Several Items on Banking Regulation

by Dollars and Sense

Several interesting items about financial (re-)regulation, and the unlikelihood of anything approaching adequate regulation getting through Congress, have come across our desk.

First, the business section of Friday's New York Times had a pretty good piece by Joe Nocera on financial regulation, Have Banks No Shame? He partially skewers Barney Frank for watering down the planned regulations, and there are some nice quotes from MIT economist Simon Johnson, a vocal critic of the banking industry. But Nocera ends up endorsing the flawed bill, even with its severely weakened provision for a consumer financial protection agency.

Next, our friends Jane D'Arista and Gerald Epstein and folks at the Political Economy Research Institute have started a new organization of economists pushing for tougher banking regulation:

Economists' Committee for Stable, Accountable, Fair and Efficient Financial Reform
September 2009 -- The Economists' Committee for Stable, Accountable, Fair and Efficient Financial Reform (SAFER) is a focal point, clearinghouse and coordinating mechanism for progressive economists and analysts to gather and present their views on financial re-regulation and reform; to reach, to the degree possible, a consensus on the key issues relating to regulation and reform; and to help incorporate this work into the public debate over these issues that will ensue over the coming six to nine months or so. By bringing these analysts together to speak in a concerted voice, we will be able to broaden the perspective on financial regulation and reform, and enhance our impact on this public debate.

SAFER was founded by economists Gerald Epstein and Jane D'Arista. Read more about them and the other analysts involved with SAFER here.

Next, the Sunlight Foundation's blog has a great post (with this great graphic) about how members of the House Financial Services Committee are "on F.I.R.E":

One year after the biggest economic collapse since the Great Depression, Congress is still debating new financial regulations to protect consumers and prevent risk-taking in the financial sector. The House Committee on Financial Services is currently undertaking the important first step of writing, amending and voting on some of the pieces of the long-proposed financial regulatory reform. While debating these issues top committee members have been the recipients of disproportionate campaign contributions from the very industry that they are tasked with regulating. Twenty-seven committee members have so far received over one-quarter of their contributions from the finance, insurance and real estate (FIRE) sector. This includes Chair Barney Frank, Ranking Member Spencer Bachus, four subcommittee chairs and four subcommittee ranking members. Of the twenty-seven, twelve committee members received over 35% of their contributions in 2009 from the FIRE sector. Ranking Member Bachus, a crucial decision maker on the committee, received 71% of his campaign contributions from the finance, insurance and real estate (FIRE) sector so far this year. (These numbers run from January 1-June 30.) For his career, the Alabama congressman receives 45% of his contributions from the FIRE sector. Bachus leads the committee in his reliance on FIRE sector campaign contributions. Bachus has taking a position in opposition to most of the regulatory reforms. Bachus recently stated in a hearing, “this is absolutely the wrong time to be creating a new government agency empowered not only to ration credit, but to design the financial products offered to consumers.

Read the rest of the post.

Last but not least, the Buffalo News had an article on the conference of post-Keynesians that was held in the rust-belt city last weekend (with D&S classroom readers available at the book exhibit). The article has its charmingly corny moments, starting with the title (get it?) and the first quotation, but it's nice coverage.

Scholars Are "Keynes" on Regulation

Economists Argue Financial Instruments Need More Scrutiny

By George Pyle | The Buffalo News, N.Y. | Oct 10, 2009

Before the financial meltdown, before the housing bubble, even before the dot.com crash, the weakness of the American economy had its roots in the collapse of its industrial base.

That was the argument of a Cornell University scholar, who said Friday that it was therefore appropriate that a conference of economists pondering the roots and the remedies of the Great Recession chose to meet in Buffalo.

"All progressive economists, wherever they live, are residents of Buffalo," said Charles J. Whalen, a Ph.D. economist and former Buffalo resident, in an echo of the speech President John F. Kennedy delivered in West Berlin. "And, therefore, as an economist, I take pride in the words 'Ich bin ein Buffalonian.' "

Whalen was a presenter at the Cross-Border Post Keynesian Conference, a bi-annual gathering of like-minded scholars hosted this year at the Burchfield Penney Art Center by the Buffalo State College economics department. He was among those arguing that an economy that no longer invests in the manufacture of tangible goods finds itself inventing other, much more mysterious things in which to invest and, hopefully, make money.

