Banking sector: Regulations, compliance and good governance By Dr. Salehuddin Ahmed

Photo: www.bangladesh-bank.org

The global financial and economic crisis started in 2007 as an aftermath of the housing sector bubble coupled with aggressive lending practices in the US sub-prime mortgage market and lax regulation of the financial sector. The financial crisis, like a contagious disease, spread to the real sector of the US economy and affected both financial and real sectors of the world, making the crisis a global and very serious challenge for economic activities.
The root cause of global recession can be traced back to the mismanagement of banks and financial institutions. Despite all the measures taken by different countries, with the US taking the lead, full recovery has not yet been forthcoming. The year 2015 will be a challenging one. Small economies like Bangladesh are by no means invulnerable to fallouts from global downturns or negative spill over of policies of large economies and therefore have a strong stake in global stability and economic growth.  In forums such as the G-20, countries like Bangladesh need to argue forcefully for the same priority in stability as recovery, as well as for stability action agenda going beyond addressing symptoms (i.e. lapses in risk management, inadequacies of regulation and supervision) to addressing underlying causes (i.e. lax policies, non-compliance of prudential and management norms, poor financial reporting, unbridled liquidity expansion that incubate bubbles.)
So what are the implications of the Bangladesh economy minimising external shocks and internal shocks? This paper will mainly address the several challenges faced by the banking sector in creating internal shocks in the economy. Recently, the Hallmark and Bismillah Group financial scams, which started mainly at state-owned commercial banks, have demonstrated cracks in the management of these banks. From the Board of Directors to the management group to the lower level officials, these banks have not shown any sign of good governance, transparency and accountability. The disturbing fact is that these irregularities have permeated to private commercial banks as well.

Illustration: Internet

There are several state-owned and private banks that have slightly different governing structures but follow the operational guidelines of Bangladesh Bank in terms of prudential and management norms. The norms provided by Bangladesh Bank are fairly well formulated and follow international standards. The International Accounting Services Board (IASB) under the Bank for International Settlements (BIS) in Basel, Switzerland, has provided three major norms namely Basel I, Basel II and Basel III. Basel I of 1988 required that banks and financial institutions have sufficient capital adequacy, which was originally 8% of risk weighted assets (RWA). Later on, it was raised to 10% for banks, including those in Bangladesh. There are some banks in Bangladesh whose required capital adequacy falls short of the norm.  Basel I set up a mechanical, non-market oriented measurement of capital adequacy which could not take care of fundamental risks, e.g. operational risk and market risk.  Basel II, introduced in 2004, took care of the different types of risk for financial intermediaries (i.e. banks) as well as the supervisory review process for the management of banks. The global community realised the inadequacies of Basel I and Basel II during the recent global financial crisis of 2007. Basel III was introduced in 2013 and is supposed to be completed in 2020. The major aspects of Basel III are: first, to strengthen the capital framework of banks and to give more emphasis on equity capital (Tier-1, core capital); second, to ensure global liquidity; third, to highlight systematic risks as well as mitigation measures that address the risks. Two major aspects regarding liquidity are Liquidity

