Brook Taye (PhD) was selected to lead the newly established Ethiopian Capital Market Authority (ECMA) at the end of last year, and since then, he has been laying the groundwork for the much-anticipated debut of Ethiopian Securities Exchange (ESX).
With a background of an advisory role at the Ministry of Finance, as well as regulatory analyst and investment fund manager at two firms based in the United States of America, Brook has developed the expertise in law and economics required to steer the capital market. He pursued several law and economics degrees, as well as a PhD from European universities.
Since taking on the role of founding Director General of the ECMA, he has been working with a team of experts to establish all the legal frameworks and necessary groundwork before Ethiopians can begin trading through the ESX.
Samuel Bogale of The Reporter conversed with the Director General regarding the prospects of establishing a transparent stock exchange in Ethiopia. Excerpts:
The Reporter: What is the core rationale for setting up a capital market in Ethiopia, and how is it going to benefit businesses besides easing the selling and buying processes of stocks and bonds?
Brook Taye (PhD): Organizing the transfer and sale of shares is just one element, but the overall importance of the capital market is huge. As the name indicates, it is a market place where securities are transacted. In the same way that a supermarket is where we buy a product that has a name and relevant information, the capital market is where different types of securities are traded.
The general idea of a capital market is that it is a place where we will be able to have an orderly and efficient transaction in terms of securities.
There are different types of securities that we can divide into several main components. The first one is the securities on the fixed income side, where you will be able to generate a fixed income on a set principal and interest payment. These are government and corporate bonds.
For example, if companies want to raise capital for an expansion but don’t want to sell their shares or borrow money from the bank, they would go out and float a promissory note of a certain amount with a certain amount of interest throughout a number of years.
It has only been the government doing that so far, yes?
Yes, through the treasury bills and bonds. But now corporations too will be able to do that. Even the government can do it in a much more expansive way. If you were to buy the government treasury bills on the primary market right now, which are on the initial offering by the government, you would have to hold it to maturity in 28 days, 90 days, 180 days, or whatever the time frame is. You won’t be able to sell it on the market because you don’t have a secondary market.
What we are establishing will enable you to sell it any time before the maturity date in a much more orderly structure on the exchange. So that’s one of the very important elements.
There are different types of securities in the fixed income component. On the equity side, this is where shares are traded, bought and sold. It is already happening, but not in an organized way. If you have a bank share and want to sell it, you have to find a buyer yourself and negotiate. Then you will have to go to the bank so that the transfer can be executed and the money can be transferred to your account. This is all fragmented and not done in a structured manner. These are the two major components that we are talking about.
We are also going to create alternative markets. These are for small and medium-sized enterprises, which are not going to fulfill all the stringent requirements that we will set in place for big companies. It will be a modest market, and at the same time, it will allow small and medium-sized enterprises to be able to access funds, sell their equity and raise capital.
There are other instruments we are working on, such as crowd funding for companies to raise huge amounts of money through it. We are working on the directives to enable us to manage crowd funding and what type of process should be in place.
The other thing we are working on is factoring, in which you may have delivered a product or service to a certain company and the company gives you a 90-day check while you can’t wait for 90 days to cash the check. So there could be a mechanism and market structure whereby a bank or an institution will be able to buy you the 90-day check, give you the money today at a discounted rate and then they can use that check as part of an aggregated financial instrument that could be traded on the exchange. There are multiple products that we are considering introducing on both the equity and fixed income sides.
Why do countries have capital markets, and what good does it do for the economy of a country?
It is the most efficient way to allocate resources. If you were to borrow money from a bank right now, they would ask you for collateral and review your business plan, which would be decided on a bilateral basis between you and the bank. But if you were to go to the market and ask for a certain amount of birr worth of debt through a debt instrument, millions and millions of people who don’t know each other will have access to buy your securities, with all the access they have to the information that you provide.
They will be determined to buy your debt instrument at a certain interest rate. You may succeed or not, but this will allow you to have a serious level of resource allocation efficiency for different types of security products.
For example, if a manufacturing company in Ethiopia wants to build a factory with a capital expenditure need of 10 billion birr, it won’t be able to do that unless it is a government body. No bank is going to give you 10 billion birr, and they won’t even talk to you. But to raise 10 billion birr from the market in the Ethiopian context, it isn’t that huge.
