, but you have to have customers to have a business long term, and this business is so small.

Jason Wheeler: And I'm here to tell you, I do meetings with just grain elevator people all the time, and I can't tell you how this business is all about relationships. Guys absolutely treasure relationships. A lot of guys, they're not going to do certain types of contracts, even though maybe their competitors do, just because they're worried that somebody might get into it, not understand it, it goes the wrong way, and it hurts a relationship. They just can't afford to lose a relationship. So I mean a good grain elevator is extremely protective of their farmers and that relationship, and they don't want to ... they don't want to do something that's not in your favor, but they do want to make money from year to year, and understanding when elevators make their money off basis and spreads, and farmers make it off price, everybody can do well and not make it from each other.

Jason Wheeler: Like I said, I teach people how to buy it for $5, sell it for $3, and make money. And honestly, talk to every one of them to a person, they would absolutely love if every year that's how it went. Because the other thing, not only are they going to help their farmers get a higher price and help their local users get a better price to feed chickens, or cows, or pigs, or whatever, or ethanol plants, you name it, they'll help all those, but that is a good cashflow game too. Because they're going to buy it for five and hedge it, and the market falls down, that means they're not paying margin calls. So I mean that's just a perfect scenario for a grain elevator, really.

Rodney Connor: Selfishly, that's good for you too because you're not making margin calls to those guys, right?

Jason Wheeler: Man, that's funny. That's part of our ... We're futures brokers, and so when I am in the office, I make margin calls for my territory of customers, but if I go on the road, if I'm traveling out visiting people, which I do quite a bit of, somebody else in the office does that. And so I'm to the point now, it's just rallying so much I can't take it anymore. I'm like, "Guys, I got to go. I'm on the road." I don't necessarily need it, but I'm just going to get on the road so I don't have to make these margin calls. It's insane.

Rodney Connor: Yeah, that's right. Down days, Jason's in the office, up days, Jason's out seeing customers. That's a good strategy. Opposite of a grain originator, for sure. So we've been talking for a bit now about how important the buyer is to the community, making money and all this stuff. I'm sure we've convinced all the farmers listening to this right now, Jason, that they should just give all their money to the buyer so that it trickles down back to them, right? No more fighting over basis and all that.

Jason Wheeler: Just like the government.

Rodney Connor: Exactly.

Jason Wheeler: Get your stimulus back sometime.

Rodney Connor: To the extent you're willing to share, I mean what can a farmer do just a little different? The average farmer. Look, what can the farmer do that will make the buyer a little more money and not really cost the farmer anything? Any thoughts on that? I'm looking for specific things.

Jason Wheeler: I have great ideas for that, which is easy for me because I don't farm. So I'm sure you guys listening love for someone who doesn't farm, have never had to sell their own grain tell you how you should do it. Everybody loves that.

Rodney Connor: Yeah, that's super relatable.

Jason Wheeler: It's funny, but I do a lot of farmer meetings for our grain elevators and we do our deal. And I guess we are futures brokers, so people expect me to put up a bunch of charts, and technical analysis, and stuff. And there's information that's valuable and then there's noise. And most of the stuff out there is noise that doesn't really affect you, and it's a distraction, I guess, from what you should. Again, here comes my Arkansas simplicity here, but farming is putting a whole bunch of ... taking a whole bunch of money and putting it into the ground, and then taking it all out of the ground and having more money than when you started.

Jason Wheeler: That's what it is. And so can get hung up on trying to guess where prices are going and all that or we can manage that cash grain farm. Because if you got opinions on price and you think prices should go here, and this way, this time, and we should do this and that, you don't need to have the overhead of a farming operation. And I've told people that speculate a grain elevator, I'm like you don't need a grain elevator either if you want to guess which way the spread's going. That's not your business.

Rodney Connor: In fact, you sell the elevator, you have more capital to spec on spreads, right? Yeah, it's holding you back.

Jason Wheeler: That's right. And yeah, you don't have all ... you don't have to pay people's health insurance. What are you doing? But you go and I guess it's focused on what is your business. Is your business needing to know about the strike in Argentina, and the drought in Australia, and all that stuff? And I'm not saying it doesn't indirectly affect things over time and everything, but there are lots of people who actually do that. They just speculate and trade for a living, and they know all this stuff and by the time we hear it, it's already traded out in the market, for the most part. So it's out there and all that. So my deal is remember what your business is. And so your business is to make money and make it every year, not just be like, "I'm going to be in position so if we ever get a rally during harvest of multiple dollars, I'm going to kill it." Because that's what happened this year, I get it, but it doesn't happen most years.

