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28 October 2011

This week in "Brussels"
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Articles from 20 October 2011 - 28 October 2011

Banking

EBA details the EU measures to restore confidence in the banking sector
The European Banking Authority (EBA) supports the agreement at EU level on measures to restore confidence in the banking sector. These measures form part of a broader package aimed at addressing the current situation in the EU by restoring stability and confidence in the markets.  View Article
No forced recapitalisation for financial institutions, says European Savings Banks Group
The forced recapitalisation plan for European financial institutions which the European Commission is working on is a matter of concern for the European savings and retail banks that are members of the European Savings Banks Group.  View Article
Basel III FAQs answered by the Basel Committee
The Basel Committee on Banking Supervision published answers to a second set of Basel III frequently asked questions.   View Article
IIF: Major global banks are making significant progress on compensation risk alignment
An international survey of reforms in compensation systems at leading banks shows major progress towards full implementation of the global standards embodied in the Financial Stability Board's (FSB) Principles on Compensation, issued in April 2009.   View Article
EPC calls on European lawmakers to align forthcoming SEPA regulation with bank customer requirements
The European Payments Council (EPC) has created this web page to provide journalists with an easy reference point to view relevant documents and source content that will assist in understanding the latest issues.  View Article
Eurofinas: Sixth Consumer Market Scoreboard - the right priorities?
Eurofinas, the voice of consumer credit providers at European level, takes note of the publication of the European Commission's 6th Consumer Market Scoreboard (the "Scoreboard") which, for the first time, includes the market for loans and credit cards.  View Article
Gillian Tett: Central bankers must update outdated analytical toolkit
In her article for the FT, Tett writes that Claudio Borio, a senior economist at the Bank for International Settlements, has just produced a paper on the world's central banks which, in Borio's words, are struggling to find any workable “compass” in these new, stormy waters.  View Article
BBA: Resolving the eurozone crisis
EU leaders meeting to discuss the future of the eurozone need to undertake three actions quickly, British Bankers' Association's chief executive, Angela Knight, blogged on Friday.  View Article
FT: Basel to change trade finance reforms
Global banking regulators have agreed to tweak the way the new “Basel III” capital requirements are calculated for trade finance to help low income countries, but have rejected industry calls for a full rewrite.  View Article
BBA: The Independent Commission on Banking - six weeks on
Six weeks on from the publication of the BBA's final report, BBA's Angela Knight reminds policy-makers that the ICB is a body that recommends, not a body that decides.  View Article
BIS: Sovereign risk in bank regulation and supervision - where do we stand?
Speech by Mr Hervé Hannoun, Deputy General Manager of the BIS, at the Financial Stability Institute High-Level Meeting, Abu Dhabi, UAE, 26 October 2011.  View Article
BIS: Basel capital framework's treatment of trade finance
The Basel Committee on Banking Supervision has evaluated the impact of Basel II and Basel III on trade finance in the context of low income countries.   View Article
BoE's Haldane: Basel III does not go far enough
Bank of England executive director of financial stability, Andrew Haldane, says the capital requirements placed on banks under Basel III may not be enough to stave off another banking crisis.  View Article
VOX: 'The Future of Banking'
This new Vox eBook presents a collection of essays by leading European and US economists that offer solutions to the crisis and proposals for medium- to long-term reforms to the regulatory framework in which financial institutions operate.  View Article
Dirk Schoenmaker: The future of cross-border banking
This column says stable cross-border banking is incompatible with national financial supervision, which means the European banking market needs European authorities.  View Article

