OCMI.ca Real Estate

OCMI.ca Real Estate OCMI is a leading real estate investment firm specializing in strategic development projects. We are patient investors. We honor and respect our investors.

Our expert team delivers high-potential opportunities for investors through innovative strategies, hands-on management, and a focus on long-term value creation. OTBEC Capital Management Inc (OCMI) is co-founded by three partners, each with over 20 years experience in the multi-family residential market. Our investment philosophy enshrines consistency, dependability, reliability, and responsibility

. We do not rush in during economic booms like during the 2006 to 2008 global real estate phenomenon. We took action after the crash to acquire well-positioned opportunities. We believe that investors have agency and are the agents of their financial destiny. When they understand the balance of risk and reward, investing is about capitalizing on opportunities with appropriate risk mitigation. They are sacred. We apply the Parable of the Talents (Matthew 25:14-30) in our investing philosophy. We endeavour to multiply investor talents wisely. We employ stewardship and fiduciary duties of care, loyalty, good faith, and confidentiality. We operate LEAN eschewing inefficiencies and waste. We always strive for CANI (constant and neverending improvement). We love to add value to other people’s lives. Indirectly, we operate with this guiding mission statement: to empower and inspire the world to live in hope and victory through collaboration, contribution, and cooperation. Serving investors in British Columbia, Alberta, Manitoba, and Ontario. Member Private Capital Markets Association of Canada https://www.pcmacanada.com/

What’s Up With Runaway Developer FeesIn the April 2, 2026 Western Investor article, Vancouver Mayor Ken Sim wants an agr...
04/09/2026

What’s Up With Runaway Developer Fees

In the April 2, 2026 Western Investor article, Vancouver Mayor Ken Sim wants an agreement with Ottawa to reduce municipal development charges.

However, this is not the solution. Municipalities can continue raising their development fees and cry for more Federal funding.

Development Cost Charges (DCCs) are the fees that municipalities charge developers for infrastructure upgrades such as roads, sidewalks, water and sewer, parks, childcare. Developers pay 12 items in addition to DCCs such as ACC, DP, RZ, BP, bonus density, inspection fees, permit fees, and everything in between. There is a lot of overlap in the in-between.

Amenity Cost Charge (ACC) is a recent addition. It replaced the Community Amenity Contribution (CAC), a voluntary contribution. ACC is supposed to cover amenities such as childcare, libraries, and parks. If developers are required to provide amenities onsite, why are they paying for ACC and DCC if they are providing it? Is this double-dipping?

Base density is 2.5. Developers pay to have the base density increased. A bonus density fee must be paid for all zoning over the base. If ACC and DCC fees cover infrastructure upgrades, what does the bonus density cover? Is this triple-dipping?

This is why 20% of the cost of a project is municipal fees.

Permit fees increased 75%. The Total Regional Base DCC tripled in 3 years. It went from $6,291 to $20,533. This is the base DCC rate. Then every municipality adds their DCC to this base rate.

In 2018, the DCC in the Township of Langley was $625 per unit. Today, the DCC is $38,482 per unit. That’s a 6,157% increase in 8 years. Developers also pay property taxes that are supposed to cover libraries, parks, roadwork, etc. A lot of developers could no longer make their projects viable once DCCs reached $26,000 per unit. Is this quadruple-dipping?

One solution is for municipalities to proceed with infrastructure upgrades as necessary, pay for it up front instead of waiting for a developer to pay for it, and charge developers a Latecomer Fee when they start to build.

A Latecomer Fee is a cost recovery system to ensure fairness among developers. This fee allows an early developer to recover part of the costs for installing infrastructure from developers who come into the area later. However, there is a maximum 15-year time period for this recovery after which the early developer is no longer eligible to recover costs.

Another solution, just a suggestion because it’s not ideal, may be for the Province to be in control of these runaway fees and subsidize municipalities.

The point is that without addressing the escalating and overlapping structure of municipal development charges at their source, shifting costs to other levels of government will only perpetuate inefficiency and further erode the feasibility of delivering affordable housing.

Source links available at

What’s Up With Runaway Developer Fees In the April 2, 2026 Western Investor article, Vancouver Mayor Ken Sim wants an agreement with Ottawa to reduce municipal development charges. However, this is not the solution. Municipalities can continue raising their development fees and cry for more Federa...