Coverage Ratio (LCR) and Net Stable Funding Ratio (NSFR). Bangladesh bank has recently issued a circular to implement Basel-III liquidity ratios. Besides the three international Basel norms discussed above, banks follow other guidelines prescribed in the various Acts and regulations in their respective countries.
Financial reporting by banks is very important in ensuring the interest of depositors, as well as that of the clients. I shall now highlight the aspects that are related to the compliance of different rules, regulations and norms, prescribed for banks. In Bangladesh, as pointed out earlier, the regulatory requirements of banks follow international standards. Besides these, the Bank Company Act provides guidelines for the preparation of reports, including audit reports. On  top of that, state-owned commercial banks and specialised banks, like Krishi Bank (RAKAB), follow the requirements laid down in the respective Acts through which they were established. The Registrar of the Joint Stock Company (RJSC) also has certain rules for entities registered under the Company Act and the Societies Registration Act. Similarly, Bangladesh Security Exchange Commission (BSEC) has laid down rules for companies to prepare their financial reports. On the whole, requirements for the financial reports of banks, non-bank financial institutions (regulated under the Financial Institution Act) and various companies are quite satisfactory in Bangladesh. The disturbing part is that these requirements are not properly complied with by various institutions. This means that the implementation (enforcement and compliance) of rules and regulations is the “Achilles Heel”. Despite supervision and monitoring by the regulatory bodies such as Bangladesh Bank and BSEC, serious mismanagement and malpractices have occurred in the banking sector as well as in the capital market. The disclosure of banks in their financial reports is prepared by following International Accounting Standards-30 (IAS-30). This has been replaced by International Financial Reporting Standards (IFRS-7). According to this format the financial disclosure is more logical, which means that banks now face higher risk in the investment and management of capital. If the required standard is followed then depositors and clients of the bank and the general people will not face any loss. Besides IAS-30, there are also IAS-32, IAS-39 and IFRS -9, which are prescribed for the management, supervision, and monitoring of financial intermediaries. The government of Bangladesh took an initiative in 2001 to promulgate the Financial Reporting Act, which hitherto has not been done. In 2013, a draft was circulated to the main stakeholders, one of which is the Institute of Chartered Accountants in Bangladesh (ICAB) and the other the Institute of Cost and Management Accountant in Bangladesh (ICMAB). These two institutions have opposing views regarding the proposed FRS Act and the proposition that the constitutions of the Financial Reporting Council (FRC) be headed by the Governor of Bangladesh Bank. ICAB opposes the establishment of the FRC, while ICMAB supports its establishment. ICAB opposes on the ground that it is a self-regulatory professional body which is competent enough to ensure proper financial reporting. But a very strong point is made by others that a membership organisation like ICAB cannot perform the job of an independent, accountable and autonomous regulatory council like the proposed FRC.

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It must be pointed out that a balance must be made between the regulation and independence of a bank. This means that banks should neither be overregulated nor should they be left alone to enjoy complete freedom, which often results in banking disasters.  This point has been very aptly articulated by Jean Tirole, the Nobel Prize winner of Economics in a book jointly written with his colleagues. It is important to keep in mind what financial regulation is meant to achieve. The most important objective is to protect depositors, investors, the general public and the real economy (real goods and services) as a whole.  The second rationale for regulation  is to  minimise the domino effect  of  the systematic risks of the financial institutions whichs destroy  the foundation of economic  activities  resulting  in loss of real output, lower growth, higher unemployment  and reduction of human welfare.
Good governance in the banking sector is an important agenda of our country, especially in the present context of the crisis in the banking sector. Transparency and accountability have recently become an issue of greater concern with revitalised importance in the context of public and private responsibility of managing banks. The International Monetary Fund (IMF) has defined transparency as “an environment  in which  the objectives  of policy, its  legal, institutional and economic framework, policy decisions and their rationale,  data and information  related to  monetary and financial policies,  and in terms of  agencies'  accountability,  are provided  to the public on an understandable, accessible and timely basis” (IMF-1999). Transparency in government operations is an important pre-condition for macro-economic fiscal sustainability good governance, and overall fiscal discipline. Accountability, in the words of Lessinger (1970), “is the product of a process  which means that an agent, public or private, entering into a contractual  agreement  to perform a service  will be held  answerable  to perform  according to agreed upon terms, within an established time period  and with  stipulated use of resources and performance standard .” Transparency is necessary to ensure accountability among the major group of participants in financial markets: borrowers and lenders; issuers and investors; and national authorities and international financial institutions. Transparency and accountability are mutually reinforcing. Transparency enhances accountability by facilitating monitoring, and accountability enhances transparency by providing  an incentive  for agents  to ensure that  the reasons  for their actions  are properly  disseminated  and understood. A perfect example is the Hallmark scandal of the state-owned Sonali Bank which occurred due to the lack of both transparency and accountability. Both the borrowers and the officials colluded in a non-transparent manner and siphoned off huge amounts of public money. The people who were caught have not yet been subjected to administrative and legal actions, in fact they got “perverse incentives” and the honest and dedicated people working in the same bank and elsewhere are pushed back into inefficiency. As the saying goes, “Bad money drives away the good money.”
The transparency of financial statements of banks is secured through full disclosure and by providing fair presentation of useful information necessary for making economic decisions to a wide range of users. In the context of public disclosures, financial statements should be easy for users to interpret. Whereas more information is better than less, the provision of information is costly. Therefore the net benefits of providing more transparency should be carefully evaluated by standard setters. The adoption of internationally accepted financial reporting standards is necessary to facilitate transparency and contribute to proper interpretation of financial statements. In the context of fair presentation, no disclosure is probably better than disclosure of misleading information. Left to themselves, markets cannot generate a sufficient level of disclosure. Here is the vital role of the accountants, as the bulk portion of useful financial information used by the market participants are provided by the accounting information systems, where the preparers (the employed accountants) provide information which is authenticated by external accountants on the basis of International Accounting Standards (IAS) and International Standards of Auditing (ISA). An accountant should not depend on numbers only, one should engage one's own logic and judgment to analyse a set of numbers.
With the view of strengthening good governance in the financial sector, especially in the banking sector, Bangladesh Bank embarked on several financial sector reforms over the years. A large number of home grown reforms have already been taken and some are underway. Bangladesh Bank attempted to strengthen the legal framework of the financial sector, bring in dynamism, extend autonomy to the central bank, combat money laundering offences, and stop financing for terrorism. There are several other prudential norms already discussed in the previous section in relation to the Basel Guidelines and the guidelines of various Acts of Bangladesh. One important aspect is the management norms, which concern the fit and proper test for CEOs and directors of a bank, restrictions on the composition and functions of the Board of Directors. Banks have been directed by Bangladesh Bank to include one independent director in the Board of Directors.  Audit Committees for all banks were mandated with clear guidelines, and TORs and an early warning system (EWS) were introduced. The Core Risk Management Guidelines on five major risks were introduced quite some time back and credit risk assessment by External Credit Assessment Institutions (ECAI) have been recommended for all commercial banks. However, in recent times we have seen that many of these management norms are not followed by banks. There are several privately owned banks where a number of family members are on the Board of Directors, which is contrary to the notion of good corporate governance. Therefore one of the main challenges for the banking sector is to ensure good corporate governance which will benefit the depositors, borrowers and investors; expand potential markets; broaden ownership; create alternative financing options; accelerate growth; increase employment and help reduce poverty in Bangladesh.
To balance the objectives of good governance and ensure compliance of regulations, three major steps are necessary: (a) a strong and independent central bank with more focus on core banking issues, (b) a well thought out set of prudential and management norms of the central bank that are not subject to frequent changes due to external political/administrative pressure, and (c) a system of prompt corrective actions for management of crises and for legal/administrative actions against persons responsible for crises in a particular bank or in the banking 'system' as a whole.


