John H. Langdon
Education:
Bachelors in Business Administration
University of Notre Dame
Professional Affiliations:
Million Dollar Roundtable
Finseca
National Association of Insurance and Financial Advisors
John Langdon graduated from the University of Notre Dame in 1984 earning a Bachelor’s degree in Business Administration with a Marketing concentration. John was a member and competed on Notre Dame’s Varsity Track and Field Team.
While still attending college, John joined Langdon Ford Financial, now Allied Wealth Partners, as a Case Planner. In the summer of 1983 he became a broker for the Firm and a full time Advisor in November of 1984. John was later appointed Sales Manager in 1988. For six years John recruited, trained, and helped develop new advisors. He was appointed Managing Partner in March 1994 and continues to lead the Firm with President, Marc Del Gaudio.
Since becoming CEO of Allied Wealth Partners, the firm has won many major financial services industry awards for firm management including, Finseca’s National Management Award and has been consecutively recognized as a Master Firm since 2000. In 2011 and 2014, AWP was honored with Finseca’s First in Class Award.
The Firm has consistently been recognized by its affiliates. Since joining Securian Financial Services in 2004, AWP has finished based on firm production in the Top 5 of all Securian Firms nationwide. Under John’s leadership, the Firm has won the Terrance M. Sullivan Build on People Award five times for New Advisor Development and was Securian’s Top New Firm in 2005. Every year for the past 11 years AWP has been recognized as a Chairman’s Club Firm, an award given by Securian Financial Services for firm production. In 2014, AWP was Securian’s Gold Firm of the Year, and was the silver firm of the year in 2015 to 2021.
John was elected by his peers to Securian Financial Group’s National Advisory Board (NAB) from 2005 through 2009. In 2009 he served as its chairman. He was re-elected in 2012 to the NAB and was the 2015 Chairman. He was reelected to the NAB in 2018 and currently is serving on his third elected term and is the 2022 Chairman of the National Advisory Board. He also was a member of Securian Financial Services Advisory Board from 2006 to 2009, also serving on its chair in 2009.
John is active within his community and charitable organizations. He is the current Chairman of the Board of the St. Joseph High School and is on the Board of Directors of the Brothers of the Sacred Heart Foundation.
He and his wife Mary Janine, live in Martinsville, New Jersey with their three children, Katelyn, Molly and John.
John Langdon is a registered representative and investment advisor representative of Securian Financial Services, Inc. Million Dollar Round Table (MDRT) is an independent membership organization of life insurance and financial service professionals. Membership levels are based on commissions, premiums, or fees generated within a year from investment and insurance products. Members must apply annually and pay a fee. Members must be members in good standing of a Professional Association which has met the following criteria: in existence at least 2 years, have 100 or more members, must be a nonprofit organization, must have a code of ethics and an effective means of dealing with breaches of its code. Members must also adhere to the MDRT Code of Ethics. Finseca is a membership organization for which individuals must submit applications and payment. The organization is geared toward those in a recruiting, training, or supervision role in the financial services industry. Awards are based primarily on commissions, premiums, or fees generated from investment and insurance products and other criteria relative to leadership, achievement, and recruiting selected by the applicant. Individuals must be current with membership dues and submit an application fee for consideration. Securian awards and club memberships are based primarily on commissions, premiums, or fees generated from investment and insurance products other criteria relative to leadership, achievement, and recruiting. Working with this advisor is not a guarantee of future financial results. Investors should conduct their own evaluation.
Marc J. DelGaudio CFP®
Education:
Bachelor of Science in Economics, Yale University
Professional Affiliations:
Financial Planning Association
Million Dollar Roundtable
1993 Marc DelGaudio graduated from Yale University and shortly thereafter joined the Allied Wealth Partners team as a full time Financial Advisor. Within a span of ten years, Marc went on to become a CERTIFIED FINANCIAL PLANNER™ (CFP®) Practitioner and Director of Investments and Financial Planning at Allied Wealth Partners. Marc was named a Managing Partner of Allied Wealth Partners in 2006, co-managing the firm with John Langdon. In 2014, Allied Wealth Partners expanded its presence into New York opening several new offices. Within that same year, Marc was officially appointed as President of the firm.
