Prof. Jayanth R. Varma's Financial Markets Blog

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Prof. Jayanth R. Varma's Financial Markets Blog, A Blog on Financial Markets and Their Regulation

© Prof. Jayanth R. Varma
jrvarma@iima.ac.in

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Tue, 31 Mar 2009

Indian Financial Sector Self Assessment Report

Updated: Ajay Shah corrects me and points out that this is not a true FSAP but an imitation of the real thing. Even less reason to take it seriously. Incidentally, I think that the real FSAP itself is a waste of time if not worse. But that is beside the point.

The Indian financial press is today full of stories based on the Financial Sector Self Assessment Report prepared jointly by the Reserve Bank of India and the Ministry of Finance.

I think the coverage given to this self assessment report is quite disproportionate to its true significance because the report is prepared as part of the country’s participation in the Financial Sector Assessment Programme (FSAP) conducted by the IMF and the World Bank.

As anybody who has prepared or evaluated a self assessment report knows, it is critically important for such a report to demonstrate (a) an awareness of major weaknesses and (b) some thinking about possible measures to overcome them. If these are present in the self assessment, the external evaluator can and often does condone all the weaknesses!

By these standards, the self assessment report does an admirable job. But by the same token, it is silly to think that the report reflects the thinking of the RBI or the government on any of these matters.

Posted at 21:22 on Tue, 31 Mar 2009     View/Post Comments (2)     permanent link


Mon, 30 Mar 2009

Links

Links to some interesting stuff that I have been reading

Posted at 14:28 on Mon, 30 Mar 2009     View/Post Comments (1)     permanent link


Fri, 27 Mar 2009

Obstfeld on FX Reserves and Panic of 2008

I have been reading an NBER Working Paper by Obstfeld, Shambaugh and Taylor Financial instability, reserves, and central bank swap lines in the panic of 2008. These are well respected authors, so I was quite disappointed to find that they have made several errors and missed several key features of what they call the “panic of 2008.”

Most important of these is the fact that currency depreciations during 2008 were driven to a very great extent by the foreign currency liabilities of the banks and of the corporate sector. This reality was staring them in the face in the form of Iceland, but they amazingly treated Iceland as an outlier and dropped it from all their analysis. They seemed to have forgotten that in risk management, the outlier is the data and everything else is a distraction. Iceland was an extreme case, but the short dollar position of banks and companies were a critical factor behind currency depreciations in the three large emerging economies that Obstfeld et al plot in Figure 1 (Russia, India and Korea).

Failure to consider the exposure of the banking system leads them to under estimate the reserve needs of emerging economies. They make the statement that countries like India “do have foreign reserves sufficient to allow them to act as crisis lenders to foreign governments.” This is simply not true.

Obstfeld et al make another mistake in asserting that for countries like Korea, the swap lines from the US Fed served only a signaling purpose because these countries had plenty of reserves and the magnitude of the swap line was not meaningful in relation to the reserves. This again is simply false. Earlier this month, the Wall Street Journal quoted a finance ministry official as saying that the Bank of Korea had drawn down more than half of the swap line and that it might need a second or third line. Korea is really short of reserves and it has also been reported that not all of its reserves are sufficiently liquid.

It is distressing to find such serious errors in a paper by economists of such high standing who have done so much of widely cited work in this field. I know a working paper is supposed to be for dissemination in preliminary form and is not necessarily subject to peer review, but still ...

Posted at 12:55 on Fri, 27 Mar 2009     View/Post Comments (0)     permanent link


Sat, 21 Mar 2009

Exchange competition and governance

The Mint has two articles on exchange competition and governance which quote me extensively. I made the following statements:

Competition is always good, but in the exchange space one must also ensure that this doesn’t go in a totally different direction, where the competition is on who’s the least governed exchange.

Where one trades is driven by liquidity more than anything else. People want the ability to trade and will chase liquidity. An exchange with a near-monopoly in a particular contract can raise margins and transaction charges significantly without losing much market share.

Even with a low ownership stake, one entity can control an exchange. And with an ownership cap, the threat of takeover is diminished, giving the entity in control a free run.

In other jurisdictions, the regulatory role of exchanges have been separated to non-profit entities to avoid conflict of interest. Such options could be considered in India.

