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Mortgage Advice News ArchiveThere is much in the press over the last few days in terms of what the Spanish Government will do with the Banks and their exposure to real estate. Whilst some positive measures, that should have been implemented many months if not years ago, are now happening some fundamentals to help ease the situation are not being covered at all.
The instruction of two independent valuers to value the assets held, can only be a positive that will ensure Spanish banks are transparently owning up to the size of the problem they have, and will encourage them to more realistically price their stock.
The insistence that they clear at least 5% of their stock held will also help in pushing prices to rock bottom which is always where you have to start a recovery. Where there appears to be no concentration is on the repossession process itself which is long winded, costly and rife with activities bordering on fraud as the whole process is run by a tight knit community of people in the know with complete lack of transparency. The process helps neither the borrower nor the Bank but does help line the pockets of the auctioneers, Bank Staff and those with court links.
Even after what ultimately will almost be a closed auction, where the best was creamed off before getting to court, the Bank does not immediately get possession. Having waited possibly up to three years to get to court the Bank may then wait many months for the court to pass ownership to them.
Often the Banks themselves are left in the dark about the points in the process and have little to no rights to manage the court action effectively. Prior to this the bank has no access to the property, cannot check the situation of repair of the property and worse still incurs taxes and costs even before they can in fact market it.
Spanish Bank owned property two independent valuers to value the assets held is a post from: Spanish Mortgages Experts International Mortgage Solutions
In the current environment some clients find themselves precluded from borrowing in Spain.
This can be in circumstances where satisfactory income evidence cannot be provided that meets the Banks stringent requirements; equity needs to be released for purposes not allowed by Spanish Banks or for commercial activity.
We have access to private funds for loans between € 25k to € 2m for any purpose
Interest rates 7.5%
Up to 10 years on interest only basis or repayment
For further information contact us today.
Private Lending Commercial and residential is a post from: Spanish Mortgages Experts International Mortgage Solutions
Reports out today have confirmed the situation on lending in Spain has deteriorated further.
Despite taking advantage of the European Central Banks cheap bonds issued over the last few months the Banks in Spain have chosen to buy sovereign debt with these funds rather than to lend to the residential and commercial sectors.
Data shows that mortgage lending in Feb 2012 was down 9.4% from the previous month and a whopping 47.1% down from the same month the previous year.
Interest rates were up year on year by 17.3% at an average granted rate of 4.54%.
These figures include lending to the resident and nonresident market and also lending given by Banks where their own stock is being bought. This suggest lending for independent properties is down even further and average rates being offered for the purchase of an independent property are even higher.
All Banks plan to contract their lending books this year in an effort to meet new balance sheet and provisioning requirements.
At IMS our completions over the same periods for non residents show that completions for us are up 28% year on year with January and Februarys 2012 figures being very similar with a slight increase in February over January rather than the national average of a 9.4% decline.
Average granted rates were 4%.
Whilst the Banks remain cautious this is evidence that with the right research, experience and presentation of packaged applications the trend can still be bucked.
Spanish Mortgage Lending news 2012 is a post from: Spanish Mortgages Experts International Mortgage Solutions
The Bank of Spain has announced its intention to continue to look at the possibilities of their new mortgage index the IRS, which replaces and combines the Caja and the Banks IRPH mortgage index, as the preferred index for all loans in Spain.
The view of the Bank of Spain is that the IRS will provide a more stable index than the more volatile Euribor.
It is now being considered whether to abolish the Euribor for mortgage purposes and move to one index for all new loans. It is expected a decision will be made by the end of the year.
Spanish rate index. is a post from: Spanish Mortgages Experts International Mortgage Solutions
Many buyers are asking this question. For many years it has been normal practice when buying in Spain for a buyer to be requested to pay over a sum of money to remove the property from marketing activity until such a time as a purchase contract can be signed. These sums range between 3k to 6k.
Back when this general practice started it was true that there were more buyers than property and to not put down a reservation fee would certainly risk the property being sold to another individual as everyone stampeded to buying their dream home or investment in Spain.
Despite quite clear changes to the market the practice of taking a reservation fee has not changed and it is still always requested by agents determined to get some financial commitment to a property before a client can get back on a plane and in case they suffer from buyer’s remorse.
Is it still necessary?