As President, Marc shares in the supervisory responsibility of firm administration while continuing to work closely with his clients. Marc is also an active mentor to the firm's financial professionals. In such role, Marc shares his philosophy on wealth accumulation and preservation strategies that help clients achieve their definition of financial success.
Marc DelGaudio currently serves on the Securian Financial Services,Broker Dealer and Trust Company Committee. He also recently served as chairman of Securian’s National Advisory Board.He is an active member of the Greater Essex Chapter the Financial Planning Association (FPA) and is also a Life and Qualifying Member of the Million Dollar Roundtable (MDRT), with several Court of the Table qualifications.
In 2013 and 2015 Marc and CEO, John H. Langdon were presented with GAMA International’s James H. Krueger First in Class Award for outstanding leadership and excellence in recruiting, training and production. This honor recognizes first-line leaders in the insurance, investment and financial services industry. In 2006 Marc received the Securian David W. Goers Award. This award is given to Managing Partners who have reached new organization excellence measured by new professionals growth and new professionals production.In 2005, Marc received Securian's "Aiming High" award which is given for outstanding contributions to the success of the broker/dealer.
Marc is an active member of the Board of Elders, Zeta Psi fraternity; Yale University and is a contributing member of the Yale alumni association. Marc lives in Martinsville with his wife, Candace and his twins Max and Chiara. In his spare time, he enjoys spending time with family and friends at the beach.
Marc J. DelGaudio, CFP® is a registered representative and investment advisor representative of Securian Financial Services, Inc. Million Dollar Round Table (MDRT) is an independent membership organization of life insurance and financial service professionals. Membership levels are based on commissions, premiums, or fees generated within a year from investment and insurance products. Members must apply annually and pay a fee. Members must be members in good standing of a Professional Association which has met the following criteria: in existence at least 2 years, have 100 or more members, must be a nonprofit organization, must have a code of ethics and an effective means of dealing with breaches of its code. Members must also adhere to the MDRT Code of Ethics. Working with this advisor is not a guarantee of future financial results. Investors should conduct their own evaluation. GAMA International is a membership organization for which individuals must submit applications and payment. The organization is geared toward those in a recruiting, training, or supervision role in the financial services industry. Awards are based primarily on -commissions, premiums, or fees generated from investment and insurance products and other criteria relative to leadership, achievement, and recruiting selected by the applicant. Individuals must be current with membership dues and submit an application fee for consideration. Working with this individual is not a guarantee of future financial results. Investors should conduct their own evaluation. Awards and club membership are based primarily on commissions, premiums, or fees generated from investment and insurance products and other criteria relative to leadership, achievement, and recruiting. Working with this individual or firm is not a guarantee of future financial results. Investors should conduct their own evaluation.
Anthony M. Bonanno CFP®, CPFA
Education:
Bachelor of Science in Finance, University of Scranton
Professional Affiliations :
Premier Resource Group (PRG)
Anthony Bonanno joined Allied Wealth Partners in 1999 after attaining his Bachelor of Science in Finance from the University of Scranton. Anthony holds the professional designations of Certified Financial Planner™, (CFP®), and Certified Plan Fiduciary Advisor (CPFA) . He is also a member of Premier Resource Group (PRG), an organization that is comprised of accomplished financial services professionals within Securian Financial Services who leverage their expertise and experience to bring innovative ideas to benefit their clients.
Anthony has built a strong reputation with individuals for developing strategies that support the accumulation, protection, distribution and transfer of wealth. He specializes in offering financial services to families with special needs children. He is also the Co-Founder and Partner of Benefits Source, LLC, an employee and executive benefits provider servicing small and middle market businesses ranging from 10 - 1,000 employees.
He has a passion for educating others on the importance of Finance to help empower them with the knowledge and confidence needed to guide them towards financial security. Since 2013, Anthony has been teaching comprehensive retirement education courses at universities and educational venues throughout New York and New Jersey including Caldwell University, Union County College, Suffolk County Community College, and West Morris Central High School. These financial workshops provide education for pre-retirees on issues they will encounter before, during, and after retirement commences and strategies to manage these risks. Additionally, he has presented financial wellness classes to employees at two Fortune 500 companies.
Anthony currently serves as the Vice President and Treasurer on the P.G. Chambers School Board of Trustees; a school dedicated to helping children with disabilities reach their full potential. He is a committed volunteer for the Catastrophic Illness in Children Relief Fund of New Jersey, an organization which assists families that incur significant financial loss in caring for their special needs child.
