| Financial Education or Financial Capability - Who should learn from whom in the Financial Services System? iff Contribution to Brussels Conference. |
EU-COMMISSION HOLDS CONFERENCE IN BRUSSELS - UK CONFERENCE AS A MODEL
On Wednesday DG Internal Market holds its financial capability conference in Brussels. Like many of their initiatives also this one seems to be modelled to an UK predecessor the
UK "Financial Capability Conference on 18th October 2006" where according to its website "Ed Balls, Economic Secretary to the Treasury and John Tiner, Chief Executive, Financial Services Authority (FSA) jointly hosted the first National Conference on Financial Capability at Lancaster House. The conference showcased progress on the UK's financial capability agenda; promoted the work of the FSA and its partners in the industry, Government and the voluntary sector; and raised awareness of financial capability and the need to build on existing activity."
The idea of Financial "Capability" tends to view banks as teachers and consumers as pupils. Thus also in Brussels supplier orientation prevails. In his critical intervention Udo Reifner from ECRC will put a continental question mark to such policies.
Money business has to serve the people and learn how to offer suitable, adapted financial services which are affordable, do not discriminate, give customers a choice are respectful to social cohesion, culture and environment. It is dangerous to assume that banks have already accomplished this task to learn. Instead many odd products and predatory services inundate the market so that the true question is more how consumers are able to influence banks. For this they need indeed increased knowledge about their basic needs and how to transform given offers in financial services into tools to allocate their financial resources to where they are needed.
In his short intervention Udo Reifner (iff) will try to represent ECRC's views on a learning system which is based on the notion of "financial education" (Finanzielle Allgemeinbildung) instead of financial capability of financial literacy. Of course consumers do have to learn to use the system properly. But those who truly run the system have even more to learn hwo to cope with the biggest challenges of our time: usury, overindebtedness and social discrimination in a profit driven system. More market freedom alone will not suffice.
The annexed speech shows that also with such critical approach a joint and fruitful cooperation as in the Hamburg Schuelerbanking.de project shown is possible.
INTRODUCTION TO THE PRESENTATION (whole speech and powerpoint presentation annexed)
Udo Reifner
“WORKING TO ACHIEVE RESPONSIBLE CREDIT”
Financial education has become necessary through the credit society. The subject is mostly still unknown in most of European school agendas. It can be found in the legislation of the state of New York and some UK school regulations. In Germany after a three year joint project the state of Hamburg was the first to write this subject expressively into its school plans.
But what is true for financial education is not true for financial services as a subject in education. According to our analysis of school books especially mathematics in 7th and 8th grade use many examples from financial services to demonstrate growth and interest calculation incorporating more or less plausible economic insights into their solutions.
Where economic issues are taught the money system, banks and credit as well as savings play an important role for the understanding of markets. Even in primary schools we find household education as moral education towards an economic use of scarce resources juxtaposing savings and credit in order to differentiate between the good and the bad way in life. Financial services also play a crucial role in professional education in vocational schools and higher education which are copied in many general books on economics. Here people are prepared for a professional use of financial services either as bankers or in another commercial environment so that products and their cost structure and mechanisms can be learned. Many banks offer material to understand their specific products free to schools so that product knowledge as a form of hidden marketing conquers the economic education of lazy teachers. A German bank even made a quiz posing their own products to the public and concluded wrongly that those who did not know their functions and language were uneducated while an analyses of their own product knowledge revealed that they were equally uneducated with respect to different products that competitors offered on the market.
But neither general economic nor professional education for the finance services economy, neither household finance nor moral savings education meet the present need for financial education. They are answers either to different questions or for different times. Financial education responds to the following question
“How and how far can under market conditions consumers satisfy their needs to allocate their income adequately by making a productive use of professionally offered financial services?”
Present answers in Europe and the US show that we are still quite far away from a comprehensive answer. While often old whine is offered in new skins there is also an increasing paternalistic misuse of consumer education to justify own irresponsibility and laisser-faire politics in financial services regulation. Education thus becomes a pass partout for all problems of the money system just as environmental education of consumers is sometimes propageted to divert public opinion from the failures of the automobile industry.