Probably not. Whilst there are still good properties around that have more than one buyer interested, given the amount of property for sale the chances of another buyer coming along and buying before all the necessary legal checks etc are done and a contract can be signed are remote.
The reservation is normally not refundable and even where instances of clauses are included, like subject to mortgage approval, papers all in place etc the piece of paper itself is worthless in a court of law in Spain. This means you have little to no protection if the seller or agent refuses to pay back the reservation monies.
Where the reservation fee is taken as refundable this is normally refundable for a very short period and a period of time that is unlikely to allow for full legal checks to be done and or a mortgage approval to be arranged and valuation where required undertaken. This means in reality if you pass over a reservation it is most likely it will not be refundable if you need to back out.
Most good agents would not of course keep your money and there are plenty of examples of people getting back reservation fees because for whatever reason they have decide to back out but why take the risk.
The only benefit is the reservation fee technically removes the property from the market. The reality however is very different. It is most likely more than one agent is marketing the property and should another buyer be found before you can get to purchase contract the seller has no obligation not to take another offer. Whilst if you pull out you risk losing your reservation fee there are no penalties for the buyer pulling out, they just have to return your money to you.
The best advice, unless you genuinely believe you will lose the property of your dreams is, never to put down a reservation fee. Make a formal offer in writing via the agent subject to contracts. If your offer is accepted appoint an independent lawyer and ensure that all necessary checks and searches are done as quickly as possible and sort your finances so you can safely move to purchase contract at which point the property is secured.
Occasionally a seller will not accept an offer without some indication of financial commitment, if this is the case make sure any reservation fee is passed by your lawyer and that the monies are instructed to be held in yours or the sellers lawyer account not the seller or the agent direct.
If you appoint a lawyer before you visit Spain to act on your behalf, and arrange a mortgage approval in principle before coming to look at property you will be able to move at the optimum speed that will help you secure the property but in no way risk any of your hard earned cash.
Should I pay over a reservation fee or deposit in Spain. is a post from: Spanish Mortgages Experts International Mortgage Solutions
Anyone working in Spain within the purchase sector has long known that the quality and independence of many legal advisers has been questionable. Often relying on agents or developers to bring clients to them some Lawyers have sacrificed best advice to clients for volume of business.
Today the market is much more transparent and professional but as sales start to grow some poor practices are beginning to raise their ugly head.
Finally the Embassy in Madrid is seeing fit to point out to UK buyers the pitfalls and warn buyers that most historic issues on purchases have been driven by poor advice.
Quality and independent legal advice is possible to get in Spain but one should avoid the eternal triangle of legal adviser, estate agent or seller, and buyer and ensure a legal representative is sourced independently and not by recommendation of a third and involved party.
FROM THE BRITISH EMBASSY IN MADRID
Potential buyers of property in Spain were yesterday warned to avoid cutting corners when purchasing a home or holiday apartment. Estate agents, lawyers and property developers who offer ways to save money and speed up the Spanish conveyancing system may lead to purchasers ending up with hugely expensive headaches later on, the British Embassy advised.
Despite the well-known problems facing thousands of past purchasers of property in Spain, the Embassy is aware that there are still property industry representatives who are trying to tempt future buyers with apparently attractive methods to secure their dream homes more quickly or cheaply. Such offers may in fact be very bad value.
You should exercise extreme caution if an estate agent, promoter or lawyer urges you to cut corners to save money or time, said Embassy property adviser Alex Brown. The Spanish property conveyancing system is different to the UK. When you choose an estate agent, promoter or lawyer to help with your purchase, check that they are qualified, reliable professionals and have significant experience of operating in Spain and expert knowledge of how the system works.
Although the vast majority of British property owners enjoy life in Spain and have had no problems, thousands of British expats are facing some kind of legal problem with their homes, some because they were advised to cut corners during the purchasing process. Many others are facing difficulties through no fault of their own, caught up in the complexities of Spanish planning regulations.
There is a wealth of information on the Embassy’s UKinSpain website, said Ms Brown. We strongly urge people to check the advice in full, make sure they use fully qualified, reputable advisers throughout the purchase process, and avoid any kind of ‘dodgy deal’ that could end up costing huge amounts of heartache and hard-earned money later on. The advice comes as thousands of Britons head for the annual A Place in the Sun show in London from 30th March until 1st April, aimed at potential purchasers of property abroad. The show’s website www.aplaceinthesun.com/ offers information about legal and tax issues when buying overseas.