Founded in 1966, Allied Wealth Partners mission is to be an elite Independent Wealth Management Firm within the New York/New Jersey Metropolitan area. As of December 2021, we assist clients with over $5.8 billion of assets and have over $6.7 billion of Life, Disability and Long Term Care Insurance coverage in force for our clients. We offer comprehensive financial services covering: Investment and Insurance Products & Services, Employee Benefits, Financial Planning, Executive Compensation, Business Succession and Estate Planning.
*Formerly Langdon Ford Financial
Awards and club membership are based primarily on commissions, premiums, or fees generated from investment and insurance products and other criteria relative to leadership, achievement, and recruiting. Working with this advisor is not a guarantee of future financial results. Investors should conduct their own evaluation.
Anthony is a registered representative and investment advisor representative of Securian Financial Services.
Michael Boudway CFP®
Education:
Clarkson University
Bachelor of Science - Engineering & Management
Professional Registrations and Licenses:
FINRA Series 7 & 66 Registrations
Life, Health, and Accident Insurance Licenses(multiple states)
Registered Certified Financial Planner (CFP®)
Michael Boudway joined Allied Wealth Partners in 2010, after having worked as a financial advisor for Smith Barney (Morgan Stanley). The firm recognizes his exceptional talent and appreciates his unique professional background, including five years in wealth management and 15 years in the capital equipment industry. This combined expertise gives Michael a distinctive edge and perspective towards asset management for individuals and businesses alike.
As a Financial Advisor, Michael Boudway goes beyond the expected client-advisor approach by consistently fostering new ideas in the way people view their financial well-being. From the very first consultation to developing a financial strategy, Michael’s primary focus is to instill client confidence, provide a sense of awareness and help to protect one’s legacy. Individuals are provided investment management, insurance protection strategies, estate planning, and custom pre and post retirement solutions. Corporate clients are accustomed to in depth analysis and counsel on succession planning, pension strategies, investment management and executive and employee benefits.
Michael Boudway graduated from Clarkson University earning a Bachelor of Science in the Interdisciplinary Study of Engineering & Management. He currently resides in Boonton, NJ with his lovely wife Yasmin. He is also a member of the Denville Rotary Club, Morris County Ski Club and Enzian Ski Club.
In his leisure, Michael enjoys hiking, motorcycling, hockey, and travel.
Michael has earned his FINRA Series 7 & 66 registrations and holds his Life, Health, and Accident Insurance licenses in multiple states
Michael Boudway is a registered representative and investment advisor representative of Securian Financial Services, Inc. member FINRA/SIPC
Frank Brogan
Professional Experience:
Senior Financial Advisor - Allied Wealth Partners
Manager - Allstate Insurance Company - Special Fraud Investigation Unit
Frank Brogan is a Senior Financial Advisor with *Allied Wealth Partners. Prior to joining the firm, he was a Manager with Allstate Insurance Company in the Special Fraud Investigation Unit. Frank's expertise includes risk management, investment strategies, retirement strategies, life and disability protection and client development.
Frank is a registered representative and investment advisor representative with Securian Financial Services, Inc. and is a licensed broker of life, health, accident, disability, and long term care insurance in multiple states. He also holds his FINRA Series 6, 7 and 63 registrations. Frank received his Bachelors of Arts degree in Business Management from Moravian College and was the recipient of the Jack Langdon New Advisor of the Year Award in 2002.
In addition to his career as a financial advisor, Frank is also dedicated to his community and volunteering. He is an active member of the Moravian College alumni association.
Frank lives in Franklin Lakes, NJ with his wife, Regina and daughters Danielle, Amanda, and Karlie where he enjoys coaching and playing basketball.
*formerly Langdon Ford Financial
Awards and club membership are based primarily on commissions, premiums, or fees generated from investment and insurance products and other criteria relative to leadership, achievement, and recruiting. Working with this individual or firm is not a guarantee of future financial results. Investors should conduct their own evaluation.
Donna L. Brower RICP
Donna takes pride in providing excellence in comprehensive wealth management. She does a thorough analysis of a client’s financial situation and strives to provide recommendations in order to meet or exceed a client’s expectations. Donna designs practical solutions custom-tailored to the financial goals of the individual and business owner, specializing in working with clients at or near retirement.