03/11/2026

The Case for Renting vs. Owning

Strata fees are going through the roof. Recently I heard about a townhouse complex in Vancouver where owners are paying $1,800 per month in strata fees. That alone is equivalent to a modest mortgage payment—and it may only be the beginning.

Many strata corporations in British Columbia have significantly underfunded reserve funds compared with other provinces. Keeping monthly dues low may feel like short-term relief, but it often postpones the real cost of ownership. Eventually the bills arrive.

Major capital repairs are inevitable in aging buildings:
• Roof replacement
• Windows
• Balconies
• Siding
• Concrete spalling

Last year, a family member received a $250,000 special levy for a two-bedroom condo. That’s an extreme case, but it highlights the risk.

According to a March 5, 2026 Western Investor article titled "Big bills are coming due for underfunded BC stratas", BC condo budgets lag far behind those in Ontario. In fact, Ontario strata budgets are nearly 40% higher.

If that $1,800 strata fee reflected those higher funding levels, it could be closer to $2,520 per month. Over a year, that amount alone could cover the rent for many properties.

To be clear—I’m an advocate for real estate ownership. But ownership always involves a risk-reward calculation. A few questions worth asking:

• Is the property worth owning if rising costs erode your equity?
• How long do you realistically plan to hold it?
• Is this the best use of your capital?

When I purchased my townhouse in Tsawwassen, I reviewed the strata minutes and financial statements carefully. The funding deficiencies were obvious, so I negotiated a purchase price discount based on the likelihood of future special levies.

After achieving financial independence, I actually rented for seven years. Why?
Mortgage payments on a primary residence aren’t tax deductible, and renting allowed me to maintain stronger cash flow and deploy capital elsewhere.

I also try not to become emotionally attached to real estate. For me, a home is an investment decision. I’ll live in a property for as long as it supports my financial goals.

Ultimately, every personal budget has two levers:
1️⃣ Increase revenue
2️⃣ Decrease expenses

But there’s a third option that many people avoid: eliminate an expense entirely.

Try a simple experiment: Cancel a subscription. Make coffee at home instead of buying it. Small changes can reveal how flexible your budget

02/26/2026

The World Is Your Oyster, But Only For Accredited Investors (Part 2 of 2)

An Ipsos Reid 2023 survey indicated that 60% of Canadians are unfamiliar with private investments. The report estimated that accredited investors represent about 1% of adult Canadian taxfilers. So, if Canada’s population is about 39,000,000 then roughly 390,000 Canadians qualify as accredited. It hardly seems fair that the top 1% of Canadians have access to the most lucrative investment opportunities. (https://www.ipsos.com/en-ca/majority-60-canadians-not-familiar-private-investments)

That’s because investment regulation started in the 1900s, mostly in response to fraud and stock market crashes. Securities law was created to curb stock fraud and speculative promotions. After the 1929 market crash and Great Depression, securities legislation enforced mandatory requirements for public offerings. The securities framework that exists today was born out of a need to protect less knowledgeable Canadians from abuse. That’s why 99% of Canadians are limited in where they can invest such as in a savings account, term deposit, Guaranteed Investment Certificate (GIC), RRSP, TFSA, RESP, LIRA, or dabble in online trading.

The highest and best pursuit is to attain accredited investor status. The first step is to learn the language of money. The second step is to start investing. Due to the limited range of investment products, the best place to start for the highest and best return is in real estate. An investor does not need a certificate or a degree to buy, sell, or manage real estate. Investing in real estate is available to all. It offers the highest leveraged return on investment through the Seven Profit Centers in Real Estate (https://julyono.com/wp-content/uploads/2022/10/2021-05-14-The-7-Profit-Centers-in-Real-Estate.pdf).

The primary reason we raise capital with accredited investors is the cost savings. Creating an Offering Memorandum or a Prospectus is expensive. For example, when investors subscribe through these documents, their subscription value is automatically diluted because a portion of that amount is allocated towards paying off the setup costs. The legal fees to set up a private equity Proforma is significantly less expensive. The investor retains more value from the start.

Also, the profit distribution in our real estate investments is taken on the exit. The principals earn their profit only when investors profit. Many funds have front-end load fees and a host of other fees that erode earning potential such as trading fee, brokerage fee, trailing commission, management expense ratio.

In 2015, after reviewing a 111-page OM for a construction project on the island, there were a dozen upfront fees listed throughout the document totaling 22% in fees. Any invested capital is reduced before it ever goes to work.

