ProdukHukum BankIndonesia
Resolving Cross-Border Bank
Problems: East Asian Case
Bank Indonesia’s Annual
International Seminar 2009
Michael Pomerleano, PhD
Case study: Lehman's insolvency
•
•
•
Context- the use of bankruptcy in the resolution of financial institutions
distress: Prospects of illiquidity and potential insolvency are becoming more
likely around the world. This makes the effectiveness of bankruptcy regimes
an important concern for policymakers, but there are no standards.
When a large company with global operations seeks Chapter 11 protection, it
can spawn numerous legal proceedings with different rules in other countries.
• Administrators for Lehman's U.S. estate plan to ask a federal judge to
approve an international framework for coordinating bankruptcy
proceedings among subsidiaries spread across the globe.
• Administrators in Hong Kong, Singapore, Germany, Luxembourg and
Australia have signed on to the protocol. But….
• A global protocol is "unnecessary, insufficiently tailored and
unacceptably burdensome" for Lehman's U.K. estate and its creditors,
said Tony Lomas, a PricewaterhouseCoopers partner and
administrator of the London estate.
• "There need to be international standards when dealing with a global
company that collapses," said Bryan Marsal, Lehman's chief
restructuring officer and co-CEO of turnaround firm Alvarez & Marsal
LLC. "Otherwise, every country acts like 'Every man for themselves.' “
"With the increased internationalization of bankruptcy, it's more and more
important for the different jurisdictions to come to an informal agreement," said
Edward Altman, a New York University business professor who focuses on
bankruptcies. "There is no official code that brings them together."
Source: WSJ Lehman Units Argue Bankruptcy MAY 26, 2009
Reforms? What reforms?
• Finance Reforms Pared Back: The Obama
administration is backing away from seeking a
major reduction in the number of agencies
overseeing financial markets. WSJ June 9, 2009
• EU Bank Revamp Spurs U.K. Resistance to
Ceding Power Bloomberg , April 4 2009
• German Finance Minister Peer Steinbrueck
voiced skepticism today on U.S.-style stress
tests to check the health of individual banks,
dismissing an IMF recommendation, AFP
reported June 11, 2009
The State of the International Architecture- not
clear?
London Club
FATF
G7-G10-G20-G30-G24-G77
The State of the International and National
Architecture- clearer?
• Basel Committee- BIS- FSF-IMF-OECD-WTOWB-RDBs-UN-UNDP
• Paris Club- London Club
• G7-G10-G20-G24-G77
• IASB-IOSCO-IAIS-IADI- The Joint Forum
• FATF- Interpol
• ASEAN- Chang Mai - Apec –SEACEN
• MLAT’s-Swaps-MOU’s-COSRA-FSF “colleges”
What do they have in common? Westphelian, colloquial groupings without
authority
The New Financial Stability Board offers
guidance on cross-border insolvency
• The Financial Stability Board (FSB) has been
established to address vulnerabilities and to develop and
implement strong regulatory, supervisory and other
policies in the interest of financial stability.
• FSB consists of a Chairperson, a Steering Committee,
the Plenary with member countries, SSBs and
international financial institutions, and a Secretariat.
• A full-time Secretary General and an enlarged
Secretariat based in Basel support the FSB.
• Plenary members include the current FSF members
(G20), Spain and the European Commission
FSB Principles for Cross-Border Crisis
Management
1.
In it’s April 2009, the Financial Stability Forum (FSF)
issued a report addressing: “Principles for Crossborder Cooperation on Crisis Management” It states
that “In financial crisis management, national
authorities will, as far as possible” :
Maintain incentives for financial institutions to behave
prudently .. The Bank-Support Measures Implemented in US, Europe
as well as Asia‐Pacific do not provide incentives to behave prudently
2.
3.
Promote private sector solutions and intervene only to
preserve financial stability
Maintain a level playing field internationally in the spirit
of the Basel Accord the capital requirements
produced two market responses: risk weights designed
for evasion and avoidance -the “shadow” banking
sector, including institutions which turned out to be toobig-to-fail .