Securities

EBF: European banks welcome MiFID Review proposal
The European Banking Federation (EBF) welcomes the proposals published by the European Commission, reviewing the current regulatory framework for the provision of investment services and activities in Europe under the Markets in Financial Instruments Directive (MiFID).   View Article
S&D call for ban on flash trading techniques
S&D Euro MPs welcomed new measures from the European Commission to strengthen transparency and sanction wrong-doing on financial markets.  View Article
FN: Commission drops MiFID gender quotas
The European Commission has dropped a controversial rule that would have imposed gender quotas upon firms regulated under new securities trading rules, after it was criticised for trying to introduce gender legislation via the “back door".  View Article
FN: MiFID II - in a nutshell
After two years of information gathering, frenzied lobbying, several leaks, and hundreds if not thousands of column inches, the European Commission has finally published its legislative proposal for MiFID II. But don't get too excited - it is hardly inscribed in stone.  View Article
ISDA comments on EC's MiFID proposals
The overarching objective of the original MiFID framework was to further integration, competitiveness and efficiency of European financial markets, and ISDA supports changes that build on that goal, including the introduction of a well-calibrated post-trade transparency regime for OTC derivatives.  View Article
European investors and exchanges ask for the MiFID Review to put the economy first
These associations jointly call on the EU Institutions to ensure that the MiFID Review achieves what should be its primary objective: making the capital markets work for Europe's real economy and society as a whole.  View Article
AFME comment on the Markets in Financial Instruments Directive and Regulation
Simon Lewis, AFME's CEO, said that the main concern is that some of today's proposals could affect customer choice, service and cost, for businesses and individuals.  View Article
NYSE Euronext statement on MiFID review
According to NYSE Euronext, the proposed amendments will lead to safer, sounder and more transparent financial markets in Europe.  View Article
FT: Bankers fear political moves will kill off CDS
Bankers fear the market could be “killed dead”, if politicians put pressure on banks to accept big haircuts without triggering a CDS payout, while a ban on naked trading could hit liquidity.  View Article
Asset managers decry purely political short selling ban
Asset managers and brokers have reacted against the purely political imposition of a ban on naked shorting of European Union sovereign government bonds and stocks, which is expected to come into law following the agreement between the European Parliament and representatives of EU Member States.  View Article
Hedgeweek: Exchange-traded derivatives provide silver lining in dark clouds
The exchange-traded derivatives market has been one of the few highlights of the post-financial crisis period, driven by innovative products such as exchange-traded fund options and volatility index derivatives in the developed markets of the US and Europe.  View Article
FN: ETF transparency drive creates more confusion
Attempts to provide clear definitions for different exchange-traded funds are being undermined by commercial considerations, which is creating further confusion.  View Article
IOSCO publishes recommendations on market integrity
The Technical Committee of the International Organization of Securities Commissions (IOSCO) has published its Final Report on Regulatory Issues Raised by the Impact of Technological Changes on Market Integrity and Efficiency.  View Article
Commission requests Poland and Slovenia to implement rules for settlement systems and collateral arrangements
The requests take the form of reasoned opinions, the second step of EU infringement procedures. If the two Member States do not notify measures to implement the Directive fully within two months, the Commission may refer the matter to the Court of Justice of the EU.   View Article
BoE Paul Tucker: Central counterparties - the agenda
Speech by Mr Paul Tucker, deputy governor for financial stability at the Bank of England, at the European Commission Conference on "European Post Trading Landscape: The Road Ahead" in Brussels.  View Article
FN: Five reasons against 'banning' sovereign ratings
The European Commission is actively considering allowing the region's financial regulator to ban the issuing of sovereign credit ratings in the region for countries in bailout talks.   View Article
Paul N Goldschmidt: EU proposals on strengthening control over rating agencies - a flawed approach at an inappropriate moment
As the EU struggles to bring credible answers to its sovereign debt and interrelated banking crisis, proposing radical measures to regulate the agencies further can only be interpreted as an attempt to identify scapegoats as well as to hide the deep disarray in which the authorities find themselves.  View Article
FT: EU shake-up for rating agencies
Sweeping changes to regulation of credit ratings are to be proposed by Brussels. Under one of the most contentious proposals, European regulators would be given powers to suspend credit ratings of countries undergoing bailouts.  View Article
IOSCO Secretary General to leave organisation in December 2011
The International Organization of Securities Commissions (IOSCO) announced that Greg Tanzer, its current Secretary General, will stand down as Secretary General at the end of December 2011, in order to take up an appointment as a Commissioner of the Australian Securities and Investments Commission.  View Article