FINANCIAL EDUCATION FOR CONSUMERS - THE HELP-YOURSELF-IDEOLOGY
“A decrease in financial knowledge brings many people into economic distress. We therefore offer a school service with our consultancy service “Money and Household” as well as by supporting debt advice agencies in many regions. In this we do not intend to market products but to teach people the right handling of money. This we called “Education for saving” in former times.“
This recent statement of the president of the biggest consumer finance group in Germany mirrors the tradition of financial education in continental Europe as well as Japan. Save instead of taking up credit. Credit is a dangerous good. The prove are the overindebted which should be taught a better behaviour through advice and, as the American legislator just ordered it, through compulsory education which we in Europe know from traffic regulation where drunken drivers have to attend compulsory lessons to get their driver’s licence back. Consumers are less knowledgable than in good old times where no consumer seem to have been unable to pay back his or her debts.
Is this true? The credit society did not invent credit but only loans. Credit, saving and value transfer are as old as partition of labour and social life is where overindebtedness had only another name: poverty. In former times credit was given in kind and not in money (just as landlords as well as the state or parents still do). Overindebtedness and financial exclusion appeared as homelessness, orphanage or lack of food and income. Today everything can be bought. Cash is the key to heaven. So all problems can be solved with cash.
But you do not earn it at the time and the lieu where you spend it. This is the main problem which drives all that do not have inherited a comfortable bank account into the use of financial services. Financial services help you to transport your income from your past into your future as old age pensions and savings show, but helps also to access your future earnings at present as loans reveal: It helps to carry it from here to there as payment services promise or from unknown other risk group members to me in case of accidents and mishaps as apparent in insurance contracts.
FINANCIAL EDUCATION FOR CONSUMERS – THE HELP-YOURSELF IDEOLOGY
“A decrease in financial knowledge brings many people into economic distress. We therefore offer a school service with our consultancy service “Money and Household” as well as by supporting debt advice agencies in many regions. In this we do not intend to market products but to teach people the right handling of money. This we called “Education for saving” in former times.“
This recent statement of the president of the biggest consumer finance group in Germany mirrors the tradition of financial education in continental Europe as well as Japan. Save instead of taking up credit. Credit is a dangerous good. The prove are the overindebted which should be taught a better behaviour through advice and, as the American legislator just ordered it, through compulsory education which we in Europe know from traffic regulation where drunken drivers have to attend compulsory lessons to get their driver’s licence back. Consumers are less knowledgable than in good old times where no consumer seem to have been unable to pay back his or her debts.
Is this true? The credit society did not invent credit but only loans. Credit, saving and value transfer are as old as partition of labour and social life is where overindebtedness had only another name: poverty. In former times credit was given in kind and not in money (just as landlords as well as the state or parents still do). Overindebtedness and financial exclusion appeared as homelessness, orphanage or lack of food and income. Today everything can be bought. Cash is the key to heaven. So all problems can be solved with cash.
But you do not earn it at the time and the lieu where you spend it. This is the main problem which drives all that do not have inherited a comfortable bank account into the use of financial services. Financial services help you to transport your income from your past into your future as old age pensions and savings show, but helps also to access your future earnings at present as loans reveal: It helps to carry it from here to there as payment services promise or from unknown other risk group members to me in case of accidents and mishaps as apparent in insurance contracts.
Because financial services have given a key to the kingdom to everybody mobilising his or her lifetime earnings other credit systems are fading away: the family, social welfare, tenant housing even steady income relations. Financial services just as housing, electricity and phones are goods of basic necessity today in order to be able to use your labour income properly.
This is in general a wonderful opportunity provided by capitalism and the money society to replace the old ties with the freedom of choice and self arranged systems to allocate one’s life-income freely to where and when it is most needed. But this is not for free.
It is offered within a market system based on offer and demand and guided by suppliers who have interests that are different from the needs of consumers. By selling such services they want to say it in consumers’ language “get rich” which translates under a short term perspective into the “shareholder value” approach. It is their view which dominates also such educational concepts which see consumers as “users” or even “investors”. For a banker such attitudes are easier to understand. They can apply their ideologies, knowledge and bargaining skills to find rational solutions. In fact no consumer will be able to ignore these attitudes. In a market economy they have to play these roles and make use of its investment attitudes to get maximum gains in terms of profit and loss. But it would be very dangerous if they forget that money is only a tool to satisfy their needs and that a focus on mere profit making may leave them with unsupportable risks.
