The Most Expensive Assumption in HR
The global corporate training market is estimated at approximately USD $391 billion a year (Training Industry, Inc., 2025 State of the Corporate Training Market). It is worth being precise about what that number is: a market-sizing estimate of what is spent with and inside the training industry, not an audited total of corporate L&D budgets. No such audited total exists — which is itself the first sign of the problem this report is about. What that money buys is harder to establish than it should be. The measures most organisations collect — completion, satisfaction and recall — do not by themselves establish that behaviour changed in work. Whether it changed, and for whom, is usually not recorded at all. Several transfer-rate figures circulate widely in this field. We have not been able to trace the most common of them to a primary study that supports the exact denominator and time point they are quoted with, so this report does not use any of them.
One thing should be said before anything else: the transfer number is not new. Anyone who has worked in L&D has known it since Baldwin and Ford published in 1988, and the research community has kept measuring it ever since. What this report adds is not the finding. It is a question asked one step upstream — not why transfer fails, which is well studied, but why so little of the accountability structure that governs comparable budget lines has ever been built to answer for it.
The conventional response has been to redesign the training — better content, better platforms, better facilitation. This report argues the problem lies elsewhere. Before an intervention is designed, organisations rarely diagnose a variable that shapes whether development converts into behaviour, and one that is rarely diagnosed before an intervention is designed: the individual’s readiness and rate of conversion — whether this person, at this moment, is converting what they are given into changed behaviour. In the AERTHEIX instrument this is read across two separate axes — growth momentum and core vitality — rather than as one variable.
A $391 Billion Line Item With No Attribution Model
Budget lines of this size are usually engineered for accountability. This one is not.
In aggregate, corporate learning is one of the largest discretionary people investments on earth. At company level it typically runs at 1–3% of payroll — smaller than marketing or R&D, but with one difference that matters: budget lines of comparable size are normally built with an accountability chain attached, and this one generally is not.
| FUNCTION | HOW RETURN IS MEASURED |
|---|---|
| Marketing | Attribution models, customer acquisition cost, conversion tracking by channel |
| R&D | Stage-gate reviews, pipeline value, patent and product output |
| IT | Uptime, total cost of ownership, service-level performance |
| L&D | Completion rates and post-course satisfaction scores |
The measures the function is asked for are not the measures that would settle the question.
ATD's own 2026 benchmark data makes the point without any help from us: fewer than a quarter of talent development functions measure whether their programmes achieved the organisational goals they were funded against, and a smaller share again measures return on investment. The measurement gap is not cosmetic. Research on the dominant evaluation habit — the post-course satisfaction survey — finds the correlation between how much participants liked a programme and whether their behaviour actually changed is close to zero (Alliger et al., 1997; Sitzmann et al., 2008). For decades, the function has been asked to prove its value using instruments that were never designed to measure the destination. The issue is not that L&D chose weak measurement — it is that the operating model never demanded, funded or built the measurement infrastructure that transfer accountability requires.
Where the Investment Leaks
Transfer failure is not a single event. It is a two-stage leak: some of what is learned is never attempted in the work at all, and some of what is attempted stops being done within the following year. Organisations rarely measure either stage, which is why the size of each is contested and why this report does not attach a figure to them.
The leak is thought to be worst where the money is biggest
The leak is worst in exactly the category that receives the most money.
Research distinguishes near transfer (procedural skills applied in conditions similar to training) from far transfer (open skills — leadership, collaboration, judgement — applied in novel situations). Far transfer decays fastest and depends most heavily on the learner’s motivation and environment. It is also exactly where organisations concentrate their largest development budgets.
The instinctive explanation — bad training — is the one the evidence supports least.
The instinctive reading of these numbers is that the training was poorly designed. Four decades of evidence point to a different conclusion: the leak is mostly determined before the training begins, and after it ends — by the person’s readiness and by what their environment does next.
Three Scenarios Most HR Leaders Will Recognise
A The high performer who plateaus
A regional sales manager consistently exceeds targets. The organisation invests in an executive leadership programme to prepare her for a GM role. She completes it, scores well, receives strong feedback. Twelve months later her leadership style is unchanged. The organisation concludes the programme was ineffective.
B The manager who knows but doesn’t change
A middle manager receives 360° feedback that his team feels micromanaged. He gets coaching, a delegation workshop, a mentor. He articulates the concepts perfectly in follow-up conversations. His team’s engagement scores never move. He leaves two years later, fundamentally unchanged.
