PARIS CLUB - DECEMBER 2008 TOUR D'HORIZON AND DISCUSSIONS

UNCLAS SECTION 01 OF 23 PARIS 002344 SENSITIVE SIPDIS STATE FOR EEB/IFD/OMA TREASURY FOR DO/IDD AND OUSED/IMF SECDEF FOR USDP/DSCA PASS EXIM FOR CLAIMS - MPAREDES PASS USDA FOR CCC -- ALEUNG/WWILLER/JDOSTER PASS USAID FOR CLAIMS -- WFULLER PASS DOD FOR DSCS -- PBERG E.O. 12958: N/A TAGS: EFIN ECON EAID XM XA XH XB XF FR SUBJECT: PARIS CLUB - DECEMBER 2008 TOUR D'HORIZON AND DISCUSSIONS ON METHODOLOGICAL ISSUES ¶1. (SBU) Summary: The December 2008 Paris Club Tour d'Horizon included Argentina, Burundi, Comoros, Congo, Cote d'Ivoire, Ecuador, Grenada, Guinea, Guinea-Bissau, Iraq, Pakistan, the Seychelles, Sri Lanka, and Togo. Argentine Economy Minister Fernandez had told the Secretariat that repayment was still "politically relevant," but that "technical conditions" for repayment no longer applied in the short term. Both sides had agreed to continue technical contacts, including efforts to reconcile late interest. The IMF conceded that Cote d'Ivoire's performance under its Emergency Post-Conflict Assistance (EPCA) program had been weak, and indicated that financing gaps for 2008 and 2009 still needed to be filled before a new Poverty Reduction and Growth Facility (PRGF) program could be approved. Creditors expressed divergent views about the implications of the timing of the IMF's assessment of Cote d'Ivoire's qualification for debt relief under the Heavily Indebted Poor Countries (HIPC) Initiative; the IMF asserted that a delay beyond March 2009 might prevent Cote d'Ivoire from qualifying, given more recent debt data. The Club agreed to enter into force on December 17 the final tranche of Iraq's 2004 debt relief. The IMF reported Sri Lanka's financial situation had become "very precarious," and that the country could be forced to seek an IMF program and Paris Club debt relief. The Secretariat strongly supported the Seychelles' request that the Paris Club commit to a two-stage debt treatment a "flow" rescheduling followed by a "stock-of-debt" reduction in the upcoming negotiation - in order to PARIS 00002344 002 OF 023 maximize the chances that private sector creditors will provide comparable treatment. ¶2. (U) The Club also discussed four methodological issues (outreach to non-Paris Club creditors, so-called "illegitimate" debt, the global financial crisis, and updates to the Paris Club website) and provided preliminary approval of additional debt relief for Togo. On December 11, creditors negotiated a new "Agreed Minutes" with Congo (Brazzaville) that resumes interim HIPC debt relief. Because of Congo's high capacity to pay, creditors provided only the standard debt relief terms, which will include cancellation of $643 million and rescheduling of $119 million over the 2008-2010 time period. End Summary. -------------- Argentina -------------- ¶3. (SBU) The Secretariat reported on a meeting with Economy Minister Fernandez on the margins of the G-20. Fernandez had said that repayment was still "politically relevant," but that "technical conditions" for repayment no longer applied in the short term. Both sides agreed that technical contacts should continue, including efforts to reconcile late interest. The IMF reported a significant deterioration in Argentina's situation, including asset price PARIS 00002344 003 OF 023 declines, capital flight ($4.5 billion in October),and falling growth. In response to a question from the U.S. delegation, the IMF noted that reserves were still at $46 billion as of end-November ¶2008. There is no date set yet for an IMF Article IV review, although the Secretariat reported that the Argentines had agreed to a Financial Sector Assessment Plan (FSAP) review during the November 15 G-20 meeting. The World Bank expects to receive net financial flows of $600 million and an estimated $300 million in 2008 and 2009, respectively. -------------- Burundi -------------- ¶4. (U) Burundi formally entered the enhanced Heavily Indebted Poor Countries (HIPC) Initiative process (decision point) in 2005 and could qualify for full debt cancellation (completion point) as early as January 2009, along with the first review of its IMF program. The IMF reported that Burundi's performance had been broadly satisfactory, with quantitative criteria already met and progress on structural criteria. The World Bank reported good progress on Burundi's reform commitments. The Bank representative warned, however, that Burundi would remain at high risk of debt distress even after completion point, due to its very low export base. PARIS 00002344 004 OF 023 -------------- Comoros -------------- ¶5. (U) The IMF reported that Comoros' track record of implementing economic reforms had weakened significantly since 2006 because of the political situation, global food and fuel prices, and economic stagnation. The country was unable to meet its commitments; arrears were accumulating. The ratio of debt to GDP (net present value basis) had reached 236 