Obama, Geithner speak loudly; Volcker previews the stick

[Cross-posted to DailyKos]

While much of the past day’s news has been focused on the Obama Administration’s populist announcement that executive pay, at the companies that accept TARP funding, will be capped at $500,000; some less noticed news with a longer term implication was being made by Paul Volcker who testified in front of the Senate Banking Committee. Volcker is the chair of President Obama’s Economic Recovery Advisory Board and the topic of the hearing was “Modernizing the U.S. Financial Regulatory System.” The New York Times reported on his testimony here:

While Volcker had been invited to testify in his role as chairman of Obama’s Economic Recovery Advisory Board, he is also the chairman of the Trustees of the Group of Thirty an influential body composed of leading financiers, academics and central bank officials from around the world. (Larry Summers, Timothy Geithner and Paul Krugman have all been listed as members in the past year)

While Volcker’s testimony was quite general it referenced the recent report of the Group of Thirty titled “Financial Reform: A Framework for Financial Stability.” This report does give us a window into the thinking of the people who are likely to create the framework for modernizing the national financial regulatory system after the dust begins to settle on the current crisis.

A couple of quotes from Volcker’s testimony will help give a general sense of where the thinking of this elite group is headed:

the Report calls for “particularly close regulation and supervision, meeting high and common international standards” for institutions deemed systemically critical. It also explicitly calls for restrictions on “proprietary activities that present particularly high risks and serious conflicts of interest” deemed inconsistent with the primary responsibilities of those institutions.

On the practical level this is likely to mean an attempt to broaden and expand the Federal Reserve’s powers to supervise and regulate the whole range of non-banks that are involved in the flow of credit around the world.

Do we think this should be done by the Federal Reserve?

If not who else would have the power and talent to keep up with the innovation and scope of the world’s financiers?

If it is to be the Federal Reserve, how do we inject the possibility of public input and oversight when the Federal Reserve is controlled by economic “libertarians” as it was during the Greenspan years?

And then:

the Report implicitly assumes that, while regulated banking institutions will be dominant providers of financial services, a variety of capital market institutions will remain active. Organized markets and private pools of capital will be engaging in trading, transformation of credit instruments, and developing derivatives and hedging strategies, and other innovative activities, potentially adding to market efficiency and flexibility.

These institutions do not directly serve the general public and individually are less likely to be of systemic significance. Nonetheless, experience strongly points to the need for greater transparency. Specifically beyond some minimum size, registration of hedge and equity funds, should be required, and if substantial use of borrowed funds takes place, an appropriate regulator should be able to require periodic reporting and appropriate disclosure. Furthermore, in those exceptional cases when size, leverage, or other characteristics pose potential systemic concerns, the regulator should be able to establish appropriate standards for capital, liquidity and risk management.

This seems like pretty weak tea. Remember that Timothy Geithner spent much of his time during the past five years as President of the New York Federal Reserve speaking about the need for capital and liquidity standards and the need for banks to put better risk management systems in place. But it all proved futile because of the lack of specific rules and regulations and an enforcement system with the capacity of actually holding the players accountable.

I’m all for the Obama administration putting salary caps on the TARP recipients, but for the longer term the harder job will be creating a regulatory structure that controls or eliminates the current perverse economic incentives for companies to engage in risky behavior in the pursuit of short term profits. This behavior by everyone from the brokers to the lenders, to the investment bankers to the hedge fund managers will not be eliminated by a public scolding, but rather by creating a regulatory system which rewards long term thinking and punishes short term risk taking. In a system in which risk-taking and "innovation" have been highly rewarded, this will be no small task.

Finally Volcker’s testimony points to the critical role that the issue of financial regulation will play in the April meeting of the G-20 leaders in London. President Obama is expected to attend that meeting and it will be likely that some of the framework for the future regulation of the financial services industry that is to be coordinated internationally will begin to be fleshed out. We need grass roots people watching the details during the lead up to this meeting.

Who will watch the watchers?

Bankbane

Larry Summers and his friends

Democratic Congressman Pete DeFazio commenting on Larry Summers, who President Obama picked as director of the White House National Economic Council.

