Mish's Global Economic Trend Analysis

You Ain't Seen Nothin' Yet; Another Trillion (or Two) Euro LTRO Coming Next Month
Portugal's Debt Will Be Restructured; 3-Year Government Bond Yield Tops 25%; CDS at Record High, Implies 72% Chance of Default
Brussels Hit by First Coordinated Strike in Nearly Two Decades; Spain to Miss Deficit Reduction Goals; France Halved 2012 Growth Forecast to 0.5 Percent; Ten Things to Expect in Europe
Greek Bond Math (Assuming the Deal Goes Through) ; Merkel Faces Backlash Over Deal; Political Zugzwang
Why the Tobin Tax is a Bad Idea; Sweden's Experience With the Tax; Details of Sarkozy's Proposed Tax; Sarkozy Wants to "Provoke a Shock"

You Ain't Seen Nothin' Yet; Another Trillion (or Two) Euro LTRO Coming Next Month

Posted: 30 Jan 2012 03:57 PM PST

Last month, European banks tapped the ECB for €489bn in a long-term refinance operation dubbed LTRO. On February 29, another round of LTRO is coming up and expect banks to go for the gusto. Banks like cheap money to speculate and that is exactly what they will do.

The Financial Times reports Banks set to double crisis loans from ECB

European banks are preparing to tap the European Central Bank's emergency funding scheme for up to twice as much as the ECB supplied in its debut €489bn auction last month, providing further evidence of the sector's liquidity squeeze.

Several of the eurozone's biggest banks have told the Financial Times that they could well double or triple their request for funds in the ECB's three-year money auction on February 29.

"Banks are not going to be as shy second time round," said the head of one eurozone bank at last week's World Economic Forum in Davos. "We should have done more first time."

Three bank chief executives, all of whom asked to remain anonymous, said they were planning to increase their participation twofold or threefold.

Unlimited Money for Three Years at One Percent

The ECB is offering unlimited money to banks for three years, at one percent. Banks are salivating because the first round went well.

The money is supposed to go for bank lending but it won't. Why should banks lend? They have a guaranteed profit by speculating in Spanish or Italian bonds, assuming of course Spain and Italy do not need bailouts coupled with a writedown on government debt.

However, that's quite a risk, and in my opinion Spain will need such a writedown. If so, Germany will be on the hook once again.

For a discussion about how futile this is, please see Premature Dollar Obituaries and Mainstream Economists' Monetary Insanity; Keynes-Inspired Great Depression; Lessons Not Learned

Money Supply Will Soar, Lending Won't

Don't expect the next LTRO to make it into the real economy. It won't. Rather the LTRO will fuel more bank speculation and more leverage in government bonds. Money supply will soar, lending won't and this rates to be good for gold.

In the meantime, please sing along with Bachman Turner Overdrive (and the ECB).

Link if video does not play: Bachman Turner Overdrive - You Ain't Seen Nothing Yet .

Mike "Mish" Shedlock
http://globaleconomicanalysis.blogspot.com
Click Here To Scroll Thru My Recent Post List

Portugal's Debt Will Be Restructured; 3-Year Government Bond Yield Tops 25%; CDS at Record High, Implies 72% Chance of Default

Posted: 30 Jan 2012 01:01 PM PST

Inquiring minds are watching Portuguese government bonds soar into the stratosphere, with record-high bond yields across the entire yield curve.

In all the images below, the numbers are accurate but the charts reflect yesterday. I have mentioned this to Bloomberg a number of times to no avail.

Portugal 2-year Government Bonds

Portugal 3-year Government Bonds

Portugal 5-year Government Bonds

Portugal 10-year Government Bonds

Notice the opens and the lows in the charts above.

Bloomberg reports "The Frankfurt-based ECB bought Portuguese government bonds today, according to three people with knowledge of the transactions, who declined to be identified because the deals are confidential. A spokesman for the ECB declined to comment when contacted by phone."

My take is the ECB foolishly attempted to manipulate Portugal's bond market at the open, then was blown out of the water in the process. The ECB recklessly bought Greek bond and learned nothing from it.

Portugal's Debt Will Be Restructured

Adrian Miller, a fixed-income strategist at GMP Securities LLC, talks about the outlook for the European debt crisis. He speaks on Bloomberg Television's "InBusiness with Margaret Brennan."