percent. Because of the political situation, Comoros had been unable to obtain an IMF program under the Poverty Reduction and Growth Facility (PRGF). Comoros had requested about $5.1 million in IMF financing under a six-month Emergency Post-Conflict Assistance (EPCA) program and the rapid access component of the Exogenous Shocks Facility. The country's performance under the current EPCA could eventually pave the way for a PRGF program and HIPC debt relief. Subsequent to the Paris Club discussion, the IMF Executive Board approved both facilities on December 15. The IMF also reported that an upcoming donors' conference would seek additional support and that Comoros would likely continue to accumulate arrears, including to Paris Club creditors. -------------- Republic of Congo (Brazzaville) PARIS 00002344 005 OF 023 -------------- ¶6. (SBU) On December 11, Paris Club creditors and Congolese Finance Minister Pacifique Issoibeka agreed on a debt restructuring accord that resumes Congo's HIPC debt relief, (suspended in September 2006). Brazil, a non-Paris Club creditor, also signed the "Agreed Minutes," which set the terms for each creditor to implement the deal bilaterally. Under the new three-year Agreed Minutes, $643 million will be cancelled and $119 million will be rescheduled, provided Congo's track record of performance on its PRGF program is satisfactory. The Secretariat's analysis showed a very strong payment capacity because of oil revenues, unusual for a HIPC country. As a result, creditors denied several of Congo's requests for exceptional terms, such as further restructuring debts already treated in the 2004 Agreed Minutes. ¶7. (SBU) There was some discussion of so-called "vulture funds" (litigating creditors) after the U.S. delegation asked Finance Minister Issoibeka to clarify an apparent contradiction in different GROC documents about whether the cases had been "extinguished." Based on the minister's ambiguous responses, our understanding is that the legal claims are on hold for now because of a $180 million GROC "goodwill" payment and the standstill agreement; the financial claims against the GROC still exist. Finance Minister Issoibeka described how aggressive litigating creditors had seized oil and PARIS 00002344 006 OF 023 export income, as well as official development assistance from Belgium that was intended to support construction of a power plant. According to the minister, neither IMF and World Bank calls against such litigation, nor the GROC's own pleas for help from its international partners, had had any effect. ¶8. (SBU) Given many creditors' concerns about litigating creditors' claims against Congo, the U.S. delegation suggested during the December 10 tour d'horizon that the Club strengthen the conditions for the entry-into-force clauses of phases 2 and 3 for Congo and all future HIPCs. (Note: A key principle of Paris Club debt treatments is the requirement that a debtor country must seek the same or "comparable" debt relief from its non-Paris Club creditors.) In the December 11 negotiation, the GROC delegation accepted both the requirement to submit reports prior to the IMF's Board discussions and the financial terms the Club offered. ¶9. (SBU) There was relatively little discussion of creditors' concern that Congo's $1.6 billion framework agreement with China threatened debt sustainability. Following up on GROC written clarifications provided in November at the Paris Club's request, Minister Issoibeka assured the Club that Congo would respect the concessionality requirements (minimum 50 percent grant element) of its new PRGF program. Issoibeka asserted that the 2006 framework agreement with the PRC would allow for investments in priority PARIS 00002344 007 OF 023 sectors, generate exports, and improve Congo's payment capacity. Given the IMF's confirmation that its debt sustainability analysis had taken Congo's expected new borrowing from China into account, creditors did not ask Issoibeka for further information. The IMF representative reported that Congo could complete the HIPC initiative ("completion point") as early as May 2009, which would trigger cancellation of Congo's remaining eligible debts to bilateral and multilateral lenders. -------------- Cote d'Ivoire -------------- ¶10. (U) The IMF reported ongoing negotiations on a PRGF program. Despite prior fiscal slippages, the government had indicated that it was committed to remedial measures, safeguards, and transparency. The IMF hoped that the Executive Board could approve a PRGF program in February or March; however, 2008 and 2009 financing gaps still needed to be filled. The significant donor support Cote d'Ivoire needs through 2011 had been delayed due to weak policy. Market tightening had prevented Cote d'Ivoire from raising financing on the West African Economic and Monetary Union (WAEMU) market. As a result, clearance of arrears at the African Development Bank (AfDB) has been delayed. Paris Club Co-Chairman