Although private equity offerings are higher risk and higher reward, they only available to elite investors except for the “family and friends” exemption.

02/26/2026

The World Is Your Oyster, But Only For Accredited Investors (Part 1 of 2)

Before we get into the article I’d like to clarify some terms, so we are on the same page.

What is an accredited investor? An individual whom the government deems financially sophisticated enough to invest in higher risk private investment opportunities. There is a financial fitness test to determine if the individual qualifies, the top two most common criteria being:

Asset threshold: $1,000,000 or more in financial assets excluding your home or $5,000,000 or more in total net assets including your home.

Income threshold: $200,000 per year individually for the past 2 years or $300,000 per year combined with spouse for the past 2 years.

What is Private Equity? This is capital invested in companies that are not publicly traded. The Securities Commission deem these types of investments as high risk. Only accredited investors are allowed to invest in the private market.

What is an eligible investor? This is a lower tier threshold used under an Offering Memorandum exemption. The government caps the investment amount and limits risk exposure whereas an accredited investor has no such investment caps.

What is an Offering Memorandum (aka OM)? This is a government regulated document used in the exempt market to protect investors from misrepresentation by an issuer; it increases transparency along with disclosures and stringent controls. It is used primarily by private companies, private investment funds, and exempt market dealers.

What is a Prospectus? This is a detailed disclosure document that must be prepared when issuing securities to the public for investments such as mutual funds. Ironically, these documents are so heavily focused on disclosure that it takes serious effort to understand the contents. Here is an example of a 136-page popular Canadian mutual fund:https://www.rightprospectus.com/documents/RBCGlobalAsset/PRO_EmergingMarketsEquityFund.pdf

What is Exempt Market? This is the regulatory framework that allows companies to raise money without filing a full public prospectus. A prospectus is very expensive document starting at $100,000 and up. The most common investments that use a prospectus are mutual funds offered by financial institutions. The legal costs for creating a prospectus are covered by investors, thus diluting the share/unit value until the fund makes money.

02/23/2026

Owner-Managed Rentals: The Key Advantage

There is a clear difference between an owner-managed building versus third-party management of a building and that of a strata corporation. All may be handled by professional property managers, but the incentives and accountability are not the same.

In our experience, third-party management companies have the challenge of balancing vacancies across their entire portfolio. If one building is sitting at 40% vacancy and another at 12%, occupancy can be shifted so each property reflects a similar average. While this may protect the management company’s broader client relationships, it disadvantages the owners who invest heavily in marketing and tenant selection. We discovered that prospective tenants generated by our advertising were redirected to other clients. This prompted us to move into direct owner-management.

The shift sharpened our focus on asset performance and tenant quality. We strengthened screening standards with credit checks and guarantors, along with continual building improvements. The outcome was measurable: higher occupancy, lower vacancy, and significantly reduced bad debt.

Enforcement is another key distinction. In a strata corporation, managers enforce bylaws on behalf of multiple individual owners. When a tenant breaches a bylaw, notice is issued to the unit owner, who must then address the issue with the tenant. This indirect structure can slow response times and dilute accountability.

This becomes more complex in larger buildings. Data from BC Housing shows that buildings with more than 100 units account for 52.7% of registered strata units in the province with another 24.4% in buildings of 51–100 units. As if community dynamics are not stressful enough among owners, amendments to the Strata Property Act in 2022 removed most rental restrictions and brought more tenant occupants into the mix.

By contrast, an owner-managed rental building operates directly under the Provincial Residential Tenancy framework by upholding both landlord and tenant rights to quiet enjoyment and habitable standards. Landlords act decisively and swiftly with enforcement when violations occur.

Thus, living in a well managed rental property can be a desirable option. Owner-managers are highly accountable and motivated to act decisively with a focus on asset performance and lifestyle quality. Responsive management equates to a more harmonious community dynamic, ergo happier tenants.

Source:
2022 BC Residential Building Statistics & Trends Report

02/14/2026

Architectural Resilience: Preventing claims through smart design

For more than two decades, I have watched the costly consequences of water damage in condominium towers—along with the steady rise in insurance premiums. When I asked construction consultants about prevention, the response was predictable: too expensive.

I later realized I was speaking to the wrong audience—developers focused on building and selling condominiums. Their objective is to complete the project, maximize profit, and move on. Ongoing maintenance becomes someone else’s responsibility.