Link if video does not play: Portugal's Debt Will Be Restructured

CDS at Record High, 72% Chance of Default

Bloomberg reports Credit default swaps implied a 72 percent chance Portugal will default within five years.

Mike "Mish" Shedlock
http://globaleconomicanalysis.blogspot.com
Click Here To Scroll Thru My Recent Post List

Brussels Hit by First Coordinated Strike in Nearly Two Decades; Spain to Miss Deficit Reduction Goals; France Halved 2012 Growth Forecast to 0.5 Percent; Ten Things to Expect in Europe

Posted: 30 Jan 2012 11:23 AM PST

The Financial Times reports Brussels hit by strike as EU leaders meet.

A general strike brought widespread disruption to Belgium on Monday, as European Union leaders arrived for a summit in Brussels with a focus on boosting employment across the region. Trains, shipping, air travel and public transport were all hit by the trade union action, called in response to reforms enacted hastily by the new government of Elio Di Rupo.

It is the first time in nearly two decades that unions from all sectors of the economy have co-ordinated a strike. As well as schools, the postal service and other branches of the public sector, some private enterprises were affected as unions flexed their muscles.

The strikes in the EU's capital are a reflection of union discontent across the continent, worried that austerity measures will jeopardise the recovery. A Europe-wide "day of action", bringing together unions from across the continent, is planned for February 29.

Voter distress and open dissent is no where close to peaking.

Spain to Miss Deficit Reduction Goals

Courtesy of Google Translate, please consider Spain deficit to Hit 6.8% in 2012 and 6.3% in 2013, according to IMF

6.8% is far from the 4.4% that the European Commission has imposed
IMF predicts two years of recession, with declines of 1.7 and 0.3% in 2012 and 2013

Spain will not meet deficit reduction goals of the European Commission in 2012 and 2013. Specifically, the IMF projects that the deficit will be within 6.8% of GDP in 2012 and 6.3% in 2013, when Brussels requires, at most, a deficit of 4.4% this year and 3% next.

The agency, predicts a recession of two years for the Spanish economy, ending the last three months of this year with a contraction of 2.1%. This indicates the organization in the latest update to its Global Growth Outlook, published today in Washington.

France Halved 2012 Growth Forecast to 0.5 Percent

Yahoo! Finance reports EU leaders struggle to reconcile austerity, growth

European leaders struggled to reconcile austerity with growth on Monday at a summit that approved a permanent rescue fund for the euro zone and was trying to put finishing touches to a German-driven pact for stricter budget discipline.

Officially, the half-day 27-nation summit was meant to focus on ways to revive growth and create jobs at a time when governments across Europe are having to cut public spending and raise taxes to tackle mountains of debt.

But disputes over the limits of austerity, and Greece's unfinished debt restructuring negotiations with private bondholders, hampered efforts to send a more optimistic message that Europe is getting on top of its debt crisis.

Spain's economy contracted in the last quarter of 2011 for the first time in two years and looks set to slip into a long recession.

France halved its 2012 growth forecast to a mere 0.5 percent in another potentially ominous sign for President Nicolas Sarkozy's troubled bid for re-election in May. Prime Minister Francois Fillon said the cut would not entail further budget saving measures.

Conservative Spanish Prime Minister Mariano Rajoy, attending his first EU summit, said Madrid was clearly not going to meet its target of 2.3 percent growth this year. That has raised big doubts about whether it can cut its budget deficit from around 8 percent of economic output in 2011 to 4.4 percent by the end of this year as promised.

European Commission President Jose Manuel Barroso hinted Brussels may ease Spain's near-unattainable 2012 deficit target after it updates EU growth forecasts on February 23.

Bickering Continues

It is quite rare, if not unprecedented, for the head of the European Parliament to criticize what Merkel and Sarkozy hailed as "progress", yet that is exactly what happened.

European Parliament President Martin Schulz told the leaders the new fiscal treaty was unnecessary and unbalanced, because it failed to combine budget rigor with necessary investment in public works to create jobs.

"To write into law a Germanic view of how one should run an economy and that essentially makes Keynesianism illegal is not something we would do," a British official said.

Merkel has said she will not discuss the issue of the ESM/EFSF's ceiling until the next EU summit in March. Meanwhile, financial markets will continue to worry that there may not be sufficient rescue funds available to help the likes of Italy and Spain if they run into renewed debt funding problems.

