Indonesian Financial Architecture: Designing an Appropriate Market for the Financial Sector
Synopsis
The Global Financial Crisis (GFC) has demonstrated the failure of both the regulatory framework and the operation of financial markets. While the opportunity for more effective regulation clearly exists (especially in the USA), there are intrinsic limitations on what prudential regulation can achieve. Thus the response to the GFC should be on two fronts. Concurrent with efforts to strengthen regulation, the structure of the financial sector should be made more robust and resilient.
For the past quarter -century, the logic of deregulation has resulted in light prudential rules focused on market imperfections. But financial markets need to be designed to meet specific characteristics. Financia l sectors require regulation, in the same way that other aspects of the economy work best if their operation is embedded in carefully-designed rules, rather than relying just on “the magic of the market”.
Indonesia, with its financial sector dominated by banks and with the process of conglomeration still at an early stage, has the opportunity to design a simpler but stronger approach, not available in mature financial systems where conglomeration is, to the regret of many, too entrenched to change. The advantage of a simple system is that it would be robust and easier to supervise.
The suggestion made here is that banks should specialise in domestic deposits and loans, and payments services: no more universal banks. The “core” financial sector would offer simple products backed by strong intrusive prudential regulation and government protection for
depositors/investors. Outside this core sector, there would be the “buyer beware” institutions, with risks prominently disclosed.
crisis coordination. KSSK should evolve over time to do this job, in the process becoming the OJK.
Introduction: the Global Financial Crisis Reveals Weaknesses
The Global Financial Crisis is bringing about significant changes in the international financial landscape. Market-making investment banks have essentially disappeared. Banks which relied heavily on wholesale funding have a limited future. Complex universal banks have been shown to be unmanageable. At the same time the crisis has delivered a warning to all those responsible for financial stability (central banks, finance ministries and regulators). It is now painfully clear that deficiencies in the financial sector can generate dramatic shocks and that these shocks can be transmitted quickly and profoundly to other countries, even countries which are in good shape.
(a) Lessons
First, was the failure of financial markets. The core economic paradigm – efficient markets – was hopelessly at variance with the real world. This failure manifested itself in two different ways: in the way market
participants behaved; and in the regulatory framework in which they operated.
The efficient markets theory perceived a benignly beneficial world. Current prices incorporate all available information, thus providing the appropriate signals for resource allocation. Prices are anchored by fundamentals. Arbitrage will swiftly eliminate price anomalies. Speculation would be stabilising. Risk has a well-defined probability distribution (measured as short-term price volatility) and so could be effectively managed.
Diversification would not only spread risk (as merchants in former times spread their cargoes among different ships), but would also reduce it through bundling uncorrelated assets.
In practice things worked differently. Animal spirits were more important than some text-book notion of efficient markets. Endogenous risk proved to be more important than conventional exogenous risk. Endogenous risk is reflected in the sharp movements of financial prices, not driven by any
dynamic of the market itself. All the market players had the same mindset
(„while the music is playing, you have to dance‟). They assumed that they could sell their assets without affecting the price, but when the downturn arrived, they all found themselves selling into „crowded markets‟ because their similar risk systems had the same triggers for sale. At the same time collateral, funding covenants and hedging insurance requirements forced asset-owners to sell, into markets where there were no buyers. As prices fell, more forced sellers entered the market. The market reacted with price
movements which, as one participant ruefully observed, would be expected only once in the lifetime of the universe -- and they occurred on successive days. The risk model is comprehensively broken1.
These problems were exacerbated by the interconnectedness of markets and institutions. There was so much layering, securitisation and multiple stages in transactions, with the complexity ensuring that when things went wrong counterparty risk suddenly became paramount. The underlying collateral could not be identified. Uncertainty was greatly heightened, so risk margins blew out and previously-liquid markets dried up. The market pressured banks to add to their capital, just at the moment when this was hardest to do (and least logical: reserves and capital are there to be used in a downturn), and when the banks‟ attempts to strengthen their balance sheets would cause maximum damage to the real economy.
