[Federal Register Volume 63, Number 80 (Monday, April 27, 1998)]
[Notices]
[Pages 20633-20637]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 98-11028]
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FEDERAL DEPOSIT INSURANCE CORPORATION
Differences in Capital and Accounting Standards Among the Federal
Banking and Thrift Agencies; Report to Congressional Committees
AGENCY: Federal Deposit Insurance Corporation (FDIC).
ACTION: Report to the Committee on Banking and Financial Services of
the U.S. House of Representatives and to the Committee on Banking,
Housing, and Urban Affairs of the United States Senate Regarding
Differences in Capital and Accounting Standards Among the Federal
Banking and Thrift Agencies.
SUMMARY: This report has been prepared by the FDIC pursuant to Section
37(c) of the Federal Deposit Insurance Act (12 U.S.C. 1831n(c)).
Section 37(c) requires each federal banking agency to report to the
Committee on Banking and Financial Services of the House of
Representatives and to the Committee on Banking, Housing, and Urban
Affairs of the Senate any differences between any accounting or capital
standard used by such agency and any accounting or capital standard
used by any other such agency. The report must also contain an
explanation of the reasons for any discrepancy in such accounting and
capital standards and must be published in the Federal Register.
FOR FURTHER INFORMATION CONTACT: Robert F. Storch, Chief, Accounting
Section, Division of Supervision, Federal Deposit Insurance
Corporation, 550 17th Street, NW., Washington, D.C. 20429, telephone
(202) 898-8906.
SUPPLEMENTARY INFORMATION: The text of the report follows:
Report to the Committee on Banking and Financial Services of the
U.S. House of Representatives and to the Committee on Banking,
Housing, and Urban Affairs of the United States Senate Regarding
Differences in Capital and Accounting Standards Among the Federal
Banking and Thrift Agencies
A. Introduction
This report has been prepared by the Federal Deposit Insurance
Corporation (FDIC) pursuant to Section 37(c) of the Federal Deposit
Insurance Act, which requires the agency to submit a report to
specified Congressional Committees describing any differences in
regulatory
[[Page 20634]]
capital and accounting standards among the federal banking and thrift
agencies, including an explanation of the reasons for these
differences. Section 37(c) also requires the FDIC to publish this
report in the Federal Register. This report covers differences existing
during 1997 and developments affecting these differences.
The FDIC, the Board of Governors of the Federal Reserve System
(FRB), and the Office of the Comptroller of the Currency (OCC)
(hereafter, the banking agencies) have substantially similar leverage
and risk-based capital standards. While the Office of Thrift
Supervision (OTS) employs a regulatory capital framework that also
includes leverage and risk-based capital requirements, it differs in
several respects from that of the banking agencies. Nevertheless, the
agencies view the leverage and risk-based capital requirements as
minimum standards and most institutions are expected to operate with
capital levels well above the minimums, particularly those institutions
that are expanding or experiencing unusual or high levels of risk.
The banking agencies, under the auspices of the Federal Financial
Institutions Examination Council (FFIEC), have developed uniform
Reports of Condition and Income (Call Reports) for all commercial banks
and FDIC-supervised savings banks. Effective with the March 31, 1997,
report date, the FFIEC and the banking agencies adopted generally
accepted accounting principles (GAAP) as the reporting basis for the
balance sheet, income statement, and related schedules in the Call
Report. Prior to 1997, the reporting standards for the bank Call Report
were substantially consistent with GAAP. In the limited number of cases
where the bank Call Report standards differed from GAAP, the regulatory
reporting requirements were intended to be more conservative than GAAP.
Adopting GAAP as the reporting basis for recognition and measurement
purposes in the basic schedules of the Call Report was designed to
eliminate these differences, thereby producing greater consistency in
the information collected in bank Call Reports and general purpose
financial statements and reducing regulatory burden.
The OTS requires each savings association to file the Thrift
Financial Report (TFR), the reporting standards for which are
consistent with GAAP. Thus, through year-end 1996, the reporting
standards applicable to the bank Call Report differed in some respects
from the reporting standards applicable to the TFR. However, with the
banking agencies' move to GAAP for Call Report purposes in 1997, the
most significant differences in reporting standards among the agencies
that were cited in previous reports have been eliminated.1
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\1\ In the following areas, differences in reporting standards
between the banking agencies and the OTS were eliminated in 1997:
sales of assets with recourse, futures and forward contracts, excess
servicing fees, offsetting of assets and liabilities, and in-
substance defeasance of debt.