The sticking point is German public opinion which is tired of bailing out the euro zone's financially less prudent.

Ten Things to Expect in Europe

More bickering
More strikes
More emergency meetings
More trade wars, especially between Spain and France
Tobin Tax will backfire in France
Missed budget estimates across the board
Missed growth estimates across the board
Deep and lengthy recession will affect entire global economy
Recession will include France and Germany contrary to popular belief
End of Sarkozy's political career

Mike "Mish" Shedlock
http://globaleconomicanalysis.blogspot.com
Click Here To Scroll Thru My Recent Post List

Greek Bond Math (Assuming the Deal Goes Through) ; Merkel Faces Backlash Over Deal; Political Zugzwang

Posted: 30 Jan 2012 09:26 AM PST

Rumors that a deal will be reached "soon" have gone on for weeks. Indeed announcements of an expected agreement today have already hit new snags.

For the sake of argument, let's assume a deal does go through, then crunch the latest numbers to see what the situation looks like from the point of view of Greece (and the lenders as well) before and after the deal.

The place to start is the current projection for the size of the next needed bailout.

Please consider Greece Needs EU145 Billion in Second Aid Package

Greece requires 145 billion euros ($192 billion) as part of a second aid package for the cash- strapped country, 15 billion euros more than was agreed in October 2011, Der Spiegel reported, citing an unidentified official from the so-called troika of European Commission, European Central Bank and International Monetary Fund.

Greece needs more money because the country's economic situation is worsening, the German magazine cited the official as saying. The gap can't be filled by contributions from private creditors alone, it said.

Bigger Bailout Needed

So, presuming a deal goes through, Greece is going to take on another 145 billion euros of debt, up from 130 billion last week.

Let's now turn our attention to the latest deal rumors.

Private Investors Near Deal on Greek Debt

Bloomberg reports Private Investors Near Deal on Greek Debt

Let's assume for the moment that "near" really means "near" and not five weeks from now when undoubtedly Greek conditions will have deteriorated further, requiring of course a bigger bailout. Here are the pertinent ideas from the article to consider.

Investors holding euro206 billion in Greek bonds would exchange them for new bonds worth 60 percent less
The new bonds' face value is half of the existing bonds. They would have a longer maturity and pay an average interest rate of slightly less than 4 percent.
The deal would reduce Greece's annual interest expense on the bonds from about euro10 billion to about euro4 billion.
When the bonds mature, instead of paying bondholders euro206 billion, Greece will have to pay only euro103 billion.
The deal would reduce Greece's debt load by at least euro120 billion
Greece faces a euro14.5 billion bond repayment on March 20, which it cannot afford without additional help

Three Essential Facts

The new deal will reduce existing debt by 120 billion
The new bailout funds will take the debt load up by 145 billion
The net result is an increase in Greek debt of 25 billion

This is supposed to work? The reduced interest rate to 3.6% will of course help Greece. But what is the interest rate on new debt?

Regardless, given Greece's deteriorating financial condition, exactly how long will it take before the EU and IMF realize once again that Greece cannot possibly pay back the new 145 billion?

In whose best interest is this deal? I fail to see how it benefits anyone.

Merkel Faces Backlash Over Deal

The Financial Times reports Merkel faces backlash over EU pact

Angela Merkel, the German chancellor, is facing growing political pressure at home to demand stricter fiscal discipline from her eurozone partners at an extraordinary European Union summit in Brussels on Monday.

She also faces a potential revolt by conservative members of the German parliament over any call for more taxpayers' money to bail out the ailing Greek economy.

"If the Greeks don't put the reform programme into effect, there can be no more help," said Horst Seehofer, leader of the Bavaria-based Christian Social Union, in an interview with Spiegel magazine.

Philipp Rösler, economy minister and leader of the liberal Free Democratic party, junior partners in Ms Merkel's government, threw his weight behind the call for stricter control over the Greek programme. "If the Greeks cannot do it themselves, there must be stronger leadership and supervision from outside, for example from the EU," he said.

On the eve of the EU summit, which is supposed to finalise a formal treaty on budget discipline, Ms Merkel's supporters in the German Bundestag are also calling for those rules to be made tougher.