The writer is Former Governor of Bangladesh Bank and currently Professor, School of Business of BRAC University.

Published: 12:00 am Tuesday, March 10, 2015

Banking sector in search of respite By Dr Fahmida Khatun

Photo: Star ARCHIVE

Banking sector is an important component of the financial system that mobilises resources for productive investments in a country which in turn contributes to economic development. Over the years the banking sector in Bangladesh has flourished in terms of the number of banks and their branches, amount of asset and contribution to the economy. The sector has also undergone several reforms and fallen under the jurisdiction of a number of acts for improving its efficiency. Nevertheless, the sector in recent times has been plagued by various problems including inefficiencies, malpractice and scams. This has impacted the soundness of the banking system in the country and resulted in huge losses in the sector. While the sector is yet to recover from these shocks, new challenges continue to appear in different forms.

MAJOR CHALLENGES
One of the problems that banks, particularly state-owned commercial banks face at present is that of dealing with the high volume of non-performing loan. Though Bangladesh Bank adopted a flexible loan-rescheduling policy in December 2013 in order to provide respite to borrowers in view of the political turmoil and reduce the burden of non-performing loan on banks, the policy did not lead to fruition. Rather, the amount of non-performing loan has increased partly due to the flexible loan scheduling policy itself. Lack of proper screening of loan proposals and due diligence, non-adherence to project selection criteria, consideration of non-economic factors in sanctioning loans and lack of monitoring during project implementation are the major reasons behind high non-performing loan in Bangladesh.
The high volume of non-performing loan is taking a toll on capital adequacy and profitability of banks. Capital adequacy ratio, measured as capital to risk weighted assets, is below the international standard of maintaining a minimum capital adequacy ratio of 10 per cent in state-owned banks. Non-performing loan coupled with lower demand for loan has affected the profitability of most banks. Return on asset and return on equity have been negligible and even negative in state-owned banks. This not only reflects the quality of assets in the banking system, but also raises concerns about the sustainability of these banks.
With generous support from the government, state-owned banks were able to adjust their accounts and make up for their losses created through various financial malpractices. In order to strengthen the banking sector, Tk 5,000 crore was earmarked in the national budget. While the government is injecting capital into these troubled banks in order to keep them afloat, allocation for other priority areas including social sectors remain less than adequate. On the other hand, though financial inclusion in terms of population per bank branch has improved over the years, a large number of people still remain outside the purview of banking services. Thus, recapitalisation of these banks raises questions as regards the prioritisation of the allocation of public resources, particularly when state owned banks continue to be fraught with governance challenges. The fact that such capital infusion has not seen any improvement in the receiving banks is rather frustrating.