This is failure of markets in one of their primary functions: in price
discovery. This failure (specifically, in producing a set of prices which was far below the longer-term underlying prices dictated by fundamentals) set in train a dynamic which had serious allocation effects as well. In
Schumpeter‟s view, business downturns are beneficial because „creative
destruction‟ clears out the weaklings among economic enterprises. But this downturn has not been very discriminating: it also weeded out good firms which relied on markets for ongoing funding, or those balance sheets which
1This interview with Myron Scholes highlights the problem neatly: „
Some economists believe that mathematical models like yours lulled banks into a false sense of security, and I am wondering if you have revised your ideas as a consequence.
contained assets whose market price fell sharply. It is hard to argue that the investment process worked well when it was driven by risk-ignorant
euphoria in the upswing, and the downswing saw official interest rate settings (the base for cost of capital) close to zero. In the previous Glass-Steagall world, banks served as the „guardians on the gateway‟ for
investment. They were able to keep their balance sheets in reasonable shape through the downswing because they provisioned rather than marked-to-market, and because their core funding (from ordinary household deposits) did not dry up precipitately. But they were replaced by „shadow banking‟ intermediaries with an „originate and distribute‟ business model, who didn‟t care much whether the investment they funded was good, and who were unable to go on funding longer-term illiquid real assets during the
downswing.
The disturbing question that this raises is just how much benefit we got in terms of resource allocation and productivity in return for the substantial resources taken by the bloated financial sector of recent years (Friedman, 2009).
Second, the failure of the regulatory framework. The efficient markets view had a profound effect on the supervisory framework as well. Despite a long history of business cycles and serial financial crises, the deregulation era of the past quarter-century embodied a strong presumption that
regulation should be minimal. This is hardly surprising: efficient markets have no need for constraining rules or intrusive supervision. It suited market participants (even those who understood that their bonuses depended on
significant market anomalies) to adopt the „efficient markets‟ model as a self-serving mantra. They acted as a powerful lobby group (not only in the US, but in Basel where the international banking rules were formulated) in inhibiting the regulators from putting in place adequate supervision with the necessary political backing.
asymmetric information and externalities from failed promises of financial institutions). The deregulated financial sector would evolve in the direction of capital markets, in which all financial instruments would be traded in liquid markets. All that was needed was a level playing field in regulation: consolidation and similar risk treatment for all institutions.
This view fostered “light touch” (some say “soft touch”) prudential
supervision confined to individual banks. This is most clearly and comprehensively seen in the case of the USA, where regulators were fragmented and weak. But there was wide-ranging failure, even in the UK, which had put in place comprehensive „best practice‟ arrangements. Action at the international level was similarly inadequate. Basel II took almost ten years of intensive discussion to put in place, but the risk pillar, relying on credit rating agencies, is fundamentally flawed and the market discipline pillar has shown itself to be grossly pro-cyclical.
Crisis management was seen as largely a matter for central banks (liquidity facilities and lender-of-last-resort), calling for prompt corrective action (so that the bank shareholders took the hit), and requiring deposit guarantees (largely self-funding). But if the crisis is systemic, this self-sufficient low-cost view of crisis resolution is naively simplistic. When the financial
system is at risk, unpalatable political choices have to be made, to rescue the very people who are to blame for the problems. Moral hazard concerns have to be put to one side. Deposit guarantees are invariably widened in coverage. Risks are shifted from private individuals to the public purse. Pressure has to be brought on parties to facilitate necessary outcomes. Substantial
(sometimes huge) funding is required from general budget revenue: i.e. from taxpayers who were innocent bystanders. Sorting this out is not a job for the technocrats of central banks, supervisors and deposit agencies: the political, coordination and strategic issues are central. The ministry of finance has to take a key role, not just in providing the funding, but in acting as the
political interface2.
2
In the US, where the regulatory system is disjoined, cooperation has been achieved by the close working relationship between the Treasury Secretary and the central bank Chairman. But the damage done by disjoined and inadequately-resourced regulators (monolines, insurance, investment banks) is clear. As the crisis unfolded, it was clear that there were no well-developed plans or conceptual framework in place and “suck it and
What are the implications for Indonesia?
The Indonesian financial sector is coming through the GFC in pretty good shape but there are important policy implications3. Both here and overseas, part of the post-crisis response will be in the form of different and stronger regulation. While not all regulators failed as comprehensively as those in the US, there is room for enhancement in most countries, Indonesia included. But many of the weaknesses of regulation are intrinsic and ubiquitous. Regulators everywhere will always be “bloodhounds chasing greyhounds”, inevitably behind the pace of financial innovation. The political constraints on them are always likely to be formidably inhibiting, as are the pressures of vested interests. The in-built delays in recognition and action make
forbearance the norm: prompt corrective action an ideal rather than a reality. Regulators may be congenitally cautious people anyway. Thus, for Indonesia and elsewhere, regulatory reform will not be enough.
