Meet the Man Who Blew the Whistle on LIBOR

an introduction, let's talk about what libor is. Librar is the London Interbank Offered rate, and it is, as you mentioned, Joe, in a state of transition. Just for background, this is basically the reference rate that governs trillions of dollars worth of asset prices. So, for instance, if you sell a bond in the market, it will be priced off lib or um, so whatever the inter bank offered rate is plus an additional yield. Same thing if you sell alone

home mortgages priced off lib or. Basically, the financial system has for many many years run on library and that is a big deal because we are supposed to be moving away from that particular reference rate, right, So this is not a topic that I know particularly well. I know about the centrality of the rate. I know that there is an effort afoot to move all of these various offerings that currently index in some way to libel onto something new, which will get to in this series.

And I know that around the time of the crisis there was a manipulation of this price and that that was a major scandal, and that the way the price is set and measured opened itself to all kinds of shenanigans. But honestly, I don't know much more about it than that. I don't know much about its history. I don't know

the degree to which the manipulation really affected things. I don't know why it's so difficult to change, and I'm very much looking forward to learning more as we embark on this series, because although I don't know very much about it, I get the sense that this is extremely important and that people in credit market it's one of the big things that is going to affect their industry, and that they're all watching absolutely And you've set the

scene perfectly, and we are actually going to start with a discussion about what lib or is, how it came into being and of course the manipulation scandal that happened after the financial crisis. So it's a good place to start. And our guest is actually the perfect guests to talk about this. Uh. He's basically been a Cassandra when it comes to warning about the potential for banks to do sketchy stuff with lib or. His name is Richard Rob.

He's currently the CEO of the hedge fund Christoffers and Rob also a professor at Columbia and many many years ago, he was actually a rates trader at d KB Financial in New York, and he famously wrote a letter to one of the regulators, the CFDC, warning of the potential for library manipulation. And this was way back in I think the late So really the perfect person to discuss this. I can't wait. I can't wait to learn all about it. Excellent, Richard,

thank you so much for coming on. Great to be here, so I guess too. Just to begin with, I'm curious, what was it like being a rates trader in the nineties. Quite a lot happening back then when it comes to interest rates. Oh, it was so much fun. Um the interest rates would move ten fifteen bases points. Today the interbank market was very active. You know, the ib and lib or stands for interbank. So banks would and borrow and lend to each other, and the rates that they

would lend were important to the banks. They're important to financial markets at the time. So d k B was stands for Dai Chi Kangyo Bank and we're actually the largest bank in the world at the time. And you know, I know it's my students Columbia, Japanese students and some of them, you know, have never heard of d k B. It kind of breaks my heart, you know. But then my my students at Columbia, Uh, it breaks my heart that they haven't heard of d k B because a

great bank. It was a fun place to work. It's merged and formed Mizuho now, which readers will know, listeners will know. The capital markets were developing. They're developing in Japan, and it was kind of the heyday of financial engineering before the word term financial engineering became, um, you know, a way to disparage. You know, it's an exercise, and financial engineering and those as it was something to be

proud of. So let's you know, let's really break this down into simple basic ideas for people like me and maybe a few of our listeners who don't know as much. You mentioned, uh, you know, the ib and library inter bank. What was it attempting to measure specifically and why did did this need there to be an index at all? Yeah, well,

this was created by the British Bankers Association. It was meant to provide a benchmark index for short term borrowing costs, originally for banks, and then over time that was extended to companies, to loans, to home mortgages, and then into many different currencies as well as U S dollars. The index was created for not just three months live or but six months, one year and various other terms of one year and less. So it's set once a day in London. It's meant to reflect the term the L

in Library can be confusing. It it really stands for offshore when offshore activity was headquartered in London, but it can be a deposit booked in Cayman or Nassau or London or any place that's outside of the scope of of taxation or deposit insurance to reflect the truest cost of funds that a bank would encounter without any of these special institutional details that might be UH, come with an onshore deposit. It's been a survey. It's always been

a survey. And at the time the question that was created by the British Bankers Association was to pull banks and they would ask them, if you were to go out and borrow US dollars at to call another bank and in UH in normal size, what rate did you perceive you would be able to borrow if you didn't negotiate the price. So that's what makes it the off heard side. You call, you don't negotiate, and you say

where where could I borrow money? M What made libror special compared to other interest rates that were in use in the eighties or the nineties. Why did the market need an expected rate versus an actual rate? You know, we had the prime rate, which was UH. Some some loans and derivatives were based off the US prime rate, which was a hard thing to understand. It was set by banks. Different banks would have different prime rates, and

there wasn't much theory. There wasn't sometimes it wouldn't respond to market developments. It was and in each bank, which set it at its own discretion um there was so the market needed an index. If you wanted to borrow money and you wanted the rate to go up. You could except the rate going up if inflation went up or short term rates go up according to the business cycle.

