NYC Comptroller Lander and City Pension Funds’ 2023 Shareowner Initiatives Postseason Report Highlights Leadership on Responsible Investment

 

Systems secured historic wins at Starbucks and Wells Fargo amid a challenging year for shareholder proposals and ongoing attempts to misinform about ESG

New York City Comptroller Brad Lander and the boards of the New York City retirement systems (NYCRS) released the annual Shareowner Initiatives Postseason Report for the 2023 proxy voting season. The report highlights the field-leading work of the Bureau of Asset Management’s Corporate Governance and Responsible Investment team to confront systemic, sectoral, and company-level risks through engagement with the funds’ portfolio companies.

As investment adviser to NYCRS, the Comptroller’s Office is responsible for voting the pension funds’ proxies and implementing shareholder initiatives. New York City’s pension funds have a long history of active ownership and “systemic stewardship,” from opposing apartheid in South Africa to winning “proxy access” to give shareholders the right to nominate directors at U.S. companies.

“New York City’s pension funds are longtime leaders in meaningfully engaging with some of the largest companies to achieve real progress. By pushing companies like Starbucks to respect workers freedom of association, Wells Fargo to prevent harassment and discrimination, and Fox to stop defaming people, we are helping to raise corporate governance standards and ensure a more inclusively-thriving economy. That’s good for our retirees, and good for the economy as a whole. I am grateful to our Corporate Governance and Responsible Investment team for their work to drive sustainable change throughout our investment portfolio,” said New York City Comptroller Brad Lander.

Proposals for more fair and equitable workplaces received the most support. Starbucks investors expressed their growing concern regarding the company’s labor relations and strongly supported the Systems’ proposal to request a board-commissioned assessment of the company’s adherence to its commitments to workers’ rights, including freedom of association and collective bargaining. The proposal received 52% support. Starbucks released the assessment earlier this month, showing that its actions deviated from its policies.

The Systems also secured majority support (55%) for a proposal requesting that the Wells Fargo Board of Directors prepare an annual public report describing and quantifying the effectiveness and outcomes of the company’s efforts to prevent harassment and discrimination against its protected classes of employees received a majority vote.

In addition to extensive corporate engagement, the Comptroller’s Office continued its work on myriad investor coalitions on human capital and workers’ rights and as founding members of the Climate Action 100+.

On behalf of the Systems, Comptroller Lander also penned letters to portfolio companies requesting increased disclosure and transparency on workplace concerns including 11 public companies named in a New York Times investigation as allegedly profiting from the use of U.S. suppliers that illegally employ underage migrant children.

During 2023, the Systems also sued the Fox Corporation for neglecting its duty to shareholders by opening itself up to defamation lawsuits from the persistent broadcasting of falsehoods about the 2020 presidential election.

This season, the Systems submitted shareholder proposals to 32 portfolio companies to address a broad range of risks to our portfolio companies and withdrew approximately 47% of their shareholder proposals, down from 85% in 2022. Of the proposals that went to a vote, voting support averaged 27%, down from 35% in 2022.

Overall, shareholder proposals experienced a steep decline in support across the board driven largely by the conservative backlash to environmental, social and governance (ESG) investing.

The Systems’ proposal on climate change received the least support from investors, averaging only 13% support. This included resolutions calling on JP Morgan Chase, Goldman Sachs, Morgan Stanely, and Royal Bank of Canada to set and report on absolute emissions targets for their energy and utilities sectors, something other major banks have done.

“While we were disappointed by investors’ lack of support for common-sense climate resolutions that were entirely consistent with company performance and shareholder interests, we can’t back away from work to confront the systemic financial risks of climate change,” said Comptroller Lander. “We will be considering new options for corporate engagement and shareholder action in 2024 to insist that banks and other portfolio companies act to implement their net-zero commitments. We need to see action, backed by transparent reporting, not just words.”

In response to the backlash against ESG, Comptroller Lander joined with hundreds of private and public sector leaders to call on policymakers to protect the freedom to invest responsibly. This array of leaders reminded policymakers that building profitable businesses and investment portfolios demands an analysis of all material financial factors.  In a joint statement, the leaders argued that they should be free to consider material factors relevant to the sustainability of business: “Our consideration of material environmental, social, and governance (ESG) factors is not political or ideological. Incorporating these issues into financial decision-making represents good corporate governance, prudent risk management, and smart investment practice consistent with fiduciary duty.”