But, they said, exotic instruments such as securitized mortgage certificates and credit default swaps not only don't provide the industrial infrastructure -- and the jobs -- that the old manufacturing economy built up, they also aren't fully understood by those who create them, those who buy them and those who regulate them. Or those who would regulate them if the law hadn't been changed to allow those financial processes to operate beyond the reach of government.

Eric Tymoigne, an economics professor from Lewis and Clark College in Portland, Ore., argued that new financial instruments should be regulated in the same manner as medicines, tested and approved before they are allowed on the market.

"If the side effects kill you," Tymoigne said, "it probably wasn't a good innovation."

Presenters in Friday morning's sessions condemned the deregulation of financial institutions that has been going on over the past 15 years, with the support of both Democrats and Republicans.

Robert W. Dimand, economics professor at Brock University in St. Catharines, Ont., said investment bankers convince themselves, and then convince government, that they can control their own creations and that they no longer need the kind of regulatory regime that was put in place in answer to the Great Depression.

"The mistakes in policy did not just happen," Dimand said. "They were mistakes that the banks lobbied for."

Participants said the deregulatory trend ignores the lessons of history as well as the precepts of noted economists such as the namesake of their conference, John Maynard Keynes, and the post-Keynes scholar that most of them cite in their work, Hyman Minsky.

Both taught that governments need to be more aggressive than they usually are in regulating financial markets and in stepping in with such things as public works spending during economic downturns. But, while Keynes is often cited (wrongly, these scholars contend) as arguing that government intervention is needed only rarely, Minsky was more explicit in claiming that markets are inherently unstable and run the risk of frequent global crashes without outside supervision and, as needed, intervention.

Whalen lamented that it is only in times of financial crisis that government leaders, and even most mainstream economists, heed Keynes or even hear tell of Minsky. The rest of the time, they said, both government and academia hew to the belief, which he called seriously mistaken, that markets are rational and self-regulating.

Buffalo State professor William T. Ganley quoted 19th century journalist Charles McKay to make his point: "Men think in herds and go mad in herds. They only recover their senses slowly, and one by one."

The conference continues today with sessions for scholars, students and, starting at 2 p.m., presentations that are open to the public at no charge. They include a lecture by Buffalo State history professor Mark Goldman on the Great Depression and Buffalo art culture, a panel discussion on the future of capitalism and, at 8 p.m. a presentation of songs, stories and images from the Great Depression entitled "... Whose Names Are Unknown."

Read the original article.

Labels: banking regulation, barney frank, Gerald Epstein, Jane D'Arista, Joe Nocera, PERI, post-Keynesianism

 

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10/14/2009 01:14:00 PM 0 comments

 

Some Takes on the Regulatory Overhaul

by Dollars and Sense

Here are some assessments of the Obama administration's overhaul of financial regulation:

In his front-page New York Times article on Wednesday (upgraded from the left-hand column of the business section), Joe Nocera finds "only a hint of Roosevelt" in what Obama described as "a sweeping overhaul of the financial regulatory system, a transformation on a scale not seen since the reforms that followed the Great Depression."

Michael Greenberger of the University of Maryland comments on the new regulations in an interview on WBAL Radio, AM 1090 (Baltimore) on Wednesday (it opens up directly into Quicktime audio, but the interview comes through just fine).

And Greenberger contributed to this piece from Reuters (also from Wednesday).

There's a new sheriff in town, and the freewheeling era of the credit-default swap is about to fade into the sunset. As part of the overhaul of financial regulation to be announced by the administration today, Treasury Secretary Timothy Geithner has signaled that he plans to corral these troublesome trades. When it comes to instruments like credit-default swaps and that whole class of derivatives blamed for battering the economy, everyone is speaking the language of change. Unfortunately, everyone also has a different idea of what that means. Populist outrage is running high, both branches of Congress have bills percolating that would impose strict governance on trading, and the Commodity Futures Trading Commission wants to solidify its relevance in a climate of political uncertainty. There are a lot of different opinions—and divergent agendas—on how to manage these fiscal problem children.