This was the index. Another know, another possibility would be to use US Treasury bills, but those have their own special features that might not be relevant to a company that was borrowing or a bank that was borrowing. The rate on US Treasury bills could depend on the supply

and demand of T bills. It could depend on yeah costs of borrowing in the private credit markets could go up without a corresponding change in Treasury bills, and banks would Banks that were receiving live ard payments would expect to see more and UH that would not be accounted for in an index based on treasury bill So there was a demand for an index. It had to be based on a survey. They would survey. The survey got

up to twenty banks. Banks voluntarily participated at the time because it was considered prestigious to be in the index, and they British Bankers Association would throw out the you know, when it got up to when it was sixteen banks, they would throw out the top four and the bottom four.

They were pulled each morning at eleven o'clock London time, throughout the top four, the bottom four average, the eight that remained round to five decimal places and that's US dollar libar that day in one month, two month, three months, four or five, six, and so on up to twelve months. So it's kind of like how they measure gymnastics or ice skating at the Olympics and they throw out the Russian judge and they throw out the US judge so that they skew unscrew the polls, and then everyone else

they get an average. Yeah, and it's also similar and that you get to see what in the Olympics. You see what each judge rates the performance. Uh. It was also out in the open at the time, so you could see what right each bank that was in the survey,

which rate, what rate they posted. We tend to think of transparency is being virtuous and good under every circumstance, but that was part of that was also a part of the problem at the time, because if a bank was perceiving that was having funding troubles, it would have a self interest not to reveal that to the whole world by posting a high rate. There's the question posed by the British Bankers Association, if you went to borrow

without negotiating, what rate do you perceive? And let's say in the late nineties during the Asian crisis, a bank like d k B or Fujibank was having funding pressures. They didn't want to say, oh, well, all right, would be very high because nobody wants to lend to us, and by the way, we just want everybody to see it in this official calculation. So there was a moment

in um again. I think it was the late nineties when library sort of became even more embedded with the financial market, and that was when the CME, the Chicago Mercantile Exchange decided to use libor instead of a reference rate that it had been calculating previously. Why did it decide to do that and how did that impact the market and librars overall integration with the market. The Chicago Mercantile Exchange had a contract UH that it launched shortly

after the British Bankers Association created libor. The They used to have also another index they used to have as a commercial paper index, but that also had a lot of idiosyncrasies that were attached to it. That made it, that made it unhelpful. So they switched to something that they call your dollars and euro dollars were based on an index that the Chicago More can Till Exchange created to try to mimic the mimic library, and it would

differ from library by a basis point or two. So there they would conduct their survey on four times a year on the Monday before the third Wednesday of every March, June, September, and December. So and it was they would draw from a very large panel of banks. It was random. Then they would they picked twenty banks, and then they threw out the top and the bottom it was anonymous, and then they did the whole thing again. They randomized again

to pick twenty banks, and then they surveyed them. They didn't know banks, didn't know who was going to be surveyed, and then they would average the results of those of

those two surveys together. Um it was. It was created and in the in the mid eighties by the chief economist fred Ar Ditty at the Chicago Mark Until Exchange, who who was a beloved character in the futures markets by many people, including me, UM and then in ninety sex the Chicago more Until Exchange applied to the CFTC to switch to using the Official British Bankers Association UH contract.

They were worried at the time that some competitive competitive exchange would create a contract based on Official Library and that that might give them an advantage because loans, interest rate swaps and so forth we're all tied to the Official Library. Talks to us a little bit about that

sort of network effect. Why in why there are can't be or why it's difficult to imagine a world of multiple indexes or mortgages and credit cards and all these things and they all eventually sort of uh coalesce around one. Why does that naturally happen? And uh one sort of has to emerge the LIB you know, if there are

many industries around first to create its noise. For if you if you have an interest rate swap and you're paying b B a official library, and you're hedging using your dollar futures, you have a kind of basis risk there. Now you can be trying to be very clever and understand the basis risk and make it operate to your advantage.