C The new hire who doesn’t stick
A retail company invests heavily in structured onboarding for frontline staff. Content is well designed, facilitators experienced, managers briefed. Six-month attrition stays at 35%. Exit interviews cite “lack of growth opportunity” — the exact gap the programme was built to close.
In each case the organisation’s response was to improve the training. The variable that went unexamined in all three was the person in the room — and whether they were ready to use what they were being given.
Each of these three scenarios has a name, and the names are not interchangeable. Part 4 sets out five patterns of momentum breakdown; the three cases above map onto three different ones, and the mapping is the whole point — because the correct response to each is different, and in every case above the organisation applied the response that fits only the first.
| SCENARIO | MOST LIKELY PATTERN | WHY THE STANDARD RESPONSE FAILED |
|---|---|---|
| A The high performer who plateaus | PRIORITY GAP | She had no unmet need the programme addressed. Nothing in it connected to anything she personally wanted next, so the content was absorbed and shelved. |
| B The manager who knows but doesn't change | RECOGNITION GAP, possibly SYSTEM GAP | He can articulate the concepts because he never disputed the concepts — he disputed that they describe him. Coaching that assumes agreement is coaching a premise he never accepted. |
| C The new hire who doesn't stick | SYSTEM GAP | The programme promised growth the operating environment did not supply. Better onboarding cannot deliver a career path that does not exist. |
Note the diagnostic honesty required in case B: PRIORITY GAP and RECOGNITION GAP look almost identical from the outside, and distinguishing them is the single most consequential judgement in this whole framework. The demonstration later in this report is built around exactly that distinction.
Diagnose the What, Ignore the Why
Competency frameworks answer a real question. It is not the question that determines whether development lands.
When development fails to deliver, the instinct is to sharpen the diagnosis of what is missing. This has produced increasingly sophisticated competency frameworks, gap analyses and skills taxonomies. These tools have real value — common language, role clarity, structured talent conversations. But they tend to share one design assumption, so embedded it is rarely said out loud:
Once a person knows what they need to develop, and is given the means to develop it, they will.
This assumption holds sometimes. It fails often. And the framework provides no tools for telling the two apart.
The Inversion: Where Budget Goes vs Where Learning Happens
The 70-20-10 model, first articulated by McCall, Lombardo and Eichinger at the Center for Creative Leadership, should not be read as a universal empirical law — it is an experiential observation that has never been replicated as a controlled study, and its precise ratios have been challenged (Clardy, 2018; Jefferson & Berthelsen, 2021). Nevertheless, the practical imbalance it highlights is consistently supported by evidence: organisations tend to overfund formal learning assets while underfunding the application conditions, manager reinforcement and work-based practice that research most strongly links to durable behaviour change.
The commonly cited shape of the imbalance is this: formal training absorbs the majority of the L&D budget while being associated with a small share of durable learning, and on-the-job application and practice show the reverse. We give the shape rather than precise percentages deliberately. The often-quoted 62%/10% and 70%/14% pairings circulate widely but combine two different sources measuring two different things — a budget-allocation survey and an experiential estimate — and we could not verify either pairing against a single primary document. The direction of the imbalance is well supported; the decimal places are not.
The imbalance persists for a procurement reason, not a pedagogical one.
Why does the inversion persist? Partly because classroom output is visible and easy to report. But the deeper reason is structural: formal training is purchasable — it has vendors, invoices and completion certificates. On-the-job design and manager reinforcement have no PO line; they cost management attention, which sits outside the L&D budget.
L&D has often been asked to prove value using measures that were never designed to capture transfer — and to deliver results through the only channel the procurement system recognises. The function did not choose this operating model; it inherited it. Changing the model requires more than better measurement — it requires a different conversation about what L&D is accountable for, and what it needs from the rest of the organisation to deliver.
The Hidden Variable: Readiness and Rate of Conversion
When two people receive the same intervention and only one changes, the difference may sit in readiness, opportunity, feedback, load — or the intervention itself.
Consider two employees who receive identical 360° feedback: both need to manage conflict more constructively. Both attend the same workshop. Three months later one has visibly changed; the other has not. Programme quality does not explain the difference — they sat in the same room. The difference walked in with them.