Her unique blend of advanced education, practical business experience and entrepreneurial expertise has given Donna a unique background to assist clients so that they clearly understand decisions that will improve their financial future.
Donna resides in Mountain Lakes, New Jersey with her husband, Brian. They have two adult children. In her spare time, Donna enjoys spending time with her family, going to the beach, playing tennis and reading.
Professional Affiliations:
Member of the National New Jersey & New York Association of Financial Planners,
Member of the New Jersey Retired Education Association
Education:
Masters of Business Administration
Fairleigh Dickinson University
Registrations & Licenses:
FINRA Series 7 & 66
Life, Accident & Health Insurance Producer
Donna L. Brower is a registered representative and investment advisor representative of Securian Financial Services, Inc.
George E. Carter
Education:
Bachelor of Arts in Economics - Denison University
Professional Registrations and Licenses:
Registered Investment Advisor
FINRA Series 7, 63 and 66 Licenses
George Carter is a Financial Advisor with Allied Wealth Partners, having more than 22 years of financial services experience. Prior to joining the AWP team, George worked with three of Wall Street's most prestigious firms; AXA Advisors, Merrill Lynch, and JP Morgan Chase. With Merrill Lynch, George was a member of their "Executives Club."
From the simple to complex, George has an extensive background in developing tailored financial strategies that encompass all aspects of insurance and investment solutions. George’s primary focus is to provide sound wealth management advice to business owners, individuals, and their families. His consultative approach begins with assessing one’s current financial situation, clearly mapping out future goals and then offering recommendations that work towards achieving those aspirations. An integral part of George's wealth management process is to help clients protect what they have worked a lifetime building. For this reason, George remains committed to educating his clients to fully understand all the financial tools and resources available to help them reach their wealth potential.
George graduated from Denison University in 1989 with a Bachelor of Arts degree in Economics. George, his wife Sheila and their three daughters; Catherine, Elizabeth, and Mary reside in Gladstone, NJ. In his spare time George enjoys bridge, golf and tennis.
Founded in 1966, Allied Wealth Partners mission is to be an elite Independent Wealth Management Firm within the New York/New Jersey Metropolitan area. As of December 2018, we assist clients with over $3.4 billion of assets and have over $4.5 billion of Life, Disability and Long Term Care Insurance coverage in force for our clients. We offer comprehensive financial services covering: Investment and Insurance Products & Services, Employee Benefits, Financial Planning, Executive Compensation, Business Succession and Estate Planning.
George E. Carter is a registered representative and investment advisor representative of Securian Financial Services, Inc.
Paul Ciavarella CLTC
Education:
William Paterson University
Bachelor’s degree in Finance
Minor in Economics
Registrations and Licenses:
FINRA Series 7, 65 and 66
Paul Ciavarella joined Allied Wealth Partners in 2017 after over eight years of success assisting clients with their finances.
Prior to his career as a financial advisor, Paul was a business owner. His 25 years of experience as a business owner enables him to provide a wealth of information to his clients. Paul focuses on helping small and medium size business owners attain their goals. His association with other experienced financial professionals allows him to offer a full range of services to meet the needs of businesses and individuals alike.
Through his experience and association with other specialists in the financial services industry, Paul has high standards when it comes to assisting clients. Paul’s goal as a financial advisor is to help bring a level of financial protection and independence to his clients that they had thought previously unattainable. This is accomplished through various conservative strategies of protection and long term financial growth.
Paul utilizes a macroeconomic approach to help clients balance the primary financial domains of Protection, Assets, Liabilities and Cash Flow. This approach recognizes the interdependence of these domains and tests all financial strategies across them in an effort to maximize the protection and performance of assets and cash flow. This unique approach can help provide clients with enhanced benefits in areas such as tax savings, risk management, and control of personal wealth.
Paul is very active in his community. He is a member of Wayne Lions Club, Chilton Hospital Professional Advisory Board, Morris County Chamber of Commerce, North Jersey Chamber of Commerce, and Pequannock Regional Chamber of Commerce. Paul has attained several designations over the years. These include his FINRA Series 7, 65 and 66. He is a Registered Representative and Investment Advisor Representative of Securian Financial Services, inc., Life and Health Licensed and holds the CLTC (Certified in Long-Term Care) designation.