Insurance

EIOPA launches consultation on good practices for disclosure and selling of variable annuities
This is EIOPA's first consultation in the area of consumer protection. The consultation links EIOPA's work in consumer protection with financial innovation. The results of this consultation will shape the view on how to deal with disclosures and selling arrangements for insurance contracts.  View Article
EIOPA published final reports on the equivalence assessment of the Bermudan, Japanese and Swiss supervisory systems
The goal of this equivalence assessment is to ensure that the third country regulatory and supervisory regimes provide a similar level of policyholder / beneficiary protection as the one provided under the Solvency II Directive.  View Article
FEE commented on amendments to the proposal for a Directive of the EP and the Council amending Directives 2003/71/EC and 2009/138/EC
FEE published its comment letter on amendments to the proposal for a Directive of the European Parliament and of the Council, amending Directives 2003/71/EC and 2009/138/EC in respect of the powers of the EIOPA and the ESMA – Omnibus II.  View Article
Time for insurers to stand and deliver on Solvency II
The Chief Architect of Solvency II, Karel van Hulle, head of the insurance and pension division at the European Commission, has warned that the time for talk and compromise over Solvency II is over, and that insurers must be prepared to stand in full view of their supervisors.  View Article

Asset Management

EIOPA extends IORP Directive consultation deadline to January 2012
The European Insurance and Occupational Pensions Authority extended the period for the second consultation exercise on the reform of workplace-based pensions legislation to January 2012.  View Article
IPE: EU concerned about 'pressure and scrutiny' on pension funds
According to Commissioner for employment, social affairs and inclusion, László Andor, the "pressure and scrutiny" pension funds are under has become a growing concern within the European Union.   View Article
AMF: Finalisation of UCITS IV Directive transposition
The modifications to the AMF General Regulation, transposing the UCITS IV Directive and modernising the legal framework of asset management, were approved.  View Article
FN: Investors wish for liquid hedge funds
In the current economic uncertainty, pension funds and other institutional investors are increasingly turning to liquid hedge fund strategies as they seek to have easy access to their money in shifting conditions.  View Article
NAPF comment on the EU Review of the IORP Directive
The National Association of Pension Funds commented on the launch of the European Insurance and Occupational Pensions Authority's consultation on changes to the Institutions for Occupational Retirement Provision Directive.  View Article
IPE: Solvency II requirements in IORP Directive would be catastrophic
Introducing Solvency II measures within the Institutions for IORP Directive could lead to an important increase in funding requirements and deeply impact defined benefit (DB) pensions schemes, the consultancy LCP has warned.  View Article
FN: Pensions watchdog raises spectre of Solvency II
EIOPA has refused to rule out applying Solvency II capital rules to retirement schemes, despite reassurances last week from a top European commissioner that the EC “knows the difference” between insurance companies and pension funds.  View Article
IPE: Next stage of IORP consultation to launch this week
The European Insurance and Occupational Pensions Authority (EIOPA) is to launch a second consultation exercise on the reform of workplace-based pensions legislation (IORP) under instructions from the European Commission.  View Article
FN: Pension funds get to grips with swaps
UK pension funds are more comfortable than ever with derivatives, an integral part of liability-driven investments and increasingly used in growth portfolios too. But market volatility and the prospect of new EU regulations are clouding the horizon.  View Article
IPE: CEE countries unlikely to come under IORP Directive, predicts EIOPA stakeholder member
The mandatory retirement pillars of central and eastern European countries, as well as unfunded pension funds, will not be subject to a new IORP Directive once the new draft is published, a member of the European Insurance and Occupational Pensions Authority (EIOPA) stakeholder group has predicted.  View Article
FN: Schemes to be hit by strict EC rules
The European Commission is due to produce its long-awaited 500-page consultation paper on pension scheme solvency.  View Article