What builds — and erodes — momentum
In high-momentum environments, feedback arrives close to the behaviour; development is framed as investment, not deficiency; people see evidence that growth leads somewhere; and trying something new is not career-threatening. In low-momentum environments, development is remediation, feedback is annual and tied to ratings, high performers have no cognitive space left, and the implicit message is: perform the current role at maximum capacity — there is no time or recognition for growth. The same programme lands in these two environments as two entirely different interventions.
Five Patterns of Momentum Breakdown
Five working patterns, drawn from practice rather than from validation research, describe most of the cases we have seen where development does not convert. They are an AERTHEIX working framework, not a validated diagnostic classification, and they are offered as a way to structure a conversation rather than as a test that produces a result. Each one calls for a different response, and a competency gap analysis is not designed to distinguish between them — which is why the same programme, delivered well, produces five different outcomes in the same cohort.
| WHAT THE PERSON IS ACTUALLY SAYING | PATTERN |
|---|---|
| "I want to change, but I don't know how." | CAPABILITY GAP |
| "I understand, but I don't think it matters." | PRIORITY GAP |
| "I disagree with the assessment." | RECOGNITION GAP |
| "I agree, but the environment won't let me." | SYSTEM GAP |
| "I don't have the bandwidth right now." | CAPACITY GAP |
These five names are used consistently throughout this report and in everything that follows from it. Where you see them elsewhere in the series, they mean exactly what they mean here.
1 “I want to change, but I don’t know how.” — CAPABILITY GAP
Genuinely motivated, lacks a pathway. Structured guidance, worked examples and coaching land well — this is where standard training actually works.
2 “I understand, but I don’t think it matters.” — PRIORITY GAP
Feedback absorbed but not connected to anything personally valued. Investment is premature: a reframing conversation must come first.
3 “I disagree with the assessment.” — RECOGNITION GAP
Does not accept the premise. Training before this is resolved produces resistance, compliance theatre or quiet disengagement.
4 “I agree, but the environment won’t let me.” — SYSTEM GAP
Motivated and self-aware, but the system inhibits the very behaviour being asked for. The constraint is structural — individual coaching redirects blame and damages retention.
5 “I don’t have the bandwidth right now.” — CAPACITY GAP
Sometimes a genuine resource limit, sometimes a deflection. Distinguishing the two takes an honest conversation about timing and workload — not a new programme.
An experienced HR business partner can often tell these patterns apart, provided the question is asked before the intervention is designed rather than after it has failed. The conversation is short. What it changes is which of five different responses gets funded.
When the Pattern Is Misread: Common Responses vs Effective Responses
| PATTERN | TYPICAL RESPONSE | WHY IT FAILS | EFFECTIVE DIRECTION |
|---|---|---|---|
| Capability Gap | Generic programme | Lacks specificity | Targeted skill pathway + structured practice |
| Priority Gap | More training | Solves wrong problem | Value reframing conversation before any investment |
| Recognition Gap | Coaching or workshop | Premise not accepted | Feedback alignment; address disagreement directly |
| System Gap | Individual coaching | Redirects blame to person | Manager/system-level intervention first |
| Capacity Gap | Mandatory IDP | Adds load to overload | Timing/workload reset; revisit when capacity exists |
What a Momentum Diagnosis Actually Looks Like
The five patterns are only useful if you can tell which one you are looking at. The following is a single anonymised case, reconstructed from a frontline retail environment. Identifying details have been removed and the timeline generalised; the dialogue is reported in substance rather than verbatim.
The situation. A senior sales associate had, in one year, recorded a strong result on his employer's independent third-party service assessment — comfortably inside its upper band. Over the following period the organisation introduced a revised set of service standards. He declined to adopt them. Across two consecutive review cycles his assessment scores fell out of the top band and eventually sat near the bottom of it.
What was actually observable. Not an attitude — two behaviours. He did not take part in the newly introduced structured floor walks, and he stopped attending team briefings. Both were scheduled, both were logged, and both were verifiable without anyone having to interpret his state of mind.
What he said when asked. In substance: I understand your approach is sound, but we work brand-first. I have already done what the brand asks. The assessors mark me down because they do not understand the brand's own requirements — so a low score is a problem with the guidelines, not with me. I can hardly abandon the brand standard and just make small talk instead.