People try to do that and then if there are many industries floating around, the users of those industries will worry that, you know, some whoever is offering them the product or some index that they didn't expect, is doing this in an unscrupulous way. So if there's a single index, then it's the same for everybody. And it's clearly the same for everybody. I think it's a healthy thing, just

not the index of the b B A head. So by library has sort of edged out a bunch of other rates in the market and sort of is on its way to becoming the standard. The CME has just adopted it for Euro dollar futures, and that I think is when you wrote your very well known letter to the CFTC in protest of this move. What did the

letters say? Yeah, I wrote the letter before they actually had permission from the CFTC to make the switch because I wanted to stop them from doing it, because I thought their survey was much better than the than the B B A survey. I argued that there were two problems with the b B A index. First, that a small number of banks were were selected and the same ones were selected again and again. They were all active participants in derivatives and that they might move the rate

to their own advantage, that they might manipulate it. At the time, it was unregulated, there were no particular criminal penalties for doing this, and all that's changed after after the crisis. Um. And then I also argued that a bank might try to disguise its funding troubles because it was because it didn't want to make them worse by

posting a high rate. If that's what it truly believed in the letter, I just I just dug up the letter the other day before I came to see you, and I wrote in the letter that you know the CME claims that the b b A survey will self correct if markets become more volatile. They argue that the outstanding notional of instruments tied to b b A fixings is enormous, and I wrote, but enormous markets create enormous temptations. The CME argument works only to the extent that we

rely on BBA members to look beyond their self interests. Again, without impugning any of the b b A banks, we do not consider this to be a sound basis for predicting human behavior. So I was a snarky little guy then,

But well, obviously spot on two. But so in retrospect, obviously your argument, we'll get to the manipulation that did occur, But in retrospect the issues that you highlighted back then, they're like, oh, yeah, it seems obvious the potential for manipulation to make trades go one way, and a bank facing funding stress isn't going to want to put an accurate number on a survey in which the survey is not anonymous, So that all seems like obvious in retrospect.

Why wasn't this a source of concern from the very beginning or while? Because? Yeah, why weren't there more worried about that? Because it seemed to be working? Uh, it was. The derivatives market was growing, that forward rate agreements, which are tied to live or were growing. Um, the whole market was centered on live ar was expanding to sixteen currencies. It's I think you have to wait for something bad to happen before you can disrupt a force like that

sounds like how the world works, and I'm afraid it does. Yeah. Did anyone from the c f TC get back to you? Yeah, they got back to me. As I recall, they said they worked at a daylet it was a business decision, and they gave me a sweatshirt. They gave you a sweatshirt. Do you still have it? Oh? Man? That that that

was That was the outcome. Ah, I love that detail. Um. So obviously librar continued to grow by the time, you know, fast forward a few years, by the time we get to the financial crisis and when the Shenanigan started to be uncovered. How much of the world credit markets and how much was linked then to this one index. You know, they say that US dollar libar has a four dred

and fifty trillion dollar footprint right now. It's probably about the same at the time if you count your at dollar futures, corporate loans, all loans are tied to live bar. This is just dollars and it's probably just as big in euros tied to your eye bar um, British poems, yeah, Swiss frank and many other currencies at the time. So the number safe something. I mean, if you count every year at all our futures contract you get to quite lofty numbers. I mean adding them all together is is

in a way kind of buff fishy. But that's that it's huge by by any standards of hugeness, it's huge. So if we fast forward to two thousand eight or two thousand nine, as far as I can remember, the charges of liborary manipulation or the rumors of liborary manipulation started surfacing in the financial media I think in early two thousand nine, and you sort of got a steady drip of allegations of certain behavior. What did you think in those days watching this where you just sort of

sat in your office, going, see, I told you so hopefully. Uh, in those days I had other things, um problems of my own at that moment. There's a key turning point in the first quarter of two thousand and eight in understanding what happened to Liebor, we have to recognize the change in the policy of the Federal Reserve to start paying interest on access reserves that banks held at the FED. Banks would the starting in in Q one O eight um.