What if the company’s proposed project isn’t actually worth 10 billion birr?
That’s what they have to put in their prospectus. The document should say that they are establishing a company that needs 10 billion birr to expand their business throughout the country or the continent, and how they plan to do it. The investors will then look at the proposal, background, and track record to believe in your ability to deliver or to take a risk in your business. Then it is not going to be very difficult to raise the amount.
Right now, even if you have the most amazing business plan, amazing track record and wanted to really do amazing work for your country, you won’t be able to raise that amount of money. It is not for the lack of the idea, not for the lack of your expertise, not for the lack of your track record; it is just because you don’t have a mechanism and a market to get this huge amount of capital. That is the major role the capital market will have.
The other element is for owners who want to sell their companies and exit the market. If you and your family ran a company for, let’s say 50 years, and want to leave the business, your only option is to find individuals yourself and talk to them about selling the shares or the whole company. But through the capital market, you can do an initial public offering (IPO) and sell your company to millions of people.
Talking to individuals on a bilateral level, the valuation is determined by the agreement between the company and the individuals. Very importantly, the overall market will have a say through an IPO on the exchange platform. You may say my company is worth a thousand USD per share, but the market might say it is actually worth two or five thousand. Based on this, you will be able to find at least a much more realistic valuation for your company when you plan to sell it.
Observing other countries, when prominent executives in a company receive negative publicity, stock prices tend to fall, and when they receive positive publicity, stock prices tend to rise. Shouldn’t stock prices be determined more by a company’s intrinsic value rather than the reputations of its individuals?
The market has a psychology of its own as well. We have to be very frank about that. The way the market functions isn’t necessary because if you pull one string, the other string will fall. It isn’t like that, and it has its own different psyche. The underlying reason why the share price goes up and down is not usually attributed only to the individuals who manage or own it. There are many different factors.
But I take the point. If the company is deeply associated with an individual, then most people might invest not only relying on the underlying facts about the company but also on the individual’s being part of the company and the way they will drive it.
For example, when Steve Jobs was the CEO of Apple and they were introducing a lot of products, people were really looking at what Steve Jobs was saying and doing to invest their money in Apple stocks.
Ultimately, the company by itself doesn’t just exist; it has people inside it. The actions and activities of these individuals, especially the principals in the companies, will impact whether the value of the shares goes up or down.
For some years, the concept of establishing a stock market in Ethiopia was discussed but ultimately abandoned. What’s changed now, and why is there a need to act now?
Even though we did not have a formal exchange in Ethiopia, we had a sort of over-the-counter trading platform where people could buy and sell shares of many of the old share companies that were established in the 1950s and 1960s. Since then, of course, the political and economic environment has not allowed it.
During the Derge era, you’re not going to be able to think about the exchange. In the previous administration, political economy thinking in terms of the role of the government and the role of the market was different.
Since 2018, there have been a huge number of activities that are focused on liberalizing the market, which started with telecom and is now going to the banking sector. In many different areas, the government’s position is that there are certain things that the government is better at doing and other things that the private sector is better at doing.
So the capital market falls right into that overall picture, and it was also part of the Home Grown Economic Reform agenda that was introduced in 2019. The corner of the Agenda was correcting the macro imbalances, and in order to correct the macro imbalance, allocating efficiencies is important. As I’ve said earlier, capital markets are better suited to efficiently allocate scarce financial resources to the best utilizers in the marketplace.
The general is said to have low technology literacy to manage shares online. Many may lack resources to buy stocks. Do you see these challenges?
Let’s divide them into different parts: technology first. You don’t necessarily need technology to buy shares. All you need is a phone to call your broker and say that you want to buy shares worth a certain amount at a company. In order for you to execute a trade, you don’t need to have technology, and you don’t need to be a technology savvy person who knows how it operates. The most important thing that you need to know is information about that company, whether it is profitable or at a loss and its performances. It isn’t technology that you need for this; it is information, so it is the journalists’ job to inform the public about the background of a company.
There are also collective investment schemes, for which we’re finalizing the directives and issuing them for public consultation. They are the investment strategies where I only care about the scheme and put my money in it. This collective investment scheme will be responsible for going out and investing on my behalf because they have better knowledge about the market. I don’t look at the numbers, what area they invest in, or which company they invest in. All I look at is whether they are capable of investing, as well as their performance and track record.