The equation changes entirely with a purpose-built rental tower. An owner-developer who intends to hold the asset for decades thinks differently. Instead of designing for resale value alone, the priority becomes durability, efficiency, and long-term maintenance reduction.

Recent headlines illustrate the financial impact of water loss—litigation, special assessments, and steep insurance increases. The January 30, 2026 article reported by Western Investor involved an Aquilini Group-linked lawsuit seeking $87,000 from a university tenant. And the October 31, 2025 article reported by the Victoria Estate Digest highlighted the double-digit increase in deductibles and premiums. These disputes are costly and disruptive for all parties.

Yet many incidents stem from preventable overflow. A practical design enhancement—installing in-floor drains in kitchens, laundries, and bathrooms—could capture water before it spreads beyond the unit. The incremental cost is modest when incorporated at the construction stage, as it typically requires tying additional drains into existing plumbing lines.

In parts of Asia and Europe, high-end hotels often integrate discreet linear or “infinity” drains that blend seamlessly into the floor design. They are nearly invisible, yet highly effective.

Now imagine a high-rise where every unit includes built-in drainage and layered waterproofing. A resilient system would emphasize redundancy, proper slope, compartmentalization, and continuous membranes beneath all plumbing fixtures. Even a sprinkler activation would result in controlled drainage rather than widespread damage. These are some of the considerations for the Lougheed Landmark project.

The vision is straightforward: eliminate preventable water claims through intentional design. The most effective way to reduce insurance losses from water damage is to design against them—before the building is ever constructed.

01/23/2026

The Construction Conundrum: When Risk Meets Bureaucracy

Canada faces an affordable housing crisis and despite government incentives, the housing shortfall persists. A recent headline in the Jan 16 issue of Western Investor claims housing starts are increasing when the statistic reflects a national average. A closer reading shows year-over-year declines in major markets such as Toronto and Vancouver. In British Columbia, conditions remain especially challenging, making headline optimism misleading.

Current policy focuses on stimulating construction without addressing the root cause of delays: municipal processes. Federal and provincial mandates pressure municipalities to accelerate approvals, yet often bypass critical checks to ensure infrastructure can support new density. Cities must provide adequate water, sanitation, transportation, emergency services, and community amenities for developments that may double or triple local demand.

To cope, municipalities rely on Development Cost Charges. These include transportation, water, sanitary sewer, drainage, parks, fire and police services, plus regional levies such as TransLink and school site acquisition. As population density increases, so does the need for schools, community centres, and parks. These costs routinely reach into the millions and are borne upfront by developers.

Developers therefore assume enormous financial risk long before a project is approved. Construction is highly time sensitive: delays translate directly into rising carrying costs, particularly interest payments. When approvals stall, projects can become financially unviable, leading to bankruptcies and foreclosures. The result is wasted capital, stalled housing supply, and losses for all parties.

Developers are the true risk takers in this system. They envision the final product and its benefits for builders, municipalities, and end users, while managing the triple constraints of project management: cost, time, and scope. Municipal staff, by contrast, are largely insulated from these pressures and lack direct exposure to escalating construction costs and financing risks.

This disconnect creates a paradox. Cities and politicians depend on private developers to deliver housing, yet the bureaucratic structures governing development are becoming slower, more complex, and more expensive. If projects cannot achieve profitability, they will not proceed, regardless of demand.

A practical solution would be the creation of a dedicated municipal liaison or mediator. This role could bridge the gap between developers and city hall, resolve bottlenecks, and streamline timelines. Without such reforms, incentives alone will not solve the housing crisis. Addressing risk and bureaucracy together, rather than separately, is essential to delivering sustainable, affordable housing where it is most urgently needed.

Their inconvenience is your assetIf you are waiting for the perfect time to invest in real estate, then you’ll probably ...
12/29/2025

Their inconvenience is your asset

If you are waiting for the perfect time to invest in real estate, then you’ll probably be waiting a long time because every day is perfect timing. The key ingredient is that investors wait and create perfect timing in any market: up, down, or sideways.

When the market is up, that means real estate transactions are increasing. As more buyers enter the market, multiple offers start taking place, driving prices up. This is where most buyers focus – in a rising market bustling with activity.