"As it stands, the draft treaty does not go far enough," a senior official of the Christian Democratic Union in the parliament said on Sunday. He said the centre-right group wanted sanctions to be imposed more automatically for excess debt and deficits, and a tighter timetable for all 17 eurozone members to introduce a binding commitment to balanced budgets in their national constitutions.

Political Zugzwang

Zugzwang is a term in chess. A player has to make a move but every move weakens the position. Pass is not an option.

Merkel is in such a no-win position. Everything she does will put her under attack by someone. Doing nothing, is an option in politics but not chess. However, doing nothing also exposes Merkel to attack.

Attacks Fly

Check out this nonsense from former European Commission chief Jacques Delors who says Resistance to eurozone bailout boost 'scandalous'

Former European Commission chief Jacques Delors on Sunday blasted the reluctance of eurozone countries like Germany to boost the size of the Greek bailout and create a system of eurobonds to facilitate lending.

"It is scandalous. You cannot be a member of the euro cooperation and at the same time say no to elementary demands for solidarity with other members within the framework of existing agreements," the prominent European federalist said in an interview with Dagens Nyheter, Sweden's daily of reference.

"We have to save Greece together. What has been done so far is too little, too late," he added.

Delors, who was commission chief between 1985-95 and a key player in creating the framework for the euro's 1999 launch, said it was "out of the question" to push Greece out of the eurozone and insisted the solution was for "Greece to privatise more of its economy."

"The euro countries also must together introduce common eurobonds, ... not to finance the current debt but to create greater efficiency and connectivity in the financial and monetary system," the 86-year-old Frenchman said.

The creation of such a "eurobond," which would pool the debt of the entire monetary bloc in a bid to reassure markets and facilitate lending, has long been a contentious issue among top policymakers, with the European Commission and France being in favour of such an instrument but Germany strictly opposed for now.

"It is a mistake of German Chancellor Angela Merkel to refuse to go along with such bonds," Delors said.

Delors' Self-Serving Pomp

What's scandalous if for political hacks like Delors to assume the Eurozone is worth saving, then tell everyone else how to go about it without taking into consideration any restraints others may have.

I suggest the euro is not worth saving. For the sake of argument, however, let's assume the eurozone is worth saving, and start with a look at Merkel's options.

Merkel's Predicament

If Merkel proposed Eurobonds, her coalition would collapse and she would be ousted. Moreover, the German supreme court would certainly demand a referendum which would fail. The irony then, is if Merkel did what Delores asked, the eurozone would fly apart right here right now.
If Merkel proposed significantly more bailout money, her coalition would also collapse and once again the proposal would be at risk of a challenge from the German supreme court.
If Merkel does nothing, she takes heat from political dimwits like Delors and an entire gamut of other nanny-zone supporters. She also takes heat from her coalition.
If Merkel steps up the pressure on Greece she hears it from her political opposition, from Delors, and from a whole host of parties representing a myriad of political views.

That my friends is political zugzwang and that is precisely why she called for Greece to Cede Sovereignty to Eurozone "Budget Commissioner".

Her proposal elevated the ire of Greeks as well as the likes of political hacks like Delors. Yet, that option is the one that made the most sense. It was her least-worst option, that also bought her and the eurozone the most time.

It is the only option that has any chance of working.

By making those demands, she has a chance of keeping her coalition together. Indeed, if her demand are met or if Greece exits the eurozone in response, she might even be viewed as a hero!

Simply put, she is doing everything she can to keep the eurozone together. For doing the best she possibly can under the circumstances, she gets nothing but grief.

I think the best thing for the Eurozone would be for Germany to exit. The irony is that would likely happen if Merkel embarked down the path demanded by eurofools like Jacques Delors.

Mike "Mish" Shedlock
http://globaleconomicanalysis.blogspot.com
Click Here To Scroll Thru My Recent Post List

Why the Tobin Tax is a Bad Idea; Sweden's Experience With the Tax; Details of Sarkozy's Proposed Tax; Sarkozy Wants to "Provoke a Shock"

Posted: 30 Jan 2012 12:57 AM PST

There is massive theoretical as well as actual real life evidence that financial transaction taxes will backfire, but that never stops politicians hell-bent on plowing ahead with "it's different this time" horrendous ideas.

Via Google Translate from Les Echos, please consider Sarkozy's stock exchange tax as of August 1

The 0.1% tax on financial transactions will apply from 1 August. In addition to equities, derivatives and high frequency trading are also covered.