Part of the answer must be in modifying financial sector market design (the financial architecture), to make it more resilient. The GFC has delivered a powerful indictment of the efficient markets view. The financial sector should no longer be exempt from the regulatory norms that we see, say, on the roads and in construction sites: in these areas short-term “efficiency” has to be weighed against the need for systems to be safe and robust. We don‟t let drivers decide what risks they are going to take on public roads, nor airlines decide how much training their pilots need.
Thus this paper looks at how the GFC might influence the Indonesian reform agenda in two areas. First, the financial structure (Indonesia‟s Financial Sector Architecture or ASKI): second, the regulatory framework.
(a) The Structure of the Financial Sector
The mind-set of the existing architecture (BankIndonesia, 2009) is that the Indonesian financial system should look like a smaller version of the financial sector in mature countries. The centre-piece to this approach to market design is universal banks. While the universal or conglomerate nature of these banks is still at an early stage, the links between banks, on
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the one hand, and mutual funds, investment-type banking activity (underwriting and finance facilitation), brokers, finance companies and insurance companies, on the other hand, already presents a vulnerability to the Indonesian banking system. If one of the lessons of the current crisis is that financial institutions should be simple, very transparent and robust, then Indonesia may be on the wrong track in allowing its banks to have strong conglomerate links with other types of financial institutions (Haldane, 2009).
At the same time, it is not realistic, in the newly-revealed dangerous
international financial world, to see Indonesian banks as having the potential to become international banks like HSBC or the Singapore banks, as is envisaged in the current ASKI. Iceland demonstrates, in extreme form, the dangers of relatively small countries having relatively large international banks. As Mervyn King noted, „banks live internationally but die at home‟ (to the cost of the domestic taxpayers). The regulators should be ready to rein in the international ambitions of these banks4.
An alternative starting point is to recognize that Indonesia‟s conditions and requirements are different from the mature economies. Indonesia is more likely to be subject to sudden foreign capital reversals, large falls in the exchange rate, inflation and asset price shocks, big terms-of-trade shifts and large NPL experiences, as well as micro problems such as financial sector fraud, mis-selling and gross mismanagement. There is more opportunity (and likelihood) for sharp swings in opinion and confidence. Markets are not deep and liquid (foreign investors are flighty rather than “sticky”), there is no well-established history of what a normal price is and how it behaves over the course of the cycle, market “price discovery” is imperfect, company information is unreliable and the legal system is questionable. Prudential
4 Indover is another reminder.
The case against allowing Indonesian banks to have ambitions to become international
banks is made in Buiter‟s “inconsistent quartet” - (1) a small open economy; (2) a large internationally exposed banking sector; (3) a national currency that is not a major international reserve currency; and (4) limited fiscal capacity BUITER, W. (2009) Lessons from the global financial crisis for regulators and supervisors. Paper presented at the 25th anniversary Workshop " The Global Financial Crisis: Lessons and Outlook" of the
Advanced Studies Program of the IFW, Kiel on May 8/9..
supervision will inevitably be weaker, with more problems of enforcement. Consolidated supervision, for example, is hard to do properly.
At the same time the demands on the financial sector – what is expected to achieve - are greater and more taxing than in developed countries. The Indonesian government is expected to protect depositors who are
inexperienced with sophisticated institutions and instruments: that is a legitimate expectation. The financial sector must fund a faster pace of
development, in more uncertain conditions (where the availability of foreign funding is likely to be seriously curtailed), and provide funding to the full range of investments, including high-risk/high profit ventures (providing not only working capital but longer-term illiquid funding of specialized assets). SMEs have to be supported; SoEs have to be funded; SoBs have to be maintained [reference to Malang paper], if only for historical and
sentimental reasons, with their ambivalent objectives; and even rural banks and tiny micro financing have to be promoted. The full range of risk funding has to be available: in a high-risk environment, there should be provision for identifying and funding the high-return projects amongst the dross.