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Section 303 of the Riegle Community Development and Regulatory
Improvement Act of 1994 (12 U.S.C. 4803) requires the banking agencies
and the OTS to conduct a systematic review of their regulations and
written policies in order to improve efficiency, reduce unnecessary
costs, and eliminate inconsistencies. It also directs the four agencies
to work jointly to make uniform all regulations and guidelines
implementing common statutory or supervisory policies. The results of
these efforts must be ``consistent with the principles of safety and
soundness, statutory law and policy, and the public interest.'' The
four agencies' efforts to eliminate existing differences among their
regulatory capital standards as part of the Section 303 review are
discussed in the following section.
B. Differences in Capital Standards Among the Federal Banking and
Thrift Agencies
B.1. Minimum Leverage Capital
The banking agencies have established leverage capital standards
based upon the definition of Tier 1 (or core) capital contained in
their risk-based capital standards. These standards require the most
highly-rated banks (i.e., those with a composite rating of ``1'' under
the Uniform Financial Institutions Rating System (UFIRS)) to maintain a
minimum leverage capital ratio of at least 3 percent if they are not
anticipating or experiencing any significant growth and meet certain
other conditions. All other banks must maintain a minimum leverage
capital ratio that is at least 100 to 200 basis points above this
minimum (i.e., an absolute minimum leverage ratio of not less than 4
percent).
The OTS has a 3 percent core capital and a 1.5 percent tangible
capital leverage requirement for savings associations. However, the
OTS' Prompt Corrective Action rule requires a savings association to
have a 4 percent leverage capital ratio (or a 3 percent leverage
capital ratio if it is rated a composite ``1'' under the UFIRS) in
order for the association to be considered ``adequately capitalized.''
Consequently, the 4 percent leverage capital ratio is, in effect, the
controlling leverage capital standard for savings associations other
than those rated a composite ``1.''
As a result of the agencies' Section 303 review of their regulatory
capital standards, the agencies issued a proposal for public comment on
October 27, 1997, that, among other provisions, would establish a
uniform leverage requirement. As proposed, institutions rated a
composite 1 under the Uniform Financial Institutions Rating System
would be subject to a minimum 3 percent leverage ratio and all other
institutions would be subject to a minimum 4 percent leverage ratio.
This change would simplify and streamline the agencies' leverage rules
and make them uniform. The comment period for the proposal ended on
December 26, 1997.
B.2. Interest Rate Risk
Section 305 of the Federal Deposit Insurance Corporation
Improvement Act of 1991 mandates that the agencies' risk-based capital
standards take adequate account of interest rate risk. In August 1995,
each of the banking agencies amended its capital standards to
specifically include an assessment of a bank's interest rate risk, as
measured by its exposure to declines in the economic value of its
capital due to changes in interest rates, in the evaluation of bank
capital adequacy. In June 1996, the banking agencies issued a Joint
Agency Policy Statement on Interest Rate Risk which provides guidance
on sound practices for managing interest rate risk. This policy
statement does not establish a standardized measure of interest rate
risk nor does it create an explicit capital charge for interest rate
risk. Instead, the policy statement identifies the standards that the
banking agencies will use to evaluate the adequacy and effectiveness of
a bank's interest rate risk management.
In 1993, the OTS adopted a final rule which adds an interest rate
risk component to its risk-based capital standards. Under this rule,
savings associations with a greater than normal interest rate exposure
must take a deduction from the total capital available to meet their
risk-based capital requirement. The deduction is equal to one half of
the difference between the institution's actual measured exposure and
the normal level of exposure. The OTS has partially implemented this
rule by formalizing the review of interest rate risk; however, no
deductions from capital are being made. As described above, the
approach adopted by the banking agencies differs from that of the OTS.
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B.3. Subsidiaries
The banking agencies generally consolidate all significant
majority-owned subsidiaries of the parent bank for regulatory capital
purposes. The purpose of this practice is to assure that capital
requirements are related to all of the risks to which the bank is
exposed. For subsidiaries which are not consolidated on a line-for-line
basis, their balance sheets may be consolidated on a pro-rata basis,
bank investments in such subsidiaries may be deducted entirely from
capital, or the investments may be risk-weighted at 100 percent,
depending upon the circumstances. These options for handling
subsidiaries for purposes of determining the capital adequacy of the
parent bank provide the banking agencies with the flexibility necessary
to ensure that institutions maintain capital levels that are
commensurate with the actual risks involved.