When the market is down, that means there are less sales. With more sellers, this gives buyers room to negotiate particularly with motivated sellers. These are sellers who must sell because they are moving, right-sizing, divorcing, or liquidating an estate.

Interesting factoid is that buyers tend to buy in the spring and summer, less so in the winter. Why is that? It’s not just about the weather or that school is now in session. It has to do with inconvenience or more specifically, about maintaining status-quo comfort level at all costs.

Viewing and inspecting properties during inclement weather is more troublesome than during a sunny day. Bad weather is inconvenient, so some people avoid it. However, investors love to check out properties during rain or snow because deferred maintenance issues will most likely appear at this time. And those are negotiating points.

Investors embrace inconvenience because it is a hidden profit center. Oh, how I love bad weather inspections. Hidden deficiencies are revealed and magnified – so much so that it can often be used as leverage to discount the price through a credit on the statement of adjustments.

Be patient. Be prepared. Befriend inconvenience. Let it guide you to that perfect opportunity that no one else is looking at.

Reference:

In our pursuit of achievement, we often encounter so much discomfort. It's a natural part of the journey, yet many of us shy away from it, seeking refuge in our comfort zones.

A Tale of 2 Asset Classes & 2 Realities: Condos vs. Purpose-Built RentalsThere is a fundamental distinction between for-...
11/30/2025

A Tale of 2 Asset Classes & 2 Realities: Condos vs. Purpose-Built Rentals

There is a fundamental distinction between for-sale condominiums and purpose-built rental apartments. They are entirely different asset classes: comparing them leads to inaccurate assumptions.

According to the October 2025 issue of Canadian Apartment Magazine, Canada continues to face a significant housing shortfall. CMHC estimates the country will require 3.5 million additional homes by 2030. As of 2023, only 56% of that target had been delivered.

Condo development depends on 20% pre-sales to secure construction financing. Purpose-built rental projects operate differently: investors finance the entire development from beginning to end, with no revenue until the building is completed and tenants move in.

This financial structure explains why condo developers often run multiple projects simultaneously. Their business model resembles sequential flipping: once a building sells out, they must transition immediately to the next opportunity. Any delay in acquiring new sites or obtaining approvals increases holding costs and erodes margins. A typical condo pipeline might involve four stages running in parallel: selling out one project, constructing another, rezoning a third, and acquiring land for a fourth.

Purpose-built rental projects cannot absorb this pipeline style. The capital requirements are higher, the investment horizon is longer, and revenue arrives after occupancy.

Recent headlines highlight the dangers of overleveraging, including unprecedented bankruptcies involving developers with excessive project loads. Bull-market optimism and low interest rates can tempt firms to take on more than is prudent. Risk registers do not always account for emotional bias, and strong internal controls are essential to avoid herd mentality. Following the crowd is not a strategy.

Between 1974 and 1982, the federal MURB program stimulated rental construction by offering substantial tax incentives, resulting in about 122,000 new purpose-built rental units. Because this program ended over forty years ago, much of Canada’s rental stock is now aging. Successful completion requires discipline, patience, and a LEAN mindset focused on efficiency and concurrent engineering.

Our advantage lies in rigorous oversight from a forensic auditor who examines every financial and technical element of the project. We also maintain a one-project-at-a-time approach to avoid overextension, reduce risk, and position each development for long-term success. Overleveraging, much like multitasking, leads to cognitive overload, lower productivity, and increased errors—outcomes we are structured to avoid.

Sources:
https://www.youtube.com/watch?v=PRs8QhtEr-U&t=76s
https://storeys.com/1045-haro-street-debt-statement/

BMO's receivership application claimed $82.2M of debt, but the developers of 1045 Haro Street owes several other creditors as well.

Avoid Probate Delays: The Power of Joint Tenancy and a Proper WillJoint Tenants share equal ownership of an asset. Each ...
11/26/2025

Avoid Probate Delays: The Power of Joint Tenancy and a Proper Will

Joint Tenants share equal ownership of an asset. Each joint tenant has a 100% stake in the asset. This means they can only sell or transfer the asset with the consent of the other joint tenants. When one joint tenant dies, their share automatically passes to the survivor(s) known as “right of survivorship.” The deceased joint tenant’s share does not go through probate.

A Power of Attorney (POA) gives the attorney the authority to make financial decisions on behalf of an individual that is alive. The authority granted by a POA terminates upon the death of the individual.