Listing would improve accountability and lead to better disclosures. Besides, inspections and enforcements by the regulator could be strengthened.

My position is that competition is always good and the regulators should endeavour to get as much competition as possible and design a regulatory framework to deal with the consequences of competition. I believe that the “fit and proper” requirement that regulators consider while licensing regulated entities leads to unwarranted complacency. Regulators must assume that their regulatees are unfit and improper and frame regulations on this assumption. If this leads to a harsher regulatory regime than would prevail otherwise, so be it.

When I talked about listing, I had not read about the collapse of CLICO/CIB. With $24 billion of assets and 60 subsidiaries, operating in several fields, and spread over 20 countries – in the Caribbean, Central and North America and Europe, CLICO was one of the leading financial conglomerates in the Caribbean region before it failed. A couple of days ago, I read the speech of the Governor of the Central Bank of Trinidad and Tobago about the episode where he says:

For all its tremendous growth over the last several years, CLICO has remained a private company which has shielded the company from the kind of scrutiny (through, for example the submission of quarterly accounts) to which public companies are exposed.

I am veering round to the view that all systemically important financial intermediaries – banks, insurance companies, mutual funds, exchanges, operators of settlement and payment systems and so on – should be listed.

Posted at 16:09 on Sat, 21 Mar 2009     View/Post Comments (2)     permanent link


Sun, 15 Mar 2009

More on Sovereign Defaults

I blogged about sovereign defaults in November last year. Since then, I have been reading a lot about sovereign defaults with a focus on defaults by sovereigns who were great powers at the time of default. I have also been doing some reading about credit default swaps on sovereigns.

Turning first to sovereign defaults, I went back to the famous Stop of the Exchequer by Charles II of England in 1672. I regard Charles II as one of the greatest kings of England (one Royal Society is worth a few sovereign defaults!) What struck me was the brazen manner in which the sovereign proclaimed his default:

... his Majesty, being present in Council, was pleased to declare that ... his Majesty considering the great charges that must attend such preparations, and after his serious debates and best considerations not finding any possibility to defray such unusual expenses by the usual ways and means of borrowing moneys, by reason his revenues were so anticipated and engaged, he was necessitated (contrary to his own inclinations) upon these emergencies and for public safety at the present, to cause a stop to be made of the payment of any moneys now being or to be brought into his Exchequer, for the space of one whole year ... unto any person or persons whatsoever by virtue of any warrants, securities or orders, whether registered or not registered therein, and payable within that time, excepting only such payments as shall grow due upon orders on the subsidy, according to the Act of Parliament, and orders and securities upon the fee farm rents, both of which are to be proceeded upon as if such a stop had never been made.

... and that in the meantime ... his Treasury be required and authorized to cause payment to be made of the interest that is or shall grow due at the rate of six pounds per cent, unto every person that shall have money due to him or them ... so postponed and deferred.

English Historical Documents, 1660-1714 By Andrew Browning, p 352

Next I turned to the US abrogation of the gold clause in 1933. Investors in the US protected themselves from the debasement of the currency by demanding a clause requiring repayment in gold or in coins of specific weight and purity of gold. In 1933, the US abrogated this clause with a resolution that is again striking in its brazenness:

House Joint Resolution 192, June 5, 1933

Joint resolution

To assure uniform value to the coins and currencies of the United States and currencies of the United States. Whereas the holding of or dealing in gold affect the public interest, and are therefore subject to proper regulation and restriction; and

Whereas the existing emergency has disclosed that provisions of obligations which purport to give the obligee a right to require payment in gold or a particular kind of coin or currency of the United States, or in an amount in money of the United States measured thereby, obstruct the power of the Congress to regulate the value of the money of the United States, and are inconsistent with the declared policy of the Congress to maintain at all times the equal power of every dollar, coined or issued by the United States, in the markets and in the payment of debts.

Now, therefore, be it Resolved by the Senate and House of Representatives of the United States of America in Congress assembled,

That (a) every provision contained in or made with respect to any obligation which purports to give the obligee a right to require payment in gold or a particular kind of coin or currency, or in an amount in money of the United States measured thereby, is declared to be against public policy; and no such provision shall be contained in or made with respect to any obligation hereafter incurred. Every obligation, heretofore or hereafter incurred, whether or not any such provision is contained therein or made with respect thereto, shall be discharged upon payment, dollar for dollar, in any coin or currency which at the time of payment is legal tender for public and private debts.