It isn’t that difficult. We have a very sophisticated society and I don’t underestimate our people. If they can figure out how to manage their lives and go through it, this won’t be difficult. But we have to educate people about investments and what it means.
There is a huge role for the media as well, because you have to educate the public. Tomorrow, when a listed company’s performance is not trustworthy, you need to do investigative journalism and find out what the authority could have missed. This is the type of information that will help investors. So in general, I don’t think it will be very difficult for us to understand this and participate.
Compared to the general public, a small group reportedly controls the financial sector as shareholders and borrowers. Won’t this small group also dominate the exchange?
To reduce the risk of ownership by a small number of people in share companies, the Authority will have a listing requirement with a certain percentage of ownership. If you have more than a certain number of shareholding positions, the company stops being publicly traded or a share company because of your influence. We are working through the process, so it will be indicated in the listing requirement when we publish it. This is a normal practice everywhere.
You can always issue a minority share for your company, but if it’s a publicly held company where there are a lot of minorities, there’s no one significant block of ownership. If you’re buying shares and consolidating your position, then you have to declare your intent so that it does not destabilize the market.
But I won’t worry that much about it because the number of shares that will be issued is usually in the millions. For someone to capture millions of shares and control the company, they might as well do a takeover strategy to just buy the shares and then have it as a private company.
However, there are requirements and rules that we will introduce and follow. The chance of this being manipulated by a small number of people is something that we look out for and correct aggressively.
So the optimism around establishing the capital market isn’t exaggerated?
It is not exaggerated. We are optimistic about our country, Ethiopia. I’m very optimistic about my country. I’m very optimistic about the economic success of my country. That is what drives me about the exchange, the capital market and how it would work.
When today’s small companies all of a sudden have some sort of creative idea to scale and are ready, we will be ready for them; this is where the optimism comes in. It isn’t necessarily what would happen today or tomorrow, I look at it from a long historical perspective. The optimism is due to the dynamism of the country and its potential. But it does mean there is no challenge.
How has the Authority prepared itself for the stock exchange launch? Describe your activities and challenges.
Since the establishment of the authority, we’ve been mainly focusing on establishing the legal and regulatory framework by designing the necessary directives that allow us to grant licenses and set the enforcement and supervision requirements. We have been preparing for the additional legal and regulatory requirements derived from the proclamation that are needed to make us fully operational for launching the market.
The board has already given its approval to three directives that we have released for public consultation. We are now making the final changes before they become effective. There are eight additional directives that are in their final stages, which we will announce to the public for consultation.
We also have two regulations, one of which has already been sent to the cabinet, and we are waiting for the cabinet to review it. Another regulation about the compensation fund is completed, and we are going to engage the public for their comments. That is where we are in terms of regulation.
In terms of public education about the capital market, we have partnered with Addis Ababa University’s College of Commerce. We have also partnered with other accredited training institutions to provide training for people who want to take part in capital market service provision. We are traveling to regional cities to hold a public consultation and to explain what the role of the capital market is because retail investors are dispersed throughout our country.
In terms of challenges, of course, it is a new market for us, requiring a serious level of regulation. When you are a listed company, your financials, management, decisions, and corporate actions are to be communicated to the public, which is not something that we are accustomed to.
As a private company, you don’t need to communicate most of your activities. Even some of the share companies don’t necessarily follow the legal practice of declaring their corporate actions properly, so that will be a challenge for us. We have to make sure that we work with the industry, the market, and the companies that we list so they understand that this is a completely different dynamic.
The companies will have access to huge potential and a huge amount of money from the public, so we take that responsibility very seriously to protect the investors. If they want to have access to billions of birr, which is available in the marketplace for their businesses, then they have to take the responsibility of making sure that their actions and disclosures are all in line with the directives that we issue, and also the capital market proclamation.
Who are the main players in the capital market, and what are their roles?
There are a lot of participants. As investors, the first are institutional investors, who buy shares and debt instruments to hold them for long periods of time on behalf of their members. The public and private pension funds we currently have are examples. They invest in buying certain shares, allowing them to increase in value over the years because they are patient and the amortization of their payment is pretty much determined.
Then there are retail investors, people like you and myself, who are buying one or two shares depending on our capacity. These are the main components of the market.