F
urther Embassy advice on buying property in Spain can be found on the UKinSpain website at: http://ukinspain.fco.gov.uk/en/help-for-british-nationals/living-in-spain/property-in-spain
Other useful links for potential property purchasers:
- Advice on buying a property on the UKinSpain website
- Advice on UKinSpain for those who have encountered problems with their properties
- The Spanish Government’s guide to buying a property in Spain
Warning From The British Embassy Regarding Spanish Property Purchases is a post from: Spanish Mortgages Experts International Mortgage Solutions
BBVA from their London network are now offering a new 65% loan for purchases in Spain.
The product can be in Euros or sterling dependant on client’s preference and is either linked to the 3 month Euribor or Bank of England Base rate.
The loan is signed and secured in Spain but offered under UK law. The product has competitive rates, second highest loan to value available in Spain after Sol Banks 70% offering, zero early repayment penalties and no compulsory products required outside buildings insurance.
Proven rental income from buy to lets is assessed as personal income and the product has a dual underwrite against affordability ratios and income multipliers.
Minimum loan size is Euros 100k or GBP 83k.
BBVA also has a 50% equity release product for general purpose. With few other banks offering this facility and none allowing funds to be taken back to UK this provides an opportunity for clients looking to raise money against a Spanish property to take funds out of Spain.
New Spanish Mortgage Product From BBVA is a post from: Spanish Mortgages Experts International Mortgage Solutions
In an environment of very difficult lending it would appear Ubiquitous Mortgages are able to buck trend and completely outprice all the major banks in world.
While other lenders have withdrawn from the European market with many French Banks closing the doors to international clients, Spanish Banks doing the same and many international lenders like Lloyds and UCB either withdrawing totally or partially Ubiquitous Mortgages owned by Mark Foreman are out there with rates that appear unbeatable, are the same wherever you buy immaterial of underlying interest rates in that country, and rates that cannot be replicated by the major financial institutions.
Why Ubiquitous, who say they are the lender, would take a completely different view of the markets to other lenders and be able to finance the capital required to lend at rates well below the current cost of funds is not clear.
According to their website, which has been updated recently, they have the enormous sum of GBP 250k paid up share capital. This massive amount of capital obviously allows them to borrow on the open market at rates well below those of the largest Banks in world like Barclays whose Chief Exec earns more than that in a quarter.
Unless they have a banking license in all the countries they lend in it must be private lending and not covered by any banking regulation within the countries they operate in. Either way they are apparently able to sit outside the current liquidity requirements for all lenders, as having GBP £250k liquid cash would hardly allow you to lend anything if you were to fall within current balance sheet requirements stipulated by most central banks and regulators. Of course the balance sheet may have much more cash to cover risk but then if so why not mention it.
To insinuate on their web page a mortgage broker is unstable because they usually only have GBP 100 paid up share capital will not give comfort to any client who knows only too well there is a huge difference between being a service provider which a broker is and an apparent worldwide lender.
To even raise paid up share capital as an argument to use Ubiquitous seems ludicrous because of more concern to a client could be the fact they have admitted to such a small amount of paid up share capital.
The conclusion clients may come to is that they may not be the direct lender at all and are at best in fact an agent for another financial institution, who either has private investors who only want to earn just over 3% a year, or have a tranche of money from a lender who can buy funds very cheaply or have such a high level of liquid cash they can lend at rates that for other banks is unprofitable. If this is the case why say you are the lender as this is misleading.
Either way a sensible client would certainly want to see the type of legal document they would be asked to sign. Want to understand how this is covered legally in the country of purchase or equity release, how the money for monthly payments will be collected, and what could happen to interest rates in the future even if it appears to be a fixed rate for life so they can get their lawyer to check its validity before parting with any money. To request this is not unreasonable and the information should be readily available.
It would also appear that lending criteria is not always clear as interestingly in last couple of weeks one client has been told by Ubiquitous that they have a minimum loan size of € 150k (when the client only required 60k on a 300k purchase), whereas another client who was buying at 150k and needed 70% was not told there was any minimum.
A valuation fee for an automated valuation is required and often this valuation, according to various comments from previous clients on web, apparently comes in too low to allow lending.