These measures were challenged in the US Supreme Court which upheld them stating (Norman v. Baltimore & O.R. Co., 294 U.S. 240):

We are not concerned with their wisdom. The question before the Court is one of power, not of policy.

Contracts, however express, cannot fetter the constitutional authority of the Congress. Contracts may create rights of property, but, when contracts deal with a subject-matter which lies within the control of the Congress, they have a congenital infirmity. Parties cannot remove their transactions from the reach of dominant constitutional power by making contracts about them.

The Supreme Court also upheld the abrogation of the gold clause for the government’s own borrowing. The concurring opinion of Justice Stone in Perry v. United States, 294 US 330) was unusually blunt:

... this does not disguise the fact that its action is to that extent a repudiation of its undertaking. As much as I deplore this refusal to fulfill the solemn promise of bonds of the United States, I cannot escape the conclusion, announced for the Court, that in the situation now presented, the government, through the exercise of its sovereign power to regulate the value of money, has rendered itself immune from liability for its action. To that extent it has relieved itself of the obligation of its domestic bonds, precisely as it has relieved the obligors of private bonds.

Finally, I looked at the world’s leading serial defaulter. “Spain defaulted on its debt thirteen times from the sixteenth through the nineteenth centuries, with the first recorded default in 1557 and the last in 1882.” (Reinhart, Rogoff and Savastano, “Debt Intolerance”, Brookings Papers on Economic Activity, 2003(1), 1-62)

I was most interested in the defaults of Philip II, who “failed to honor his debts four times, in 1557, 1560, 1575 and 1596.” (Drelichman and Voth, The Sustainable Debts of Philip II: A Reconstruction of Spain’s Fiscal Position, 1560-1598)

Drelichman and Voth find that:

Contrary to the received wisdom, we show that Philip II’s debts were sustainable for most of his reign. ... Overall, Habsburg Spain’s fiscal discipline was similar to that of other hegemonic powers, such as eighteenth-century Britain or twentieth-century America.

Philip II managed to run a primary surplus in every year of his reign for which we have data. The king never borrowed to cover interest. ... the average primary surplus increased throughout the period as the Crown strove to deal with the increasing interest payments.

With this as background, buying CDS protection on the leading sovereigns of today does not appear to me to be the madness that Krugman claims it to be: “A world in which the US government defaults would be a world in chaos; how likely is it that these contracts would be honored?”

First of all, Alea blog points out “No, they are not crazy, the contracts will be honoured: 100%, guaranteed, for a simple reason, most sovereign CDS are packaged in fully funded credit derivatives first-to-default credit linked notes, therefore the protection buyer gets the cash upfront and is not exposed to the protection seller credit risk.”

He also points to the prospectus of one of these credit linked notes under which a Belgian bank could end up buying credit default protection against the Belgian government (and other governments) from a Belgian dentist. It would work perfectly. Of course, the Belgian dentist is exposed to default risk of the bank, but if the sovereign is solvent, it would probably backstop its bank and the risk of default is low in today’s moral hazard filled world.

Second, Credit Trader points out that the denomination of the CDS in Euros increases the value of the CDS significantly because it effectively becomes a quanto derivative. Third, the inclusion of the restructuring event as a default event makes a world of difference.

One of the scenarios that I consider plausible is that similar to the gold clause repeal, the US could decide that inflation indexed treasury bonds (TIPS) would be redeemed in nominal dollars and not inflation indexed dollars. I am not a lawyer, but I would imagine that this would pass master with the US Supreme Court just as the gold clause resolution did. I would also imagine that such an action would amount to a default event (restructuring) that triggers the CDS payment. That is why as I argued back in November, having the contract governed by a non US law is very useful.

Today, TIPS are a very attractive asset if investors could protect themselves against the US defaulting on its indexation obligation. Buying TIPS and then buying CDS protection on the US government appears to me to be a very sensible trade and not madness at all.

Posted at 17:03 on Sun, 15 Mar 2009     View/Post Comments (7)     permanent link


Thu, 12 Mar 2009

Has Barro solved the equity premium puzzle?