Paul is a William Patterson alumnus where he received his Bachelor’s Degree in Finance and a Minor in Economics. Paul is a resident of Pompton Plains, NJ. Golfing, mountain biking, and spending time with his wife Eileen and children Maggie, John, Rachel, and Chris are some things that Paul enjoys.
Vincent Commoreto
Education:
Metropolitan Technical Institute
Electronics Engineering Technology
Registrations and Licenses:
Series 6, 7, and 63 registrations
Life and Health Insurance license
Vincent Commoreto joined Allied Wealth Partners in 2016, bringing with him 5 years of experience in the Financial Services industry. Vincent currently holds his series 6, 7, and 63 registrations along with his Life and Health license. Previously working for David Lerner Associates and MetLife, as an investment counselor, Vincent gained the ideal foundation he needed for his work as a Financial Representative. During his time at MetLife he has the honor of being invited to the Leaders Conference multiple times.
Vincent prides himself on always being available to his clients, he lives by the motto “services, service, service – I will always be available to my clients. He has gained strong industry experience, serving the investment and protection of individuals and their families since 1999. As your financial Professional, Vincent will make sure that you receive financial services and solutions that meet your individual needs. He is effectively supported by Allied Wealth Partners whose teamwork and professionalism have helped him build long-term relationships with his growing client base, and provide excellent customer service.
Vincent’s practice focuses on protecting client income assets and securing one’s retirement. Vincent specializes in investing and designing personal strategies to help his clients to have access to resources and information to help them meet their financial goals. Working primarily with individuals nearing and in retirement, Vincent is also achieving success by working with younger family members of his clients, while keeping protection and legacy in minds.
Vincent is happily married to his wife Heather and has two lovely children, Cassee and Vincent Jr. Away from the business, he enjoys spending time with his beautiful family, watching the New York Yankees, tackling home improvement projects, and landscaping. Vincent also enjoys coaching his son’s soccer team and daughter’s softball team.
Vincent Commoreto is a registered representative of Securian Financial Services, Inc.
Edward L. Giuliano Jr.
Education
Ramapo College
BA Business/Finance
Registration & Licenses
FINRA Series 7 & 63 Registrations
Life, Health, LTC, and Variable Insurance Licenses (multiple states)
Edward L. Guiliano joined the *Allied Wealth Partners team in June of 2015, offering five years of experience and exceptional service to Allied Wealth Partners’ growing firm.
Prior to joining Allied Wealth Partners, Ed began his career with Paulson Investment Co. in 2009 and later joined Jersey City based, PrimeX Advisors in 2011. During that time Ed successfully expanded his practice, thus leading him to Allied Wealth Partners— a firm that allows him to offer clients a variety of products, quality service, and diverse experience.
As a Financial Advisor with Allied Wealth Partners, Ed shares in the firm’s client-focused approach to wealth management. He also takes special pride in being able to relate and truly understand his clients. Ed does not use a cookie cutter approach — taking the time to have real conversations with individuals and business about their financial goals. Through this process Ed works to establish trust and instill confidence to make a positive impact on the lives of his clients.
In his spare time Ed enjoys spending time with his family. He also has a 3rd Degree Black Belt in Tae Kwon Do and coaches students in martial arts, roller hockey and softball. Edward resides in Florham Park, NJ where he is an active member of Lions Club International, East Hanover Italian American Club, and the Elks Club.
*formerly Langdon Ford Financial
Edward is a registered representative and investment advisor representative of Securian Financial Services.
Andrea Hauptman-Perez
Education:
MBA- Finance, Pace University
Bachelor of Arts- Economics, Rutgers University
Professional Registrations and Licenses:
FINRA Series 6, 7, 63 & 65 Registrations
Life, Health, and Accident Insurance Licenses
(multiple states)
As a valued member of the firm, Andrea Hauptman-Perez offers the perfect combination of practical experience and drive to support her clients in the accumulation, protection, distribution and transfer of wealth.
Andrea spent nearly ten years serving in various financial control roles for Fortune 500 financial service companies including Prudential Securities, Union Bank of Switzerland, and Credit Suisse First Boston. In addition, she served as Controller for a Non-Profit Cultural Arts Center.
While Andrea is recognized for her talent and passion for finances, it was her entrepreneurial instincts that acted as a catalyst in her professional and self-discovery. In 1998, Andrea developed and operated her own baked goods and gift basket business, Sophisticated Sweets, for seven successful years.