It is a little strange that the client who only wanted 60k was told minimum loan of 150k requiring then a minimum valuation level of € 215k rather than minimum € 85k valuation that would be needed if he had the loan size he wanted. The more cynical client might say the minimum loan level quoted was to allow a get out on valuation as it could be difficult to substantiate not achieving 85k valuation on a purchase of € 300k even in today’s difficult times.
Automated valuations which apparently Ubiquitous can do in a variety of countries, even those where house price data per region is scant require no visit to the property and no way of substantiating it has actually been done. The fee however is as high as for a full formal visit form an authorized valuation company.
Valuation fees are quoted at GBP £239 and despite saying on website there are no application fees a registration fee of GBP £95 is also payable. This is GBP £334 for every client who has been told they are approved and is willing to hand the money over, with no guarantee of lending finally being given, and with little cost incurred by Ubiquitous who deal online email only. Perhaps it is little wonder they have GBP £250k paid up share capital.
Ubiquitous Mortgages is a post from: Spanish Mortgages Experts International Mortgage Solutions
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This week has seen the markets in turmoil.
The downgrading of a number of Spanish Banks, Spain itself and the previous weeks downgrading of a number of UK Banks who lend in Spain has seen a very quick increase in margins across the board.
Even Banks like Barclays who missed the downgrades this time round have increased their variable non resident rate from 1.95% to 2.35%.
By far the biggest impact on the Spanish market of the downgrades as it relates to foreign buyers is Lloyds moving minimum margins from 1.5% to 3%. As the last interest only lender to gain 5 years interest only with Lloyds now costs a massive 3.80% above Euribor.
Changes are immediate with only full applications received in full by 21st October having the old rates held.
Against this backdrop the good news seems to be that for their own stock Spanish Banks are absorbing increases in costs.
Banco Popular will offer 0.25% above Euribor for first year followed by 0.50% and Sol Bank are offering 0.60%. With funding up to 100% available at such keen rates Bank owned property is looking good to offer on. Yearly interest costs from the normal 4% Sol Bank rate to their bank owned rate means for every 100k you borrow you save € 1.344 per year in interest payments.
Spanish Markets In Turmoil! is a post from: Spanish Mortgages Experts International Mortgage Solutions
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Sabadell Group which includes Sol Bank have increased margins above Euribor to 1.90% as a minimum from their previous 1.25%.
The margin includes taking life cover as compulsory and in a move which show another change to their strategy for the first time Sol Bank will differentiate rate based on loan to values.
The increase for loans at 60% or below is only 0.15% with rates including life cover of 1.40% being offered the higher rate now only applies to loans between 60% to 70%.
Whilst maintaining their ability to take on 70% loans this is a clear indication that they intend to manage the portfolio of 70% loans by pricing techniques making the 70% less attractive.
This happened in the same week as one of the banks who are made up of two Cajas and intend to float launched a standard 70% product with pricing from 1.50%. The merged Caixa Nova and Caja Galicia have confirmed a new joint policy of up to 70% for non residents. All applications are agreed on a case by case basis and pricing will reflect the overall profile of the application at 70% with staring margins of 1.50% they will help fill the hole Sol Bank appear to have vacated.
Sol Bank increases rates and a new Spanish Bank adds 70% loans to their portfolio. is a post from: Spanish Mortgages Experts International Mortgage Solutions
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Following the general trend we have seen over the past few months Deutchse bank announced today that their margins above Euribor for non-resident buyers has increased from a minimum of 1.25% above with linked products to 1.80% with linked products and as high as 2.60% above without linked products.
How long it will be before the last lender at 1.25% Sol Bank hold this margin remains to be seen but we anticipate some movement upwards in the next few weeks.
This continuing trend is in danger of dampening demand. Foreign buyers have found it increasingly difficult to borrow at home by way of release of equity against their assets there as banks in other countries withdraw product for this type of loan at the same time as Spanish Mortgages become less and less attractive on rate.
We appear to be in a cycle of catch 22; demand being dampened resulting in no growth. No growth resulting in lower credit ratings for bank and Spain itself consequence of high cost if funds meaning increases in mortgage margins to make lending cost effective.
Deutchse Bank Raises Mortgage Interest Rate to 1.8% Above Euribor is a post from: Spanish Mortgages Experts International Mortgage Solutions
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In a recent statement the owners of Santander the Botin’s outlined their expectation that arrears in Spain had peaked and they expected matters and prices to improve this year.