Drawn up in haste, the tax on financial transactions is still the subject of intense discussions with the banking sector. A meeting has yet to take place on Monday to clarify the exact scope of covered products.

Many things are acquired, however: the tax will be paid by the people who buy a financial product, not by those who sell it. As reported Sunday, by the head of state, it will amount to 0.1% regardless of the nature of the product purchased (equities, derivatives) and will apply from 1 August, leaving a few months to Germany to eventually join the movement.

Three types of products involved

The law affects three different types of products: stocks, derivatives (including the famous' credit default swaps ", CDS) and high frequency trading-that is to say execution in microseconds of financial transactions by the only way of computing. This activity represents a huge chunk of transactions (about one-third). But most of the computers being located in London, the government will struggle to reach this activity. Still: he wants to show that tackles the most speculative operations.

Sarkozy Wants to "Provoke a Shock"

Bloomberg provides more details in Sarkozy Says France to Tax Financial Transactions From August

France plans to unilaterally impose a 0.1 percent tax on financial transactions starting in August, President Nicolas Sarkozy said, brushing aside opposition from the nation's banks.

"What we want to do is provoke a shock, to set an example," Sarkozy said late yesterday on French television from Paris. "There's no reason why deregulated finance, which brought us to the current situation, can't participate in the restoration of our accounts."

"CDSs, which are speculative instruments against sovereign debt, will be taxed and online speculative purchases will be taxed," he said.

Ernst & Young, an accounting company, has said in a report that while an EU transaction tax itself may raise as much as 37 billion euros, its net effect could be negative by between 2 billion euros and 116 billion euros by decreasing economic activity and reducing revenue from other taxes.

Socialist candidate Francois Hollande leads in the French presidential election polls. He has the support of 31 percent of voters in the first round, 6 points more than Sarkozy, and his second-round lead has risen to 20 points at 60 percent, according to a CSA poll published last week. Hollande, too, has pledged to impose a tax of financial transactions, if he's elected.

Sweden's Experience with the Tobin Tax

The Peterson Institute for International Economics presents Sweden's Experience with the Tobin Tax

The Swedish Social Democratic government enacted a transaction tax on stocks, bonds, options, and some other securities in 1983. The tax, named after the economist James Tobin, was abolished by the new nonsocialist government in 1991.

The tax rates varied from 0.1 percent on ordinary stock trade to 0.15 percent on treasuries and 1 percent on options.

The Tobin tax in Sweden was a devastating failure that nobody would like to revive.

1. The expectation had been that the tax revenues would be 1.5 billion Swedish krona (SEK), but they stopped at SEK80 million.

2. Most Swedish trade in securities disappeared and went abroad, mainly to Oslo and London, and never returned. Soon after, the previously tiny Oslo stock exchange overtook the Stockholm stock exchange, and it is still the larger of the two stock exchanges.

There is no way that the current non-socialist Swedish government would accept a Tobin tax, as they know the security trade would leave the European Union.

In general, the Nordic and Baltic governments are amazed by what they view as a combination of arrogance, incompetence, madness, and slowness in Brussels, Paris, Berlin, and London. These sentiments are rather stronger in this region than in Washington. These countries are run by people who know how to handle crises, but they are effectively excluded from EU decision making.

Sarkozy's Pledge of Going it Alone

That discussion is all one should need to read to determine France would be acting very foolishly to implement such a tax.

Sarkozy thinks Germany would "soon" follow. As we have seen in the Eurozone, political decisions seldom if ever happen soon. Moreover, why would Germany act instead of watching France for a while?

Ironically, as soon as Germany saw the results in France (which likely would be soon), there is little chance they would implement such a foolish thing ever.

But what if all the European countries agreed to do it? We already know the UK opted out, but for the sake of argument, let's assume even the UK agreed.

The first that that would happen would be a mad scramble to execute transactions in the US, Switzerland, or Hong Kong. Nonetheless, let's assume the long arm of the law still managed to tax those transactions. What then?

Expect Increased Volatility, Decreased Trading Volumes, Lower Share Prices

The Adam Smith Institute offers a Comparative Study of the Potential Effects of a UK Tobin Tax. Here are some snips.