Jason Wheeler: And so if you run your business where you could really just slay it in years like this, the other years are going to eat you alive. And I like to tell The thing I hate, so an investment guy, and he says, "Volatile markets over time. And here's my average rate of return." So he says, and I'm like what does that even mean? Because I look at my saving. It doesn't seem like it's growing like that, and the deal. So you take a dollar and you say, "Volatile market. Things move around," makes 50% return. What do I have now? I got a dollar 50. Beautiful. Next year, volatile markets dropped 40%.

Jason Wheeler: All right, so I get my statement. It says, "Hey, we make 10% overall. You averaged a 5% gain, but we made 50%, then we lost 40%." But if you lost 40% of a dollar 50, you got 90 cents left. I got less money when I started, but you're telling me we made ... So I apply that to farming is you can have these good home run years, but if in the other years, you give it back, you don't get ahead doing that. What you do get ahead is making money every single year. And then you can compound things, you can build wealth, which is what a lot of folks are trying to do, pass onto the next generation and all that, is consistently overtime making money every year.

Jason Wheeler: So a lot of guys this year came, they sold $11 beans, $12 beans, and guess what? They made good money. They made money this year. They didn't make as much as they could've, but they made money this year. And next year, if they stay with that, they'll make money again. And it may not be huge, but a great zinger I heard actually this week, grain merchandiser, he said he was talking to a farmer, and the farmer was mad because beans are $15 and crap, I sold mine at 11, and he's just not happy, and he's frustrated. And so the merchandiser says to the farmer, he says, "Well, did you see what orange juice prices have done though? Can you believe all that?" And the guy's like, "I don't know. I don't know what orange juice prices have done. I don't have orange juice. What do I care?" He said, "Well, you don't have beans either."

Rodney Connor: Oh man. I mean yeah, to your point, it's a distraction.

Jason Wheeler: If you always judge yourself based on what could have happened, you're always going to be disappointed. So one thing I heard is a guy, it was a university professor type guy at some conference, he said, "Look, it's easier if you guys just get it out of the way to start with, you're going to be wrong. You are either going to sell, and the price goes up later, and you wish you hadn't, or you're going to sell, and the price goes down, and you wish you'd have sold more. So you're just going to be wrong. No matter what you do, you're going to be wrong if that's how you're judging it. So just sell what makes you money." So as far as things you can do, getting back to your question, I'm sorry, was be proactive, have profitable target goals in mind that you give a lot of time to work.

Jason Wheeler: You can't get to harvest and say, "All right, well I need to make this much money or else," because once you get to harvest, if you haven't got [inaudible 00:26:19], now your costs continue to rise. Whereas your costs are set going into harvest, and then after harvest, even if you've got your own bins, there's cost to that, and not having the money, and all that other stuff. And if you've got bins, you should be selling for the time slot you want, and you can capture the basis and the spreads, but the only way you can do it is by selling ahead, because that's another thing that'll just evaporate on you. Guys look at Ben's as a ways to wait longer for the price to do something, and you can use it like that, but as we know, prices don't have to go up, they can go down too, and you don't really realize the value you should for the bins.

Rodney Connor: The same thing, you don't need a bin to speculate on if the price is going to go up or down. You use the bin to sell the carry and get paid back on that. Yeah, I think if I'm walking away from this conversation saying what's the big takeaway for me, I think it's that time piece, Jason. The more I think about it, the more I think that the more time your buyer has to merchandise and do things with that grain that you purchased ahead of time or that you sold ahead of time as a farmer, and hopefully at a good price, the more value there is on the buy side to your local elevator that hopefully they put back in the community, and it doesn't really come out of the farmer's pocket in that instance. Although again, I'm going to raise my hand here, you sell 10, 20 beans off the combine because it's a good sale, and then beans go to 15 bucks, that doesn't feel like time really helped you out there, but to your point, that's an anomaly.

Jason Wheeler: Yeah, more often than not, that's the right ... Like I said earlier, you can either be the guy that sells too early or the guy that sells too late. That's your only option. Which one do you want to be? I'll tell you over time, the guys that sell too late are in a world of hurt a lot of years because they're selling because they have to and it's a really bad situation a lot of times, and to sell $15 beans, you would have had to say no to $11 beans, and $12 beans, and $13 beans. How do you say no to all those? And if you did, and you still have beans, and it's $15, you know what I think? I don't think you're going to sell those beans. If it's $15 by now, I don't think you're going to sell them until you have to, and it's too late, and you wish you'd have sold. So I don't know, the psychology is tough, but you're right, the time thing is huge.