Such a conflict between human needs and investors’ interest may arise in a case where for example a family with three kids after having financed the establishment of their family loose their main income through death, illness, accident, divorce or unemployment which makes this household at least temporarily unable to repay its debt. According to our recent report on overindebtedness in Germany single parents are eight times more endangered than families where both parents are still there. The data from 9000 cases in debt advice agencies reveal that stable income relations and savings capabilities are the best way to cope with the existing offer of financial services not only in credit but also in old age pensions, insurance and payment services.
Statistics like the poverty reports of the German or American government tell us that getting wealthy is no longer as easy as dishwasher and self-made man stories (which strange enough never made it to a self-made woman ideology) pretended. The lower 40% of German household have a negative savings ratio. For them saving starts after sale. Are they less responsible than the upper 60% or less intelligent or less skilled than those who can easily shoulder the risks our system spreads to the weakest in society.
Most present concepts of financial education regardless whether they are offered by bankers, honourable politicians or paternalistic debt advice organisations are based on an ideology which focuses on savings and profitable investments, teaches household finance to the poor and praises a decent life. In these concepts banks appear as teachers of the consumers and are given unrestricted access to schools. Duties and not rights are the focus where products and not needs are taught.
Such concepts may help children of the upper classes to maximise the use of their money but blames those who have to use financial services to satisfy their daily needs. Its implicit reproach that consumers could have done better lifts the burden of social responsibility for financial products and strategies from the supplier side.
FINANCIAL EDUCATION FOR BANKS – THE CONCEPT OF RESPONSIBLE CREDIT
If we abandon the simple “get rich” solution for more adequate and empirically informed concepts we find that the existing products and strategies offered by the financial services industry are far from adapted to the modern challenge. Most of their products like for example the fixed rate instalment credit still target a steady earning two parents middle class family misusing family ties for guarantees exploiting temporary needs for higher interest and offer sham solutions which in case of problems profit more from the difficult situation than they help. Risked based pricing have wiped out the opportunities of rational choice for low income consumers, revolving and refinancing schemes have taken away their freedom of contract, cross selling of unnecessary and usurious life insurance with hidden internal provision for the bank act equally as a self-fulfilling prophecy for entangling into debt.
In private pension schemes thousands of skilled experts try to develop risky products with a serious image in order to lure especially low income consumers into loosing schemes. While we would need small flexible savings schemes most for the lower income strata banks have researched how best to get rid of them and minimise the use of such opportunities supposed they exist at all. Fee systems for credit cards and bank accounts are intelligently tailored to rip the poorest in order to cream the rich.
Shall we truly teach the children of the poor that they will have no chances until they get rich? Shall be teach them that they should not care about the Annual Percentage Rate of Charge because this has become the most misrepresenting price element of modern consumer credit? Should we teach children to read three time four to eight pages of financial services information which not even a banker is able to integrate to a picture will tell him or her the true meaning for his or her income, cost and risk while the simple and just information like an amortisation table is withhold until customers are inescapably entangled into the credit relation?
I have been working and calculating financial services for consumers since 1976 and I have written a number of books, made computer programmes and served on numerous occasions as a court witness to recalculate financial services. But still confronted with four selected different offers either in pension schemes or in consumer or mortgage credit, in consumer credit or bank accounts I would not be able to answer your question what would be the best for you in less than a day’s work with more than “it depends”.
Each day the efforts to develop new products that cheat the consumers increase. Bankers George Soros even ask for an external force which give all competitors a clear ceilings and borderlines that would hinder them to invent ever more devastating systems.
The European Coalition for Responsible Credit which is not restricted to credit but takes this as the most important example where banks should learn has put financial education onto the agenda of nearly all its conferences and especially in September conference in Brussels. But ECRC does not think that one can simply learn “financial services” and that bankers are the born teachers in this system or that DG Internal Market has already taken serious steps to improve the situation of consumers with regard to predatory lending.
Most of our members feel that the present 2007 draft of the Consumer Credit Directive is just a step into the other direction which will abolish many of the existing national borderlines and free the credit industry to invent and market products which are to the detriment especially of poor consumers. In this respect we are deeply concerned that also this conference may be part of a strategy where on one hand the spread of dangerous and irresponsible practices is facilitated and national supervision and regulation is reduced while on the other hand consumers shall learn to cope with these effects.