Corporate Governance/Accounting

Commission proposes review of the existing Accounting Directives
The proposal simplifies the accounting requirements for small companies, and improves the clarity and comparability of companies' financial statements within the Union.  View Article
Commission published a Communication on Corporate Social Responsibility (CSR)
The Communication offers a modernised definition of this concept that is consistent with internationally recognised principles and guidelines. It serves as a strategy that will allow companies to achieve their potential more effectively.   View Article
CEA and CFO Forum welcomed proposed IFRS 9 delay
The CEA and the CFO Forum welcomed the proposal by the IASB to delay the Mandatory Effective Date for the introduction of the new IFRS on Financial Instruments (IFRS 9), in the light of continuing delays in the finalisation of both the financial instruments and insurance contracts projects.  View Article
IFAC: IESBA proposed changes to the Code of Ethics for Professional Accountants
The memorandum provides background for, and an explanation of, the proposed changes to various paragraphs in the Code of Ethics for Professional Accountants (the IESBA Code) that address a breach of a requirement of the Code. The IESBA request comments by January 23, 2012.  View Article
FEE commented on IASB's ED Mandatory Effective Date of IFRS 9
FEE responded to the IASB Exposure Draft Mandatory Effective Date of IFRS 9 Financial Instruments. FEE welcomes the Board's decision to postpone the effective date of IFRS 9.  View Article
FASB chair Leslie F Seidman's remarks to NASBA
Leslie F Seidman, chairman of the FASB, gave a speech on her personal views to the National Association of State Boards of Accountancy (NASBA) in Nashville on 24 October 2011. Her speech regarded convergence, IFRS incorporation and “condorsement” and private company accounting.  View Article
EBA commented on the IASB's ED Mandatory Effective Date of IFRS 9
The EBA has submitted its comments regarding the IASB's Exposure Draft ED/2011/03 Mandatory Effective Date of IFRS 9.  View Article
FASB seeks comments on proposal on accounting for investment property entities
The FASB issued a proposed Accounting Standards Update intended to develop accounting guidance for investment property entities. Comments on the proposal are requested by January 5, 2012.  View Article
FASB seeks comments on proposal to clarify criteria for investment company accounting
The FASB published a proposed Accounting Standards Update intended to improve and converge financial reporting by setting forth consistent criteria for determining whether an entity is an investment company. Comments on the proposed Update are requested by January 5, 2012.  View Article
EFRAG's endorsement advice letter to the EC on the Amendments to IAS 1 Presentation of Items of Other Comprehensive Income
EFRAG completed its due process regarding the Amendments to IAS 1 Presentation of Items of Other Comprehensive Income and has submitted its Endorsement Advice Letter and Effects Study Report to the European Commission.  View Article
EFRAG's endorsement advice letter to the EC on the amended version of IAS 19 Employee Benefits
EFRAG completed its due process regarding IAS 19 Employee Benefits (as amended in June 2011) and has submitted its Endorsement Advice Letter and Effects Study Report to the European Commission.  View Article
EBF response to the IASB's ED of proposals to adjust the Mandatory Effective Date of IFRS 9
The EBF has submitted its comments regarding the IASB's Exposure Draft ED/2011/03 Mandatory Effective Date of IFRS 9 Financial Instruments.  View Article
IASB proposed an amendment to IFRS 1
The IASB published for public comment a proposed amendment to IFRS 1 First-time Adoption of International Financial Reporting Standards. The ED is open for comment until 5 January 2012.   View Article
FEE commented on EFRAG's Draft Comment Letter on IASB's ED Mandatory Effective Date of IFRS 9
FEE responded to the EFRAG Draft Comment Letter on the IASB Exposure Draft Mandatory Effective Date of IFRS 9 Financial Instruments. Like EFRAG, FEE welcomes the Board's decision to postpone the effective date of IFRS 9.  View Article
ECIIA: Auditors joining forces in the fight for better controls government in the financial crisis
Presidents of the members of the European Confederation of IIA met on 22nd October with the general secretary of EUROSAI during the ECIIA General Assembly, in a moment of thought and strategy in joining forces for the necessary betterment of internal control in government expenditure.  View Article
IAASB invites stakeholder input on post-implementation review of clarified ISAs
The IAASB released its plan for a post-implementation review of the clarified International Standards on Auditing (ISAs). Input for the purpose of the review is requested by no later than October 31, 2012.  View Article
IFAC: IPSASB's consultation paper 'Reporting Service Performance Information'
The IPSASB approved the Consultation Paper 'Reporting Service Performance Information'. This project aims to present a principles-based approach to developing a consistent framework for public sector entities.  View Article