Capital market service providers by way of brokers also play an important role. They are the ones that you would call as a retail or institutional investor and tell them that you want to buy shares of a company. They will execute that transaction on your behalf so that you can pay them the commission. They have access to the exchange platform to execute that order on your behalf so that the exchange can be registered under your name.
There are also investment banks with a significant role in the marketplace. At least, just to mention one critical role that they play, they are the conduit between the company and the investor community when the company decides to go public. What they will do is that they will help them with the valuation in determining the share price, and they will be doing several different events to promote the offering. They then engage with the exchange and with the authority to make sure that all the legal requirements are fulfilled.
How many brokers and investment banks do you expect?
I don’t know how many people are interested yet, in terms of the overall volume of people who could be interested. So I won’t be able to say how many people we’re expecting, but it is open. We invite people to come and participate in this sphere. When the volume increases in terms of the number of transactions, it’s a huge opportunity for the brokerage firms.
There is no limitation on the number of investment banks as well. If local or foreign banks want to come and be licensed, we’ll give them a license as long as they fulfill their requirements. There’s no limit to the number of investment banks that the capital market authority will provide licenses to.
As long as you fulfill the requirement, you can have a license to be a broker, a dealer, or an investment bank.
Will commercial banks participate in forming investment banks?
As it currently stands, commercial banks providing deposit-taking retail banking services are not allowed to do any type of investment banking activity. But if the current draft proclamation by the National Bank of Ethiopia goes through the cabinet and parliament and gets adopted, it would allow them to open a subsidiary.
So the deposit taking bank doesn’t get involved in investment banking, but their subsidiary will be able to do investment banking. That subsidiary is the one that we license, as it is the capital market authority’s mandate to license them.
Since investment banks will operate as subsidiaries of the banks that own them, wouldn’t that create a conflict of interest when the investment banks perform due diligence and valuations to determine their parent commercial bank’s eligibility for listing?
Usually, you don’t necessarily do your own valuation. The reason why you need an investment bank is because you need outside support to come and assess what amount of value per share you will be able to generate based on your current structure. For an investor to have confidence, it is better that a third party or somebody with an arms’ length transaction could do it.
But they aren’t prohibited from doing assessments of their parent company?
We are talking hypothetically because there is no investment bank right now and the commercial banks have not decided to list. I don’t know what the dynamics would be, so we’ll form our opinion based on reality when it happens. But since we’re now talking only in hypotheticals, I can only give you a hypothetical answer. One would want a third party to do the evaluation and submit the document so that the market could have confidence and the companies could get a better valuation per share.
If done internally, you can do a proper separation of the investment and commercial operations arms, as it is normal that other banks also do that. But we will have to look at which bank it is, what type of investment role it will have, if there is a clear delineation of responsibilities and roles, and also if what they are communicating to the public investor is clear. We have to see all of that to make a judgment and say if it creates a conflict of interest or an inappropriate valuation.
You can come and say that the per-share value of your company is this much, but ultimately you have to convince the investor that it means nothing. Just because you said it was 100 thousand or a certain amount, it doesn’t necessarily mean that I want to buy it for 100 thousand. In fact, you’re going to fall on your face and not get enough momentum when you do the initial public offering. Usually, the difficulty is that most companies undercut the true value since they want a huge amount of volume to be sold. If the value is 100 thousand, they may put out 70 or 80 thousand so that a huge number of people could come and buy, which creates scarcity, and the value could go from 100 to 150 thousand. This is the manipulation that is usually seen in value transactions. But again, this is something that we have to look at when we’re ready to issue this margin.
How clean will the trade exactly be if they are in groups and not separated?
I’m not saying they will be in the same group. It could be two separate companies. The commercial code permits a holding structure for companies. When it allows a holding structure, it doesn’t mean it allows the commingling of finance and commingling of decisions.
It means that each individual subsidiary will do its own different activity, and the holding structure is on a balance sheet basis to consolidate the finances and other activities. Not necessary everybody knows what is going on and does things to the benefit of the others. It is a very strict separation. It is not as easy as saying it’s a holding company and everything will be commingled.
When these banks open a subsidiary, my view is that it will be a subsidiary far and apart from the main commercial bank institution. Every bank now has insurance, and the insurance works in a different sector run separately by a different board. It doesn’t necessarily mean that there is a conflict of interest. However, this is something that we look through properly, but it’s not the way it is portrayed, where there is some sort of commingling happening that is very difficult to monitor.