These key characteristics provide the parameters for financial sector market design. They suggest that there should be a sharp dichotomy between a safe core sector where small-scale risk-averse savers can safely leave their money, on the one hand, and the “buyer beware” non-core sector which funds risky ventures, on the other. The safe core should be structurally simple and transparent, so that it is easy to supervise effectively, and the
taxpayers‟ funds (in the form of depositors‟ guarantees and lender of last resort) are not put at too great a risk. For simplicity, it should be structured as basic banks (i.e. Glass-Steagall-style banks, separated from other types of financial institutions, and in particular separated from the market-maker and investment-banks institutions). This core should contain the basic payments system, so that this would be maintained during a crisis. It should also have enough capacity to provide a minimal level of credit (including trade credit) during a crisis: the process of financial intermediation must be maintained even when the financial sector is under pressure and the funding of risky investments ceases. Within this core sector, deposits would be guaranteed up to a generous level, protecting household deposits.
This core could also include the government bond sector, with small denomination bonds available and a liquid market maintained by the
government, without a fixed commitment to a specific rate), to give small investors an opportunity for longer-term safe investment (safe in the sense that the nominal value will be returned on maturity).
Another category of financial arrangement is needed to supply the funding for relatively safe but illiquid long-term assets (notably, infrastructure). Such assets cannot guarantee liquidity for investors. There are, however, various institutional arrangements that might be devised to meet the need for long term funding from those investors who can afford to sit out the cyclical downturns in asset values, while at the same time offering them some assurance that their investment will be safe and will provide fair long-term returns. Insurance and superannuation funds might invest a significant proportion of their funds in this way. Development banks (private or government) are another possibility. Real Estate Investment Trusts and infrastructure bonds are other possibilities5. The key element here is that the investors understand that they are funding long-term illiquid assets: their money is not in a liquid instrument and they have to be patient, particularly for the return of their capital. Such instruments have downside for investors (how can they be sure that the fall in value of their underlying asset is merely cyclical, especially as such instruments should not be obliged to mark-to-market?). The development of such a longer-term funding market is, nevertheless, very important as this kind of funding should not be done from the balance sheet of banks, whose depositors legitimately demand immediate liquidity.
Outside this safe core, the full range of financial services could be
encouraged (although still with regulations and a degree of supervision). Innovation would be encouraged6. Careful thought needs to go into the rule-design but the presumption is that regulation should be „light‟. The
important distinction is that investors in this non-core sector should
understand (and be constantly reminded) that their money is at risk. „Very
5
Provision of government guarantees on underlying income flows and/or the capital value could well be part of this arrangement. In many cases the government ends up bearing the risk in a crisis, so it is better to acknowledge this at the start (and have the benefit of the government guarantee reflected in the funding costs).
6An analogy might be useful here. In yachting, there are one-design classes and
unrestricted innovation classes (with broader design parameters). Both have their followers, and both serve their users with a product that suits. Innovation passes
explicit disclosure to consenting adults‟ is the key concept here. There
should be the equivalent of a cigarette health warning (“your money is not safe here”) on every institution and every agreement/contract. If these products are sold in banks, it should be absolutely clear that the bank does not in any way guarantee the product.
For complex products, there might be a case for requiring new products to get a „tick‟ from the regulators. No one, however, should rely on this.
Regulators will always be reluctant to admit that they don‟t fully understand (nor, on past experience, did the promotors of the products) and will not
want to seem too „fuddy-duddy‟ and conservative. Regulators might be guided by a general admonition that finance is not the same as gambling. Products which are analogous to betting should be left in the casino. In practice, to distinguish these from legitimate risk-management products, there might be a requirement that the purchaser of the risk insurance should
have an „insurable interest‟ (i.e. something at stake that needs to be insured).
Is it fair that different products are subject to different degrees of prudential supervision? A deposit offered by a bank is not the same as a deposit-like product offered by an insurance company or a mutual fund, and there needs to be strong and specific disclosure to make this clear to potential investors. Why should we be reluctant to impose a degree of product-specialisation on financial institutions, when we make similar requirements that prevent, say, surgeons from offering financial advice to the public?
There are difficult practical issues not addressed here (how to ensure that the border between the safe core and the non-core institutions is clearly and securely maintained: how to shift from the present embryonic universal banks to basic banks). But the starting point in addressing these issues is to recognize that the current approach to market design has the wrong centre-piece: universal banks7.