Under the OTS' capital guidelines, a statutorily mandated
distinction is drawn between subsidiaries engaged in activities that
are permissible for national banks and subsidiaries engaged in
``impermissible'' activities for national banks. For regulatory capital
purposes, subsidiaries of savings associations that engage only in
permissible activities are consolidated on a line-for-line basis, if
majority-owned, and on a pro rata basis, if ownership is between 5
percent and 50 percent. For subsidiaries that engage in impermissible
activities, investments in, and loans to, such subsidiaries are
deducted from assets and capital when determining the capital adequacy
of the parent.
B.4. Servicing Assets and Intangible Assets
The banking agencies' rules permit mortgage servicing assets and
purchased credit card relationships to count toward capital
requirements, subject to certain limits. These two categories of assets
are in the aggregate limited to 50 percent of Tier 1 capital. In
addition, purchased credit card relationships alone are restricted to
no more than 25 percent of an institution's Tier 1 capital. Any
mortgage servicing assets and purchased credit card relationships that
exceed these limits, as well as all other intangible assets such as
goodwill and core deposit intangibles, are deducted from capital and
assets in calculating an institution's Tier 1 capital.
The OTS's capital treatment of servicing assets and intangible
assets is generally consistent with the banking agencies' rules.
However, the OTS rule grandfathers core deposit intangibles acquired
before February 1994 up to 25 percent of core capital and all purchased
mortgage servicing rights acquired before February 1990.
B.5. Capital Requirements for Recourse Arrangements
B.5.a. Leverage Capital Requirements--With certain exceptions, the
banking agencies required full leverage capital charges on assets sold
with recourse through December 31, 1996. This leverage capital
treatment applied to most assets sold with recourse because the banking
agencies' pre-1997 regulatory reporting rules generally did not permit
such assets to be removed from a bank's balance sheet. As a result,
assets sold with recourse were included in the asset base used to
calculate a bank's leverage capital ratio.
As a result of the adoption of GAAP as the reporting basis for bank
Call Reports in 1997, banks have now joined savings associations in
being able to remove assets transferred with recourse from their
balance sheets if the transfers qualify for sale treatment under GAAP.
Thus, banks, like savings associations, are not required to hold
leverage capital against assets sold with recourse and this difference
in capital standards was eliminated in 1997.
B.5.b. Senior-Subordinated Structures--Some asset securitization
structures involve the creation of senior and subordinated classes of
securities. When a bank originates such a transaction and retains the
subordinated interest, the banking agencies generally require that the
bank maintain risk-based capital against the entire amount of the asset
pool unless the low-level recourse rule applies.2 However,
when a bank acquires a subordinated interest in a pool of assets that
it did not own, the banking agencies assign the investment in the
subordinated security to the 100 percent risk weight category.
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\2\ When assets are sold with limited recourse, the banking and
thrift agencies' risk-based capital standards limit the amount of
capital that must be maintained against this exposure to the lesser
of the amount of the recourse retained (e.g., through the retention
of a subordinated interest) or the amount of risk-based capital that
would otherwise be required to be held against the assets, i.e., the
full effective risk-based capital charge. This is known as the
``low-level recourse'' rule.
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In general, the OTS requires a thrift that holds the subordinated
interest in a senior-subordinated structure to maintain capital against
the entire amount of the underlying asset pool regardless of whether
the subordinated interest has been retained or has been purchased.
On November 5, 1997, the banking and thrift agencies issued a
proposal that, among other provisions, generally would treat both
retained and purchased subordinated interests similarly for risk-based
capital purposes, i.e., banks and thrifts would be required to hold
capital against the subordinated interest plus all more senior
interests unless the low-level recourse rule applies. The proposal also
includes a multi-level approach to capital requirements for asset
securitizations. The multi-level approach would vary the risk-based
capital requirements for positions in securitizations, including
subordinated interests, according to their relative risk exposure. For
positions that are traded, the risk-based capital treatment would be
based on credit ratings from nationally recognized rating agencies. For
positions that are not traded, the proposal presents three alternative
approaches for determining the risk-based capital requirements. In
general, these alternative approaches would use ratings from two rating
agencies, benchmark guidelines developed by the banking and thrift
agencies, and statistical evaluations of historical loss data. The
comment period for the proposal ended on February 3, 1998.