“Harvard had it right”

Daniel Tarullo - Beginning to Change the Federal Reserve

[Cross-posted to DailyKos]

On Wednesday, President Obama’s first nomination to the Board of Governors of the Federal Reserve, Daniel Tarullo, was sworn in, after being confirmed by the Senate by a vote of 96 to 1 on Tuesday. (The old curmudgeon Senator Bunning strikes again.)

The members of the Board of Governors serve 14 year terms, and because there are currently two additional vacancies on the seven-member Board and Chairman Bernanke’s four year term as Chairman is up on January 31, 2010, President Obama has the potential to effect a lasting change in the direction of the Federal Reserve within a year. While Chairman Bernanke’s full term lasts until 2020, a chairman who is not re-nominated to that post usually resigns from the Board of Governors fairly quickly.

Who is Daniel Tarullo:

Perhaps most obviously, he was one of Obama’s economic advisers during the campaign, and a man with a history of working for Democrats. He has been a Professor of Law at Georgetown University since 1999, but prior to that he served in the Clinton administration as Assistant to the President for International Economic Policy. The Wall Street Journal says, “He is expected to play a key role in rebuilding international regulation of financial markets and banks.”

Prior to his service in the Clinton Administration he served in the Antitrust Division of the Department of Justice and as Chief Counsel for Employment Policy for Senator Kennedy.

Professor Tarullo is also the author of the recent book, Banking on Basel: The Future of International Financial Regulation, in which he expresses considerable skepticism about the utility of a regulatory system that focuses too narrowly on capital regulation and monitoring bank risk management systems as epitomized by the International Basel I and Basel II Accords.

It is important to note the prevalence of giddy optimism about the ability of risk management systems during much of the last decade among the academics and regulators who focused on the financial regulalatory system. The greatly discredited Credit Default Swaps were commonly seen as a powerful tool for managing risk.

One Timothy Geithner, then the president of the Federal Reserve Bank of New York, said this in remarks to the Global Association of Risk Professionals as recently as February of 2006.

“We have seen dramatic changes in the U.S. and global financial system over the past 25 years, and we are now in the midst of another wave of innovation in finance. The changes now underway are most dramatic in the rapid growth in instruments for risk transfer and risk management, the increased role played by nonbank financial institutions in capital markets around the world, and the much greater integration of national financial systems.

These developments provide substantial benefits to the financial system. Financial institutions are able to measure and manage risk much more effectively. Risks are spread more widely, across a more diverse group of financial intermediaries, within and across countries.”

For people with this mindset banks with the proper levels of capital and the proper risk management systems barely needed to be regulated at all.

But the intellectual credibility of this philosophy has come crashing down to the point where even that most fervent deregulator, Alan Greenspan, had to make at least a partial mea culpa in his appearance last fall in front of Henry Waxman’s House Oversight Committee.

"I have found a flaw," said Greenspan, referring to his economic philosophy. . . . "I made a mistake in presuming that the self-interests of organisations, specifically banks and others, were such that they were best capable of protecting their own shareholders and their equity in the firms."

Greenspan’s deregulatory philosophy held sway at the Board of Governors during his years as chairman. Regarding the regulation of subprime lending, much of which the Federal Reserve could have eliminating by using its powers to prohibit unfair and deceptive practices, he insisting on wielding a light regulatory hand. The Wall Street Journal interviewed Clinton appointee to the Board, Edward Gramlich, shortly before his death and wrote about his interactions with Greenspan:

Edward Gramlich, who was Fed governor from 1997 to 2005, said he proposed to Mr. Greenspan in or around 2000, when predatory lending was a growing concern, that the Fed use its discretionary authority to send examiners into the offices of consumer-finance lenders that were units of Fed-regulated bank holding companies.

"I would have liked the Fed to be a leader" in cracking down on predatory lending, Mr. Gramlich, now a scholar at the Urban Institute, said in an interview this past week. Knowing it would be controversial with Mr. Greenspan, whose deregulatory philosophy is well known, Mr. Gramlich broached it to him personally rather than take it to the full board.

"He was opposed to it, so I didn't really pursue it," says Mr. Gramlich, a Democrat who was one of seven Fed governors.

As we begin to hear discussion of an expanded regulatory role for the Federal Reserve over the whole range of non-banks that affect the financial markets, it is important that we build in rules that protect consumers and the taxpayers and that we have a majority on the Board of Governors on our side. We can’t just have one lone voice in wilderness like Gramlich, we need at least four strong advocates for responsible regulation of consumer law and the safety and soundness of financial institutions.