What the follow-up produced. His line manager had pursued the same issue repeatedly. After several rounds the manager's own summary was that there was nothing further to be done — the person simply did not want to change. That sentence is worth pausing on, because a manager reporting exhaustion is a diagnostic signal in its own right, not merely a management failure.
What we expected, and why we were wrong. We came to this case expecting a SYSTEM GAP — the pattern where a motivated person is blocked by conditions they do not control, which is the one most often missed and the one we were actively looking for. The evidence did not support it. Nothing in his environment prevented him from attending a briefing; the briefings were scheduled, and his colleagues attended them. We record the mis-read deliberately: a framework that lets you find whatever you went looking for is not a diagnostic instrument, and the only way a reader can tell the difference is if the cases that overturned the initial reading are published alongside the ones that confirmed it.
What it actually reads as. On the surface this looks like a PRIORITY GAP — he appears to be saying the new standard is not what matters to him. It is not. Read the sentences again: he is not deprioritising the assessment, he is rejecting its validity. The assessors are wrong; the guidelines are the problem; the low score is evidence of someone else's error. That is a RECOGNITION GAP, and the brand-first argument is not a competing priority but a legitimising frame for refusing the premise. The test that separates the two is simple. Ask whether the person accepts that the gap exists. Someone in a PRIORITY GAP says yes, and I have bigger things to worry about. Someone in a RECOGNITION GAP says no, and here is why the measurement is wrong.
Why the distinction cost real money. The organisation responded as if it were a CAPABILITY GAP: more training, more standards, more briefings. Part 4's table predicts what happens when you train against a premise the person has not accepted — resistance, compliance theatre, or quiet disengagement. All three were visible at one point or another. Roughly eighteen months of declining third-party scores followed, in a role where those scores feed directly into commercial judgement.
What eventually moved him — and what did not. Not the training. Not the coaching. Not the manager. What changed the behaviour was a change in his reference group: new colleagues joined the department who engaged with the new standards readily, the visible distance between them and him widened, and he began to register that he was being left outside. He resumed attending briefings and training.
The part that must not be rounded off. The RECOGNITION GAP was never actually closed. He still maintains that the standards keep shifting. What changed was the social cost of holding that position, not the position itself. That distinction matters commercially: behaviour bought by peer pressure reverts when the peer group changes, and a compliance recovery is not the same asset as a genuine one. A correct diagnosis at the start would not have avoided the disagreement. It would have addressed it directly — feedback alignment, evidence he could examine himself, a conversation about the measurement before a conversation about the behaviour — and it would have cost a fraction of eighteen months.
Telling the Patterns Apart: One Question Per Boundary
The five patterns are easy to name and hard to separate, and the pairs that get confused tend to be the same pairs. In practice a diagnosis rarely fails because someone did not know the five categories. It fails because two of them present almost identically in the room, and the wrong one is more comfortable to conclude. Each boundary can be settled by a single question, asked directly.
| EASILY CONFUSED WITH | THE QUESTION THAT SEPARATES THEM | HOW TO READ THE ANSWER |
|---|---|---|
| CAPABILITY GAP vs PRIORITY GAP | If you knew exactly how to do this, would you? | Yes → CAPABILITY. Hesitation, or a reason why it wouldn't matter → PRIORITY. |
| PRIORITY GAP vs RECOGNITION GAP | Do you accept that this gap exists? | Yes, but I have bigger concerns → PRIORITY. No, and here is why the assessment is wrong → RECOGNITION. |
| RECOGNITION GAP vs SYSTEM GAP | Is the objection about the measurement, or about the conditions? | The measurement is wrong → RECOGNITION. The measurement is fair but I am blocked → SYSTEM. |
| SYSTEM GAP vs CAPACITY GAP | If you had the time, would the obstacle disappear? | Yes → CAPACITY. No, the obstacle is structural → SYSTEM. |
What Four Decades of Research Actually Says
Four decades of research point to interacting person, design and environment conditions; practice often still overweights the course itself.
BALDWIN & FORD (1988) — the foundational transfer model: outcomes are a function of learner characteristics, training design, and work environment. Thirty-eight years later, budgets still target design almost exclusively, while the other two variables — the person and the environment — remain undiagnosed.
Self-Determination Theory: Not All Motivation Is Equal
Controlled motivation — driven by external pressure: compliance targets, fear of consequence, “because HR said so.” Produces short-lived, monitored behaviour that rebounds the moment oversight relaxes.