The overflow of detailed information duties with misleading notions like the “borrowing rate”, the abolition of the handwritten signature opening the credit market for mouseclick and foreign predatory lenders, the right of a supplier to hide much of the credit cost in an ancillary insurance product whose cost have not to be included and where most of the premiums instead flow back to the creditor in the form of hidden provisions are not encouraging for financial education.
The present European wide scandal concerning extortionate credit insurance fees shows the limits. Education and regulation must go hand in hand and just as stranded car drivers in the desert cannot be educated to refrain from drinking the battery water when being parched. People in financial distress are hard to convince not to have recourse to the mirages financial suppliers offer as a sham solution.
There are more examples where regulation could save much of the time pupils need at school to learn truly important things instead of short term inventions. The introduction of an early repayment fee into consumer credit will encourage refinancing and revolving systems where even the courts will be unable to find out the true damage. Exempting small and credit card credit as well as overdraft from important information duties will give opportunities to ever more use this form to create overindebtedness with usurious interest rates, chain and multiple credit and extra fees for special situations that basically will burden the poorest.
Information to consumers have is limits and so does a form of education that favours knowledge over social competence. Nobody is able to fully understand what impact financial services will have on his or future life. Needs and money are too different to render this easy.
If financial education is taken serious to prevent adverse effects on weak consumers both sides must be educated.
MUTUAL LEARNING
Who should be the educator? In a liberal democracy a model of financial education is needed where the market participants teach each other what is good and what is possible. Both have the necessary information which the other has to learn. The individual consumer knows his or her needs, the banks know their products and can add the statistical significance of perspectives for the respective consumer situation.
In this respect iff is presently working for different banks to show what impact a certain product will have on different target groups and how a negative impact could be levied by a more adapted and a more targeted financial product. Thus responsible banks that do marketing research extend their research to sociological questions concerning needs, social risks and income. They have the money and can buy the expertise so that the consumer who delivers his personal information can get adequate evaluation instead of obscure scoring points.
But while the consumer has only time to loose from learning to transform needs into financial services the banks are in a prisoners’ dilemma. They are captured by their profit and loss assessment with respect to their competitors and shareholders. Of course on the long ignoring consumer needs and offering socially dysfunctional products and extortionate prices will inflict damages to the whole of the industry. Overindebtedness and failure will certainly diminish the number of potential clients as it is already feared in the United States. But each single supplier may think in shorter terms and build upon the assumption known from environmental policies that others will carry the damages he has done to his customers.
To reverse this mechanism the consumer must be equipped with tools that help to circle these damages back to those who are unwilling to learn.
There are only two such instruments which with regard to profit orientation are able to have this effect evenly: the law and consumer demand. Regulation has the enormous advantage that it affects all suppliers alike and that it creates a body of limits to exploitation and misrepresentation. Just as the most creative music has always been composed within a system of most strict rules the law can stimulate the genius of bankers and thus create a diversity just line Bach developed diversity in music with the “Art of the Fugue”. If such regulation creates closed loops between supply and social effects new products will emerge and just as environmental protection has become a concern in many innovations the prevention of financial distress will be part of the product development. Sociologists can add to marketing as much as biologists and ecologists added to engineering.
Good regulation goes beyond the present regulatory ideology that bad products will be better if only the consumers know that they are bad. It creates trust in a market which is about to slide into anarchic mutual mistrust and misuse. Because the consumer knows that whatever happens he or she will not be left to the sole mercy of one supplier having certain rights which give access to an impartial court system (and not only to supplier dominated arbitration boards) as well as to legal advice (the duty to it has regrettably been taken out of the EU regulation) that will assess the impact of this behaviour for the whole of society and the law.
With more trust in the system banks will gain more consumer confidence too. Moral hazard and adverse selection will be significantly eased when customers experience a system where trust plays a significant role. The highly regulated and supervised Swedish or German financial services system has created enormous consumer confidence and trust which again allowed to include many more low income customers at profitable rates than the Anglo-Saxon systems where exploitation has its only borderline in information.
The other important element is competition which in financial services has enormous problems for consumers. In theory consumers can use competition as a tool to make banks attentive to their needs and learning how to develop responsible financial services by employing exit and voice. But in practice this presupposes that exit is possible and the regulator does not allow or even legislate additional early prepayment fees or other mechanism like the joint use of databases or negative scoring for shopping around as well as hidden prices from X% on hinder a functioning market.