The Systems voted on 16,552 shareholder meetings in 70 markets globally. This includes 3,126 annual and special meetings for U.S. companies. In addition, the Systems voted against the election of 34.7% of directors in the U.S. market.

The annual postseason report covers proxy voting and shareholder proposal outcomes for the 12 months ending June 30, 2023. It includes detail on each shareholder proposal.

Proxy voting decisions for each of the Systems can be viewed here, and are available within 24 to 48 hours of electronic votes being submitted.

In addition to Comptroller Lander, the trustees of the aforementioned systems are as follows:

Teachers’ Retirement System (TRS): Mayor Eric Adams’ Appointee Bryan Berge, Director, Mayor’s Office of Pension and Investments; Chancellor’s Representative, Dr. Angela Green, New York City Department of Education Panel for Educational Policy; and Thomas Brown (Chair), Victoria Lee, and David Kazansky, all of the United Federation of Teachers.

New York City Employees’ Retirement System (NYCERS): Mayor Eric Adams’ Appointee Bryan Berge, Director, Mayor’s Office of Pension and Investments; New York City Public Advocate Jumaane Williams; Borough Presidents: Mark Levine (Manhattan), Antonio Reynoso (Brooklyn), Donovan Richards Jr. (Queens), Vito Fossella (Staten Island), and Vanessa L. Gibson (Bronx); Henry Garrido, Executive Director, District Council 37, AFSCME; Richard Davis, President Transport Workers Union Local 100; and Gregory Floyd, President, International Brotherhood of Teamsters, Local 237.

New York City Police Pension Fund (Police): Mayor Eric Adams’ Representative Bryan Berge, Director, Mayor’s Office of Pension and Investments;  New York City Fire Commissioner Laura Kavanagh (Chair); New York City Finance Commissioner Preston Niblack; Andrew Ansbro, President, Robert Eustace, Vice President, Chris Viola, Treasurer, and Eric Bischoff, Staten Island Representative and Chair, Uniformed Firefighters Association of Greater New York; Sean Michael, Chiefs’ Rep., Joe Camastro, Lieutenants’ Rep. and Liam Guilfoyle, (Chair), Uniformed Fire Officers Association; and Peter Devita, Marine Engineers Association.

New York City Fire Pension Fund (Fire):  Mayor Eric Adams’ Representative Bryan Berge, Director, Mayor’s Office of Pension and Investments; New York City Finance Commissioner Preston Niblack; New York City Police Commissioner Edward Caban (Chair); Chris Monahan, Captains Endowment Association; Louis Turco, Lieutenants Benevolent Association; Vincent Vallelong, Sergeants Benevolent Association; Paul DiGiacomo, Detectives Endowment Association; and Patrick Hendry, Daniel Terrelli, Albert Alcierno and Arthur Egner all of the NYC Police Benevolent Association.

Board of Education Retirement System (BERS): Schools Chancellor David C. Banks, Represented by Karine Apollon; Mayoral appointees Lilly Chan, Marjorie Dienstag, Gregory Faulkner, Anita Garcia, Anthony Giordano, Dr. Angela Green, Alan Ong, Phoebe Sade-Arnold, Maisha Sapp, Venus Sze-Tsang, Gladys Ward; CEC appointees Naveed Hasan, Jessamyn Lee, Thomas Sheppard, and Ephraim Zakry; Borough President Appointees Geneal Chacon (Bronx); Tazin Azad (Brooklyn); Kaliris Salas-Ramirez (Manhattan); Sheree Gibson (Queens); Aaron Bogad (Staten Island); and employee members John Maderich of the IUOE Local 891 and Donald Nesbit of District Council 37, Local 372.