Sweden's Experience with the Tobin tax

The rise and fall of the only case of a "pure" Tobin tax began in Sweden, when a 0.5% tax on the purchase of all equity securities (and stock options) was introduced on 1st January 1984. The tax applied to both domestic and foreign customers, and was levied directly on registered Swedish brokerage services.

Until 1987, inter-broker trades were considered intermediate (and hence exempt). 'Round trip' taxation effectively made the net taxation 1%, or 100 basis points. This was doubled in 1986, and later to include fixed income. Furthermore, a tax on stock options of 2% was introduced (1% relating to the premium, 1% upon exercise).

Understandably, investors devalued their assets to reflect the present value of future tax payments on the marginal share. The 2.2% average decrease in share prices on the announcement day added to the -5.35% index return over the 30 day period including the announcement. A further 1% share price reduction was seen in 1988 in reaction to the rate doubling.

Decreased Trading Volumes

Decreasing trading volumes led to secondary effects such as a reduction in capital gains taxes, almost entirely netting the (exceptionally low) tax revenue being generated.

Despite the tax being higher on equities, it was the fixed income market that suffered most. Despite the 'low' 0.003% tax levied on 5-year bonds, trading volumes dropped by 85% alone in the first week after implementation. Futures trading fell by 98%, and the options market was virtually non-existent.

Liquidity

All market participants would be subject to the tax; a Tobin tax is unable to discriminate between de-stabilising trades and those which provide liquidity, information and tradefinancing. With short-term trading providing invaluable liquidity to the market, an incapability to segregate individual trader motivations will therefore lead to a reduction in both liquidity and welfare-enhancing trade, in addition to increasing market susceptibility to individual shocks.

Robin Hood

Whilst the Tobin tax's roots lie in economic theory, its current appeal is evidently political. The Robin Hood imagery drives the tax's public support. It is its 'stealing from the rich to give to the poor' appeal that attracts many of its advocates, not the belief in its realistic economic capability. Understandably, some people are more-easily influenced by a well publicised, celebrity-endorsed Robin Hood Tax marketing campaign than by econometrical analysis or time series data.

Capital Flight

The experience of Sweden is one of capital flight. Odds are it would happen again.

The ATM Effect

The Adam Smith article contained an interesting analogy regarding ATM usage. When fees were zero, people would think nothing of doing an ATM transaction for $20. With fees of $2, you have to be pretty desperate to do an ATM transaction for $20. Instead, you would do one for your maximum limit. Some only use an ATM in an emergency and keep a pile of cash in their house instead.

In a falling market short-term traders provide liquidity (so do those shorting). Yet, Robin Hood proponents will drive those short-term traders away.

"In thinner markets, each trade would have a larger impact on price; resulting in less fluidity within the currency inventories of broker-dealers, the 'liquidity providers' of the market."

I fail to see how reduced liquidity and increased volatility will not be the result.

Four Reasons Tobin Tax is a Bad Idea

It would encourage capital flight (I know hedge funds that have contingency plans to move their entire operations to the Caribbean if such a tax is passed)
It would drive out short-term traders who provide much needed liquidity
Reduced liquidity would lead to increased volatility at the worst times
Pension plans and mutual funds would bear much of the brunt of the tax. Rest assured market makers will find a way to pass their costs on.

The results in Sweden are conclusive. A 'low' 0.003% tax levied on 5-year bonds caused trading volumes dropped by 85% in the first week after implementation.

Five-year US treasuries now yield .74%. Three-month treasuries yield .05%. Corporate bond yields are pathetic. How much of that do you want to take away?

Excluding bonds is not the answer. Liquidity and capital flight arguments suggests this idea should never get off the ground for any transactions.

By the way, buyers of CDS are often hedgers. Tax them heavily and there will be less interest in the underlying bonds. I would also point out that the speculators Sarkozy want to drive out of the market just happen to provide liquidity. Short sellers eventually cover, and provide fuel for rallies. Day traders will step into falling markets when others won't.

Sarkozy will "provoke a shock" alright, and it may crash the markets when he does.

Mike "Mish" Shedlock
http://globaleconomicanalysis.blogspot.com
Click Here To Scroll Thru My Recent Post List

Home Refinance Calculator

Monday, January 30, 2012

Mish's Global Economic Trend Analysis

Mish's Global Economic Trend Analysis

No comments:

Post a Comment