REFORMS UNDERTAKEN
In a bid to improve the performance of the banking sector the government of Bangladesh embarked on a policy of liberalisation through denationalising the nationalised commercial banks in the 1980s. In view of the deteriorated performance and inefficient resource management the government decided to open up the banking sector and adopt a number of reforms for the sector. As part of the reform process two of the six nationalised commercial banks were denationalised and a few commercial banks were given license to operate in the private sector to create competition in the banking sector. The reform process accelerated towards the end of 1980s and the beginning of the 1990s under the directions of the World Bank and the International Monetary Fund. The National Commission on Money, Banking and Credit was constituted in 1986 to look into the problems of the banking sector and suggest ways to overcome those under the direction of the World Bank. The Commission pointed out, among others, problems relating to the supervisory task of Bangladesh Bank and overall structure of the banking sector, and pointed out that non-performing assets required improvement. The consequent Financial Sector Reform Programme and Financial Sector Adjustment Credit carried out in the 1990s were geared towards implementation of various reform measures in the financial sector. The objectives of these measures were to liberalise interest rate; enhance the capacity of loan classification and provisioning; capital restructuring and risk analysis; strengthening the central bank; and improving the legal system and framework for loan recovery.
Following the phase out of the Financial Sector Reform Programme in 1996, subsequent governments continued to undertake reform measures in the financial sector. The Commission on Banking and the Banking Reform Committee were formed in 1998 and 2002 respectively to make recommendations for the improvement of the performance of banks. A bill was passed in the parliament in 2003 to bring more reforms in the banking sector. Most important of the relevant initiatives was the Bangladesh Bank Amendment Bill, 2003 through which Bangladesh Bank received the autonomy to operate on its own and to formulate the monetary policy. The World Bank and the government of Bangladesh undertook a reform initiative called the Central Bank Strengthening Project to put in place a strong and effective regulatory and supervisory system for the banking sector of the country. The focus of this project was on three broad areas, those of (i) strengthening the legal framework; (ii) reorganisation and modernisation of Bangladesh Bank, and (iii) capacity building of Bangladesh Bank.
Another major reform attempt was the corporatisation of four state owned banks into limited companies and restructuring of three state-owned banks in 2007 to operate as more of a commercial entity. Supported by the World Bank and monitored by the Bangladesh Bank, the reform initiative included measures such as selection of the chief executive officer, deputy managing director and four general managers of the state-owned banks through a competitive process, and fixation of the compensation package that was commensurate with the private sector and in accordance with respective performance records. Monitorable goals were set for cash recovery of non-performing loan, limits on new non-performing loan, operations, computerisation, income and profitability, increased net worth and disclosure.
However, the reform initiatives for the banking sector in Bangladesh have not been able to deliver the expected results. Achievements in terms of efficient resource allocation through disbursement of credit to productive sectors, prudent risk analysis, supervisory and management quality have not been encouraging in many banks even after so many reforms since independence. Moreover, lack of governance has featured prominently in the recent years in several banks including the state-owned banks.
Following the unprecedented level of misappropriation by the Hallmark group in 2012 from a state owned bank, a number of incidences of malpractices have been unearthed in other banks. These incidences have exposed serious flaws in the governance of the sector, the associated corruption in the sector and negligence of the responsible people. Sadly, the sector has not been able to make any visible progress in terms of restoring governa        nce since the Hallmark incidence.
Ironically, in most cases, these incidences have occurred in collaboration with officials and directors of banks through various types of dubious practices such as by setting up fake companies, forging bank documents, documenting fake board meetings and influencing the monitoring officials. Private commercial banks are not unscathed either. Fraudulent activities, which owners and the management have been party to, are also observed in these banks. This has compelled the central bank to appoint observers in a few banks.