Cooperation for Cross-Border Crisis
Management
3. Develop common support tools to manage cross-border
crisis
4. Meet annually (??), coordinated by home authorities
5. Home authorities to keep all countries informed of
arrangements
6. Share minimum information- at this stage it does not
appear that European countries share information
7. Ensure firms can supply required information
8. Encourage firms to maintain contingency plans for
wind-down
9. Ensure firms have robust funding plans
10. Seeks to remove practical barriers to efficient
internationally coordinated resolutions
During crisis, national authorities commit to:
11. Find internationally coordinated solutions- what are
they?
12. Share national assessments of systemic implications,
using agreed framework
13. Share information as early as possible
14. If fully coordinated solution is not possible, discuss as
promptly as possible possible national solutions
15. Share plans for public communications for clarity and
coordination”
•
•
The FSB’s broad set of principles is just that broad principles” that
a) do not have concrete solution b) a clear road map to to
implementation.
What is left? MOUs between Home and Host Regulators ..Is it
effective?
Without a Global roadmap, oversight and
implementation is is left to Home and Host Regulators
1.
Can regulation be effective through a “Westphalian”
voluntary cooperative “memorandum of understanding”?
2.
Unique issues in emerging markets- what is not
systemic in a mature market can be highly systemic in
an emerging market- e.g., capital flows reversals,
sudden stops.
3.
What was thought to be non-systemic can rapidly
evolve to become highly systemic- “subprime is a
small part of a small part..” .
4.
The present memorandums of understanding do not
have sufficient legal standing or powers of mediation in
the event of disagreements between home and host
regulators. Frequently the case. witness Lehman
5.
Without Global Bankruptcy Rules or Court, difficult to
resolve failures of "large complex financial institutions"
10
(“LCFIs”) on cross-border basis.
Presenting for Andrew Sheng: The real issues are
common processes for resolution --who determines who pulls
the plug?
(b) If info is shared with college of supervisors, the smallest/least
affected can pull plug to protect domestic interests and damage all
the other efforts, or leaks of info will result in collapse of
negotiations. Therefore the prospects for sharing of information
are dim
(c) No common laws - each regulator must comply with local law and
protect local interests. E.g., American Security was ring fenced
during BCCI by the US
(d) No dispute resolution between different regulators on different
views
(e) No international court to resolve how to allocate priority in
payment.
Therefore, if domestic laws prevail and domestic protection prevails,
international bankruptcy of Large Complex Financial Institutions
(LCFI) will be fragmented & uncoordinated and go to lowest
common denominator, leading to large losses.
They are all Too Interconnected TO FAIL, not Too Big to Fail .
Hence, the question is at what price of National Treatment (NTA)
would it be worthwhile to rescue or to allow to fail?
(a) No
Conclusion – the present voluntary
cooperative efforts are not effective
• The Westphalian principles governing international
financial oversight (sovereignty of states; the
fundamental right of political self determination; equality
between states; and consultation but non-intervention of
one state in the internal affairs of another state) are not
adequate to address the global financial system
• The intl’ financial authorities need to make progress with
a binding post-Westphalian global financial order.
• The prospects for such an accord are dim.
• The World Bank’s Global Bank Insolvency initiative did
not go anywhere .
info.worldbank.org/etools/library/latestversion.asp?83870
• So what’s left- improvisation in resolutions…
In the absence of resolution processes a variety of ad-hoc Bank-Support
Measures Implemented in US, Europe as well as Asia‐Pacific
Guarantees
for banks’
existing
and/or newly
issued
obligations
Potential
direct capital
support
Removal of
and
guarantees for
bad assets
Direct
liquidity
support
Blanket
deposit
guarantees
Forbearance
Asia
Australia Korea
New Zealand
Hong Kong
India Japan
Singapore
South Korea
Japan (?)
South Korea
South
Korea
Australia
Hong Kong
Malaysia
New Zealand,
Singapore
Taiwan
India
North
America
U.S., Canada
U.S.
U.S.
U.S.
U.S. - deposit
insurance
raised
U.S. – revisions
to mark to market
Europe
Austria
Denmark
Finland France
- Dexia S.A
Germany
- NORD/LB.
Greece
Ireland
Italy
The
Netherlands
Portugal
Spain
Sweden.
UK
UK Germany
Germany UK
Switzerland
UK
UK
What is the solution?