During a recent asset transaction, we assumed that the Executor of an estate had the authority to sign legal documents on behalf of the deceased. This was not so. We were notified that the Executor cannot sign on behalf of their deceased spouse. Fortunately, an online check of the mortgage documents confirmed the spouses were listed as joint tenants. The mortgage transaction was completed by way of release via “transmission to surviving joint tenant” when presented with an original death certificate.

If the couple had been listed as separate individuals known as tenants in common, this would have prevented the closing. The only other option would have been to wait for probate of the estate which could take six months to a year or more.

In the past year, two close friends that I’ve known for decades passed away suddenly, no history of illness, no symptoms, no warning. It’s the wakeup call that prompted me to update our last will and testament that I hadn’t looked at in 19 years.

It took years for an older friend of mine to finalize the estate of her friend who died without a Will. During the 5-year probate, the empty condo sat vacant while property taxes, utilities, and strata fees accumulated with interest and penalties.

Fewer than half of Canadians have a Will. There are DIY options if your estate is simple. It may take a little bit of time and effort to think about bequeathing your assets, but this document ensures a faster and smoother transition for your beneficiaries.

Source:

June 3, 2024 Where there’s a will, there’s a way. … Continue reading "Half of Canadians don’t have a last will and testament, while DIY online providers are now responsible for a quarter of existing wills."

Solving The Affordability Crunch: The Power of Co-OwnershipA recent report from a national real estate franchise highlig...
11/03/2025

Solving The Affordability Crunch: The Power of Co-Ownership

A recent report from a national real estate franchise highlights a startling reality: the average home price in Metro Vancouver has risen 325 percent over the past 30 years.

The analysis points to familiar culprits. A 74% surge in population, insufficient housing supply, stagnant wages, escalating construction costs, and paused developments all continue to erode affordability. Yet the article focuses narrowly on individuals pursuing homeownership through government housing programs. That path is going the way of the dinosaur (increasingly obsolete). It is time to embrace a new approach.

A practical solution is joint venture homeownership. While families have traditionally done this through parents co-signing mortgages or gifting down payments, today’s market demands broader thinking. Consider partnering not only with family, but also with peers facing similar barriers, real estate investors seeking tangible assets over low-yield deposits, or downsizing baby boomers who prefer co-ownership to renting or living alone.

Treat your first home as an investment property with the shared goal of equity growth. This becomes your filter for selecting partners. Every participant should have written goals and a clear values statement. Misaligned values are the root of most partnership conflicts, so define expectations at the outset, including the eventual exit strategy.

Plan to revisit your agreement at the 5-year refinancing mark. Discuss questions like:
• Has the property appreciated enough for each partner to move into individual ownership?
• Should the group refinance and extend the partnership for two, three, or five more years?
• Should equity be pulled out to continue investing?
• Should one or more partners exit, triggering a deemed disposition and title change?

Clarify responsibilities including legal fees for any exit. Ensure all partners understand the financial and tax implications. If everyone lives in the property, capital gains are tax-free at sale. Investors who do not occupy the home will pay tax on their portion of the gain.

Partnerships amplify borrowing power. Instead of struggling to qualify for a $1.2-million property alone, a group may qualify for $2 million or more, expanding options and reducing competition.

Why strain under a stretched debt-to-income ratio just to meet traditional expectations? Shift your mindset toward optimizing returns. Personal sole ownership can come later.

Begin with clear thinking, planning, and strategy. Collaborate early, build consensus, and only then begin your property search.

Below are free joint-venture agreement templates to guide your structure. Have a lawyer review the document to ensure it is complete and enforceable.

Sources:

https://www.dexform.com/joint-venture-agreement

https://www.lawdepot.ca/contracts/joint-venture-agreement/?loc=CA&pid=msnppc-1241348802059167-77584497830261_sl-msnkey_canada%20joint%20venture%20contract&utm_source=bing&utm_medium=cpc&MSCLKID=b6b2599ab74a12dd12f630996bf2fffd

https://www.westerninvestor.com/real-estate/metro-vancouver-home-prices-spiked-326-over-past-three-decades-says-report-11390986?utm_source=Western+Investor+Newsletter&utm_campaign=f11dc33422-EMAIL_CAMPAIGN_2018_01_03_COPY_01&utm_medium=email&utm_term=0_9b89d35e1e-f11dc33422-98253922&mc_cid=f11dc33422&mc_eid=4aafb99784

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