Take a minute to write a note or make a call to the President to let him know that we in the grassroots care about the quality and ideology of his Federal Reserve appointments.

You can call the White House Hotline at 202-456-1111.

Or write a note on the White House contact page.

I’ve even provided a draft comment that you can steal or borrow from.

Dear Mr. President:

Thank you very much for appointing Daniel Tarullo to the Federal Reserve. Because there are two remaining Board of Governor vacancies at the Federal Reserve you have an immediate opportunity to bring on Governors who support bringing strong consumer protection and robust safety and soundness regulation back to our financial system. It is important that you begin to change the hands-off regulatory culture that now characterizes the Federal Reserve.

Geithner Chief of Staff was Goldman Sachs Lobbyist

[Cross posted to DailyKos]

The morning’s New York Times confirms that Treasury Secretary Geithner has picked Mark Patterson as his chief of staff, paradoxically within a story about Geithner’s announcement of new “rules to ‘combat lobbyist influence’ over the bailout program. . . .”

Who is Mark Patterson? He has a Democratic pedigree, having served as staff of Senator Moynihan and Senator Dasschle. But most recently, from 2003 until April of 2008, he served as a lobbyist for Goldman Sachs, serving as the “co-head of U.S. government relations” for at least part of that time.

So is making a high-profile announcement about “combating lobbyist influence” just one of those “head fakes,” to throw the activists off, or do we really need someone who was right in the belly of the beast to understand how to tame the beast?

I’ll reserve judgment on this new Treasury Secretary and his team until their fruits start becoming obvious, but I have to say that it doesn’t look good to me so far.

What did Mr. Patterson work on as a Goldman Sachs lobbyist?

According to Implu Corporation which tracks the activities of major corporation executives at least part of his portfolio was lobbying the banking committees on the following bills:

H.R. 3915, MORTGAGE REFORM AND ANTI-PREDATORY LENDING ACT OF 2007, ALL SECTIONS

H.R. 3609, EMERGENCY HOME OWNERSHIP AND MORTGAGE EQUITY PROTECTION ACT OF 2007, ALL SECTIONS

S. 2452, HOME OWNERSHIP PRESERVATION AND PROTECTION ACT OF 2007, ALL SECTIONS

H.R. 3221, FORECLOSURE PREVENTION ACT OF 2008, ALL SECTIONS; S. 2636, FORECLOSURE PREVENTION ACT OF 2008, ALL SECTIONS; MARKET CONDITIONS

S. 2636, FORECLOSURE PREVENTION ACT OF 2008, ALL SECTIONS

I’m just guessing here, but as a Goldman Sachs lobbyist I don’t imagine he was on the side of making sure that assignee liability stayed in the anti-predatory lending bill, or on the side of allowing bankruptcy judges to “cram down” mortgage principle on bad mortgages.

Geithner It Is!

[Cross-posted at DailyKos]

The Senate has confirmed Timothy Geithner as Treasury Secretary by a 60 to 34 vote. The Democrats joining the Republicans, who mostly opposed this nomination, were Feingold, Harkin and Byrd, also joined by Sanders.

I want to be clear that I support President Obama and I am mostly happy with what he has done since becoming President. But this team of Geithner, Summers and (reportedly) Sunstein, who will have a lot to say about how regulations that govern the the Financial Services industry get reformed, make me plenty nervous about a subject I care deeply about.

During the confirmation hearing the best questions for Geithner came from Senator Bunning of Kentucky, a man who I’ve never thought I had anything in common with. The following four questions and their no-content answers in particular bothered me.

Senator Bunning:

“What steps did you take, if any, to address the risks of the derivatives markets? I do not mean efforts to improve the functioning of the markets, such as the central clearinghouse, but the systemic risks of the products and markets more generally.”

“The New York Fed oversees the Fed’s Large Financial Institutions regulation. Therefore, as President of the New York Fed, one of your most important responsibilities is regulating and preventing the collapse of systemically important banks. And that has been your job since 2003, which means it was your job to watch those institutions during the time they acted most irresponsibly and made the decisions that eventually led to our current crisis. All one has to do is look at the near-total collapse of Citigroup to see that you failed at that job. Why did you fail at that job and why should that not disqualify you from overseeing the entire financial system?”