Benoit Coeure reported that his recent meeting with the Ivoirian Finance Minister PARIS 00002344 008 OF 023 corroborated the IMF's assessment. The poor cocoa crop, lower cocoa prices, and liquidity problems in the WAEMU bond market had contributed to a very tense cash flow situation. However, the country was setting up a special account for oil revenues, which would be transparent and audited. ¶11. (SBU) The IMF also explained that the December 12 Executive Board meeting would address Cote d'Ivoire's performance track record, noting that the Board had sufficient discretion to allow performance under an EPCA program to be acceptable to qualify for the HIPC Initiative. (Note: The December 12 Board meeting was inconclusive. IMF staff awaits final performance on the current EPCA program before recommending whether Cote d'Ivoire should enter the HIPC process as it begins its PRGF program or, as the USG advocates, wait until the first PRGF review. End Note.) The IMF underscored that postponing a decision on Cote d'Ivoire's qualification for HIPC until after March 2009 could mean that the country might not be eligible. Under IMF rules, more recent figures would have to be used in taking a HIPC-related decision after March 2009, and end-2008 data would likely show lower indebtedness ratios. Failure to qualify for HIPC would also prevent Cote d'Ivoire from benefiting from the Multilateral Debt Relief Initiative (MDRI),a more valuable prize than HIPC debt relief. The IMF also conceded, however, that Cote d'Ivoire could conceivably still receive HIPC and MDRI later on the basis of end-2009 data. PARIS 00002344 009 OF 023 ¶12. (SBU) There was some discussion about the implications were Cote d'Ivoire not to qualify for the HIPC Initiative, and what restructuring the Club would offer in such a situation. The Secretariat opined that the country did want to benefit from HIPC, and Germany urged that a way be found to allow Cote d'Ivoire to qualify for HIPC. The discussion ended inconclusively as all agreed that this was an issue for the boards of the International Financial Institutions (IFI). -------------- Ecuador -------------- ¶13. (U) Discussion of Ecuador focused on the External Debt Audit Commission's recent report, which characterized up to 40 percent of Ecuador's commercial external debt as either illegitimate or illegally contracted. The IMF reported that Ecuador's financial position had worsened, although the banking system was strong, with little exposure to the international system, and Ecuador would be able to cover its needs from its liquidity cushion and borrowing from the Andean Development Corporation (CAF) and the Inter-American Development Bank (IDB). The World Bank noted the Bank had been cited in the commission's report, and that the Bank expected net flows of about $80 million from Ecuador in 2008. Following guidance PARIS 00002344 010 OF 023 from President Zoellick, the Bank would "find a way" to stop new disbursements at the first sign of GOE failure to repay debts to the Bank. ¶14. (SBU) The Secretariat noted that the commission had also criticized the Paris Club. The Secretariat suggested possible responses, including a Paris Club Chairman's letter warning Ecuador not to default, hardening of export credit terms (noting that some export credit agencies had halted new lending already),and coordinating a position at the Inter-American Development Bank (IDB),where a $1.5 billion loan was under discussion. The Co-Chairman rejected these ideas for now, urging that the Club wait to see GOE action on December 15 and status of payments to Club creditors, saying they could provoke the Ecuadorians further. ¶15. (SBU) The Spanish delegate complained that the report cited three loans owed to Spain, and called for a Chairman's letter if payments were not received. Stressing reputational damage to Spain, the Spanish delegate criticized the Norwegian delegation for circulating an NGO document on illegitimate debt (see paras 31-32 below) that included a sentence welcoming Ecuador's decision to conduct the audit. The Norwegian delegate responded, indicating that the GON welcomed discussion of the issue but did not approve of Ecuador's process, which had lacked transparency and balance. PARIS 00002344 011 OF 023 ¶16. (SBU) Italy said the report had labeled one of its concessional loans as illegitimate, but that Ecuador had nevertheless just made a payment on it. Brazil had been heavily criticized in the report, and its representative noted there were no arrears. The Club agreed to wait to see whether the GOE defaulted on official debt before taking action. As of December 22, Ecuador appears to be servicing its debts to Paris Club creditors. -------------- Grenada -------------- ¶17. (SBU) At issue was Grenada's November 17, 2008 request to extend its 2006 rescheduling through end-2009. In July 2008, the IMF Board had completed a long-delayed review of Grenada's PRGF program, including PRGF