Part of the problem is that even administration officials are divided on how to handle derivatives. The two main camps are exchange trading and clearinghouse oversight. In a May 13 letter, Geithner called for unregulated derivatives trading to occur via one or more central clearinghouses. He stopped short of mandating that all such business must be conducted on an exchange, allowing that some customized derivatives contracts could still happen over the counter (that is, privately). Senate agriculture committee Chairman Tom Harkin, D-Iowa, went further and called for a mandate to have all derivatives treated as futures contracts and traded on an exchange. Gary Gensler, President Obama's nominee to head the CFTC, has sought to split the difference, telling the agricultural committee in a speech on June 4 that derivatives should be regulated by his commission as strictly as exchange-traded instruments, although he didn't say they have to be traded on an exchange.

Before we go too much further, it's important to keep in mind that both Harkin and Gensler have vested interests in how this turns out. A cynic might consider Gensler's eagerness to craft a broad new role for the CFTC disingenuous given the widespread speculation earlier this year that the administration might close the agency and fold its duties into a beefed-up SEC. For his part, Harkin might also be guilty of self-interest. The agricultural committee is the CFTC's bureaucratic "parent." While their motivations may be upright and more oversight would be great, it can't hurt that such changes would solidify the relevance of each man's respective Beltway fiefdom.

So let's take a look at the question of clearinghouse vs. exchange. While both cover some similar turf, there are also big differences that would affect their performance and, possibly, their ability to weed out abuses. Firstly, the two entities aren't mutually exclusive. Exchanges generally include clearinghouses, but a clearinghouse can also exist as a standalone entity. A clearinghouse functions as a kind of fiscal referee. It makes sure participants aren't too deeply indebted and make good on their contracts and records price information. An exchange would do much the same.

Exchanges offer one clear advantage in terms of transparency, though. A clearinghouse gathers and publicizes pricing data only after transactions take place. But an exchange would create what the experts term "price discovery." It would do for the derivatives market what e-commerce did for the retail landscape. If you wanted to buy a set of patio furniture in the pre-Google (GOOG) years, you would just go to the store and pay whatever the tag read. Now, with a few keywords and clicks, you can comparison shop among dozens of merchants.

Banks abhor regulation in general and exchange-trading requirements in particular. If given any say at all (and their lobbyists are insuring they probably will be), they'd prefer a clearinghouse option with healthy exceptions—some would say loopholes—for custom-built credit instruments. What banks really want to avoid is mandatory exchange trading because they pocket the difference between the asking price and the offered price in an opaque market. This difference would still be present in exchange-traded products, but it would be much smaller because everyone would be able to see the going rate, so bid amounts would be much closer to sellers' asking prices.

The price transparency afforded by exchange trading has another advantage not directly related to the trades themselves. With prices out in the open, everyone from private-sector analysts to academics to policymakers will be able to see fluctuations as they happen and possibly catch the next bubble before it mushrooms out of control. In short, having more pairs of eyes is a good thing. Like getting a friend to proofread your résumé on a macro scale.

If exchange trading is required, banks would also lose the opportunity to make money off customized offerings, a relatively small niche that pulls in larger returns—a revenue source they're loathe to relinquish. All exchange trading takes place using standardized contracts, which takes pricey customization out of the equation. Banks argue that the degree of customization necessary for more complex derivatives is too great for them to shoehorn these contracts into a standard format. But critics are quick to point out that banks can and do charge a lot more for creating a custom contract, making their protest a bit suspect, especially since some relatively complex "standard" instruments already exist.

Banks also argue that forcing every trade onto an exchange will stifle innovation. That's certainly possible. And it also might not be a bad thing. When JPMorgan (JPM) invented credit-default swaps back in the '90s, it could package and sell them directly to clients—clients who probably didn't really understand just what this new toy they were purchasing could do. In 2000, when the Commodity Futures Modernization Act explicitly excluded CDS from regulation, the move was widely viewed as one of resignation. The market for swaps and related derivatives had grown into a thicket of economic kudzu so quickly that regulators decided to leave it be rather than hack through it. Given what CDS have given the world in recent years, it could be argued that a little vetting on the front end might have given market participants a better understanding of the inherent risks before they got in over their heads.

Some people worry that the clearinghouse option—which the banks view as the lesser of two evils—doesn't carry enough regulatory clout to prevent risky trading. As this New York Times article points out in great detail, a clearinghouse could wind up being owned by the banks it's meant to regulate. Fox, henhouse, and so forth. ICE U.S. Trust, widely seen as the front-runner clearinghouse, is 50 percent owned by some of the biggest banks in the business. Critics worry that if the home team is also the umpire, it'll permit generous exceptions to disclosure requirements.