“What, if any, decisions on interventions by the Federal Reserve or the Treasury during the current crisis did you disagree with at the time? And were there any such decisions that you did not participate in?”

“During your time at the New York Fed, have you disagreed with any of the monetary policy or regulatory actions of Chairman Greenspan or Chairman Bernanke? If so, please explain.”

You can read 102 pages of Geithner’s mostly non-responsive answers to the Senators on the Finance Committee here. It won’t be comforting.

So why did Obama pick this crew. A smart man enamored of other smart men? Was he thinking “It takes one to know one?” Was he thinking, "Who better to fix this mess than someone who has been in the middle of it and now understands what went wrong?"

We can hope.

But the sinking thought I have looking at this gang is, “Here come the 'brightest and best' again, God help us.”

To save you the trouble of wading through the 102 pages of questions from the Senate Finance Committee with Geithner’s answers, I’ve excerpted his answers to the four questions above in order.

“The systemic risks of the derivatives markets were a major focus of my work while I served at the New York Fed – not only to make the infrastructure of those markets more mature and more robust, but also to make sure the institutions at the center of the derivatives markets were managing their risks more effectively. In addition to working directly with the firms that represented almost all of the volume in these markets, I engaged lead regulators from the U.S. and around the world – from the SEC, Switzerland, Germany, France, the United Kingdom, and Japan – to encourage these firms to have a better sense of the risks they were exposed to in credit derivatives as well as their risks from a broad range of other complex financial products. These efforts, I believe, helped make the system stronger.

Nonetheless, we will have to take a broad look at the framework that surrounds derivatives and incentives created for institutions that participate in these markets.”

“There were systematic failures of risk management and supervision across the financial system, and addressing these failures will require comprehensive changes to financial regulation here and around the world. As President of the New York Fed, I led a number of initiatives to strengthen the financial system ahead of this crisis. Those efforts were important and effective in addressing many of the weaknesses at the center of past financial crises, and they helped limit the damage caused by the present crisis. But those efforts were inadequate.”

“The decisions over this period often had to be made quickly, and on the basis of much less information than one would like to make public policy judgments of this magnitude. With time we will be able to look back and undertake a more meaningful assessment of these judgments, and doing this carefully and thoroughly will be a critical part of designing a system that will be more robust and less vulnerable to the type of situation in which we find ourselves.”

“As Vice Chairman of the Federal Open Market Committee, I helped shape and supported the monetary policy decisions by the FOMC under Chairmen Greenspan and Bernanke. I also helped shape regulatory policies over this period, although those policies are the responsibility of the Federal Reserve Board.”

We’ll soon find out. Is he a man who understands the problems through and through and just didn’t want to tip his hand in a confirmation hearing? Or is he a bloodless technician excited about having a complicated problem to work on, who can answer complicated questions without ever bothering to have his own beliefs?

To me it sound like "errors were made" all over again.

The Keatings Thrive

There once was a Governor named Alan,

Advised Keating before he's a felon,

"What's great with a thrift

Is the risk you can shift

To the people who buy what you're selling."

Doggerel Dan

Obama's team and financial regulation - who will watch the watchers?

The New York Times reports that the Obama Administration's plans for overhauling the financial regulatory system is starting to taking shape.

The plans include "stricter federal rules for hedge funds, credit rating agencies and mortgage brokers, and greater oversight of the complex financial instruments that contributed to the economic crisis."

All important issues, but one of the underlying issues that doesn't get much discussed is how to prevent the ongoing continual capture of regulatory bodies by the industries that they are supposed to regulate. Most community-based groups would say that making sure to give the public a practical way to monitor, and when needed, effectively intervene in the regulatory process is the best way to keep the regulators honest.

Every regulatory agency employee knows that if they make friends within the industry, and know their way around the Federal bureaucracy, they are prime candidates for a future job within the regulated industry that will pay them considerably more than they can earn doing government work. And particularly during industry-friendly Administrations, employees quickly learn that angering someone important in the regulated industry is a lot more risky for their career than it is to be a weak protector of consumers and small investors.

Strong prohibitions against regulators going to work within the industry until significant time has elapsed definitely helps limit that conflict, but it doesn't do much to prevent top political appointees from simply ignoring the law. For example, Bank of America has pretty much been bumping up against the current law which prevents banks from controlling more than 10% of domestic deposits since its purchase of LaSalle Bank. But an accommodating Federal Reserve has been amenable to loopholes.