• Shouldn’t wait for dramatic changes at the global level
• The development of vigorous regional financial and monetary
institutions is an essential objective
• Better promise and prospects by investing in the domestic and
regional building blocks, to complement and lead to an eventual
global financial stability order
Global
Domestic Infrastructure
Regional
Domestic Infrastructure
Global
3 examples of domestic steps
•
•
•
Domestic Prudential Regulation : Ring-fence affiliates of foreign banks in
subsidiaries subject to local prudential regulatory measures
– Guillermo Ortiz is a wise man. Concerned since early 2000 re domestic
affiliates foreign banks, and explored "ring fencing".
– Ring fencing with the affiliate treated with the full local prudential norms,
including some additional, such as
• prudential limits on the ratio of foreign liabilities/foreign assets (to
prevent either flight or inflow for arbitrage) is the best solution.
• Period.
Financial institutions insolvency. The use of bankruptcy in the resolution
of financial institutions distress. Prospects of illiquidity and potential
insolvency are becoming more likely around the world. This makes the
effectiveness of bankruptcy regimes an important concern for
policymakers.
Strengthen domestic institutions. Singh, Raju; Kpodar, Kangni; Ghura,
Dhaneshwar IMF Working Paper No. 09/113: Financial Deepening in the
CFA Franc Zone: The Role of Institutions. The results indicate that the gap
in financial development between the CFA franc zone countries and the rest
of SSA can be explained by differences in institutional quality (e.g.,
availability of credit information, and strength and enforcement of property
rights), variables that policy makers can influence.
Source: http://www.imf.org/external/pubs/cat/longres.cfm?sk=22974.0
International steps:
• International steps: The burden is left on
home and host regulators to establish a
sound foundation.
• Forge better regional exchange of
information, harmonization of regulations
and standards, develop capacity,
institutional capacity , organization
• A possible example is the Committee of
European Banking Supervisors
– Exchange of information is limited, but
– The Community Directives are excellent tools
Committee of European Banking Supervisors
http://www.c-ebs.org/
• The Committee of European Banking Supervisors
(CEBS) is composed of high level representatives from
the banking supervisory authorities and central banks of
the European Union. Their role is to:
– CEBS gives advice to the European Commission on banking
policy issues and promotes cooperation and convergence
of supervisory practice across the European Union. The
Committee will also foster and review common implementation
and consistent application of Community legislation
– Advise the Commission, either at the Commission's request,
within a time limit which the Commission may lay down
according to the urgency of the matter, or on the Committee's
own initiative, in particular as regards the preparation of draft
implementing measures in the field of banking activities.
– Contribute to the consistent implementation of Community
Directives and to the convergence of Member States'
supervisory practices throughout the Community
– Enhance supervisory co-operation, including the exchange of
information.
• No parallel in East Asian …. SEACEN focused more on exchange
of views, training
Marek Belka, Director of the IMF`s European Department,
commented in an editorial in the FT lamenting the risks to
Europe`s 52-year quest for a single financial market
“
While its rationale remains compelling, this aspiration is under threat as the crisis has
pushed national authorities to reassert control over their financial systems. Whether
this setback is temporary depends critically on the outcome of the debate on
Europe`s cross-border financial stability arrangements. (.) A related debate is on the
future of the "single passport."(.). The existing set-up, in which cross-border
operations are covered solely by the financial stability arrangements of the home
country, is unsustainable. (.) A more general challenge is that of imposing discipline
on those banks deemed "too big to fail". In such cases, the threat of bankruptcy is not
credible: the private and social costs are simply too prohibitive.” "Increased host
country control over foreign branches, as some advocate, is not a comprehensive
solution to these complex challenges. (.) What is needed is a dedicated EU level
resolution framework that can credibly discipline Europe`s large cross-border banks
while offering depositors protection equivalent to national deposit guarantee
schemes. (.) Europe`s 50-100 largest banks, and smaller banks whose cross-border
activities raise concerns, should migrate to this scheme on reasonable conditions. In
return, they should benefit from an unrestricted single passport. (.) The single
passport has so far shown only glimpses of its potential. Realizing this potential
requires that the proposed EU-level supervisory authorities establish trust between
home and host countries. (.) In parallel, the EU should embark on an accelerated
program to create a dedicated resolution framework for its cross-border banks. The
potential gains are large. Settling for less-effective solutions risks entrenching the
dynamic towards refragmentation of financial markets. Much depends on the choices
that the European Council will make.