So the Authority doesn’t simply accept assessors’ valuations at face value.
It’s not up to us to say that the value of this company is this amount. The process and the person who has done the assessment are what we look at. You need to be licensed by our authority in order to assess the value, and in order for you to be licensed, there are a number of things that you need to fulfill.
So when you go and assess, you already have a huge amount of responsibility since you have a legal requirement. If we think that there is fraud in the process or some sort of market abuse happens, of course we will stop the whole process, and then they will get a fine. If it is a criminal activity, they will also be charged under the criminal code.
Checking on the exchanges of other African countries, all of them have less than a hundred companies listed except Egypt, South Africa, and Nigeria. Ethiopia not being different from them, what will be the case here?
To this point, yes, it is a small number. For example, from around the 65 companies that are listed in Kenya, the largest share of total market capitalization is that of Safaricom’s. This company controls the highest percentage of the entire capital market value, and the others have smaller values. But if you look at Morocco, the Casablanca Stock Exchange is something that we are really looking at very closely. In terms of comparable, the one we are looking at is Morocco’s.
I think Ethiopia is different. We are very different in terms of our population size and economic dynamism. Even without an exchange and a capital market, how many share companies do we have by way of a bank? It is over 30. How many share companies do we have by way of insurance? It is over 11.
But it is not guaranteed that they will be listed.
I understand it is not guaranteed, but look at the pipeline. We already have potential companies that could be listed. The listing or not listing decision is up to the companies, but these are share companies, not privately held companies. Each bank already has about 10,000 or 15,000 shareholders.
They are not listed companies, but when they are listed, they can become publicly traded companies on the exchange. In my view, what makes us different is that we have a pipeline of companies that can be listed and create the necessary dynamism. This is without including the SOEs that the government can decide to list fully or partially.
Then we also have the government bond and treasury markets. We will also get into municipal and corporate bonds. This is something the market can absorb. We’re not 50 or 14 million people; we are 120 million people, with three or four million people living outside of Ethiopia with a huge amount of capital that they wanted to invest in Ethiopia.
How will diaspora and foreigners participate? Don’t they need to reside here?
For the diaspora Ethiopians, there is a different treatment for investment and their participation in the banking sector. That is something we will follow. But to participate in the exchange as a foreigner, we have to define what parameters and requirements there should be. That’s something that we’re working on, as it’s not defined yet. It may not be in the near future, but in the mid- to long-term, we see the future.
We think that we will come up with a mechanism where we can have foreign investors participate in buying and selling shares in the marketplace. We are defining the policy elements for their participation.
Will foreigners be allowed to buy and sell stocks on the exchange?
Right now, we are working on the policy aspect of allowing foreign investments in buying and selling shares. They are allowed to come and establish their businesses as other market participants, but not to buy and sell shares.
This is because we have the capital account restriction and other laws that prohibit us from doing that. As a capital market authority, we are working on the policy ideas to propose to the macro team, as well as the other necessary institutions.
If you want to buy USD 1,000 worth of shares, the money comes in and you buy the shares. But if you want to repatriate it, how is that going to be? What type of investor are you going to be?
For a foreign investor, there is a requirement in an investment law that it has to have a certain threshold. So all of that doesn’t allow us, but we are not in a rush. We have to think this through properly and align it with all the other government policies so that we’ll be able to introduce our policy suggestions to the government based on that.
Share companies in the form of financial institutions have been the most successful ones in Ethiopia. Most share companies in other businesses have failed to fulfill the promises they made to the public. Given these experiences, will the public have an appetite to invest in share offerings now?
I think we have to ask what the reason is for banks to be successful as share companies versus others. We have heard so many of them say that they’re going to generate a huge amount of return. We hear them every day. Even recently, I was reading some things. I won’t be able to comment on the specific company in this issue, but in general, we have to ask what the difference is.
If the Authority regulates share sales, what is holding it back from stopping such advertisements now?
As we stand currently, the law allows us to stop that, but because it is just a new institution, we haven’t designed the legal framework and we don’t have the directive yet. We don’t have the process to stop this type of activity. I will be very clear about it: once we have the directive, it will all stop. It is one of the eight directives under preparation, and we are actually expediting it at bullet speed just because of the issues we are seeing in the market and advertisements.