extension through April 2010 and boosting lending by $2.2 million. A second PRGF review took place on December 12. The IMF reported deterioration since July, including forecast declines in 2009 for remittances, tourism, and tourism-related foreign direct investment. The IMF felt that the new government was committed to the PRGF program and was implementing reforms. The IMF noted concerns about a proposed loan from China, but said that the GOG had committed to delay the loan until late 2009 at the earliest and planned to seek concessional terms and a smaller amount than originally planned. PARIS 00002344 012 OF 023 ¶18. (SBU) The Secretariat highlighted that extension of the Fund program had not assumed extension of the Paris Club's 2006 restructuring. Under questioning, the Fund conceded that the Paris Club accounted for a small part of Grenada's external debt and that the program would not unravel if the Club rejected the extension request. Nevertheless, the IMF argued that Grenada's external situation had since deteriorated, and that Grenada had reportedly reached agreement on a "significant" discount below face value with private creditors. Taiwan's threatened litigation over a credit it refused to restructure presented an additional obstacle. Similar to its intervention with respect to the Republic of Congo (Brazzaville) (see para 8),the U.S. suggested that Grenada provide a report on comparable treatment before a Club decision on extending its debt relief. Co-Chairman Coeure and the Club endorsed the idea, suggesting that creditors could assess Grenada's record of seeking comparable debt relief from other creditors and Grenada's request in January 2009. -------------- Guinea -------------- ¶19. (SBU) The IMF reported that the Executive Board's July 2008 favorable review of Guinea's PRGF program included a $34.9 million PARIS 00002344 013 OF 023 augmentation to help Guinea cope with external shocks from rising food and fuel prices. The IMF called the macroeconomic situation "broadly satisfactory," noting that the GOG had met its fiscal targets despite social unrest and tension. In early 2009, the IMF intends to discuss Guinea's exit from the HIPC Initiative ("completion point") and hold the second review of Guinea's PRGF program. The World Bank reported that Guinea had already met seven out of the ten performance criteria for completing the HIPC Initiative. Two criteria were partially met (on auditing of large government contracts and prenatal consultations); however, there was slow progress on increasing access to social services. The Secretariat intends to have negotiations with Guinea in March 2009 to cancel the remaining stock of eligible debt. -------------- Guinea-Bissau -------------- ¶20. (SBU) The IMF noted that end-2006 debt (including arrears) totaled $1 billion (322 percent of GDP). Guinea-Bissau had benefited from $5.7 million in loan disbursements under the Emergency Post-Conflict Assistance (EPCA) program approved in January 2008. Performance had been broadly satisfactory in the first half of 2008, but had weakened since then. Discussions on a new PRGF program stalled, however, since Guinea had missed the PARIS 00002344 014 OF 023 EPCA's June 2008 reform targets and was expected to miss September ones as well. Guinea was requesting about $5 million under the Rapid Access Component of the IMF's Exogenous Shocks Facility and might request additional post-conflict support. -------------- Iraq -------------- ¶21. (SBU) The IMF reported that Iraq had nearly met the requirement under the November 2004 Agreed Minutes to complete three years of continuous performance on an appropriate IMF program. (Note: On December 17, the IMF Executive Board approved the final review of Iraq's Stand-By Arrangement (SBA) End note.) The Fund described Iraq's economic situation - both oil and non-oil - as encouraging. The World Bank indicated preparation of a new interim strategy; limited IBRD lending was possible. ¶22. (SBU) Brazil repeated previous statements that there had been no progress in implementing the November 2004 Paris Club treatment since its letter to Paris Club in June 2008, though it was hoping to schedule a technical meeting in early 2009. The Brazilian representative claimed that the GOB had been unable to obtain copies of terms granted to other non-Club creditors and argued that while Iraq had done well in terms of number of creditors, the GOI had done PARIS 00002344 015 OF 023 poorly in terms of share of debt treated - particularly since it had not signed with Saudi Arabia. The Secretariat noted Iraq's recent report on comparable treatment, declaring that Iraq had met the Club's terms on comparability, which only required best efforts on the part of the debtor country and that the country not provide more favorable terms to any creditor. After a contentious discussion, creditors decided to use December 17 (the date of the IMF Board discussion) to enter into force the final phase