B.5.c. Recourse Servicing--The right to service loans and other
financial assets may be retained when the assets are sold. This right
also may be acquired from another entity. Regardless of whether
servicing rights are retained or acquired, recourse is present whenever
the servicer must absorb credit losses on the assets being serviced.
The banking agencies and the OTS require risk-based capital to be
maintained against the full amount of assets upon which a selling
institution, as servicer, must absorb credit losses. Additionally, the
OTS applies a capital charge to the full amount of assets being
serviced by a thrift that has purchased the servicing from another
party and is required to absorb credit losses on the assets being
serviced.
The agencies' November 1997 risk-based capital proposal would
require banking organizations that purchase loan servicing rights which
provide loss protection to the owners of the serviced loans to begin to
hold capital against those loans, thereby making the risk-based capital
treatment of these servicing rights uniform for banks and savings
associations.
B.6. Collateralized Transactions
The FRB and the OCC assign a zero percent risk weight to claims
collateralized by cash on deposit in the institution or by securities
issued or guaranteed by the U.S. Government or the central governments
of countries that are members of the Organization of
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Economic Cooperation and Development (OECD), provided a positive margin
of collateral protection is maintained daily.
The FDIC and the OTS assign a 20 percent risk weight to claims
collateralized by cash on deposit in the institution or by securities
issued or guaranteed by the U.S. Government or OECD central
governments.
As part of the Section 303 review of their capital standards, the
banking and thrift agencies issued a joint proposal in August 1996 that
would permit collateralized claims that meet criteria that are uniform
among all four agencies to be eligible for a zero percent risk weight.
In general, this proposal would allow institutions supervised by the
FDIC and the OTS to hold less capital for transactions collateralized
by cash or U.S. or OECD government securities. The proposal would
eliminate the differences among the agencies regarding the capital
treatment of collateralized transactions.
B.7. Presold Residential Construction Loans
The four agencies assign a 50 percent risk weight to loans that a
builder has obtained to finance the construction of one-to-four family
residential properties. These properties must be presold, and the
lending relationship must meet certain other criteria. The OTS and the
OCC rules indicate that the property must be presold before the
construction loan is made in order for the loan to qualify for the 50
percent risk weight. The FDIC and FRB permit loans to builders for
residential construction to qualify for the 50 percent risk weight once
the property is presold, even if that event occurs after the
construction loan has been made.
As a result of their Section 303 review, the agencies' previously
mentioned October 27, 1997, regulatory capital proposal includes a
provision under which the OTS and the OCC would adopt the treatment of
presold residential construction loans followed by the FDIC and the
FRB. This would make the agencies' rules in this area uniform.
B.8. Junior Liens on One-to-Four Family Residential Properties
In some cases, a bank may make two loans on a single residential
property, one secured by a first lien, the other by a second lien. In
this situation, the FRB and the OTS view both loans as a single
extension of credit secured by a first lien and assign the combined
loan amount a 50 percent risk weight if this amount represents a
prudent loan-to-value ratio. If the combined amount exceeds a prudent
loan-to-value ratio, the loans are assigned to the 100 percent risk
weight category. The FDIC also combines the first and second liens to
determine the appropriateness of the loan-to-value ratio, but it
applies the risk weights differently than the FRB and the OTS. If the
combined loan amount represents a prudent loan-to-value ratio, the FDIC
risk weights the first lien at 50 percent and the second lien at 100
percent; otherwise, both liens are risk-weighted at 100 percent. This
combining of first and second liens is intended to avoid possible
circumvention of the capital requirement and to capture the risks
associated with the combined loans.
The OCC treats all first and second liens separately. It assigns
the loan secured by the first lien, if it has been prudently
underwritten, to the 50 percent risk weight category; otherwise, it
assigns the loan to the 100 percent risk weight category. In all cases,
the OCC assigns the loan secured by the second lien to the 100 percent
risk weight category.