The rather optimistic view is at odds with what is happening to other banks and their view of the market.
It is difficult to see how arrears in Spain; particularly for a bank like Santander who lent predominately to the resident market; will actually drop over coming months.
Unemployment all be it predominately for the younger generation is at 21%. Most businesses particularly those in the financial sector expect to retrench rather than employ this year as mergers between Caja’s gather pace and look to list. They require cost savings to make these attractive to investors and the bulk of this will come from efficiencies and economies of scale. The firms looking to shed jobs this year will not affect those at the beginning of their careers but will affect the 40 plus in a way perhaps not seen in Spain before.
The people who will be affected by companies cost cuttings are those with mortgages and this year we will see more of these types of cuts than previous ones.
Euribor rates which hit an all time low last year and have shielded mortgagees for the last 12 months with overall rates of anything as low as 1.5% have steadily risen. This month for reviews and new loans the 12 month Euribor is 2.08%. Even if the loan was secured at a very low margin above this year most mortgagees will be hit by a minimum 1% increase in their rate. For a mortgage of 100k on a 25 year term this equates to an extra € 376 per month the household will have to find. 12 Euribor rates are expected to continue to climb so by end of year mortgage reviews we could see increases as high as 2% or more to overall rate.
Spain has no control over these rate rises so has to live with a stagnant economy and rising household costs.
Given this environment it is difficult to see the Botin’s predictions of a stabilising arrears book and improving property prices actually be realistic this year.
Most pundit would predict 2011 will continue to see arrears rising and prices in some areas continuing to fall as banks make efforts to clear the vast numbers of surplus stock.
Santander say Spanish Mortgage Arrears Will Fall is a post from: Spanish Mortgages Experts International Mortgage Solutions
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A Place in the Sun reports today that sales for Spanish properties in April fell to their lowest level since the crisis began. Sales were 32% down year on year and 25% lower than March this year. Whilst most agents are reporting higher sales to the non resident market the resident market is slow due to economic situation and the pulling forward of buying decisions last year to beat the removal of tax relief being applicable on the interest of loans.
Price are expected to continue to fall and it is difficult to see in some areas prices bottoming out before the end of this year or next although in some areas demand remains reasonably high.
Banks will continue to be cautious about the granting of mortgages in a declining sales and price market so we expect no relaxation of criteria or enhancement of loan to values to happen during 2011.
Clients requiring above 60% to 70% will need to focus their searches on bank owned property.
There continues to be pressure on cost of funds for the bank and last month for the first month in many borrowing from the Central Bank by Spanish Banks increased as money markets contracted for them.
The price of funds is reflected in the mortgage pricing banks are offering.
Deutsche Bank increased their margin from 1.15% this month to 1.5% above Euribor. Lloyds did the same a couple of months ago.
Many banks have now removed the ability to take a mortgage without life cover at higher rates and instead insist life cover is taken full stop. This is to ensure profitability of lending. Many banks like Sol Bank, and La Caixa now add a lump sum life cover to loan to prevent the life cover being cancelled at a later date.
Barclays and Lloyds remain the only two banks with some products where life cover is not compulsory. The Spanish Banks still lack transparency in ensuring clients understand the linked products when quoting and it is not uncommon for brokers to forget to tell clients either.
No longer can headline rates be taken as the true cost and clients should always ask the question, is life cover required, and what would be the cost. For clients age 45 years and younger, life cover premiums are reasonable, but for client 45 years and older there is a very strong argument for taking a higher rate from one of the banks that does not have life cover than a lower rate with one that does. Finding all this out at Notary on day of signing rather than being clear beforehand may make it all too late to change and could put deposits at risk.
Spanish mortgages market update June 2011 is a post from: Spanish Mortgages Experts International Mortgage Solutions
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Barclays
Post the ECB base rate increase and the continuing upward trend of Euribor rates with little relief in site for the cost of the funds for Spanish Banks Barclays recently increased margins above Euribors to a minimum of 1.75% on their variable rate.
The three year fixed rate rose to 4.25% and the full term fixed to 5.95%. The three year fix still looks relatively good value for money with expectations the 12 month Euribor will rise to 3% by end of 2011. With most banks charging from at the bottom end 1.15% above Euribor to the top end of 3.9% above Euribor a 4.25% fix followed by 1.3% above 12 month Euribor at end of fixed rate remains one of the better products on the market.