Autonomous motivation — driven by internalised value: the person sees the change as theirs. The motivation type most consistently linked in research to durable behaviour change (Deci & Ryan, 2000; Gagné & Deci, 2005). A programme cannot install it directly; conditions can make it more likely.
THE LTSI — the Learning Transfer System Inventory (Holton, Bates & Ruona, 2000) is a validated 16-factor transfer system scale. Its factors span the person, the training design and the work environment; several of them describe individual states such as readiness, motivation to transfer, self-efficacy and outcome expectancy. What matters for this report is that the instrument treats those states as part of the system at all, and that most development decisions are taken without asking about any of them.
Acknowledging the Field
Several established methods already work on this problem, and they work downstream of where this report is looking.
This report is not the first to address transfer failure. The Six Disciplines of Breakthrough Learning (Wick, Pollock & Jefferson, 2006) made a significant contribution by extending accountability beyond the classroom into application and reinforcement. Brinkerhoff’s Success Case Method (2003) introduced a rigorous approach to identifying what actually transferred. The updated Kirkpatrick–Katzell model reframed evaluation around business results rather than course satisfaction.
These methods advanced the field materially, particularly in post-training reinforcement. However, they share a common starting assumption: that the training has been correctly targeted at the right person, at the right time. This report addresses what happens upstream of that assumption — the diagnostic step that determines whether a person is in a convertible state before any investment is designed. The five momentum patterns described in Part 4 are an attempt to make that upstream variable visible, specific and actionable.
The Cost of Misdiagnosis
Misdiagnosis is not merely wasteful. Two of the five patterns are actively made worse by the standard response.
Send an employee in a RECOGNITION GAP to training, and the cost is not the programme fee — it is the cohort energy, the manager hours, and the reinforced narrative that development is theatre. Coach an employee in a SYSTEM GAP individually, and the problem is not solved but redirected — from a structural issue to a personal one. The employee absorbs blame for a situation they cannot control. Engagement and retention pay the price. The variable that explains most of the variance in L&D ROI is not the programme. It is the readiness of the people in the room.
A Different Starting Point
Nothing here argues for abandoning what already works. It argues for one step being added in front of it.
The implication is not that competency frameworks should be abandoned — they create common language and structure that serious talent work needs. The implication is that gap analysis should be preceded by a momentum diagnosis. Before any individual development plan is funded, three questions deserve honest answers:
Q1 Does this person currently have the motivation to use this opportunity — connected to something they personally want to achieve?
Q2 Does their environment support the behaviour change being asked for? If the constraint is structural, individual investment is unlikely to move the needle.
Q3 What is the specific nature of their readiness or resistance — and which of the five patterns does it match: CAPABILITY, PRIORITY, RECOGNITION, SYSTEM, or CAPACITY?
Self-Diagnostic — Where Is the Momentum in Your Team?
Think of one person who completed a development programme in the last twelve months without visible behaviour change:
| IF YOU CANNOT ANSWER THIS… | IT MEANS… |
|---|---|
| Did they explain, in their own words, why this development mattered to them? | No intrinsic motivation was ever confirmed |
| Did anyone ask whether they agreed with the capability gap identified? | The plan was built on an unexamined assumption |
| Does anything in their environment work against the new behaviour? | A structural constraint may have been missed — investment is likely to leak |
| Did they get a structured chance to practise with feedback within 90 days? | The decay curve was left to run its course |
VITALIS is not a training-ROI instrument and does not establish why transfer failed. It creates a structured record of whether behaviour changed in real work, what evidence supports that reading, and where the explanation remains open.
That record can help a manager decide whether the next move is instruction, coaching, a change in conditions, a change in load, or more observation. Live deployments will test whether the protocol can make those distinctions consistently and usefully, without overstating what the evidence shows.
Sources and notes
- Every figure in this report is attributed below to the document it came from. Where a source has been revised since first publication, the version cited is stated. Where we could not verify a widely circulated number against a primary document, we have said so in the text rather than repeating it.