of debt reduction and to begin accrual of ordinary interest. The Club also decided to issue a press release reporting that the last tranche had entered into force and calling on other creditors to provide comparable treatment. -------------- Pakistan -------------- ¶23. (SBU) The IMF reported on the impact that food and fuel prices, followed by the global economic turmoil, had had on Pakistan and described the reform goals of Pakistan's Stand-By Arrangement. Pakistan still had large financing requirements, particularly for the first year, which it hoped to cover through privatization revenues and additional bilateral support to be discussed at a donors conference in the new year. When Canada asked whether Pakistan would come to the Paris Club, the Fund noted that the SBA PARIS 00002344 016 OF 023 did not envisage a rescheduling; Pakistan's external debt was mostly commercial, and restructuring it could be difficult and have adverse effects. In response to a question from the Netherlands, Germany indicated that it had entered into a euros 40 million swap for health programs, under which the GOP would have to pay the equivalent of euros 20 million. Russia complained that Pakistan had blocked $163 million of Vneshekonombank accounts. -------------- Seychelles -------------- ¶24. (U) The Paris Club had granted financing assurances for Seychelles in a November conference call, clearing the way for IMF Board approval of its two-year SBA lending program on November 14. The Secretariat noted that the GOS had agreed to major reforms, most notably movement to a floating exchange rate. While Seychelles wanted to complete its debt restructuring rapidly, ensuring a comparable treatment of its comparatively large share of external debt owed to private creditors would be a challenge. The IMF echoed the far-reaching nature of the SBA's reform goals. The Seychelles faced major challenges from the global financial crisis (and impact on tourism). The country was moving forward on the restructuring of its Eurobond, according to the IMF, and additional outreach to private creditors was planned for February 2009. The World Bank PARIS 00002344 017 OF 023 reported that it was near approval of a two-year interim strategy together with the African Development Bank that envisaged $9 million of budget support in each year. ¶25. (U) The Secretariat distributed a December 9, 2008 letter from the Finance Minister, and observed that treatment would be difficult, since private creditors would want assurance of the Club's terms for the overall restructuring before moving forward. In the Secretariat's view, this would require the Club to commit at the outset to a "stock-of-debt" reduction to be delivered in a second stage, even if the first stage was only a rescheduling. Co-chairman Coeure urged the Club to do its utmost to support a country that is making best efforts to seek comparable debt relief from all creditors. The Paris Club will discuss additional options at its January 2009 meeting; negotiations with the Seychelles could take place in March. -------------- Sri Lanka -------------- ¶26. (U) The IMF reported that Sri Lanka's financial situation was deteriorating rapidly. The country had been financing its current account through remittances, but these had fallen, so it had resorted to foreign currency borrowing. Since July, financing had PARIS 00002344 018 OF 023 dried up, reserves had fallen sharply, and the situation had become "very precarious." Sri Lanka would be hard-pressed to continue its strong record of servicing debt, according to the IMF. The World Bank echoed the bleak assessment, noting that tea exports and prices had fallen, and that garment exports were slowing due to the U.S. and European recessions. Under a strategy approved this year, the Bank had a lending envelope of $900 million over three years. The IMF said that although the authorities had not yet discussed seeking Paris Club debt relief, such a request could come quickly, since large amounts were due and external financing options were no longer available. -------------- Togo -------------- ¶27. (SBU) Following the IMF and World Bank's November 25, 2008 decision allowing Togo to enter the HIPC Initiative ("decision point"),Paris Club creditors provided preliminary approval for additional debt relief. The Fund reported Togo's performance had been mostly commendable, especially given external shocks and flooding. Despite a September donors conference and the IMF Board's approval of a $29 million program augmentation, financial conditions remained "challenging," according to the IMF, due to the global situation and difficulties related to privatization and attracting PARIS 00002344 019 OF 023 foreign investment. The Secretariat agreed to correct several errors and recirculate for final approval the draft Agreed Minutes providing Togo with stepped-up debt relief on so-called "Cologne terms." -------------- Methodological Discussion: Outreach to