Barclays affordability criteria’s makes access very difficult, with one of the lowest debt to income ratios of 30% and the current requirement that the risk teams only assess 80% not 100% of after tax income means only a handful of high earners with little or no UK debt are likely to qualify.
Maximum loan to value 65%
Santander
Santander remains currently at 50% loan to value and with the highest margins above Euribor in the market. A whopping margin of 3.9% above 12 month Euribor with low loan to value means Santander have by default extracted themselves from the lending market for non residents in Spain
Spanish mortgages lender updates is a post from: Spanish Mortgages Experts International Mortgage Solutions
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Finally some good news for Spanish Banks!
Yesterday it was announced the recently announced (Forbes Magazine) richest man in the world Carlos Slim has bought into La Caixa.
La Caixa should be one of the first savings bank to fully list and this endorsement will undoubtedly help the listing process and encourage other investor to buy the banks shares.
Finally some good news for Spanish Banks! is a post from: Spanish Mortgages Experts International Mortgage Solutions
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Whilst on the face of it low interest currency mortgages can seem attractive the reality can be quite different.
Lenders like Banco de Valencia regularly promoted their currency mortgages to Spanish Buyers as an alternative to taking a Euro loan. During the years of 2007 to 2010 when Euribor rates were climbing and loan rates hit their height of over 5% many clients were convinced a Japanese Yen rate was much a much better bet.
Many of these clients have now found they have a loan that is in size considerably more than the loan they first took out due to the exchange rate fluctuations. The loan is always in Euros and converted to Yen at completion and converted back to Euros from Yen if the loan is cleared early.
Because the Yen has strengthened against the Euro anyone wishing to clear the loan would have less Euros coming back when the conversion was done and therefore left with outstanding amount on the loan despite having a loan that has been paid up to date for the entire time it has been held. Any benefit on rate has been completely wiped out. Clients therefore are tied into the loan and victims of exchange rate fluctuations requiring a reversal of the trend to reduce the capital outstanding on either sale or early repayment.
The Perils of Currency Mortgages When Taking a Loan in Spain is a post from: Spanish Mortgages Experts International Mortgage Solutions
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Whilst many companies advertise the buying of property in Spain via auctions none of these web based advertisements are actually official auctions where Spanish repossessed property can be bought.
The official auction process in Spain is a very different process to those being touted on the web.
When a property is going through a repossession process the final part of this process; before the bank can take ownership; is that the official court auction takes place. This auction is only advertised on the Court Boards of the relevant and local court to the property.
Each Spanish property has on its deeds an auctionable amount recorded when the loan was originally granted. At court auction the property cannot be sold for lower than 70% of this defined amount. Bidders must put into court 30% of the current value of the property or they will not be able to attend.
If the property is not sold at auction then the bank takes ownership at 50% of the auctionable value and must pay transfer taxes etc relevant to this amount. The 50% value is then deducted from the amount owing to either pay off fully the outstanding Spanish mortgage or leave an amount outstanding that the mortgagee will be pursued for.
The Spanish Bank has 21 days before taking over property to find a buyer who will then buy direct from the courts. At this point the bank can agree to sell the property at any amount they wish but cannot if they choose to sell at a lower price pursue the original owner for any more money than was crystallized at day of Court Auction.
The Spanish Auctions advertised on the web are in fact private auctions where direct sellers can chose to advertise their property and try to sell it by a bidding process in comparison to perhaps using an Estate Agent or other marketing avenues. They are not however official auctions which in anyway form part of the normal repossession process in Spain and nor are they currently used by Spanish Banks to offload surplus stock.
Access to official Spanish Auctions is difficult to gain as many remain a closed shop but buying from the banks in the days in between auction and them taking full ownership is by far the timescale at which point the best price can be achieved.
Anyone genuinely believing that going to a private auction means they are getting true Spanish Bank auction stock will find this is far from the reality.
In the UK eventually bank owned stock not sold within a period of time via normal processes ends up at auction this is not the case in Spain. The auction process is the final part of the re-possession process not how the Spanish Banks sell the stock they have taken over.
Property Auctions In Spain is a post from: Spanish Mortgages Experts International Mortgage Solutions
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