As a result of the Section 303 review of their capital standards,
the agencies' October 27, 1997, proposal would extend the OCC's
treatment of junior liens on one-to-four family residential properties
to all four agencies and thereby eliminate this difference among the
agencies.
B.9. Mutual Funds
The banking agencies assign the entire amount of a bank's holdings
in a mutual fund to the risk category appropriate to the highest risk
asset that a particular mutual fund is permitted to hold under its
operating rules. Thus, the banking agencies take into account the
maximum degree of risk to which a bank may be exposed when investing in
a mutual fund because the composition and risk characteristics of the
fund's future holdings cannot be known in advance. In no case, however,
may a risk-weight of less than 20 percent be assigned to an investment
in a mutual fund.
The OTS applies a capital charge appropriate to the riskiest asset
that a mutual fund is actually holding at a particular time, but not
less than 20 percent. In addition, both the OTS and the OCC guidelines
also permit, on a case-by-case basis, investments in mutual funds to be
allocated on a pro rata basis. However, the OTS and the OCC apply the
pro rata allocation differently. While the OTS applies the allocation
based on the actual holdings of the mutual fund, the OCC applies it
based on the highest amount of holdings the fund is permitted to hold
as set forth in its prospectus.
As part of the agencies' Section 303 review of their regulatory
capital standards, one provision of their October 27, 1997, proposal
would apply the banking agencies' treatment of mutual funds to all
institutions. However, the proposal also would permit institutions, at
their option, to adopt the OCC's pro rata allocation alternative for
risk weighting investments in mutual funds. This proposal would make
the agencies' risk-based capital rules in this area uniform, thereby
eliminating this capital difference.
B.10. Noncumulative Perpetual Preferred Stock
Under the banking and thrift agencies' capital standards,
noncumulative perpetual preferred stock is a component of Tier 1
capital. The FDIC's capital standards define noncumulative perpetual
preferred stock as perpetual preferred stock where the issuer has the
option to waive the payment of dividends and where the dividends so
waived do not accumulate to future periods and do not represent a
contingent claim on the issuer. Under the FRB's capital standards,
perpetual preferred stock is noncumulative if the issuer has the
ability and legal right to defer or eliminate preferred dividends. For
these two agencies, for a perpetual preferred stock issue to be
considered noncumulative, the issue may not permit the accruing or
payment of unpaid dividends in any form, including the form of
dividends payable in common stock. Thus, if the issuer of perpetual
preferred stock is required to pay dividends in a form other than cash
when cash dividends are not or cannot be paid, the issuer does not have
the option to waive or eliminate dividends and the stock would not
qualify as noncumulative. The OCC's capital standards do not explicitly
define noncumulative perpetual preferred stock, but the OCC normally
has not considered perpetual preferred stock issues with this type of
dividend requirement to be noncumulative.
The OTS defines as noncumulative those issues of perpetual
preferred stock where the unpaid dividends are not carried over to
subsequent dividend periods. This definition does not address the
issuer's ability to waive dividends. As a result, the OTS has permitted
perpetual preferred stock issues that require the payment of dividends
in the form of stock in the issuer when cash dividends are not paid to
qualify as noncumulative.
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B.11. Limitation on Subordinated Debt and Limited-Life Preferred Stock
Consistent with the Basle Accord, the banking agencies limit the
amount of subordinated debt and intermediate-term preferred stock that
may be treated as part of Tier 2 capital to an amount not to exceed 50
percent of Tier 1 capital. In addition, all maturing capital
instruments must be discounted by 20 percent in each of the last five
years before maturity. The banking agencies adopted this approach in
order to emphasize equity versus debt in the assessment of capital
adequacy.
The OTS has no limitation on the ratio of maturing capital
instruments as part of Tier 2 capital. Also, for all maturing
instruments issued on or after November 7, 1989 (those issued before
are grandfathered with respect to the discounting requirement), thrifts
have the option of using either (a) the discounting approach used by
the banking regulators, or (b) an approach which allows for the full
inclusion of all such instruments provided that the amount maturing in
any one year does not exceed 20 percent of the thrift's total capital.
B.12. Privately-Issued Mortgage-Backed Securities
The banking agencies, in general, place privately-issued mortgage-
backed securities in either the 50 percent or 100 percent risk-weight
category, depending upon the appropriate risk category of the
underlying assets. However, privately-issued mortgage-backed
securities, if collateralized by government agency or government-
sponsored agency securities, are generally assigned to the 20 percent
risk weight category.