COALITION OF CITIES CALL FOR MORE FEDERAL SUPPORT TO RESPOND TO NATIONAL MIGRANT CRISIS, MAYOR ADAMS ISSUES EXECUTIVE ORDER REQUIRING CHARTER BUS COMPANIES TO COORDINATE SAFE, ORDERLY MIGRANT ARRIVALS

 

Coalition of Mayors Call for Immediate Federal Support as Number of New Migrant Arrivals Increases Again 

 

As State of Texas Increases Number of ‘Rogue’ Buses Sent to New York City, Order Will Ensure Coordination, Protect Safety of Arriving Migrants and City Staff 

As Texas Governor Greg Abbott triples down on efforts to use asylum seekers as political pawns, New York City Mayor Eric Adams, Chicago Mayor Brandon Johnson, and Denver Mayor Mike Johnston called for additional federal support to manage the national asylum seeker crisis. With a record number of crossings at the border set yet again, New York City and other impacted cities have begun to see another surge of migrants arriving via buses. In response, Mayor Adams today issued Executive Order 538 requiring improved coordination from charter bus companies transporting new migrant arrivals into New York City, ensuring the safety and well-being of both migrants and city staff receiving them. Effective today, chartered buses bringing migrants into the city — many of which have been and continue to be sent by the State of Texas — will be required to provide 32 hours’ notice before arriving in New York City and information on the population they are transporting, as well as be required to drop passengers off at a designated location in Manhattan only during specified hours.  

 

New York City has seen a significant increase in chartered buses dropping off passengers at random locations throughout Midtown Manhattan in recent weeks, without any prior notice to city officials. This is hampering the city’s ability to manage this humanitarian crisis, including efforts to provide emergency services as needed to migrants. In the last month, the city has begun to see another surge, recording more than 14,700 new arrivals. Last week, 14 rogue buses with migrants arrived from Texas in a single night — the highest one-day total recorded by the Asylum Seeker Arrival Center since last spring — in addition to migrants still arriving via other modes of transportation. Today’s executive order will help ensure the city can continue to manage this humanitarian crisis in an orderly way. 

 

“New York City has begun to see another surge of migrants arriving, and we expect this to intensify over the coming days as a result of Texas Governor Abbott’s cruel and inhumane politics,” said Mayor Adams. “Just last week, 14 chartered buses with migrants arrived overnight from Texas, the highest recorded number in a single night, in addition to the hundreds of migrants who arrived that very same day via other modes of transportation. We are proud to have helped nearly 60 percent of the more than 161,000 migrants who have come through our intake system move out of shelter. But cities cannot continue to do the federal government’s job for them. We need federal and state help to resettle and support the remaining 68,000 migrants currently in New York City’s care and the thousands of individuals who continue to arrive every single week, and for Governor Abbott to finally stop the games and use of migrants as political pawns. I'm proud to stand with Mayor Johnson and Mayor Johnston and push for more federal support for cities impacted by this growing humanitarian crisis. This executive order will also ensure safe, orderly, and coordinated bus arrivals going forward, and will hold accountable those bus companies that refuse to coordinate with us.” 

 

"I am proud to stand with Mayor Adams and Mayor Johnston as we come together to advocate for viable solutions to this humanitarian crisis," said Chicago Mayor Johnson. "Chicago will always be a welcoming city, but we need collaboration at all levels of government and our federal partners to provide the necessary coordination and resources so that cities like Chicago, Denver and New York have what is needed to do this crucial work. We are united in our continued call for federal support to ensure that all those seeking asylum in this country are treated with dignity and humanity.” 

 

"As Denver continues to see an increase of newcomers arriving in our city, many of whom are families with children who arrive in the middle of the night in below-freezing conditions, it's clear that what the U.S. is currently doing is not working," said Denver Mayor Johnston. "Our cities are working shoulder-to-shoulder to support newcomers, but it's time for the federal government to increase work authorization, create a coordinated entry strategy, and provide more federal dollars to ensure cities can manage this crisis and help newcomers thrive.” 

 

“For more than a year and a half, chartered buses of asylum seekers have arrived across our city with mere minutes’ notice and no information on how many men, women, or children are on board, making our herculean task of caring for our newest New Yorkers even harder,” said Chief of Staff Camille Joseph Varlack. “This executive order will better allow us to coordinate arriving buses, so we can efficiently manage this crisis. But let’s be clear: this is not a substitute for the urgent federal action that New York City — and cities across the country — need. This is a national crisis, and it demands a national solution.” 

 

“Texas has been trying to manufacture chaos in our shelter system by sending bus after bus without letting us know when they’ll arrive or how many people are on the buses, and often dropping off passengers on city streets in the middle of the night,” said City Hall Chief Counsel Lisa Zornberg. “Today’s executive order will allow us to better coordinate when and where chartered buses arrive and ensure that we get significantly more information about who’s on the buses, well ahead of their arrival. To be clear though, this isn’t a replacement for federal action.” 