A banking framework to rescue the single market Jun 04 2009, By Marek Belka and
Wim Fonteyne, Financial Times
Problems: East Asian Case
Bank Indonesia’s Annual
International Seminar 2009
Michael Pomerleano, PhD
Case study: Lehman's insolvency
•
•
•
Context- the use of bankruptcy in the resolution of financial institutions
distress: Prospects of illiquidity and potential insolvency are becoming more
likely around the world. This makes the effectiveness of bankruptcy regimes
an important concern for policymakers, but there are no standards.
When a large company with global operations seeks Chapter 11 protection, it
can spawn numerous legal proceedings with different rules in other countries.
• Administrators for Lehman's U.S. estate plan to ask a federal judge to
approve an international framework for coordinating bankruptcy
proceedings among subsidiaries spread across the globe.
• Administrators in Hong Kong, Singapore, Germany, Luxembourg and
Australia have signed on to the protocol. But….
• A global protocol is "unnecessary, insufficiently tailored and
unacceptably burdensome" for Lehman's U.K. estate and its creditors,
said Tony Lomas, a PricewaterhouseCoopers partner and
administrator of the London estate.
• "There need to be international standards when dealing with a global
company that collapses," said Bryan Marsal, Lehman's chief
restructuring officer and co-CEO of turnaround firm Alvarez & Marsal
LLC. "Otherwise, every country acts like 'Every man for themselves.' “
"With the increased internationalization of bankruptcy, it's more and more
important for the different jurisdictions to come to an informal agreement," said
Edward Altman, a New York University business professor who focuses on
bankruptcies. "There is no official code that brings them together."
Source: WSJ Lehman Units Argue Bankruptcy MAY 26, 2009
Reforms? What reforms?
• Finance Reforms Pared Back: The Obama
administration is backing away from seeking a
major reduction in the number of agencies
overseeing financial markets. WSJ June 9, 2009
• EU Bank Revamp Spurs U.K. Resistance to
Ceding Power Bloomberg , April 4 2009
• German Finance Minister Peer Steinbrueck
voiced skepticism today on U.S.-style stress
tests to check the health of individual banks,
dismissing an IMF recommendation, AFP
reported June 11, 2009
The State of the International Architecture- not
clear?
London Club
FATF
G7-G10-G20-G30-G24-G77
The State of the International and National
Architecture- clearer?
• Basel Committee- BIS- FSF-IMF-OECD-WTOWB-RDBs-UN-UNDP
• Paris Club- London Club
• G7-G10-G20-G24-G77
• IASB-IOSCO-IAIS-IADI- The Joint Forum
• FATF- Interpol
• ASEAN- Chang Mai - Apec –SEACEN
• MLAT’s-Swaps-MOU’s-COSRA-FSF “colleges”
What do they have in common? Westphelian, colloquial groupings without
authority
The New Financial Stability Board offers
guidance on cross-border insolvency
• The Financial Stability Board (FSB) has been
established to address vulnerabilities and to develop and
implement strong regulatory, supervisory and other
policies in the interest of financial stability.
• FSB consists of a Chairperson, a Steering Committee,
the Plenary with member countries, SSBs and
international financial institutions, and a Secretariat.
• A full-time Secretary General and an enlarged
Secretariat based in Basel support the FSB.
• Plenary members include the current FSF members
(G20), Spain and the European Commission
FSB Principles for Cross-Border Crisis
Management
1.
In it’s April 2009, the Financial Stability Forum (FSF)
issued a report addressing: “Principles for Crossborder Cooperation on Crisis Management” It states
that “In financial crisis management, national
authorities will, as far as possible” :
Maintain incentives for financial institutions to behave
prudently .. The Bank-Support Measures Implemented in US, Europe
as well as Asia‐Pacific do not provide incentives to behave prudently
2.
3.
Promote private sector solutions and intervene only to
preserve financial stability
Maintain a level playing field internationally in the spirit
of the Basel Accord the capital requirements
produced two market responses: risk weights designed
for evasion and avoidance -the “shadow” banking
sector, including institutions which turned out to be toobig-to-fail .
Cooperation for Cross-Border Crisis
Management
3. Develop common support tools to manage cross-border
crisis
4. Meet annually (??), coordinated by home authorities
5. Home authorities to keep all countries informed of
arrangements
6. Share minimum information- at this stage it does not
appear that European countries share information
7. Ensure firms can supply required information
8. Encourage firms to maintain contingency plans for
wind-down
9. Ensure firms have robust funding plans
10. Seeks to remove practical barriers to efficient
internationally coordinated resolutions
During crisis, national authorities commit to:
11. Find internationally coordinated solutions- what are
they?