The Federal Reserve order approving the Bank of America acquisition of Countrywide on June 5, 2008 is instructive. Very early in the order the Federal Reserve acknowledges that Bank of America is already above the 10% threshold:

"The Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994 ("Riegle-Neal Act"), Pub L/ 103-328 (1994), codified at 12 U.S.C. 1842(d), provides that the Board may not approve any application for the interstate acquisition of a bank if consummation of the acquisition would result in the applicant controlling more than 10 percent of the total amount of insured depository institutions in the United States."

Then later:

"Bank of America, with total consolidated assets of $1.7 trillion, is the largest depository organization in the United States measured by deposits, controlling deposits of approximately $711.7 billion, which represents approximately 10.04 percent of the total amount of deposits of insured depository institutions in the United States . . . .On consummation of the proposal, Bank of America would remain the largest depository organization in the United States, with total consolidated assets of approximately $1.9 trillion. Bank of America would control deposits of approximately $773.4 billion, representing approximately 10.91 percent of total amounts of deposits of insured depository institutions in the United States."

So how does the Federal Reserve justify approving the acquisition anyway?

"Countrywide Bank is chartered as a federal savings bank under the Home Owners Loan Act. 12 U. S. C. 1461 et. seq. Section 2(c)(2)(B) of the BHC Act exempts federally chartered savings associations and savings banks, as defined by section 2U) of the BHC Act, from the definition of "bank." As a result, Countrywide Bank is not a "bank" for purposes of the BHC Act and the nationwide deposit cap contained in the BHC Act. Therefore the provisions of the Riegle-Neal Act prohibiting the Board from approving an application to acquire a bank if consummation of the acquisition would result in the applicant exceeding the national deposit cap do not apply to the present notice to acquire Countywide Bank and the other nonblank [sic] subsidiaries of Countrywide."

Notice the neat lawyerly switch. The law prohibits the Fed from approving applications in which the acquiring bank will be above the deposit threshold; in this case the acquired depository institution doesn't meet the technical definition of a "bank," therefore that prohibition doesn't apply to this acquisition.

In more recent mergers Wells and Wachovia, Chase and Washington Mutual, the Federal Reserve has become even more lawless, simply using its emergency powers to avoid all public comment and Community Reinvestment Act review that the law requires during mergers.

With regulation one always has to ask, "Who will watch the watchers." For all of President Obama's reputation as a community organizer, so far it is very unclear that the Obama financial team has a clear plan for strengthening the hand of the grass roots, so that community-based non-profits and the public will have a strong role participating in the enforcement process to make sure that laws and regulations are actually enforced.

If they just leave it up to a "new and improved" Federal Reserve, we're in deep trouble.

Bankbane

In Regulation Play

Don't regulate you.

Don't regulate me.

Regulate that man

Behind that tree!

With apologies to an old Southern politician

Doggerel Dan

Look Over There

It seems like an odd story to pop up at a time like this.

But I specialize in the odd, and in searching out red herrings, and even red hair rings.

Front page of the Washington Post today and it doesn't bury the lede:

By Switching Their Charters, Banks Skirt Supervision

At least 30 banks since 2000 have escaped federal regulatory action by walking away from their federal regulators and moving under state supervision, taking advantage of a long-standing system that allows banks to choose between federal and state oversight, according to a Washington Post review of government records.

The moves, known as charter conversions, highlight the tremendous leverage that banks hold in their relationships with government supervisors.

The financial crisis has pushed regulatory reform high up the agenda of the Obama administration and congressional leaders. Timothy F. Geithner, the Treasury secretary nominee, sounded the theme at his confirmation hearing yesterday, calling for a "stronger, more resilient system."

Some regulatory experts say that eliminating the opportunity to switch regulators is critical to strengthening oversight. [my emphasis]

Well yeah!

But this has been going on pretty steadily for years now, so why does a rather minor part of the overall regulatory problem suddenly warrant such front page attention in times like these.

Reading the full story you'll learn that Commerce Bank/Harrisburg was ordered by the OCC to limit it's dealings with its officers and directors and so they switched to a state charter. Imagine that . . . officers and directors using their banks for personal profit!