Interestingly, this isn't the first time the United States has considered a centralized oversight vehicle for these kinds of instruments. Back in 1984, long before subprime mortgages and credit-default swaps hit the scene, Fannie Mae proposed a "national mortgage exchange" to regulate the complex universe of mortgage-backed securities that could, in the words of one official, "slid[e] into chaos." The agency pledged $10 million to start up the exchange but scuttled the idea a few years later after deciding that the private sector had stepped up its efforts to keep mortgage-related trading running smoothly. The powers that be should keep this in mind as they weigh who to trust with this complex arena.

Explainer thanks Michael Greenberger of the University of Maryland, Gary Kopff of Everest Management Inc. (formerly of Fannie Mae), Kevin McPartland of the Tabb Group, and Ann Rutledge of R&R Consulting.

Hat-tip to Lynn Fries for these links (though I'd seen the Nocera piece in my morning paper).

Labels: financial crisis, financial regulation, Joe Nocera, Timothy Geithner

 

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6/19/2009 01:45:00 PM 0 comments

 

Trust Your Guts (Greider)

by Dollars and Sense

Joe Nocera likes Geithner's new plan. William Greider, not so much. Here is an excerpt from his recent article in The Nation. Hat-tip to LF.

Some points I recommend people consider:

1. Euthanasia for insolvent banks. Transferring their losses to the public will not restore the trillions in capital the bankers helped destroy. It would merely relieve the banks, their creditors and shareholders of the pain. Government must take control of the system to supervise a just unwinding of the mess--whether we call it nationalization or something else. Handing out money and leaving bankers in control of how it's spent is nutty and morally wrong. People everywhere understand this. Only Washington seems oblivious to the irrationality of what it is attempting.

2. The Federal Reserve must be democratized and effectively stripped of its peculiar antidemocratic status as an unaccountable island of power within the government. A new federal agency--accountable to Congress and the president--can be refashioned from the working parts of the Fed. Call it a central bank or something else, but its governing power must not rest with heavyweight bankers on the board of directors at the twelve regional banks. (To understand why, consider that the New York Federal Reserve Bank was headed until recently by Geithner.)

3. The reformed Fed would be confined to conducting monetary policy and stripped of its regulatory functions. A different section of the Treasury or a new free-standing regulatory agency can assume responsibility for regulation and be armed with strong antitrust laws and other rules to ensure that "too big to fail" institutions are redefined as "too big to save."

4. The federal law against usury can be restored to halt predatory lending. Persistent violators would not be fined with trivial penalties, as they are now, but stripped of their government protections and subsidies--that is, doomed.

5. A new banking system--smaller and more diverse and responsible to the public interest--can fill the hole left by the demise of major banks like Citigroup. Vast public resources should be devoted to creating this system, not to saving the mastodons. Public banks (like the North Dakota State Bank) and nonprofit savings and lending cooperatives can also serve as an important cross-check on private commercial banking--a competitive model that offers credit on nonusurious terms and keeps the big boys honest.

6. Once the Federal Reserve is domesticated in a democratic fashion, then it can be reformed to assume broad supervision of the nonbank financial firms in the "shadow banking system"--hedge funds, private equity firms, pension funds, mutual funds, insurance companies. (For more on this, see my recent Nation article, "Fixing the Fed.")

7. Our first political challenge is to disturb business as usual in Washington and prevent Congress from taking hasty action to adopt Wall Street's "reform" agenda. Congress is rattled by the exploding popular anger and listening nervously. The people need to speak louder--loud enough for the president to hear.

Read the full article.

Labels: bailout, financial crisis, Joe Nocera, The Fed, William Greider

 

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3/29/2009 11:09:00 AM 1 comments

 

Madoff's Accomplices: His Victims (Nocera)

by Dollars and Sense

Finally, somebody in a mainstream publication says something close to what I have been thinking about the Madoff victims. In a column last Friday entitled Madoff Had Accomplices: His Victims, Joe Nocera argues that the investors whom Madoff cheated were irresponsible. As I will argue below, I think they were showed not just personal irresponsibility, but possibly also ethical and political irresponsibility. But here's Nocera:

[J]ust about anybody who actually took the time to kick the tires of Mr. Madoff's operation tended to run in the other direction. James R. Hedges IV, who runs an advisory firm called LJH Global Investments, says that in 1997 he spent two hours asking Mr. Madoff basic questions about his operation. "The explanation of his strategy, the consistency of his returns, the way he withheld information—it was a very clear set of warning signs," said Mr. Hedges. When you look at the list of Madoff victims, it contains a lot of high-profile names—but almost no serious institutional investors or endowments. They insist on knowing the kind of information Mr. Madoff refused to supply.