Prior to going live with the advertisements, you have to submit the advertisement to be approved, let alone go there and claim what they are claiming. There will be a process, and they will get a license from the Ministry of Trade and Regional Integration saying they will be a share company under formation.
Also before they start advertising and selling any type of share, they have to submit to us a prospectus, and that prospectus would have to indicate all the information about the company, the people who are promoting it, the risk associated with the investment, and the potential for loss, so that an investor has to be fully aware and educated before making a decision to invest in that company. If they don’t fulfill this, not only are we in a position to stop them, but it could also be a criminal offence.
This is why we aren’t ready to do that, because we don’t have the directive. I hope people aren’t foolish enough to trust these companies until we put the directive in place. It is very painful for me to see the recent cases. I wish we had expedited the process because this is really unacceptable. This is the money people have saved and probably sold their property for.
We are now working on it. I hope we really expedite it and properly set a standard so that we don’t see a lot of people going out there and doing this.
This is why the banks as share companies succeeded. Who is their regulator? It is the National Bank of Ethiopia. You can’t jump a single line without performing the necessary requirements to open a bank. The lack of regulation of share companies created what we are seeing. Now that we are established, this is our work. Once we finalize this directive, no one will come up with advertisements and call for the public to buy their shares.
There is a private placement through which you can sell shares to up to 50 people in your friend or family circle. We have not yet decided on the thresholds, but let’s say the threshold is 50 people for now. If you want to sell shares to over 50 people to collect cash, there is a requirement that you have to meet. We have to approve the prospectus.
We don’t delve into what kind of investment it is or if it’s lucrative or not, but we check in detail whether the prospectus has adequate information that the investor needs to know so that they can buy the prospectus. We make sure you’re provided with proper information before you make the investment. That is our role as a regulatory authority, and that is what we are going to do.
With the severe foreign exchange shortage, trouble with profit repatriation, and rate disparities between the parallel and official markets, are you hopeful that foreign investors will be interested in engaging with the securities exchange?
I’m hopeful that everything will work out and adjust itself, not for the sake of the capital market but because my country will be able to solve this problem. In the grand scheme of things, we will be able to resolve our foreign currency-related issues. I know its impact on businesses and the government.
Unfortunately, we don’t print dollars, so we always have to rely on a way to generate foreign currency by working in exports. So we need to be able to figure out how we can get into a position to generate enough foreign currency for our economy. It is a big issue that needs to be dealt with by the central bank and other macro institutions.
We are currently focusing on our domestic market for birr-denominated transactions. We are not really focused on foreign investors in this area right now, but gradually, my optimism is that these things will correct themselves.
How will the Exchange prevent insider trading?
We will have a mechanism to monitor insider trading—a post-rate monitoring mechanism. It is software that would allow us to monitor each individual’s sales transaction. Through the different algorithms that we developed, we will know if there are abnormal activities that are happening, and then we will investigate and take action.
You will have to justify your investment decision. If you are an employee of a company, it’s very easy because you can make the connection. This is part of our market abuse overview, for which we take serious action based on what is permitted by the rules.
Which tech company has been selected for the development of the Central Securities Depository (CSD) system, and what is the cost?
We are doing vendor due diligence right now, so we don’t want to communicate before we sign a contract, but it is one of the well-known firms existing in different parts of Africa. We are in the process of making sure that we get all the information that we need from the entities that this company is providing services for.
Once it is all done, we will sign the contract and make the public announcement with the selected company. We are getting support from Financial Sector Deepening Africa (FSD Africa) for the procurement of the system. So we don’t have any exposure in terms of payment at this point in time. All this information will be communicated clearly in due time.
It was made public that five state-owned enterprises (SOEs) would be listed first. Which ones are they?
I won’t be able to say which SOEs will be listed first because that’s a government decision to select the enterprises for selling full or minority shares. This decision will be made by a different office, but since we have the responsibility to make sure that the market environment is ready, we work with Ethiopian Investment Holdings (EIH).
We’re in the process of helping the EIH so that these five companies will be supported to be ready based on the listing requirements that we have.
We’re going to work with them to identify the order of their financial statements, their needs for corporate structure, and their valuations so that they will be ready if the government decides to list. That’s what we’re focusing on, but the ultimate decision of listing or not listing is obviously for a different office to make a decision.