Compared to say the complete lack of regulation of non-bank lenders, the hedge funds and the rating agencies, and the free-for-all of investment bank securitization of mortgage loans, charter shopping just has to be one of the most important causes of the financial system meltdown. You'll be especially convinced by the fact that 12 percent of all charter conversions were done to escape federal regulatory action. Twelve percent mind you, serious. . . . huge.

The tall money boys are facing an enormous public relations crisis. They screwed up and screwed up bad. They fought new regulation, they gutted Glass/Steagall and a pretty strong majority of the American public can draw the line pretty straight between bad regulation and the current financial crisis.

So this is how I would play it if I were them. First get your own set of "reformers" in the places that matter most (enter Geithner), then help reporters identify stories that will create a lot of noise, the stories should identify multiple causes for the crisis and should all be very serious because every one is really to blame. Then once the confusion has reached a peak, push through the new "reforms" that will sound reasonable in a sound bite sort of way, but will insure that the masters of the universe still have plenty of ways to make outrageous sums of money off of the earnings, savings and debts of working people.

That's how I'd do it, but that's just me.

Bankbane

Tiny Tim and the Ghost of Bubbles Past

In his Senate confirmation hearing today Timothy Geithner tipped his hat to the ideas we hold dear here. His written remarks said: 

"Well-designed financial regulations with strong enforcement are absolutely critical to protecting the integrity of our economy."

So what are we to make of his actual record?

As President of the New York Federal Reserve Bank during the worst of the toxic mortgage lending and investment bank securitization, Geithner showed no obvious interest in consumer protection and he seemed virtually clueless that what was happening in the mortgage market could have systemic effects on the economy.

At the March 23, 2007 Credit Markets symposium hosted by the Federal Reserve Bank of Richmond, just a couple of months before the implosion of two Bear Stearns' hedge funds, he made the following comments:  

The latest wave of credit market innovations has elicited some concerns about their implications for the stability of the financial system, concerns similar to those associated with earlier periods of rapid change in the financial markets. Will the most recent credit market innovations amplify credit cycles, contributing to "excessive" lending in times of relative stability, and then magnify the contraction of credit that follows? Will they introduce greater volatility in financial markets? Will they create greater risk of systemic financial crisis?

These concerns have been heightened in some quarters by the problems currently being experienced in the subprime mortgage sector. It will take some time before the full implications are understood and the full impact can be assessed. As of now, though, there few signs that the disruptions in this one sector of the credit markets will have a lasting impact on credit markets as a whole.

Indeed, economic theory and recent practical experience offer some reassurance against both these specific concerns and more general worries about the implications of credit market innovations for the performance of the financial system. . . .

But the bipartisan Wall Street consensus marches on. The questions, such as they are, will be about the irony of the head of the Treasury and his "innovative" treatment of his tax obligations.

We know we're in trouble when the best questions come from the blithering curmudgeon Senator Bunning. The Hill reports it this way:

"Mr Geithner has been involved in just about every flawed bailout action of the previous admininstration," Bunning said. "He was the front-line regulator in New York when all the innovations that recently have brought our markets to their knees became widespread.

"He went along with the flawed monetary policy decisions of Alan Greenspan and Ben Bernanke...and he stretched the law beyond recognition to bail out Bear Stearns," Bunning added.

Too bad that the President's advisers didn't have some of those thoughts before they nominated him.

Bankbane

Happy Inauguration Day!

Although it wasn't planned this way, I'm happy to be making my inaugural post on January 20, 2009. More than New Years Day, this day really does seem to be about new beginnings and possibilities.

I'm also struck with the enormity of the task that lies ahead. And that's just in creating a new system for regulating the financial services industry that really works. I'm reminded of the occasion on which President Roosevelt reportedly told the great labor leader A. Philip Randolph, "I agree with everything that you've said . . . . but I would ask one thing of you Mr. Randolph, and that is go out and make me do it." 

That's our task - to go out and make President Obama do what needs to be done to bring the financial services industry, which has the capacity to do so much good and and also to wreak so much havoc, under the control of "we the people."

President Obama's appointments in this area, Mr. Geithner, Mr. Summers and now reportedly, Mr. Sunstein may give us pause, but the only way to move towards a financial services regulatory framework that will put people first, is to keep on working and saying, "Yes we can!"

Bankbane