Financial Services Policy

Commission published review of the Transparency Directive
In order to close the existing gap in the notification requirements, the proposal to modify the Directive would require disclosure of major holdings of all financial instruments that could be used to acquire economic interest in listed companies and had the same effect as holdings of equity.   View Article
EC: More responsible businesses can foster more growth in Europe
The European Commission has presented a package of measures to support entrepreneurship and responsible business because a responsible approach to business means more, and more sustainable, economic growth.   View Article
Šemeta: Tax systems can be designed in a competitive way without engaging in harmful tax competition.
Šemeta stressed that by focusing on a sound tax policy that enhances the quality of taxation and involves coordination and cooperation at EU level, a competitive tax system can be combined with a sustainable level of tax revenues.   View Article
Major financial services trade associations urge UK to continue to take a strong stance against FTT
A letter sent to Mr George Osborne states that the Commission expects only a modest, adverse impact on GDP, yet if the assumptions underpinning this calculation are incorrect, then the impact assessment itself acknowledges that reduction in GDP could be much higher.   View Article
ALDE Mulder: Reforming financial regulations - the EU budget can guarantee the EFSF and be replenished by the surplus of the previous year
In its technical aspects, the recasting of the Financial Regulations, approved today during the first reading by the European Parliament in the Strasbourg plenary session, simplifies procedures and lays the foundation for a new governance of the EU budget in times of crisis.  View Article
European Parliament on the eurozone deal: relief but no time for celebration
Cautious relief characterised the plenary debate with Van Rompuy and Barroso just hours after heads of state reached a political deal on shoring up the eurozone. Many MEPs however warned that the solution only buys time, and for the medium-term more ambition and social conscience was needed.   View Article
CEA, EBF and EFAMA voice VAT concerns
The associations urge the Council to finalise the Directive and the Regulation as soon as possible, in order to provide businesses with the required legal certainty.  View Article
FSA Lord Turner: We have a major opportunity to put in place a better system of financial regulation
Turner concluded by recognising that the move towards the new UK regulatory structure was taking place against the backdrop of the eurozone problems. He emphasised that the FSA remained totally focused on its current objectives of ensuring the UK financial system was robust to withstand challenges.  View Article
FTadviser: MiFID proposals could ‘steal RDR’s thunder’
The European Commission has released its document on how MiFID would regulate financial markets and advisers, amid concerns it could overshadow the retail distribution review.  View Article

European Council/Parliament

Remarks by President Herman Van Rompuy following the European Council on 23 October 2011
This European Council focused on the economic growth and discussed the pressing matters related to banks in Europe and to the eurozone.   View Article
Remarks by President of the European Council Herman Van Rompuy after the Euro Summit
Van Rompuy listed five fronts that are being worked on in a comprehensive strategy, and said that decisions will be made at the follow-up euro summit this week.  View Article
EP: Preparing the Eurozone Summit
The main spokespersons for EP's political groups held a debate to discuss the eurozone summit. MEPs broadly criticised the "summit" management, arguing that the past year had already shown that this was not the way to handle the crisis.   View Article

International/G20

Nicolas Véron: Global financial authorities must adapt to a changed world
In spite of the G20's recent initiatives, global financial authorities remain imbalanced to the detriment of emerging economies that represent a rapidly-increasing share of the global financial system. Véron argues that it would be in Western countries' own interest to make these institutions more globally representative.  View Article
Bloomberg: Europe struggles for crisis remedy
Global exasperation with Europe's response is deepening, with politicians from Australia to North America prodding the euro area to get ahead of the crisis before it infects the world economy. A G20 meeting in Cannes, France, on November 3-4 is Europe's self-imposed deadline.  View Article
Olin L Wethington: Strengthening the stabilisers
In his Project Syndicate article, Wethington writes that the G20 summit in Cannes is a major opportunity to address the mandate, governance and institutional capacity of the Financial Stability Board, the international body that monitors, and makes recommendations about enhancing, the international financial system.   View Article
Douglas J Elliott’s Congressional testimony - the eurozone crisis and implications for the United States
Elliott testified today before the International Monetary Policy and Trade subcommittee of the Financial Services Committee of the House. From an American standpoint, the euro crisis is deeply concerning, in part because the path it follows is likely to be the main determinant of whether the US goes back into recession.  View Article