ROAD AHEAD
After several reforms in the banking sector since the eighties, the banking sector had begun to exhibit some signs of improvement in a few areas. However, recent shocks have exposed the fragility of the sector and pointed out that reforms in the sector have been incomplete.
If the banking sector has to contribute to the economic growth of the country through mobilising resources for investment in productive sectors, it needs a massive overhauling and clean up. The required measures can be categorised into three broad areas - (i) strengthening internal governance of banks; (ii) improving oversight function; (iii) removing political influence.
Most banks suffer from shortcomings such as poor selection of creditors and politically motivated lending, poor risk management, lack of due diligence, weak monitoring and misreporting. There is a lack of transparency and accountability in case of credit approval, administration, monitoring and recovery processes. Credit concentration is common in many banks. Concentration of outstanding loans in the hands of a few business groups indicates high level of risk and vulnerability in the sector. This has exposed banks to high default risks. Given that a significant proportion of this loan is non-performing loan as highlighted above, this raises serious doubts in regards to the quality of credit.
In view of the recent shocks in the banking sector and emerging challenges, a commission for the financial sector should be formed which will scrutinise the overall performance of the sector, assess the need of customers and the economy, identify the current problems and emerging challenges, and suggest concrete recommendations for prudential banking to be implemented in the short to medium terms. Considering the emerging need and in order to build up more transparent and responsible banking sector, the commission can also include non-banking financial institutions such as insurance companies and the capital market under its jurisdiction as they are interconnected. The broad terms of reference of the Commission will be to critically assess the problems and weaknesses of the banking industry in order to find whether there is any disconnect between demands of the growing economy and the realities of a backdated financial system that is failing to meet the emerging need. On the basis of a comprehensive scrutiny the commission will prepare guidelines and make recommendations as regards automation, risk management, internal control and the role of various players in banks and other financial institutions.
As the country desires to step into a higher growth momentum through exploring its potentials, the demand on the banking sector will continue to be higher in the coming days. This reiterates the need for improved efficiency of the sector. This has become important also due to the fact that the global regulatory environment is becoming tighter, the global economic environment facing more volatility and resources are becoming scarce. There will be demand for higher capital and skilled human resources for smooth functioning of banks and for ensuring compliance in the future. Hence the banking sector in Bangladesh will have to focus on using both its financial and human resources in a far more innovative, judicious and efficient way to cater to the future demand.

The writer is Research Director at Centre for Policy Dialogue and currently a Fulbright Scholar at the Earth Institute of Columbia University, New York.

Published: 12:00 am Tuesday, March 10, 2015

Towards financial inclusion By Sajjadur Rahman

PHOTO: STAR ARCHIVE

On August 15, India's Independence Day, Prime Minister Narendra Modi announced a national mission of financial inclusion. Called the Prime Minister's People's Wealth Programme, it envisions bank accounts for all Indians. In its first phase, ending August 14, 2015, the target is 7.5 crore accounts. As Modi said, “There are millions of families who have mobile phones, but no bank accounts. We have to change this. The change will commence from this point.”
Bangladesh may not beat India on many economic and social indicators. But it can be asserted that Bangladesh has realised the importance of using mobile phones for banking for financial inclusion several years before India. There are 2.5 crore mobile bank account holders (almost one-sixth of the total population) and the number is increasing every day. On an average Tk 350 crore is being transacted every day through mobile banking. Another 1 crore Tk 10 farmers' accounts exist in state banks. Nearly 8 lakh students have bank accounts now. In addition, there are around 5.5 crore formal bank accounts in the country.
Altogether, the total number of bank accounts now stand at around 9 crore or over 56 percent of the total 16 crore population. If only the adult population is taken into account, nearly 90 percent people have bank accounts, which is a remarkable achievement for Bangladesh compared to the least developed and developing countries.
On the contrary, World Bank (2008) shows that in most developing countries, less than half the population has an account with a financial institution, and in many countries the number is less than one in five households.
“We are now the second biggest mobile banking country in the world after Kenya. We will become number one in a few months,” Dr Atiur Rahman, governor of Bangladesh Bank, told The Daily Star.
Rahman is believed to be the champion of the successful campaign for financial inclusion. He has motivated central and commercial bankers to bring the unbanked population into financial services. He made the mobile banking services 'well-regulated', both by the central bank and scheduled banks.
He dreams further towards sustainability. “Financial inclusion will lead us to financial sustainability. We have also launched green banking, keeping in mind the sustainability issue,” said the governor.