7Others are exploring the same territory. “The modern financial services industry is a
casino attached to a utility. The utility is the payments system, which allows individuals and non-financial companies to manage their daily affairs. The utility allows them to borrow and lend for their routine activities and allocates finance in line with the
2. The Regulatory Framework
If the market design suggested here were to be followed, then the logic for the regulatory framework would be conceptually simple. Bank Indonesia would have operational responsibility for the core sector. The residual non-core sector could be under a single regulator („LK‟). In this non-core sector, there will be different promises for different institutions (the protection and promises for insurance will be different from that relating to pensions), but the clear starting point in all cases is that there is no promise for immediate return of a specific nominal sum. The key message, to be repeated ad nauseam, is „read the fine print of the contract‟. Market conduct regulation (what some people might call capital markets regulation i.e. Bapepam) would be in a separate grouping. Consumer protection for the non-core institutions might well be here also.
Overarching this, there is a need for a high-level coordinator with three functions: architecture and regulatory-consistency coordination for the whole financial sector; overall financial sector stability; and crisis resolution. This body has to have undoubted authority: it should be made up of the most senior representatives of the supervisors (BI governor8, head of Bapepam, head of LK). Most important, it should be chaired by the Minister of Finance or the Coordinating Minister, providing the political interface to make the non-technical social/distributional judgments that will be necessary in a crisis9.
One of the lessons of the past year is the necessity for close coordination between the various financial authorities (e.g. with Northern Rock in the UK). In Indonesia, while the existing embryonic coordination framework (the Financial Sector Stability Forum (FSSK) and the Financial Sector Stability Committee (KSSK)10) were still not fully operationalised, the work to develop Crisis Management Protocols seems to have helped in the
resolution of Bank Century. There is MUCH more to be done here, but a
8
Given the importance of the banking system, the Senior Deputy Governor, as effective head of supervision, should be included also.
9
There is no conflict there with central bank independence. The BI governor is here in his capacity as financial sector guardian. Monetary policy is made, as usual, by the BI Board. Note how Bernanke and Geithner cooperate closely in addressing the financial crisis without this compromising Fed monetary policy independence.
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good start has been made. It will be necessary for all the institutions
involved to fully accept the coordinating role of KSSK, and to put in place monitoring systems which ensure that this coordinating role can be
implemented quickly if needed.
What seems clear from the Northern Rock experience (and perhaps also illustrated in the Bank Century case) is that problems can remain with the supervisor for too long, without being subjected to a wider scrutiny. Active information-gathering and high-level monitoring of potentially-troubled institutions by the overarching committee might force less forbearance, quicker escalation, and prompter corrective action.
At the same time, if the front-line supervisor has to explain to the
overarching committee just how a new innovative financial product works and what effect it will have on system stability, they might be less ready to simply tick the product and hope for the best.
The overarching systemic regulator should be able to recognize growing dangerous trends, products which are not risky in themselves but which become risky through the fallacy of composition. If such a systemic
regulator had existed in the USA, it should have identified the emergence of
the „shadow banking system‟, the growing problems in the housing sector, and the false promise of securitization, with seemed to offer liquidity for a body of underlying assets which were fundamentally illiquid.
In countries where there has been a separation of the central bank from the prudential supervision function, the task of systemic stability has fallen
inflation, even though this was inevitably going to lead to trouble11. If they saw some systemic problems (concentration of insurance risk in institutions which would be unable to meet systemic problems, such as AIG or the monolines), they had no instrument of response. They need some micro-level instruments – such as the ability to enforce a counter-cyclical capital ratio, cyclically-varying liquidity requirements and loan-to-valuation ratios.
In many countries this problem was exacerbated by the “best practice” doctrine among prudential regulators that their remit was purely micro-economic and mainly focused on the health of individual banks. The result was pro-cyclical prudential policy: as asset prices rose, this raised capital of both banks and borrowers, raised collateral values and lowered loan-to-valuation ratios, all encouraging more borrowing. But it was not in the remit of these stand-alone regulators to add up the individual risks in institutions and respond to the systemic threat.
As well, these stand-alone regulators were new institutions, relatively weak in withstanding the pressures of the vested interests in the financial sector. It was hard to disallow “innovations” and various methods used to circumvent prudential regulations. They were not strong enough to insist on the
accounting and taxation changes which were needed to make provisioning for non-performing loans cyclically neutral, at a minimum.