non-Paris Club Creditors -------------- ¶28. (SBU) The Secretariat reported that it had held "informal, technical" talks on October 27, 2008 with eleven major non-Club creditors (Brazil, Bulgaria, China, India, Israel, Kuwait, Romania, South Africa, South Korea, Turkey and the United Arab Emirates). Turkey, Kuwait, Romania and Brazil had indicated that they wanted to be more closely associated with Club discussions, though Turkey had again suggested that the amount of relief granted should depend in part on the creditor's level of development, a departure from the most fundamental Club principle. The Secretariat suggested that it hold further discussions with these creditors in 2009, and Club members agreed to defer discussion of the Turkish idea until a later meeting. ¶29. (SBU) Co-Chairman Coeure reported that he had attended the Financing for Development conference in Doha, where Brazil and South PARIS 00002344 020 OF 023 Africa had played major roles. (Note: As G77 members, Brazil and South Africa's positions in Doha often were at odds with those of Paris Club members. End note.) The Doha final outcome document referred to "equitable" not "comparable" treatment. The Dutch delegate asserted strongly that the Club's purpose should remain twofold: (1) to maximize collections, and (2) to ensure that as much debt as possible is treated on comparable terms. The Club should not try to attract more members in order to justify its continued existence, although there is some value in having major non-Paris Club creditors at the table as had always been the practice. ¶30. (SBU) The Club agreed that attracting new members would be difficult, but that further outreach was desirable. All members agreed that the Secretariat should send a tentative list of upcoming negotiations, accompanied by a request for data about claims on debtor countries, to the 11 countries consulted in October 2008. As in the case of South Africa and Seychelles, any requests to participate in future negotiations would be handled on a case-by-case basis. If a guest creditor blocked consensus, the Paris Club could ask that creditor to leave a negotiation. Some creditors had reservations about the Secretariat's proposals; discussion will continue in January. -------------- PARIS 00002344 021 OF 023 Methodological Discussion: "Illegitimate" Debt -------------- ¶31. (SBU) Following Norway's request to make a presentation on so-called "illegitimate" debt, the Norwegian delegate told the Club that his country approaches debt issues both as a creditor and, more importantly, as a donor. In Norway, the issue of "illegitimate debt" had attracted significant attention from the highest political levels, the NGO community and Norway's state church. Norway wanted to approach the debate with an open mind, and was providing financial and other support for studies, such as a Harvard conference in January 2009 and UNCTAD's work. ¶32. (SBU) The Secretariat lambasted the concept of illegitimate debt, noting that many NGOs had outdated views of this issue and did not recognize that the HIPC and MDRI initiatives had already brought about significant debt cancellation. Basing debt relief on "political" considerations, rather than financial need, risked undermining the basis for demanding comparable treatment from non-Paris Club creditors. The Secretariat also noted that the concept of illegitimate debt carried potentially high costs for debtor countries, as shown by the dramatic rise in Ecuador's bond spreads. Other creditors attacked the Norwegian position, with the Netherlands, UK, Australia, and Spain all questioning the Club's PARIS 00002344 022 OF 023 ability to add value on the topic. Germany, however, welcomed the discussion and suggested that the Club discuss the topic at a future meeting. Following strong UK and Dutch opposition, the Secretariat confirmed there was no consensus to prepare a paper or talking points for creditors to use in answering questions from civil society. -------------- Methodological Discussion: Global Financial Crisis -------------- ¶33. (SBU) At Sweden's request, creditors discussed the financial crisis and its possible effects on the Club. The IMF reported that the Board had approved six programs in November following the current market turmoil and that a "similar number" were under discussion, although the Fund declined to name countries. The IMF's ongoing discussions affected mostly middle-income or upper-middle income countries that owed relatively little debt to Paris Club creditors, although a number of countries would have to restructure their private debts. The IMF agreed to alert the Club to countries likely to request Paris Club debt relief, as it had done with Sri Lanka. ¶34. (U) The next Paris Club meeting is scheduled for January 22, PARIS 00002344 023 OF 023 ¶2009. ¶35. (U) For more detailed information on any of the above-mentioned countries, please contact EEB/IFD/OMA David Freudenwald or Nicholle Manz.