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Financial inclusion and financial literacy have long been the words used by policymakers, bankers and researchers across the globe. There are many opinions about what financial inclusion means.
The G20 association of major world economic powers added its imprimatur to financial inclusion by recognising it as one of the four pillars in the financial sector reform structure of its Global Development Agenda and given it equal standing along with financial integrity, financial consumer protection, and financial stability. In doing so, the G20 defined financial inclusion as:
"...a state in which all working age adults have effective access to credit, savings, payments, and insurance from formal service providers..." The 'newly banked', as the


beneficiaries of financial inclusion are often called, have not necessarily been deprived of all financial services. They may have significant and often negative experiences with informal moneylenders, unofficial exchange houses, and ancient transfer systems such as hundi and hawala.
It was not very long ago that Bangladesh was dubbed as an under-banked country. Financial inclusion was a far cry at that time. Discussions were limited to the challenges, such as lack of knowledge and awareness in financial inclusion in Bangladesh. A research conducted by the Bangladesh Institute of Bank Management shows that financial inclusion of the total population was 39.76 percent in 2004 which rose to 56.42 percent in 2010 due to the opening of 90 lakh Tk 10 farmers' accounts in state banks.
There are around 9,000 bank branches along with about 18,000 branches of NGO-MFIs, 1,200 thousands post offices and 183,000 co-operative outlets totalling about 2.1 lakh branches/outlets for the 56.6 million economically active population - generating at least one financial service point per 270 people.
The game started to change further in 2011 when Bangladesh Bank, the country's central bank, issued Mobile Financial Services (MFS) Guidelines defining a model where MFS must be bank-led, but partnerships with regulated micro-finance institutions were made to reach customers.
Two MFS providers have emerged as early leaders: bKash of BRAC Bank and Dutch Bangla-Bank mobile banking. Launched in 2011, bKash, initially a joint venture of BRAC Bank and the US based company Money in Motion, has emerged as the market leader with more than 15 million customers. Following IFC's investment, Bill & Melinda Gates Foundation, one of the largest private foundations in the world, also made an equity investment in 2014. The service provider has around 105,000 agent points nationwide to facilitate cash-in and cash-out services at every corner of Bangladesh. Besides money transfer, a bKash account holder can also use his or her mobile wallet for availing other services such as mobile phone top up, salary disbursement and payment for shopping.
Bangladesh Bank has made a big effort in increasing availability of the highest quality banking services to the farmers. As per regulations, any farmer showing his/her National Identity Card/Birth Registration Certificate and Agriculture Inputs Assistance Card issued by the Agriculture Extension Department can open a bank account by keeping only 10 taka as initial deposit. The banks do not require the filling of the Know Your Customer (KYC) form for this purpose. No condition of maintaining a minimum balance will be applicable in this regard and these accounts will remain free of any additional charge or fees.
BB has also allocated a Tk 200 crore refinance scheme for these farmers so that these bank accounts will remain active. The marginal and landless farmers, small shop owners, hawkers and people affected by river erosion having the Tk 10 accounts will get loans under the refinance scheme with a 9.5 percent interest rate.
Dr Mustafa K Mujeri, director general of Bangladesh Institute of Development Studies (BIDS), hailed the country's progress in financial inclusion, saying, “We have progressed a lot in access to finance in the last several years. The number of bank branches (nearly 9000), accounts and products have increased significantly over the years.”
But he warns of being complacent with the growth in numbers only. He said people have multiple bank and microcredit accounts.
“10  crore accounts do not mean that 10 crore people have accounts,” said the top researcher of the state-sponsored BIDS. “Still, many people are ignored by the current financial system for being too poor.”
He also lauded the government and the BB for their efforts to distribute subsidies through bank accounts, otherwise the accounts (one crore Tk 10 farmers' accounts) will remain dormant. “Time has come for the BB to assess how far these accounts are being utilised,” said Mujeri.

The writer is the chief business correspondent,
The Daily Star. He can be reached at suja74@gmail.com

Published: 12:00 am Tuesday, March 10, 2015