The basic message here – applicable to Indonesia -- is that the systemic regulator needs instruments to achieve its objectives. What should system stability focus on? The instruments should address the difficulties that made the system pro-cyclical and on the endogenous dynamic and
interconnectedness that turned idiosyncratic problems into system-wide problems. Thee difficulties included:
Ratings downgrades
Collateral and covenant issues
Mark-to-market accounting requirements
Valuations and loan-to-valuation ratios
Market demands that banks increase capital in the downturn.
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Indonesia should not be rushing into the complexities of securitisation and complex hedging products. But as it moves in this direction, it could require
there to be a “lead securitiser” with obligations to keep track of the underlying collateral assets and to retain a substantial amount of the securitization on its own balance sheet. It seems sensible to tightly limit over-the-counter tailor-made hedging products and require these to be in a standard form that can be traded through a central counterparty exchange.
Finally, a vexed issue. Should bank supervision be split out from BI into a separate APRA or FSA-like institution? Elsewhere this institutional
arrangement – the separation of the central bank from the prudential authorities – was the result of a number of factors. Some factors were political (to cut the power of the central bank). Others were simply
misguided. The argument that central banks‟ monetary settings would be
distorted by their prudential obligations seems absurd as we watch central banks around the world dramatically lower interest rates in response to the crisis. The single valid argument was that conglomeration was already so complete that all financial institutions had to be supervised by the one body in order to get an accurate measure of consolidated risk. But if, as suggested here, there is a clear separation between the “core” institutions and the “non -core” institutions, there is no issue of consolidation across different types of financial institutions. The main potential systemic risks would be in the core sector, subject to the intensive supervision of BI. This separation – with the core and non-core areas supervised by different institutions -- would
emphasise the key distinction: some parts of the financial sector are protected and other parts are „buyer beware‟.
The more recent recognition across the world of the importance of macro-prudential concerns argues strongly for leaving macro-prudential supervision with
the central bank. The central bank‟s expertise in macro-economics links logically with this, and its macro focus makes it much more likely to recognize endogenous risk and problems of interconnectedness.
needs the detailed information on individual banks that comes only with the supervisory function.
In the end, the issue is mainly a pragmatic one. In the United Kingdom the FSA and the BoE are not going to be put back together, whatever the merits of doing so might be, because it would be too hard. Conversely, in
Indonesia, it would be a serious misallocation of priorities to undertake the traumatic job of splitting BI. There are enough challenges in building a resilient financial sector without taking on any unnecessary ones.
A much higher priority is to ensure that the coordinating framework should be more fully articulated than at present. The KSSK needs the resources to analyse and monitor high-level systemic risk. There should be on-going permanent exchange of information between the agencies responsible for supervision (BI for banks, Bapepam for non-bank financial intermediaries) and the MoF. The logic of this suggests that the KSSK should, over time, become the Financial Services Authority (OJK) (fulfilling the Parliamentary requirement to do this by 2010).
Conclusion
I want to finish by supporting my argument for a core financial sector
populated by simple institutions, with both a quote and a misquote. First, the quote, from Bagehot: “The business of banking ought to be simple,” he
wrote. “If it is hard it is wrong. The only securities which a banker, using money that he may be asked at short notice to repay, ought to touch, are
those which are easily saleable and easily intelligible.” Now the misquote (only slightly), from Warren Buffet: we should only allow banks that are so simple that they could be run by a fool, because one day they will be12.
Stephen Grenville May 2009
12The original quote is: “we should only invest in companies that could be run by a fool,
References
BANKINDONESIA (2009) Indonesian Financial Architecture.
BUITER, W. (2009) Lessons from the global financial crisis for regulators and supervisors. Paper presented at the 25th anniversa ry Workshop " The Global Financial Crisis: Lessons and Outlook" of the
Advanced Studies Program of the IFW, Kiel on May 8/9.
FRIEDMAN, B. (2009) The Failure of the Economy & the Economists. New York Review of Books, 56.
GRENVILLE, S. (2004) What Sort of Financial Sector Should Indonesia Have? Bulletin of Indonesian Economic Studies.
HALDANE, A. (2009) Rethinking the financial network. Speech delivered at the Financial Student Association, Amsterdam.