- Note on transfer-rate figures. Several percentages describing how much training transfers circulate widely in this field. We do not use any of them in this report. The most common — that only around 10% transfers — was stated by Holton and Baldwin (2000) to have never been empirically established, and we could not trace it to a primary study. Others come from sources that do not directly support the exact denominator and time point they are quoted with: meta-analyses of the predictors of transfer, or studies of the relationship between transfer and firm performance, are not measurements of a transfer rate. Survey estimates of how much employees apply do exist, but they record what training professionals believe about their own organisations rather than observed behaviour, and we judged that too weak to headline. Any transfer-rate figure restored to this report in future will first have to be matched to a primary study supporting that exact denominator and time point, and entered in the claim registry.
- Full source list
- Alliger, G. M., Tannenbaum, S. I., Bennett, W., Traver, H. & Shotland, A. (1997). A meta-analysis of the relations among training criteria. Personnel Psychology, 50(2), 341–358.
- Association for Talent Development (2026). 2026 State of the Industry: Talent Development Benchmarks and Trends. Alexandria, VA: ATD Press. Released May 2026, reporting 2025 data. (Cited for per-employee learning expenditure and measurement practice only; ATD does not publish a global market total. Prior editions reported $1,283 per employee for 2023 and $1,254 for 2024.)
- Training Industry, Inc. (2025). State of the Corporate Training Market. Cary, NC. (Source of the $391.1 billion global market estimate. Verify against the current edition before republication — this series is issued annually.)
- Baldwin, T. T. & Ford, J. K. (1988). Transfer of training: A review and directions for future research. Personnel Psychology, 41(1), 63–105.
- Blume, B. D., Ford, J. K., Baldwin, T. T. & Huang, J. L. (2010). Transfer of training: A meta-analytic review. Journal of Management, 36(4), 1065–1105.
- Brinkerhoff, R. O. (2003). The Success Case Method: Find Out Quickly What’s Working and What’s Not. San Francisco: Berrett-Koehler.
- Clardy, A. (2018). 70-20-10 and the dominance of informal learning: A fact in search of evidence. Human Resource Development Review, 17(2), 153–178.
- Deci, E. L. & Ryan, R. M. (2000). The “what” and “why” of goal pursuits: Human needs and the self-determination of behavior. Psychological Inquiry, 11(4), 227–268.
- Gagné, M. & Deci, E. L. (2005). Self-determination theory and work motivation. Journal of Organizational Behavior, 26(4), 331–362.
- Holton, E. F. & Baldwin, T. T. (2000). Making transfer happen: An action perspective on learning transfer systems. Advances in Developing Human Resources, 8, 1–6. (Cited for the observation that the widely quoted 10% transfer figure has not been empirically documented.)
- Holton, E. F. III, Bates, R. A. & Ruona, W. E. A. (2000). Development of a generalized Learning Transfer System Inventory. Human Resource Development Quarterly, 11(4), 333–360.
- Jefferson, A. & Berthelsen, H. (2021). 70:20:10 — towards a new learning landscape. In P. Hartley, A. Hilsdon, C. Keenan, S. Sinfield & M. Verity (eds.), Learning Development in Higher Education. London: Palgrave Macmillan.
- Lombardo, M. M. & Eichinger, R. W. (1996). The Career Architect Development Planner. Minneapolis: Lominger Limited.
- McCall, M. W. Jr., Lombardo, M. M. & Morrison, A. M. (1988). The Lessons of Experience. New York: Free Press.
- Saks, A. M. & Burke-Smalley, L. A. (2014). Is transfer of training related to firm performance? International Journal of Training and Development, 18(2), 104–115.
- Sitzmann, T., Brown, K. G., Casper, W. J., Ely, K. & Zimmerman, R. D. (2008). A review and meta-analysis of the nomological network of trainee reactions. Journal of Applied Psychology, 93(2), 280–295.
- Wick, C. W., Pollock, R. V. H. & Jefferson, A. M. (2006). The Six Disciplines of Breakthrough Learning. San Francisco: Pfeiffer.
In this series
- No.01The Signal Collapse — when AI breaks both the talent pipeline and the way we identify who belongs in it
- No.02The Transfer Deficit — why corporate learning investment fails to become behaviour
- No.03The Wrong Question — same CV, same job description, four times the difference (forthcoming)
- No.04The Readiness Gap — coaching works, the dose doesn't, and the missing variable is upstream (forthcoming)
© 2026 AERTHEIX Advisory. All rights reserved. AERTHEIX Advisory™, The Tsai Method™, VITALIS™ and LUMEN™ are trademarks of AERTHEIX Advisory. This report may not be reproduced or distributed without permission.