I suppose you could argue that most of Mr. Madoff's direct investors lacked the ability or the financial sophistication of someone like Mr. Hedges. But it shouldn't have mattered. Isn't the first lesson of personal finance that you should never put all your money with one person or one fund? Even if you think your money manager is "God"? Diversification has many virtues; one of them is that you won't lose everything if one of your money managers turns out to be a crook.

"These were people with a fair amount of money, and most of them sought no professional advice," said Bruce C. Greenwald, who teaches value investing at the Graduate School of Business at Columbia University. "It's like trying to do your own dentistry." Mr. Hedges said, "It is a real lesson that people cannot abdicate personal responsibility when it comes to their personal finances."

And that's the point. People did abdicate responsibility—and now, rather than face that fact, many of them are blaming the government for not, in effect, saving them from themselves. Indeed, what you discover when you talk to victims is that they harbor an anger toward the S.E.C. that is as deep or deeper than the anger they feel toward Mr. Madoff. There is a powerful sense that because the agency was asleep at the switch, they have been doubly victimized. And they want the government to do something about it.

I spoke, for instance, to Phyllis Molchatsky, who lost $1.7 million with Mr. Madoff—and is now suing the S.E.C. to recoup her losses, on the grounds the agency was so negligent it should be forced to pony up. Her story is sure to rouse sympathy—Mr. Madoff was recommended to her by her broker as a safe place to put her money, and she felt virtuous making 9 or 10 percent a year when others were reaching for the stars. The failure of the S.E.C., she told me, "is a double slap in the face." And she felt the government owed her. Her lawyer, who represents several dozen Madoff victims, told me he "wouldn't be averse" to a victims' fund.

Even Mr. Wiesel thought the government should help the victims—or at least the charitable institutions among them. "The government should come and say, ‘We bailed out so many others, we can bail you out, and when you will do better, you can give us back the money,' " he said at the Portfolio event.

But why? What happened to the victims of Bernard Madoff is terrible. But every day in this country, people lose money due to financial fraud or negligence. Innocent investors who bought stock in Enron lost millions when that company turned out to be a fraud; nobody made them whole. Half a dozen Ponzi schemes have been discovered since Mr. Madoff was arrested in December. People lose it all because they start a company that turns out to be misguided, or because they do something that is risky, hoping to hit the jackpot. Taxpayers don't bail them out, and they shouldn't start now. Did the S.E.C. foul up? You bet. But that doesn't mean the investors themselves are off the hook. Investors blaming the S.E.C. for their decision to give every last penny to Bernie Madoff is like a child blaming his mother for letting him start a fight while she wasn't looking.

I like Nocero's line of thinking, but I wish he'd gone beyond personal investment advice. There is an argument to be made that Madoff's victims—or some of them, at least—and (it should be added) plenty of other big-money investors, are guilty not only of failing in their duties to themselves to invest their money wisely, but also failing ethically to invest their money in ways that don't harm other people. And if this is true of the Madoff investors, then it's true of a lot of other investors in Wall Street's latest high-flying phase.

Take Elie Wiesel, for example. Here are some excerpts from the NY Times article about Wiesel's comments at the Portfolio forum Nocera mentions:

Elie Wiesel Levels Scorn at Madoff

By STEPHANIE STROM
Published: February 26, 2009

What does Elie Wiesel, the Nobel Peace Prize laureate and Holocaust survivor who has dedicated his life to fighting hatred and intolerance, think about Bernard L. Madoff?

"'Psychopath'—it's too nice a word for him," Mr. Wiesel said in his first public comments on Mr. Madoff and the Ponzi scheme he is accused of perpetrating on thousands of individuals and charities, including the Elie Wiesel Foundation for Humanity.

"'Sociopath,' 'psychopath,' it means there is a sickness, a pathology. This man knew what he was doing. I would simply call him thief, scoundrel, criminal."