12. Share national assessments of systemic implications,
using agreed framework
13. Share information as early as possible
14. If fully coordinated solution is not possible, discuss as
promptly as possible possible national solutions
15. Share plans for public communications for clarity and
coordination”
•
•
The FSB’s broad set of principles is just that broad principles” that
a) do not have concrete solution b) a clear road map to to
implementation.
What is left? MOUs between Home and Host Regulators ..Is it
effective?
Without a Global roadmap, oversight and
implementation is is left to Home and Host Regulators
1.
Can regulation be effective through a “Westphalian”
voluntary cooperative “memorandum of understanding”?
2.
Unique issues in emerging markets- what is not
systemic in a mature market can be highly systemic in
an emerging market- e.g., capital flows reversals,
sudden stops.
3.
What was thought to be non-systemic can rapidly
evolve to become highly systemic- “subprime is a
small part of a small part..” .
4.
The present memorandums of understanding do not
have sufficient legal standing or powers of mediation in
the event of disagreements between home and host
regulators. Frequently the case. witness Lehman
5.
Without Global Bankruptcy Rules or Court, difficult to
resolve failures of "large complex financial institutions"
10
(“LCFIs”) on cross-border basis.
Presenting for Andrew Sheng: The real issues are
common processes for resolution --who determines who pulls
the plug?
(b) If info is shared with college of supervisors, the smallest/least
affected can pull plug to protect domestic interests and damage all
the other efforts, or leaks of info will result in collapse of
negotiations. Therefore the prospects for sharing of information
are dim
(c) No common laws - each regulator must comply with local law and
protect local interests. E.g., American Security was ring fenced
during BCCI by the US
(d) No dispute resolution between different regulators on different
views
(e) No international court to resolve how to allocate priority in
payment.
Therefore, if domestic laws prevail and domestic protection prevails,
international bankruptcy of Large Complex Financial Institutions
(LCFI) will be fragmented & uncoordinated and go to lowest
common denominator, leading to large losses.
They are all Too Interconnected TO FAIL, not Too Big to Fail .
Hence, the question is at what price of National Treatment (NTA)
would it be worthwhile to rescue or to allow to fail?
(a) No
Conclusion – the present voluntary
cooperative efforts are not effective
• The Westphalian principles governing international
financial oversight (sovereignty of states; the
fundamental right of political self determination; equality
between states; and consultation but non-intervention of
one state in the internal affairs of another state) are not
adequate to address the global financial system
• The intl’ financial authorities need to make progress with
a binding post-Westphalian global financial order.
• The prospects for such an accord are dim.
• The World Bank’s Global Bank Insolvency initiative did
not go anywhere .
info.worldbank.org/etools/library/latestversion.asp?83870
• So what’s left- improvisation in resolutions…
In the absence of resolution processes a variety of ad-hoc Bank-Support
Measures Implemented in US, Europe as well as Asia‐Pacific
Guarantees
for banks’
existing
and/or newly
issued
obligations
Potential
direct capital
support
Removal of
and
guarantees for
bad assets
Direct
liquidity
support
Blanket
deposit
guarantees
Forbearance
Asia
Australia Korea
New Zealand
Hong Kong
India Japan
Singapore
South Korea
Japan (?)
South Korea
South
Korea
Australia
Hong Kong
Malaysia
New Zealand,
Singapore
Taiwan
India
North
America
U.S., Canada
U.S.
U.S.
U.S.
U.S. - deposit
insurance
raised
U.S. – revisions
to mark to market
Europe
Austria
Denmark
Finland France
- Dexia S.A
Germany
- NORD/LB.
Greece
Ireland
Italy
The
Netherlands
Portugal
Spain
Sweden.
UK
UK Germany
Germany UK
Switzerland
UK
UK
What is the solution?