I have been reading the paper on stock market crashes and depressions by Barro and Ursua which among other things appears to solve the equity premium puzzle. The equity premium is called a puzzle because the historical return on stocks (over multi-decadal time frames) has exceeded that on bonds by too wide a margin to be justified by the higher risk of stocks in a standard utility theory framework.

The equity premium was a puzzle because the return on stocks is not too highly correlated with consumption and in a standard utility framework, the relevant risk is actually consumption risk. Crudely speaking, the risk is that you do not have enough money from your investments to support your consumption precisely when incomes are low and therefore the investment money is needed. I say crudely speaking because in the frictionless models of the permanent income hypothesis, consumption is supposed to be a function of wealth (including human capital) and not of income at all. A model of risk premiums which ignores liquidity constraints so brazenly might not be very satisfying to finance people, but that is a different issue altogether.

The solution proposed to this puzzle is essentially that the entire consumption risk of equities is a tail risk. It arises from the high probability that stock market crashes are accompanied (with a variable lag) by an economic depression. One big advantage of depressions over wars and other calamities as the explanation for the equity premium is that depressions make risk free bonds very attractive assets.

Of course, Barro has been saying this for a few years now, but now he has the cross country data to back him up. “Conditional on a stock-market crash [multi-year real returns of -25% or less], the probability of a minor depression (macroeconomic decline of at least 10%) is 30% and of a major depression (at least 25%) is 11%.” Taking this tail risk into account is sufficient to justify the observed equity premium for plausible values of risk aversion.

I think this is definitely a promising line of analysis. Of course, a major econometric problem is that the lag between the stock market crash and the economic depression is not uniform (in some cases, it is even negative due to measurement errors). Barro and Ursua therefore “focus on the 58 cases of paired stock-market crashes and depressions ... and ... calculate the covariance in a flexible way that allows for different timing for each case.”

I am sure that a lot of methodological refinements are needed to understand the phenomenon better, but I like this approach. For Indian readers, it is interesting to note that the sample includes one episode from India (apart from the World War): during 1946-1949, real stock prices fell 49% while real GDP fell 18% during 1947-1950. That makes the current crisis seem quite bearable!

Posted at 15:44 on Thu, 12 Mar 2009     View/Post Comments (0)     permanent link


Thu, 05 Mar 2009

Is there any such thing as macro-prudential risk?

I have been grappling with this question ever since reading The Fundamental Principles of Financial Regulation by Markus Brunnermeier, Andrew Crockett, Charles Goodhart, Avinash D. Persaud and Hyun Shin. All the authors are well respected economists; and Brunnermeier, Persaud and Shin, in particular, have been among those whose writings I have admired a lot during this crisis. Yet, I am not convinced about their concept of macro-prudential risk as opposed to the micro-prudential risk that traditional risk models are allegedly concerned with.

My problem is that at least since Markowitz, risk has always meant portfolio risk. The riskiness of any asset is the contribution that it makes to the portfolio in which it is held. For an equity portfolio, therefore the risk of a stock is its covariance with the portfolio which is the approximately the same as the beta if the portfolio is highly correlated with the market portfolio. In a value at risk (VaR) model for a credit portfolio, the marginal risk of a loan is equal to its expected loss conditional on the total portfolio loss being equal to the VaR level (see for example, Hans Rau-Bredow, 2002). This is true in particular of the Basel II models as well.

Brunnermeier et al are rightly worried about herding behaviour where many banks hold similar portfolios and are thus exposed to the same risks. But in this situation, each bank’s portfolio is highly correlated with the aggregate portfolio of the banking system. Thus Basel II and similar allegedly micro-prudential risk models are in fact capturing the macro-prudential risk of each loan. At this point, (following Brunnermeier et al) I am also ignoring the technical inadequacies of the Basel II risk models. The question being asked is whether conceptually they are addressing the right risk. I think they are.

One of the problems I had with Brunnermeier et al is that they seemed to be focused on the wrong conditional probability. They frequently ask the question: conditional on a bank failing what is the probability that there is a systemic crisis. They argue correctly that this probability is higher for a bank with a AAA portfolio than for a bank with a BBB portfolio. I think the correct question to ask is the reverse conditional probability: conditional on a systemic crisis, what is the probability that the banks in question fail. This probability is higher for the bank with a BBB portfolio and this is consistent with the Basel II risk weights.