 

“For more than a year and a half, New York City has responded to what is a national humanitarian crisis,” said Deputy Mayor for Health and Human Services Anne Williams-Isom. “More than 161,000 people seeking asylum have come through our system, without much lead time or coordination from other municipalities beforehand. Today’s executive order moves to change that by gathering information from charter bus companies on the number of passengers and other details to help us prepare most effectively to receive adults, children, and families. This crisis is not letting up as we are still receiving thousands of new arrivals each week, and we are continuing to act in the absence of other federal and state coordinated support.” 

 

“Bus companies that drop off thousands of people in need of assistance at random locations and times, often at night or on the weekends, are interfering with the city’s ability to manage this humanitarian crisis and provide emergency services,” said New York City Corporation Counsel Sylvia O. Hinds-Radix. “This executive order, which requires companies to coordinate these unexpected arrivals with the city, is another urgent step we need to address this unprecedented emergency.” 

 

Effective immediately, all buses covered by the executive order must drop off their passengers at the loading zone on West 41st Street between 8th and 9th Avenues in Manhattan, unless the New York City Department of Emergency Management has designated or pre-approved a different drop-off location in advance. Furthermore, the chartered buses can only drop off migrants between the hours of 8:30 AM and 12:00 PM, Monday through Friday.  

 

Warning letters are also being sent to charter bus companies that New York City has identified as engaging in transporting newly arrived migrants from Texas to New York City. Under New York State law, knowingly violating a local executive order is a class B misdemeanor crime punishable by up to three months imprisonment and an up to $500 fine for individuals and an up to $2,000 fine for corporations. Additionally, companies that knowingly violate Executive Order 538 could have their buses impounded by the New York City Police Department.  

 

Since this humanitarian crisis began, the city has taken fast and urgent action, opening over 210 emergency sites to provide shelter, including 18 additional large-scale humanitarian relief centers; standing up navigation centers with support from community-based organizations to connect new arrivals with critical resources; enrolling thousands of children in public schools through Project Open Arms; opening application help centers that have helped submit over 23,000 asylum, Temporary Protected Status, and work authorization applications, and more. Earlier this spring, the city released “The Road Forward: A Blueprint to Address New York City’s Response to the Asylum Seeker Crisis,” detailing how the city will continue to manage the influx of asylum seekers and advocate for support from federal and state partners. 

 

As the Adams administration continues to prioritize helping migrants live independently, without significant or timely state and federal assistance, the city plans to pursue a 20 percent reduction in spending on the migrant crisis in the Fiscal Year 2024 Preliminary Budget, which will be released in January 2024.  

 

Housing Lottery Launches For McClellan Apartments At 1160 River Avenue In Concourse, The Bronx

 

The affordable housing lottery has launched for McClellan Apartments at 1160 River Avenue in Concourse, The Bronx. Designed by Aufgang Architects and developed by Maddd Equities LLC and Alembic Community Development, the structure yields 245 residences. Available on NYC Housing Connect are 198 units for residents at 30 to 100 percent of the area median income (AMI), ranging in eligible income from $18,515 to $175,100.

McClellan Apartments at 1160 River Avenue in Concourse, The Bronx via NYC Housing Connect

Amenities include an on-site super, recreation room, shared laundry room, bike storage, library, elevator, and an outdoor deck. Residences come with Caesarstone countertops, white appliances, and free in-unit broadband internet. Tenants are responsible for electricity.

At 30 percent of the AMI, there are eight studios with a monthly rent of $465 for incomes ranging from $18,515 to $33,900; ten one-bedrooms with a monthly rent of $591 for incomes ranging from $23,178 to $38,130; three two-bedrooms with a monthly rent of $700 for incomes ranging from $27,772 to $45,750; and four three-bedrooms with a monthly rent of $800 for incomes ranging from $32,092 to $52,530.

At 50 percent of the AMI, there are 18 studios with a monthly rent of $866 for incomes ranging from $32,263 to $56,500; 31 one-bedrooms with a monthly rent of $1,092 for incomes ranging from $40,355 to $63,550; four two-bedrooms with a monthly rent of $1,301 for incomes ranging from $48,378 to $76,250; and ten three-bedrooms with a monthly rent of $1,494 for incomes ranging from $55,886 to $87,550.