Jason Wheeler: And what I've been a proponent of is guys look at the goalposts, so when does my marketing year end for this grain? For corn, beans, whatever. And most guys look at it as I've got until next year's crop comes off to sell these things. I think your goal should be when it comes off the combine, it needs to be sold. That should be the goalposts. And if you've got bins, they're going into bins, it should be sold for JFM delivery, and you'll get a premium because you have bins. So this works whether you have bins or not, but by the time the combine rolls, it needs to be sold is my ... I didn't know that rhymed until I just said it.

Rodney Connor: That's good.

Jason Wheeler: Anyways, and guys are like, "Well, what happens?" You're like, "This." We'd get rallies and I mean there's going to be 1 out of 10 years you'd wish you'd had just held it all, but the 8 or 9 out of 10 years, it's a good system. And the other thing is if we do get rallies in the spring and summer, which we normally do, that's for next year's crop. It's not like just because you sold this years doesn't mean you missed out on this, now you've got stuff to sell for next year. Again, so there's my whole spiel, but I know it's easy for me to sit here and say without being in the seat that the farmer's in, and I get that. I get it's tough, but if over time we can take whatever percentage you are able to sell ahead and just grow that a little bit, maybe normally you have 20% sold or 30% sold, if you can grow that to 40% or something over time, I think it'll help you.

Jason Wheeler: And going back to the elevator and your community, if a elevator can merchandise those bushels earlier, they're going to be able to help you a lot on flexibility of where that stuff goes. They'll sell a better basis, which will pass down to you, because they'll be able to manage that position better and keep more money in the community. Elevators want to buy bushels at harvest. They just do. And that doesn't mean you sell them across the scale, that means hopefully most of them are forward contract at great profitable levels and all that. That's really their goal is to have it forward contracted.

Rodney Connor: And those guys you're dealing with, when they're making good profits, are they putting all that cash in the bank and just hoarding it for years to come or how are they spending those extra profits?

Jason Wheeler: No, absolutely, they're making it faster for you to dump, they're making it easier to ... Yeah, they're getting bigger, they're hiring people in the community, they're sponsoring animals 4-H, doing all this stuff in your community. And that's another thing, if they're not doing it, I guess bringing back some other stuff we talked about is eventually the big guys are going to come in and swallow them up. And when that happens, the 74 location co-op with headquarters two and a half hours away is not sponsoring stuff at the 4-H at the fair and everything. So anyways, it gets less and less of a community feel and you're keeping money in a community somewhere, but it's probably not your community.

Rodney Connor: That's right. Yeah, I always say I want to pull that money out of Chicago. I want to pull that Board of Trade money into Dwight, Illinois. That's my goal. And I think it's good merchandising, good farmer practices, that's how we get that done. I want to thank everybody for tuning into the GrainWaves podcast. If you're new to the podcast, remember to subscribe, leave a five star rating, and share with your friends and family.

The opinions and views contained in this presentation are those of Indigo Ag, Inc. (“Indigo”) personnel based on publicly available sources. These materials are not research reports and are not intended as such. These materials are provided for informational purposes only and are not otherwise intended as an offer to sell, or the solicitation of an offer to purchase, any commodity future, swap, security or other financial instrument. These materials contain preliminary information that is subject to change and that is not intended to be complete or to constitute all of the information necessary to evaluate the consequences of entering into a transaction and/ or investing in any financial instruments. In no event should any party rely on any material contained in this presentation to execute any trades or transactions. There are risks in participating in any trade or transaction and each party should independently consider such risks and perform their own due diligence prior to the execution of any trade or transaction. These materials also include information obtained from sources believed to be reliable, but Indigo does not warrant their completeness or accuracy. In no event shall Indigo be liable for any use by any party of, for any decision made or action taken by any party in reliance upon, or for any inaccuracies or errors in, or omissions from, the information contained in these materials and such information may not be relied upon by you in evaluating the merits of participating in any transaction. To the extent these materials include any quotes or rates, they are for informational purposes only. They are not to be relied upon to make any trades nor are they meant as a recommendation to participate in a particular trade. Indigo makes no representation as to the accuracy of the data. Trades can only be made through an account at a registered broker/dealer or futures commission merchant. Indigo is neither a futures commission merchant nor a registered broker / dealer. Indigo is not a SEF. All projections, forecasts and estimates of returns and other “forward-looking” statements are based on assumptions, which are unlikely to be consistent with, and may differ materially from, actual events or conditions. Such forward-looking information only illustrates hypothetical results under certain assumptions. Actual results will vary, and the variations may be material. Nothing herein should be construed as an investment recommendation or as legal, tax, investment or accounting advice.