At this point, it is also worthwhile to remember that the capital required for a AAA loan is far in excess of its unconditional probability of default. In fact, the unconditional probability of default is the “expected loss” which in Basel II is supposed to be covered by the credit spread and is not supposed to come out of the capital charge at all. The capital charge deals exclusively with the “unexpected loss” and is defined by conditionalizing on a systemic shock.

In short, I think today’s risk models are conceptually addressing macro-prudential risk because in any portfolio risk model these are the only risks that matter. Whether they are measuring these risks right is a totally different question (see my last blog post).

Brunnermeier et al have a long discussion about liquidity risk and maturity mismatches as a macro-prudential risk. The example of Northern Rock permeates this discussion. I think the diagnosis of Northern Rock as a liquidity risk which seemed to make sense in 2007 (I was guilty of this diagnosis myself) has been invalidated by developments in 2008. The silent run that banks like WaMu witnessed have shown that there is no safety for a bank in retail deposits. Nor is there safety in retail term deposits. All banks allow customers to prematurely encash their term deposits with modest penalties. In bank runs, people queue up to do exactly that as for example in the mini runs that we had on ICICI Bank in India. The behavioural maturity of core deposits is a meaningful notion in normal times; in periods of crisis, the behavioural maturity is zero. In wholesale markets, maturity is ill defined because of put and call features combined with step-up coupons. Normal maturity assumptions about these bonds have been invalidated during the current crisis. In short, maturity mismatch is not a well defined term during a systemic crisis.

In this context, I am perplexed by the irrational fear of bank runs among regulators and academics alike. We must not forget that frequent runs and near runs are the principal defence that we have against Ponzi schemes (both Madoff and Stanford were ultimately exposed by runs on them). Solvent institutions with normal access to central bank liquidity support can survive runs. Banks that cannot survive a run despite the central bank liquidity window are fundamentally flawed; they need to fail.

Posted at 21:40 on Thu, 05 Mar 2009     View/Post Comments (4)     permanent link


Tue, 03 Mar 2009

Risk Management Lessons for Derivative Exchanges

A few days ago, I finished a paper on Risk Management Lessons from the Global Financial Crisis for Derivative Exchanges. The abstract of the paper says:

During the global financial turmoil of 2007 and 2008, no major derivative clearing house in the world encountered distress while many banks were pushed to the brink and beyond. An important reason for this is that derivative exchanges have avoided using value at risk, normal distributions and linear correlations. This is an important lesson. The global financial crisis has also taught us that in risk management, robustness is more important than sophistication and that it is dangerous to use models that are over calibrated to short time series of market prices. The paper applies these lessons to the important exchange traded derivatives in India and recommends major changes to the current margining systems to improve their robustness. It also discusses directions in which global best practices in exchange risk management could be improved to take advantage of recent advances in computing power and finance theory. The paper argues that risk management should evolve towards explicit models based on coherent risk measures (like expected shortfall), fat tailed distributions and non linear dependence structures (copulas).

Posted at 16:48 on Tue, 03 Mar 2009     View/Post Comments (10)     permanent link


Mon, 02 Mar 2009

Did 7th January tell us about anything about the governance discount?

On January 7, 2009, when the fraud at Satyam was revealed, investors did not think of Satyam as an unfortunate exception; most of them thought of it as symptomatic of the problems that could be lurking in many other leading Indian companies. Stocks of several other companies fell dramatically on that day in a manner that did not seem to reflect industry specific shocks. Within the information technology industry itself to which Satyam belonged, some stocks with a reputation for above average corporate governance rose while some other stocks fell dramatically.

To those who believe in the strong form efficiency of stock markets, it is tempting to believe that the market was telling us something about the perceived governance weaknesses of some Indian companies. In this context, it is worthwhile to ask whether the reaction of the market on that day was a panic reaction that was reversed over a period of time.

On January 7, 2009, nine out of the fifty stocks in the S&P CNX Nifty Index fell by more than 10% while the index itself fell by 6%. The median stock in the 50 stock index fell by only 5% while the median price decline of these nine stocks was 15%. I looked at what happened to these nine stocks week after week up to the end of February. Far from reversing course, these stocks extended their losses. While the index fell by 11% and the median stock in the Nifty fell by 17% from pre-Satyam levels, the median fall for the nine stocks was 37%. That is right, the median of these nine stocks underperformed the index by a whopping 26%. Only one of these nine stocks fell less than the index; the other eight underperformed the index by margins ranging from 12% to 35%.