The Fed would pay at the top of its target at at its target rate, and then later at the top of its target range money that banks left at the fat So why would I lend to another bank when I could just leave the money at the Central Bank and get a generous interest rate, I wouldn't. So as a result of that, library became unhinged to anything that was happening in the world. Two thousand seven. It's not not to do with the financial crisis. Is just a change that Bernanke had planned for a long time

at the Federal Reserve. So the interbank, the ib and the liebar vanished. So it left banks to really guess what they might borrow if they were to borrow, even though they hadn't borrowed no long time. There's a year's roll by. It became, you know, the individuals at the banks responsible for submitting the uh libar each day would just uh, you know, imagine what they might have done if an interbank market still existed, but it didn't exist. Talk to us a little bit more about the process

back when it had existed and then didn't. So the survey says, what do you think that you could borrow at if you weren't negotiating? What would you be offered at? What was the actual process within a generic bank, someone's job was to come up with that number. How would they have done that? And then how did that change once that market disappeared. I can only speak from my

own bank at the time. We would wait. There was a bank called Fujibank that would submit it, and you could see their submission, and we would wait and do something close to their What they actually did at Fujibank, I don't know, but it would. It would pretty much be based on at the time on what the overnight rate was, plus an expectation for what the overnight rate would average over the term because borrowing overnight overnight rolling it for ninety days is a substitute for borrowing for

ninety days at a term rate. So more or less be the bank's estimate of what they expected from the Federal Reserve over the three month period, and then a little bit more because it was the offered side the o r. And then if there were some liquidity premium, some pressures on term funding, some extra compensation that a bank would be willing to pay for having the money for three months or six months, then they would tack on a basis point or two for that. But it

was that was actually very small. So it's really just what do we think the overnight rate will average during this time, um us a little bit for the offered side, and that that was how it worked. Could you walk us through the exact motivations for manipulating library because and and specifically the motivation for manipulating librar higher because I

think a lot of people will understand that. You know, you might low ball the number because you don't want to out yourself as having a higher rate of borrowing in the inter bank market than some of your other bank peers. But why would anyone want to manipulate the rate higher? How did that work? Okay? There are two classes of manipulation here. The first is if you're receiving or making a payment tied to libor, you might if you're making a payment, you would like it a little lower.

If you're receiving a payment tied to live or, you would like it to be a little higher. Now, you might be making a payment or receiving a payment depending most likely tied to an interest rate swap. So in an interest rate swap, a bank will pay fixed and receive a sequence of payments based on live or or. If it's um receiving a fixed rate, it will make payments tied to live or. So it's completely symmetrical that way.

There may be days when a bank has a big live or fixing on an interest rate swap where it's receiving fixed and would like it to be a little higher, or days when it's paying fixed and would like it to be a little lower. That's that's kind of a micro manipulation. And then there's the other there's there's the signaling effect where it would like to create lower It doesn't want to stand out from the crowd if there's

suspicion that it has um funding problems. The so called Live War scandal was the first kind of manipulation where banks would presumably change their rate based on what was going to happen on their self interest at that day. Now, you mentioned in the beginning, I think you said they pulled twenty banks. They lop off the top four and

they lop off the bottom four. So that makes it difficult, of course for anyone bank to manipulate uh the underlying price because you could post something extreme in one direction, but they'll just lop it off. This gets to where there must have been and there was an element of collusion. Okay, I don't believe I agree with your your statement that it's hard to move the rate by very much. So you know, a bank like Barclays might move the rate by let's say eight basis points, and they can still

not be lopped off. Let's take the case where they're Let's suppose that they're able to move the rate by one basis point, right, I think that's possible acting on their own. Let's say that they're receiving a five billion dollars set. They're receiving that, and they can make the dollar reset for three months, So that's twenty one basis point on a million dollars is so in five million,

it's a hundred and twenty five thousand dollars. So if they can move it up by a basis point, which would be heroic for them to do that, they could Yet they could make a hundred and twenty five dollars, So you know, this has been called Rolling Stone called this the scandal of all scandals. Some UH publications called this the greatest crime of the twentie century. I don't know what the greatest crime of the twentieth century is,

but I don't think it's this. I mean, I think it's small change that the manipulation that they were able to affect and collusion, you know, I don't believe that there was collusion. I don't know that, but would be very hard. If any collusion were to happen, it would be orchestrated by the brokers. Okay, eye cap has been implicated in this, but since banks have competing interests every day, the idea that they all want a high set on