Financial services are nearly all delivered in the form of long term contractual relations. Economic contract theory sees enormous problems to organise such relations at the beginning . Flexibility and productivity of such contractual relations need adequate institutional arrangements which keep the power of the parties alive and channel them into productive further bargaining during the lifetime of the contract. Refinancing, flipping, revolving, early cancellation fees, withholding information etc are all mechanisms which deprive consumers of their power to teach banks and let them learn. To change bank accounts is a three month costly activity with unknown effects because the bank withholds the most important informations necessary to keep economic relations unaffected.
But even where consumers have the power and means to exit they need self-consciousness, knowledge and social competence to voice their concerns and to exercise their exit visibly by using media which will turn their individual decision into a collective action of aggregate demand.
Today such tools are easier to access for ordinary people. The Internet helps to convince arrogant suppliers that the consumer should be in charge of the economy. A Japanese complainant proved that with his website he could mobilise a whole country that read his story and offered support. Consumers have to learn to use this media and they have to be able to voice their concerns in a language where others can identify with. Here the legal language ofters enormous opportunities to create solidarity and support. This all needs freedom of speech for complainants not threatened by legal actions from mighty suppliers in the member states.
FINANCIAL EDUCATION – THE FOUNDATIONS OF A MUTUAL LEARNING PROJECT IN SCHUELERBANKING.DE
Together with the biggest Hamburg consumer bank as well the state school board iff has developed a successful project which now covers about 100 schools with about 2000 pupils aged between 13 and 14 years participating. This project is presently exported to other areas and banks. It had drawn the conclusions out of six years of research on existing financial education schemes around the world which are documented in our two books on financial services.
Consumer needs and social risks are the starting point.
The 300 pages of material started in two areas: consumer credit and bank account where two cases are developed which come close to the present experience of the pupils. Three different severities allow simple, medium and advanced knowledge application. Teacher get extra information. Presently a module on old age pensions as well as a direct banking module and a student loan model for older pupils are under development.
The module translates the needs into financial components and discusses all alternatives including the non-financial as well as the non-professional financial solutions. This gives children an idea what financial services are about: Time, capital and risk have to be understood and the problem of the transportation of income.
Financial products are tailored according to the simple needs
As the financial products offered as solutions by the bankers (and also described in the material) are tailored to the simple needs expressed in the cases the understanding is not burdened with unnecessary details and names. Pupils learn the function of financial services and not the product as such. The project start with credit as the basic financial service which has all important components like time (interest), risk (own risk as well as risk of the product with variable rates in overdraft) and capital (relation between future income and repayments with the advanced capital.) Credit allows to make savings more intelligible because there is not choice but saving after the capital has been received. In order to guarantee the repayment the students have to look thoroughly at their future income and expenditure with regard to the affordable instalment.
Consumer rights and the potential power of aggregate consumer demand are the tools
Students learn about consumer rights and that banks will not only follow their arguments but their interest and the law. Working in groups gives and preparing thoroughly before meeting the bankers gives them social competence and self-consciousness.
Students ask bankers in the bank
Another principle is the principle to question. Students learn to transform their desires into questions. This process is organized in groups with the help of the teacher and the adapted material. Only if they are able to put the adequate questions they will visit the bank. The bank is the realistic out-of-school learning premise where the social competence can be used.
Bankers learn to listen
With the question principle the mutual learning process is complete because bankers have to learn to understand these questions. Students are in groups which provides self-confidence and they are mostly without teacher so that there is no censorship. As they have to write a report on their project the banker will be cautious to give quick answers. Bankers even learn to say that they do not have the right answer by now and will seek time to work on it themselves which increases their learning.
Students evaluate – Bankers evaluate
Both sides evaluate the events constantly. The evaluation on both sides is since now quite enthusiastic. Each year more schools apply for participation. The many affiliates who participate tell about grateful parents that visit them, about new experience and especially enthusiasm of young bank employees who are proud to play the role of the banker while they still recently were students too. As the groups also look for alternative offers and products on the Internet or bring in the experience of their parents with other banks the feedback is also a kind of market research.