At 70 percent of the AMI, there are 14 studios with a monthly rent of $1,266 for incomes ranging from $45,978 to $79,100; 38 one-bedrooms with a monthly rent of $1,592 for incomes ranging from $57,498 to $88,970; 19 two-bedrooms with a monthly rent of $1,901 for incomes ranging from $68,949 to $106,750; and three three-bedrooms with a monthly rent of $2,188 for incomes ranging from $79,680 to $122,570.

At 100 percent of the AMI, there are five studios with a monthly rent of $1,527 for incomes ranging from $54,926 to $113,000; 14 one-bedrooms with a monthly rent of $1,918 for incomes ranging from $68,675 to $127,100; 10 two-bedrooms with a monthly rent of $2,292 for incomes ranging from $82,355 to $152,500; and seven three-bedrooms with a monthly rent of $2,639 for incomes ranging from $95,143 to $175,100.

Prospective renters must meet income and household size requirements to apply for these apartments. Applications must be postmarked or submitted online no later than February 22, 2024.

Attorney General James Leads Multistate Coalition Defending States’ Ability to Protect Americans Online

 

New York Attorney General Letitia James led a multistate coalition of 23 attorneys general today urging the U.S. Supreme Court to uphold the government’s ability to work and communicate with social media companies to address the spread of dangerous content on their platforms. The coalition filed an amicus brief with the court in the case of Murthy v. Missouri, urging the Supreme Court to reverse a recent decision of the U.S. Court of Appeals for the Fifth Circuit that prevents the important exchange of information between the federal government and social media companies about harmful content on their platforms.

“An open exchange of information between public authorities and social media platforms is critical to keeping people safe online,” said Attorney General James. “If upheld, this decision would make it harder to stop the spread of dangerous misinformation, scams, and harmful content that puts Americans at risk. I’m grateful that my fellow attorneys general have joined in this effort to defend states’ ability to work collaboratively with social media companies and protect our most vulnerable residents.”  

In May 2022, Missouri, Louisiana, and several individuals brought a lawsuit against various federal officials and agencies regarding communications between the federal government and social media companies about misinformation on the companies’ platforms related to topics like COVID-19. In July 2023, the U.S. District Court for the Western District of Louisiana issued a preliminary injunction effectively barring any communications between many federal government officials and social media companies concerning the platforms’ content-moderation decisions. In a September ruling, the U.S. Court of Appeals for the Fifth Circuit largely upheld the district court’s sweeping injunction, preventing the federal government and social media companies from exchanging information about harmful content on their platforms.

Government agencies at the local and state levels regularly collaborate with private companies, particularly around issues that concern public health and safety and to stop the spread of dangerous misinformation online. The coalition’s brief highlights numerous examples of successful collaboration between state governments and online platforms. Examples cited include the Office of the New York Attorney General’s (OAG) work with social media companies to identify and remove content from the May 2022 mass shooting in Buffalo, New York; OAG’s efforts with Amazon to stop online sellers from engaging in price gouging during the COVID-19 public-health emergency; and multistate efforts with social media companies to protect children from online predators, cyberbullying, and inappropriate content, and to call for more robust parental controls.

As the coalition of attorneys general argues, state officials and online platforms have mutually beneficial relationships built on voluntary exchanges of information, recommendations, and guidance — which the Fifth Circuit erroneously conflated with impermissible government coercion. Upholding the Fifth Circuit’s ruling would set a dangerous precedent that could hinder states’ abilities to encourage social media companies to limit content that often violates the platforms’ own content-moderation policies, including scams that target vulnerable populations, violent images or videos, or dangerous public health misinformation.

Joining Attorney General James in filing the amicus brief are the attorneys general of Arizona, California, Colorado, Connecticut, Delaware, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, Oregon, Pennsylvania, Rhode Island, Vermont, Washington, Wisconsin, and the District of Columbia.