The OTS assigns privately-issued high-quality mortgage-related
securities to the 20 percent risk weight category. These are,
generally, privately-issued mortgage-backed securities with AA or
better investment ratings.
B.13. Other Mortgage-Backed Securities
The banking agencies and the OTS automatically assign to the 100
percent risk weight category certain mortgage-backed securities,
including interest-only strips, principal-only strips, and residuals.
However, once the OTS' interest rate risk amendments to its risk-based
capital standards take effect, stripped mortgage-backed securities will
be reassigned to the 20 percent or 50 percent risk weight category,
depending upon these securities' characteristics. Residuals will remain
in the 100 percent risk weight category.
B.14. Nonresidential Construction and Land Loans
The banking agencies assign loans for nonresidential real estate
development and construction purposes to the 100 percent risk weight
category. The OTS generally assigns these loans to the same 100 percent
risk category. However, if the amount of the loan exceeds 80 percent of
the fair value of the property, the excess portion is deducted from
capital.
B.15. ``Covered Assets''
The banking agencies generally place assets subject to guarantee
arrangements by the FDIC or the former Federal Savings and Loan
Insurance Corporation in the 20 percent risk weight category. The OTS
places these ``covered assets'' in the zero percent risk-weight
category.
B.16. Pledged Deposits and Nonwithdrawable Accounts
Instruments such as pledged deposits, nonwithdrawable accounts,
Income Capital Certificates, and Mutual Capital Certificates do not
exist in the banking industry and are not addressed in the banking
agencies' capital standards.
The OTS' capital standards permit savings associations to include
pledged deposits and nonwithdrawable accounts that meet OTS criteria,
Income Capital Certificates, and Mutual Capital Certificates in
regulatory capital.
B.17. Agricultural Loan Loss Amortization
In the computation of regulatory capital, those banks accepted into
the agricultural loan loss amortization program pursuant to Title VIII
of the Competitive Equality Banking Act of 1987 may defer and amortize
certain losses related to agricultural lending that were incurred on or
before December 31, 1991. These losses must be amortized over seven
years. The unamortized portion of these losses is included as an
element of Tier 2 capital under the banking agencies' risk-based
capital standards.
Thrifts were not eligible to participate in the agricultural loan
loss amortization program established by this statute.
Because the banking agencies' agricultural loan loss amortization
program ends on December 31, 1998, this difference will disappear on
that date.
C. Differences in Accounting Standards Among the Federal Banking and
Thrift Agencies
C.1. Push Down Accounting
Push down accounting is the establishment of a new accounting basis
for a depository institution in its separate financial statements as a
result of a substantive change in control. Under push down accounting,
when a depository institution is acquired in a purchase (but not in a
pooling of interests), yet retains its separate corporate existence,
the assets and liabilities of the acquired institution are restated to
their fair values as of the acquisition date. These values, including
any goodwill, are reflected in the separate financial statements of the
acquired institution as well as in any consolidated financial
statements of the institution's parent.
The banking agencies require push down accounting when there is at
least a 95 percent change in ownership. This approach is generally
consistent with accounting interpretations issued by the staff of the
Securities and Exchange Commission.
The OTS requires push down accounting when there is at least a 90
percent change in ownership.
C.2. Negative Goodwill
Under Accounting Principles Board Opinion No. 16, ``Business
Combinations,'' negative goodwill arises when the fair value of the net
assets acquired in a purchase business combination exceeds the cost of
the acquisition and a portion of this excess remains after the values
otherwise assignable to the acquired noncurrent assets have been
reduced to zero.
The banking agencies require negative goodwill to be reported as a
liability on the balance sheet and do not permit it to be netted
against goodwill that is included as an asset. This ensures that all
goodwill assets are deducted in regulatory capital calculations
consistent with the internationally agreed-upon Basle Accord.
The OTS permits negative goodwill to offset goodwill assets on the
balance sheet.
Dated at Washington, D.C., this 21th day of April, 1998.
Federal Deposit Insurance Corporation.
Robert E. Feldman,
Executive Secretary.
[FR Doc. 98-11028 Filed 4-24-98; 8:45 am]
BILLING CODE 6714-01-P