• Shouldn’t wait for dramatic changes at the global level
• The development of vigorous regional financial and monetary
institutions is an essential objective
• Better promise and prospects by investing in the domestic and
regional building blocks, to complement and lead to an eventual
global financial stability order
Global
Domestic Infrastructure
Regional
Domestic Infrastructure
Global
3 examples of domestic steps
•
•
•
Domestic Prudential Regulation : Ring-fence affiliates of foreign banks in
subsidiaries subject to local prudential regulatory measures
– Guillermo Ortiz is a wise man. Concerned since early 2000 re domestic
affiliates foreign banks, and explored "ring fencing".
– Ring fencing with the affiliate treated with the full local prudential norms,
including some additional, such as
• prudential limits on the ratio of foreign liabilities/foreign assets (to
prevent either flight or inflow for arbitrage) is the best solution.
• Period.
Financial institutions insolvency. The use of bankruptcy in the resolution
of financial institutions distress. Prospects of illiquidity and potential
insolvency are becoming more likely around the world. This makes the
effectiveness of bankruptcy regimes an important concern for
policymakers.
Strengthen domestic institutions. Singh, Raju; Kpodar, Kangni; Ghura,
Dhaneshwar IMF Working Paper No. 09/113: Financial Deepening in the
CFA Franc Zone: The Role of Institutions. The results indicate that the gap
in financial development between the CFA franc zone countries and the rest
of SSA can be explained by differences in institutional quality (e.g.,
availability of credit information, and strength and enforcement of property
rights), variables that policy makers can influence.
Source: http://www.imf.org/external/pubs/cat/longres.cfm?sk=22974.0
International steps:
• International steps: The burden is left on
home and host regulators to establish a
sound foundation.
• Forge better regional exchange of
information, harmonization of regulations
and standards, develop capacity,
institutional capacity , organization
• A possible example is the Committee of
European Banking Supervisors
– Exchange of information is limited, but
– The Community Directives are excellent tools
Committee of European Banking Supervisors
http://www.c-ebs.org/
• The Committee of European Banking Supervisors
(CEBS) is composed of high level representatives from
the banking supervisory authorities and central banks of
the European Union. Their role is to:
– CEBS gives advice to the European Commission on banking
policy issues and promotes cooperation and convergence
of supervisory practice across the European Union. The
Committee will also foster and review common implementation
and consistent application of Community legislation
– Advise the Commission, either at the Commission's request,
within a time limit which the Commission may lay down
according to the urgency of the matter, or on the Committee's
own initiative, in particular as regards the preparation of draft
implementing measures in the field of banking activities.
– Contribute to the consistent implementation of Community
Directives and to the convergence of Member States'
supervisory practices throughout the Community
– Enhance supervisory co-operation, including the exchange of
information.
• No parallel in East Asian …. SEACEN focused more on exchange
of views, training
Marek Belka, Director of the IMF`s European Department,
commented in an editorial in the FT lamenting the risks to
Europe`s 52-year quest for a single financial market
“
While its rationale remains compelling, this aspiration is under threat as the crisis has
pushed national authorities to reassert control over their financial systems. Whether
this setback is temporary depends critically on the outcome of the debate on
Europe`s cross-border financial stability arrangements. (.) A related debate is on the
future of the "single passport."(.). The existing set-up, in which cross-border
operations are covered solely by the financial stability arrangements of the home
country, is unsustainable. (.) A more general challenge is that of imposing discipline
on those banks deemed "too big to fail". In such cases, the threat of bankruptcy is not
credible: the private and social costs are simply too prohibitive.” "Increased host
country control over foreign branches, as some advocate, is not a comprehensive
solution to these complex challenges. (.) What is needed is a dedicated EU level
resolution framework that can credibly discipline Europe`s large cross-border banks
while offering depositors protection equivalent to national deposit guarantee
schemes. (.) Europe`s 50-100 largest banks, and smaller banks whose cross-border
activities raise concerns, should migrate to this scheme on reasonable conditions. In
return, they should benefit from an unrestricted single passport. (.) The single
passport has so far shown only glimpses of its potential. Realizing this potential
requires that the proposed EU-level supervisory authorities establish trust between
home and host countries. (.) In parallel, the EU should embark on an accelerated
program to create a dedicated resolution framework for its cross-border banks. The
potential gains are large. Settling for less-effective solutions risks entrenching the
dynamic towards refragmentation of financial markets. Much depends on the choices
that the European Council will make.
A banking framework to rescue the single market Jun 04 2009, By Marek Belka and
Wim Fonteyne, Financial Times