This amicus brief is the latest example of Attorney General James taking action to protect people online. Earlier in December, Attorney General James joined a multistate coalition urging the Supreme Court to ensure states have authority to regulate social media platforms. In October, Attorney General James and a bipartisan coalition sued Meta for harming young people’s mental health and contributing to the youth mental health crisis. Also in October, Attorney General James advanced legislation with Governor Kathy Hochul, State Senator Andrew Gounardes, and Assemblymember Nily Rozic to help keep children safe online and prevent dangerous health consequences of addictive social media platforms. In October 2022, Attorney General James investigated and released a report on the role online platforms played in the Buffalo mass shooting. In May 2021, Attorney General James joined a bipartisan coalition of 44 attorneys general urging Facebook to abandon plans to launch a version of Instagram for children under the age of 13.

Justice Department Secures Agreement from North Carolina-Based Towing Company to Resolve Violations of the Servicemembers Civil Relief Act

The Justice Department announced today that is has secured a settlement against Billy Joe Goines, owner and operator of Goines Towing & Recovery, based near Marine Corps Base Camp Lejeune, to resolve allegations that he violated the Servicemembers Civil Relief Act (SCRA) by towing and then selling vehicles without disclosing to the court that they were owned by servicemembers. 

The SCRA provides a wide variety of financial and housing protections to members of the military. It requires a towing company to file an accurate affidavit stating whether the vehicle’s owner is in military service (i.e. a military affidavit) before it can get a court judgment authorizing it to sell a stored vehicle. If it appears that a vehicle’s owner is in military service, the court may not authorize the sale of the vehicle until it appoints an attorney to represent the interests of the servicemember. If that attorney then requests a postponement of the matter, the court must grant that request and postpone the case for at least 90 days.

In a complaint filed on March 3, the United States alleged that Goines auctioned off, sold or otherwise disposed of motor vehicles owned by eight servicemembers in violation of the SCRA, which provides a wide variety of financial and housing protections to members of the military. The SCRA requires a towing company to file an accurate affidavit stating whether the vehicle’s owner is in military service (i.e. a military affidavit) before it can get a court judgment authorizing it to sell a stored vehicle. If it appears that a vehicle’s owner is in military service, the court may not authorize the sale of the vehicle until it appoints an attorney to represent the interests of the servicemember. If that attorney then requests a postponement of the matter, the court must grant that request and postpone the case for at least 90 days.  The complaint here alleges that Goines either failed to file or filed inaccurate military affidavits with the court. Goines also allegedly filed military affidavits stating that he was unable to tell whether a vehicle owner was in the military even in instances where the vehicle at issue was towed from a military installation or had military decals, and instances when the vehicle owner or owner’s spouse had informed Goines of the owner’s active military service.

“Under federal law towing companies are required to file accurate military affidavits after making a good faith effort to determine whether vehicle owners are in military service,” said Assistant Attorney General Kristen Clarke of the Justice Department’s Civil Rights Division. “By failing to follow federal law, Goines deprived servicemembers of the opportunity to reclaim their vehicles. This consent order demonstrates the Justice Department’s ongoing commitment to protecting the rights of servicemembers and their families.”

“Goines took a Marine Corporal’s SUV from a parking lot near Camp Lejeune while he was deployed in Okinawa. Then Goines asked a court to let him sell it and keep the proceeds, without ever flagging the Corporal’s service for the court,” said U.S. Attorney Michael F. Easley Jr. for the Eastern District of North Carolina. “Servicemembers sacrifice a lot — and, in many cases, everything. Debt collectors and towing companies shouldn’t be allowed to take and sell their property behind their backs. The Justice Department will vigorously enforce servicemembers’ rights under the SCRA. Try to illegally take property from a Marine and find out.”

This is the first lawsuit brought by the United States against a towing company under the provision of the SCRA requiring the filing of military affidavits. Under the settlement, which still must be approved by the U.S. District Court for the Eastern District of North Carolina, Goines has agreed to pay $66,805.06 in relief for impacted servicemembers, must forgive storage fees assessed to certain servicemembers, attend SCRA training and institute new policies and procedures that comply with the SCRA.

The case resulted from a referral to the Justice Department from U.S. Marine Corps legal assistance.

Since 2011, the Justice Department has obtained over $481 million in monetary relief for over 146,000 servicemembers through its enforcement of the SCRA. For more information about the Justice Department’s SCRA enforcement efforts, please visit www.servicemembers.gov Servicemembers and their dependents who believe that their rights under the SCRA have been violated should contact the nearest Armed Forced Legal Assistance Program Office. Office locations can be found at legalassistance.law.af.mil