this particular day, it is unlikely. Um So, you know, if under a lot of money, but it's not not a lot of money to someone in trading gigantic swamps book, So I think, uh, I think it was kind of acute and for them, acute and small time crime. What made this really scandalous? First couple, for a couple of reasons. It is scandalous. First, the email traffic is is really embarrassing, the famous I'm opening a bottle of Bolinger Champagne emails

and that sort of thing. And he it was actually Cure Curry that they were getting once his credit card was retired. And then he wrote anything for you, big boy. And I also believe, you know, if I think a lot of this was just bluster, I'm not sure. You know, I'm not sure that as much happened as the broker might say. You know, I'll arrange this for you, big boy. And then not do it, and then if the rate went the way that they were hoping, they would take

credit for it. I think there was plenty of that going on. This gets to one of my very my side issues that has almost nothing to do with finance per se, which is that all of our emails, in texts and direct messages look a lot worse than reality because people just talk and they blust her, they b s and they brag, and then if any of us were to have all of our private correspondence is dragged out in a court of law or in the media, it would look pretty terrible. That's just a general belief

beyond any sort of uh, you know, fixing of an index. Yeah, and I think people are more careful as a result of this scandal because it blew up. You know, part of there's a second scandal are there's a lot of blame to go around here, and the other scandal is paying interest on reserves for the Central Bank and then not doing anything to fix live lary. This should have been done in two thousand seven. This was because how can you continue to use as a centerpiece of three

month right that doesn't exist anymore? So if the fundamental process of setting library via survey just continued on even after the interbank market de facto ended with the payment of interest on access reserves. Is there anything visible in the data that shows weirdness, Like did the dispersion of inputs start to change because the numbers became more fictitious and made up? Like there' is there a way to sort of if you look at it forensically, could you

see something happened at that switch? I don't think so. You know, the groups were moving in a pack so they could see each other. Um, I think you know FED funds the overnight market, the domestic market also basically vanished, so there's still a FED funds index. You may wonder

who which banks are lending to each other overnight? And that became the only banks that would lend in the inter bank market for FED funds became federal home loan banks that offered reserve pulling services for their member banks that didn't have access to the Federal reserve, So it just became a very small market. They couldn't lend at the FED, so they would they would lend to Japanese banks that didn't have to pay deposit insurance. That would turn around and put the reserves at the at at

at the Federal Reserve. So it was it became a tiny market of about fifty billion dollars overnight after the first quarter of two thousand and eight. So I think the scandal became a maybe a catalyst too. Oh were Hall libar, But it had to be done eventually anyway, and I think it should have been done a long time ago. I mean, from what I remember, there there was some academic research, I think from two thousand and eight where they did look into LIEBR submissions, and I

think they did find some sketchiness. They're like some banks seem more inclined to quote higher than others um and it never came to a firm conclusion, but it sort of kicked off a lot of discussion. I was just wondering, as this came to light and as the allegations are sort of flying around post two thousand nine, were you surprised at all by the reaction of the British Bankers Association because they defended the libar process to the very end.

Maybe you know, that was a prestigious thing for them, it was what they were known for, but they there was not a role for them, um post not post crisis, but post in dollars post the first quarter of two Alston tonight. Um, So I guess it's I guess it shouldn't come as a surprise that people want to hang onto their power. So talk to us a little bit

more about the other form of manipulation in that significance. So, as you mentioned, there was the attempts to adjust the rate for perhaps to gain a little bit of an edge on a trade, or maybe to convince a client that you've done something really big for them. But as you put it, it is a scandal, but probably not the greatest scandal of the century or the biggest crime or the biggest swindle ever. But what about this other part of the significance, or the degree to which banks

disguise their funding weakness just by submitting false bits. Yeah, I'll say one one thing on behalf of the banks. Let's let's consider September two thousand and eight, on the Monday when Lehman went into administration. Okay, the question becomes, if you were to go and borrow UH for three months six months from another bank without negotiating, what right would you get? Now? On that day, Goldman Sachs and Deutsche Bank wouldn't settle spot for in exchange with each other.

So if you were to call another bank and asked to borrow for three months and not negotiate, the answer would be infinity. Okay, there's no responsible thing to do because this in this question that you're being asked is posed for a different environment, for a different background. So the question, just the grammar of the question doesn't make any sense, and you have to give something, so, you know, makeup.