In the case of the real estate stocks, is it possible to argue that the fall was industry wide; though one could counter argue that in this case, the entire industry was perceived to be plagued by governance problems. In most other cases, the market perception about governance appears to be the dominant theme. Of course, even if we believe that the market is telling us something, we do not know whether what it is saying is right or not.

Posted at 20:57 on Mon, 02 Mar 2009     View/Post Comments (2)     permanent link


Impairment test equals integrity test

I have a piece in today’s Financial Express arguing that the impairment test in the year end financials is a test of the integrity of Indian corporate sector.

Corporate India faces a significant test of the integrity of its financial statements at the end of this financial year when it has to apply an “impairment” test to a variety of assets under accounting standard AS 28. If assets are impaired, they have to be written down and the loss has to be charged to the profit and loss account.

Though AS 28 came into effect for listed companies from the year 2004-05, this is the first time that a large number of companies will be confronted with potential impairment on a large scale. Under AS 28, the requirement to carry out an impairment assessment arises only when there are external or internal indications that an asset may be impaired. The significant worsening of the domestic and global economic environment, sharp declines in market prices and deterioration in the economic performance of many assets would trigger the application of the impairment test for several classes of assets during this year.

There are four important categories of assets where impairment is likely to have taken place. These are: (a) goodwill from recent acquisitions (particularly, international acquisitions), (b) mines and other natural resource assets, (c) commercial real estate, and (d) capacity rendered redundant by demand destruction.

Indian companies made large international acquisitions at high prices during the boom. The current market value of several of the acquired companies would be well below what was paid for them. Their current and forecasted operating performance would also be much worse than what was projected at the time of acquisition. This would normally lead to a heavy impairment charge.

Some kinds of acquisitions would probably escape this charge. For example, if a foreign company was acquired mainly for its brands and marketing network or for its technology, the acquired company might not have an independent set of cash flows that can be used for an impairment test. In this case, the impairment test may have to be applied to the entire consolidated business. Companies whose shares are trading above book value are unlikely to be in the situation where the entire business is impaired and so no impairment charge may be needed.

Commercial real estate is another prime candidate for an impairment test because of the steep correction in market prices. Here again, if the real estate was bought for corporate offices or for other purposes which do not produce identifiable cash flows, impairment charges may not result unless the whole business is impaired. Real estate that was bought for development or for letting out or for producing revenue directly (as in infrastructure projects or retail stores) would be prime candidates for impairment.

Similarly, the sharp fall in commodity prices could trigger impairment charges for many natural resource assets like mines in India or abroad that were bought at the height of the boom.

Finally, the global recession has created excess capacity in a variety of industries. New capacity is coming on stream while even the old plants are running below capacity. Many of these assets might have to face an impairment charge. In many cases, it may be possible to argue that the low capacity utilisation is a temporary phase. But in some industries, the demand destruction has been too large for such a sanguine view.

Companies whose shares are trading below book value are in a worse situation. Their entire business may be impaired and they may have to write down many assets including unproductive corporate assets (ranging from art collections to aircraft) which have seen huge declines in price.

Banks and financial companies are in a separate league because the treatment of their impaired loans and investment is governed by different regulations. These losses are bound to rise, too, but that is another story altogether.

Stock markets are forward looking and are likely to have already factored in the deterioration in asset values in their valuation. Recognising this known loss in the published accounts would not cause a further drop in share prices. On the contrary, markets are likely to reward companies which are honest about what has happened, reflect this reality in their accounting and have a realistic plan to deal with their problems.

Markets are more likely to punish companies that try to avoid an impairment charge by using various accounting subterfuges. Such companies would be telling the world that their accounts cannot be trusted at all and that they are Satyams in the making. That would force the market to assume the worst and mark down even assets that are not actually impaired.

Many companies, however, do not seem to understand this. They appear to be under the delusion that all would be fine with the world if only they can find a way to avoid admitting the impairment that has taken place. That is why I think that the impairment test could end up being an integrity test for Indian accounting.

Posted at 12:15 on Mon, 02 Mar 2009     View/Post Comments (0)     permanent link