Think Tanks

Bruegel: Europe’s leaders must start making tough decisions
Jean Pisani-Ferry says that what citizens and markets alike expect from the heads of state and government is that they do the job for which they are indispensable, and map out the political choices Europe is now screaming for.  View Article
Bruegel: The Greek public debt misery - the right cure should follow the right diagnosis
Zsolt Darvas comments that the leaked confidential debt sustainability analysis by the troika (EC, ECB and IMF) has endorsed the view that there are two ways out of the Greek public debt trap: debt socialisation, i.e. official lending at a very low interest rate for decades, or a sizeable reduction in privately-held debt.  View Article
Bruegel: Three ways to save the eurozone
Writing for Project Syndicate, Jean Pisani-Ferry says that eurozone officials' decision to reform the surveillance of governments and banks and to boost the EFSF is a welcome response but, unfortunately, a partial one. Beyond firefighting, the key issue is the need to construct a more robust monetary union.  View Article
Bruegel: Europe's growth emergency
This Policy Contribution by Zsolt Darvas and Jean Pisani-Ferry puts forward policy recommendations to move towards growth rebuilding in the EU, reducing the fragility of the European banking sector and restoring the image of southern European countries as worthwhile places to invest.  View Article
Bruegel: Is recent bank stress really driven by the sovereign debt crisis?
Ahead of the European Council meeting on 23 October, Bruegel deputy director Guntram B Wolff outlines how EU Heads of States should focus on restoring confidence in euro area policymakers' ability and determination to put the euro area on a sound footing and restore market credibility.  View Article
CEPS: A three-pillar firepower to solve the European sovereign crisis - a last chance!
This paper by Senior Research Fellow, Rym Ayadi, proposes to tackle the sovereign debt and banking crises with a comprehensive multi-pillar mechanism that involves cash and synthetic solutions aimed at enhancing the European Financial Stability Facility (EFSF), but without necessitating any structural transformation.   View Article
Policy Exchange: Launch of the £250,000 (€286,000) Wolfson Economics Prize
The world's top academic economists have been challenged to suggest how to manage the orderly exit of Member States from EMU. A new Economics Prize worth £250,000 is offered by Policy Exchange, the London-based think tank, and funded by eurosceptic, Lord Wolfson.(Graham Bishop comments on this.)  View Article

Commentaries

Wolfgang Münchau: Europe is now leveraging for a catastrophe
In his FT column, Münchau says it is time to prepare for the unthinkable: there is now a significant probability the euro will not survive in its current form.   View Article
Comment on the Op-ed by Sir John Major in the FT of October 27 'The Price of the Drift to Fiscal Union'
Mr Goldschmidt writes that the summit conclusions must be used to implement as rapidly as possible the further integration of the EU 27 Members, rather than exacerbating the divisions between the EMU 17 and the other EU Members.  View Article
Stewart Fleming: A democratic foundation for the single currency
Writing for European Voice, Fleming says that the eurozone has to address its democratic deficit as well as its sovereign debt.   View Article
Paul De Grauwe: European summits in ivory towers
This column in Social Europe argues that Europe's leaders have lost touch, that the ECB has the firepower but is not prepared to use it, and that the outcome of all this is depressingly clear: defeat by the financial markets.  View Article
Sir John Major: The price of the drift to fiscal union
In his article for FT Opinion, former UK PM Major writes that the crisis in the eurozone was inevitable but has been accelerated, and worsened, by the banking collapse. It will not be solved easily or quickly. When it is, it may lead to a very different European Union.  View Article
Martin Wolf: Be bold, Mario, put out that fire
Commenting in his FT column on Mario Draghi's imminent role as ECB president, Wolf says that Draghi will take up one of the most important central banking jobs in the world; but he will also bear a frightful responsibility. The ECB alone has the power to quell the eurozone crisis. Draghi must choose between two paths: the orthodox one leads towards failure; the unorthodox one should lead towards success.  View Article
Charles Wyplosz: Resolving the current European mess
CEPR research fellow Wyplosz says that the current plan to enlarge the EFSF and recapitalise banks through markets will fail. The twin crises linking sovereign debts and banking turmoil need to be addressed simultaneously for Europe to avoid economic disaster.  View Article
John Kay: Europe’s elite is fighting reality and will lose
According to Kay in his FT column, conventional wisdom holds that the eurozone problem is the adoption of a common monetary policy without a common fiscal policy. But a common fiscal policy is not necessary - nor is it sufficient - for a successful monetary union.  View Article
Simon Nixon: Crunch time for Franco-German relations
Nixon comments in the WSJ that unless France and Germany can find a way to resolve their differences over the next few days, both the euro and the European Union itself could start to unravel — a terrifying prospect.  View Article
Douglas J Elliott: The euro crisis summit - more progress, more disappointment
Brookings Institution's Elliott comments that after the summit at the weekend which intended to produce strong steps to halt the euro crisis, the actions expected to be announced this week are likely to improve the situation, but will be far from sufficient to resolve the core problems.   View Article




© Graham Bishop

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