To complement its seasonal business cycle, Andrea started a small business consulting practice, AMH Consulting (2001- 2007*). Through her practice, Andrea developed sound financial strategies for businesses to help eliminate debt, create cash flow analysis, budgets, projections and spending plans. She soon realized that although passionate about baking, her true calling was to help shape the businesses of her valued clients.
Andrea prides herself on working with Allied Wealth Partners' team of diverse financial experts, having access to quality internal and external resources. This coupled with her client-centric approach to wealth management allows Andrea to help individuals and businesses feel confident in working towards their financial aspirations.
As a highly energetic and athletic woman, Andrea has competed in more than half a dozen triathlons, as well as the NYC Marathon. She has also completed the PMC Challenge, a 200 mile bike ride across Massachusetts to benefit the Dana Farber Cancer Institute, for three consecutive years. In addition she is the Co-Leader and Treasurer of her daughter's Girl Scout Troop.
Andrea has her MBA in Finance from The Lubin Graduate School of Business, Pace University. She also received her BA in Economics from Rutgers University. She and her husband Valentin (Val) Perez have a beautiful daughter and son.
Andrea is a Registered Representative and Investment Advisor Representative of Securian Financial Services, Inc.
*Andrea Hauptman- Perez does not provide business consulting through either Securian Financial Services, Inc. or Allied Wealth Partners.
David C. Helfrich
Education:
East Stroudsburg University
Bachelor of Science in Economics
Minor in Corporate & Personal Finance
Registrations & Licenses:
FINRA Series 6, 7 & 63 Registrations
Life, Health and Accident Insurances -
Licensed in approximately 12 States as of October 2012
As a Senior Financial Advisor at Allied Wealth Partners, David C. Helfrich is recognized for his 29 years of client dedication, leadership and excellence in all aspects of wealth management.
Valued clients are accustomed to a quality consultative experience as well as pertinent financial education. David takes pride in building life and annuity insurance solutions that compliment his clients' financial lifestyles. His approach is comprehensive, helping individuals utilize life insurance to provide protection and in some cases supplement tax advantaged streams of income for retirement or college tuition purposes. In addition, he offers financial strategies aimed to provide relief from estate taxation and helps them address estate erosion to work towards continued fiscal security of future generations. David also works closely with small business owners to implement employee benefit packages, including 401k, 403b, Simple IRA, and group health insurance.
What separates him from many of his professional peers is his commitment to listening to his clients' needs and recommending a high-quality product or service that will help enable them to meet individual objectives. He guides each client every step of the way from the fact-finding stage to implementation and goes the extra mile to maintain his professional relationships.
Since 2001, his professional excellence and personal integrity have been honored with firm awards including the Distinguished Achievement Award of 2006 and being consecutively nominated amongst the "Top 10 in Sales". David is a Life & Qualifying Member of The Million Dollar Round Table and has been nominated for Court of the Table.
Mr. Helfrich holds a Bachelor of Science in Economics from East Stroudsburg University and certification in Series 6, 7 and 63. Additionally, he is licensed in life, health and accident insurance in approximately 12 states as of October 2012.
Financial Advisors do not provide specific tax or legal advice. This information should not be considered as specific tax or legal advice. You should consult your tax or legal advisor regarding your own specific tax or legal situation.
Life insurance products contain fees, such as mortality and expense charges, and may contain restrictions, such as surrender periods. Please keep in mind that the primary reason to purchase a life insurance product is the death benefit. Policy loans and withdrawals may create an adverse tax result in the event of a lapse or policy surrender and will reduce both the cash value and death benefit.
David C. Helfrich is a registered representative and investment advisor representative of Securian Financial Services, Inc.
Million Dollar Round Table (MDRT) is an independent membership organization of life insurance and financial service professionals. Membership levels are based on commissions, premiums, or fees generated within a year from investment and insurance products. Members must apply annually and pay a fee. Members must be members in good standing of a Professional Association which has met the following criteria: in existence at least 2 years, have 100 or more members, must be a nonprofit organization, must have a code of ethics and an effective means of dealing with breaches of its code. Members must also adhere to the MDRT Code of Ethics. Working with this advisor is not a guarantee of future financial results. Investors should conduct their own evaluation.