iff publications and Websites on financial literacy
Books
• Udo Reifner (ed.): Financial Literacy in Europe. Vol. 9, Veröffentlichung: Baden-Baden Juli 2006
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• Udo Reifner: Finanzielle Allgemeinbildung: Bildung als Mittel der Armutsprävention in der Kreditgesellschaft. Band 6. Baden-Baden 2003
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• Udo Reifner, Anke Dedert, Volkmar Lübke: Finanzielle Allgemeinbildung in Schulbüchern. Eine exemplarische und didaktische Analyse und Bewertung von zwanzig ausgewählten Schulbüchern der Sekundarstufe I in Mathematik, Wirtschafts- und Gesellschaftslehre. Hamburg 2004
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• Populärwissenschaftliche Finanzratgeberreihe (Rowohlt-Verlag): Die Ratgeber sind zweckorientiert und ohne Vorwissen verständlich. Durch Checklisten, Tipps und Übersichten helfen sie den Lesern, ihren persönlichen Weg durch den Finanzdschungel des Alltags zu finden und teure Fehler zu vermeiden. Reinbek 1998-1999
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Articles
• Reifner, Udo: Groth, Ulf : Éducation financière et exclusion sociale en Allemagne. In Exclusion et Liens Financiers - L'exclusion bancaire des particuliers : Rapport du Centre Walras 2004. Paris 2005
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• Reifner, Udo: La discrimination sociale dans l'offrede services financiers : Exclusion et Liens Financiers - L'exclusion bancaire des particuliers: Rapport du Centre Walras. Paris 2004
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• Reifner, Udo; Groth, Ulf: Financial Literacy - German National Report, Hamburg 2004
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• Reifner, Udo: Kanon der finanziellen Allgemeinbildung: Spiegel-Kanon, Wiederholung oder Meisterwerk? Zum Commerzbank-Ideenlabor. Infobrief; Ratgeber zu Finanzdienstleistungen und Verbraucherschutz. Rundbrief im Abonnement 40/03; Hamburg 11.12.2003
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• Tanja Plaisier; Udo Reifner: Verlust des Handys - Was passiert mit dem Mobilfunk-/ Netzkartenvertrag? Institut Für Finanzdienstleistungen e.V.; Ratgeber zu Finanzdienstleistungen und Verbraucherschutz. Rundbrief 36/02; Hamburg 21.10.02
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• Reifner, Udo: Vorschläge zum Projekt "Verbraucherpolitik der Zukunft“. Hamburg 22.11.2000
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• Reifner, Udo: Finanzielle Allgemeinbildung. In: Deutsche Gesellschaft für Hauswirtschaft: Armutsprävention - Aufgabe und Ergebnis aktivierender Gesellschaftspolitik; Dokumentation der Fachtagung der Deutschen Gesellschaft für Hauswirtschaft vom 30.9. bis 2.10.2002. Achen 2003
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Expertise
• Tiffe, Achim; Lübke, Volkmar; Reifner, Udo: "Fit-in-Vorsorge" - Machbarkeitsstudie für ein bundesweites Angebot von Volkshochschulen zur Altersvorsorge. Im Auftrag des Bundesministeriums für Gesundheit und Soziale Sicherung; Hamburg 2004
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• Udo Reifner: Finanzielle Allgemeinbildung II: Pilotphase, Begleitforschung zur Förderung der "Finanziellen Allgemeinbildung zur Armutsprävention". iff intern: Hamburg 2004
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• Reifner, Udo; Dedert, Anke; Lübke, Volkmar: Finanzielle Allgemeinbildung in Schulbüchern; Eine exemplarische inhaltliche und didaktische Analyse und Bewertung von zwanzig ausgewählten Schulbüchern der 8. und 9. Stufe in Mathematik, Wirtschafts- und Gesellschaftslehre; Institut für Finanzdienstleistungen: Hamburg 2004
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• Reifner, Udo: Finanzielle Allgemeinbildung: Bildung als Mittel der Armutsprävention in der Kreditgesellschaft; Projektabschlussbericht zur ersten Phase des vom Bundesministerium für Familie, Senioren, Frauen und Jugend unterstützten Projektes. iff-intern: Hamburg 2001
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Websites
• www.schuelerbanking.de
• www.money-advice.net => keyword: Finanzielle Allgemeinbildung
• www.iff-finanzierungsratgeber.de
• www.finanzen-in-not.de
• www.finanzielle-allgemeinbildung.de |
| ID: |
39576 |
| Author(s): |
UR |
| Publication date: |
28/03/07 |
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Created: 26/03/07. Last changed: 21/11/12.
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