If they put you a million percent or a thousand percent, then they would have blown up all the derivatives of the world and all the home mortgages and all the floating right does so they just put something. Famously, Barclays was putting a higher rate in dollars than other banks, and Paul Tucker at the Bank of England told them to lay off a little bit because you're you're freaking

people out. I'm paraphrasing, and you know he was criticized for that, but you know, in the context of the time, it was sort of a grown up thing to do because nobody's the whole thing is is divorced from any kind of reality. People have to muddle through because the index was not constructed for this environment. So I'm not, you know, sure what else to do. Well, it just to be clear, in mid September, it's not like there was a lot of mystery that the banks were under

a lot of stress. So even if to the degree that they may have been making things up, it's not like people were under some illusion that they were all in great health, right I I I don't think it was shocking. I think looking at the details of the live or submissions and trying to read anything into that

was a hopeless exercise. So it would probably be overegging it to say that actually giving the banks a degree of control over their self reported borrowing rates might have been a good thing in September two tho eight, or at least gave them a little bit of leeway. But I think that's a good segue maybe to talk about the transition away from ybor Um. And I think the effort is mostly to again move away from this self reported survey and go back to a reference rate that's

based on actual transactions. What do you think about that move? Yeah, I think the move to SOFA which we have in the United States is the right one. It's based on actual transactions secured overnight financing. The and we should point out in other currencies the move has already been made in Australia to bank bills, in Canada to see daru, the New Zealand Danish krona, they've all made the transition

years ago to overnight secured right. And in Euros the move the equivalent to SOFAR is something called esther, the Euro short term interest rate UM, the and the E and esther is the euro symbol. And already the overnight interest rate called the one A in Euros has switched to ESTHER plus a spread and that's produced by the ECB every day. UM. The SOFA is based on secured

overnight financing. So each day at eight o'clock UM, the PO Reserve publishes the average repo rate or secured financing that was reported to them from the previous day, and it's a it's a volume weighted median. So you throw out all the top and all the bottom, and look what's in the middle, and uh so it's it's an

overnight rate. And then the the issue that the market has to confront is how to turn an overnight right into a three month rate or a six month rate in order to create new contracts and also to switch over all the legacy contracts. Okay, uh, Richard, we're going to stop it there, because we're going to devote at least I think two more episodes into really delving into the technicalities of sofer and other replacement rates for libor. But thank you so much for coming on. That was

a really fantastic conversation. Thanks, thanks, Thanks Trisy, It's a pleasure. So Joe, do you feel do you feel more up to speed on the Librar series? Yeah? That was actually incredibly helpful. Um I had only the most vague outlined, but just really walking through the mechanics of how they constructed it, how the manipulation worked, a degree of it,

why the world credit markets less around it, I found. Uh. I feel like as we continue with this series, I feel a little bit more on firmer footing than I did a little while ago. Yeah, and I think Richard is really good at getting to the nuance of a lot of this topic, like the differences in manipulation, why people did what they did, and also the degree to which it was a scandal or not, because, of course, if you're manipulating the reference rate for trillions of dollars

worth of financial assets one basis point or another. It is going to have an impact on the overall market, but your actual profit from that move is probably not going to be that huge. Yeah, exactly right, And uh, it's great to hear from someone who, like ten years before everyone to agree or recognize that the system was flawed. Seemed to nail it exactly. It's only too bad that he didn't keep that sweatshirt. Yeah, it sort of speaks

to what's the word I'm looking for, systemic complacency. I think people always knew that there was a possibility a survey of self reported borrowing costs from the banks could maybe, uh not necessarily reflect reality all the time, and people chose to overlook it because libor was easy for them, It was standardized at that point, and frankly, it was profitable and linked to lots of different financial instruments, from euro dollars to interest rate swaps. Yeah, exactly right. All right,

should we leave it there? Yeah, we have lots more to talk about in our next episode. This has been another edition of the All Thoughts podcast. I'm Tracy Alloway. You can follow me on Twitter at Tracy Alloway. I'm Joe Why Isn't All? You can follow me on Twitter at the Stalwarts, and you can follow our producer on Twitter, Laura Carlson. She's at Laura M. Carlson. Follow the Bloomberg Head of Podcasts, Francesca Levy at Francesca Today, and check out all of our podcast at Bloomberg under the A

handle at podcasts. Thanks for listening.