And this:

Asked what punishment he would like to see for Mr. Madoff, Mr. Wiesel said: "I would like him to be in a solitary cell with only a screen, and on that screen for at least five years of his life, every day and every night, there should be pictures of his victims, one after the other after the other, all the time a voice saying, 'Look what you have done to this old lady, look what you have done to that child, look what you have done,' nothing else."

Now, the punishment Wiesel describes sounds a lot like torture to me—solidary confinement alone is torture—so I was a little taken aback that Wiesel called for it. But what about a humanitarian and professor of ethics like Wiesel failing to look into the source of his and his foundation's investment profits? In the case of Madoff, the source was theft—Madoff and his accomplices used new investors' money to pay interest to older investors (this is what a Ponzi scheme is). But what if Madoff had just been a "good" (i.e., effective) money-manager (albeit with less consistently, and suspiciously, reliable returns), and had been paying Wiesel and his foundation interest that came from, say, companies that outsourced jobs to sweatshops; leveraged buyouts of companies that were then gutted and resold; companies that pollute; companies engaged in predatory lending; etc. etc.—that is to say, the usual sources of Wall Street megaprofits? Madoff was stealing from people, but many a money-manager who hasn't been branded "the most hated man in New York" (as one of the tabloids, I believe, put it), or called a "monster" on the cover of New York magazine has been complicit in plenty of human misery. Would Wiesel have known?

Labels: Bernard Madoff, Elie Wiesel, financial crisis, Joe Nocera, Wall Street

 

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3/17/2009 01:02:00 PM 4 comments

 

Bailedout Cash for Acquisition, Not Loans

by Dollars and Sense

Joe Nocera, New York Times business columnist, has a particularly interesting piece today. We all suspect that the money being injected by the Treasury Department in order to recapitalize banks is more likely to fund acquisitions than to ease the credit crisis by getting banks to lend again. In fact, we suspect that was part of the plan all along--to encourage (further) consolidation in the banking industry. Nocera helps confirm these suspicions, first by pointing us to the fine print in the bailout bill, which gives a tax break to banks that acquire other banks:

In fact, Treasury wants banks to acquire each other and is using its power to inject capital to force a new and wrenching round of bank consolidation. As Mark Landler reported in The New York Times earlier this week, "the government wants not only to stabilize the industry, but also to reshape it." Now they tell us.

Indeed, Mr. Landler’s story noted that Treasury would even funnel some of the bailout money to help banks buy other banks. And, in an almost unnoticed move, it recently put in place a new tax break, worth billions to the banking industry, that has only one purpose: to encourage bank mergers. As a tax expert, Robert Willens, put it: "It couldn’t be clearer if they had taken out an ad."

Nocera also managed to listen in on an employee-only phone conference over at JPMorgan-Chase, in which an executive tipped his hand on how the $25 billion injection the bank just took might be used. When someone asked the obvious question: "Chase recently received $25 billion in federal funding. What effect will that have on the business side and will it change our strategic lending policy?", here's how the executive responded:

"Twenty-five billion dollars is obviously going to help the folks who are struggling more than Chase," he began. "What we do think it will help us do is perhaps be a little bit more active on the acquisition side or opportunistic side for some banks who are still struggling. And I would not assume that we are done on the acquisition side just because of the Washington Mutual and Bear Stearns mergers. I think there are going to be some great opportunities for us to grow in this environment, and I think we have an opportunity to use that $25 billion in that way and obviously depending on whether recession turns into depression or what happens in the future, you know, we have that as a backstop."

Joe the journalist observes:

Read that answer as many times as you want — you are not going to find a single word in there about making loans to help the American economy. On the contrary: at another point in the conference call, the same executive (who I'm not naming because he didn’t know I would be listening in) explained that "loan dollars are down significantly." He added, "We would think that loan volume will continue to go down as we continue to tighten credit to fully reflect the high cost of pricing on the loan side." In other words JPMorgan has no intention of turning on the lending spigot.

It is starting to appear as if one of Treasury's key rationales for the recapitalization program — namely, that it will cause banks to start lending again — is a fig leaf, Treasury's version of the weapons of mass destruction.

Read the full article.

Labels: bailout, financial crisis, Joe Nocera, JP Morgan Chase, recapitalization

 

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10/25/2008 06:03:00 PM 0 comments