Banks Want to Do To Student Loans What They Did to Mortgages

On the heels of yesterday’s post about student loans and their growth.  I want you to know that Wall Street is hot on the problem.  They’ve made a quiet proposal to the “supercommittee” that’s supposedly addressing government deficits to have the government subsidize the banks via fees without creating any more student loans or taking on any risk.  The essence of the whole proposal is to leave the government on the hook for student loans but to use accounting tricks to “take them off the books”.  It’s similar to the ways the big banks prior to the crisis would take debt and obligations they had and hide them in “special purpose entities” so they wouldn’t have to show them on their books.  There’s no benefit to investors, students, or the government from the proposal. Only the banks benefit.  But maybe that’s why they aren’t talking about the proposal in public but instead try to get it passed quietly through lobbyists.

Jason Delisle of New America Foundation’s Higher Ed Watch explains (bold emphases are mine):

The investment banking industry – and its friends in Congress – have cooked up a scheme they are pitching to the “supercommittee” that they say would reduce the federal debt and cut federal spending. Supposedly, the plan would take the government’s $555 billion direct student loan holdings off of its books. In reality, the plan, which would allow the bankers to earn fees on a $555 billion deal, plus $100 billion more every year, would not reduce the debt or cut spending. But that hasn’t stopped Wall Street from trying.

A proposal that could only have been be cooked up by investment bankers is circulating on Capitol Hill. It would refinance the $555 billion direct student loan portfolio with new debt backed 100 percent by the federal government. But this new debt would not be called U.S. Treasury debt, despite the 100 percent guarantee, and therefore not counted as part of the national debt. In other words, the new debt would be used to pay off the old debt (Treasury bonds) that the government issues to finance direct student loans. To be sure, the mechanics of the proposal are more complicated than that, but the effect of the proposal would be to move all outstanding and future student loans from bonds backed 100 percent by taxpayers to another set of bonds backed 100 percent by taxpayers but not counted as part of the national debt. …

The proposal would increase federal spending because the new securities the government would issue to finance direct loans would have higher interest costs than the Treasury bonds they would replace, effectively increasing the cost of every direct loan. Investors would view the new securities as slightly less desirable than Treasuries (even though they still carry a 100 percent guarantee from the federal government) because they will not be as liquid (easily bought and sold among investors). The new securities would also be subject to prepayment risk…Then there are the fees that the government would have to pay to investment banks (the “syndicate of underwriters”) to put the new securities on the market each year. Those fees could cost taxpayers tens or even hundreds of millions of dollars every year.

Apparently the supporters of the proposal claim that it would “diversify funding sources”.  In other words, if someday, somehow, some investors wouldn’t want to buy U.S. Treasury bonds (something is emphatically NOT happening now since interest rates are at record lows), then maybe they might be interested in something that’s backed by the U.S. but isn’t called a Treasury bond.  In other words, there’s a slight chance that pigs might someday fly away from the farm so let’s have a bunch of hogs that well call “pink cows”.  Jason speaking again:

Some members of Congress – particularly Republicans – would simply feel better if the direct loan program were funded with “private capital” rather than U.S. Treasury bonds….[but] the securities would be sold in the same markets as Treasury bonds and the capital raised to finance direct student loans would be no more or less “private” than it was before.

If the Wall Street proposal to refinance direct student loans doesn’t actually reduce the debt, increases the federal budget deficit, and doesn’t make the program’s financing any more dependent on the private market than it already is, what does it do? It effectively addresses what some see as the direct loan program’s biggest shortcoming; it doesn’t allow Wall Street to make a ton of money off of it.

So Wall Street wants to do to student loans what it’s done to home mortgage finance.  Have somebody else, such as the federal government, guarantee that they cannot lose any money.  Then, they want to bundle them and re-sell them solely for the purposes of making more fees – just like they did with mortgage-backed securities and credit default swaps and other derivatives.  If I recall correctly, that didn’t really work out too well now did it?  Well it worked out for the banks, but not for the rest of us.

Warning: More Bank Bailouts Possible

One area I haven’t commented on much is the ongoing European “debt crisis”.  The Greek debt crisis is a part of it, but it’s only the tip of the iceberg.  The roots are much deeper.  One reason I haven’t commented is because it’s fairly complex and requires a lot of background explanation which I haven’t had time to write.  Nonetheless, it’s something worth mentioning.  In particular because it’s likely to mean more big bank bailouts.

In short, the crisis involves the way the Euro currency zone is constructed.  Countries that use the Euro have surrendered their sovereignty on monetary policy – that’s now the purview of the European Central Bank (ECB).  This means that government debt levels do matter for countries in the Euro.  They can default because they don’t have control over their own currency.  The U.S., Japan, UK, Canada, Australia, and others can’t default because they control their own central bank and currency.  But Euro countries can.  In the case of Greece and Ireland this means a high likelihood of default.  When the global economy crashed three years ago, it sent the economies of most countries down.  This raised the debt-to-GDP level by reducing the denominator, the GDP number.  But a country in a recession needs to increase government spending and deficits to stimulate growth.  Instead, the construction of the Euro agreement and pressures from the ECB forced these countries to pursue an austerity-based policy of cutting government programs.  But the cutting of government spending has only worsened the recession and shrunk their GDP even more, reducing tax collections.  It’s made default more likely.

In the Greek case, default appears inevitable.  The question is how much of a loss do bondholders take and when.  Therein lies a problem.  The people who own the Greek debt are largely big French and German banks. These banks themselves aren’t exactly robust.   If Greece defaults at a level that will actually help Greece find it’s way out instead of simply delaying the crisis, then these banks will likely take very heavy losses.  The losses are large enough to jeopardize the solvency of the banks themselves.  So Greek default also means figuring out how to recapitalize these big banks.  These are so-called “too big to fail banks”.

Currently there are negotiations going on about how to structure a  Greek default, simultaneously prop up the Euro banks, and stop a possible contagion effect from spreading to Ireland, Portugal, Spain, Italy, and Belgium.  But there have been negotiations over this crisis for nearly two years now with much successs.  The German and French leaders have promised a comprehensive solution later this week. It was supposed to be today, but it’s been delayed to mid-week.

What does that have to do with the U.S.?  Nobody really knows.  The devil is in the details.  At first pass, big U.S. banks aren’t supposed to have much exposure to Greek debt, so they shouldn’t be endangered by a large Greek default.  But, the big U.S. banks like Citi, JP Morgan Chase, BofA, and Goldman Sachs have large stakes in the big Euro banks.  A failed Euro bank could have repercussions.  Of greater concern are derivatives, particularly Credit Default Swaps. The U.S. banks, particularly Goldman are known to have been active in selling these derivatives.  Since the derivative markets and positions are largely secret and non-transparent (a failure of the Dodd-Frank Financial Reform bill), we don’t know if a Greek default will trigger significant liabilities for these banks.

In separate news, Bank of America, is on a death-watch by some analysts.  Yves Smith at Naked Capitalism clues us in:

If you have any doubt that Bank of America is in trouble, this development should settle it. I’m late to this important story broken this morning by Bob Ivry of Bloomberg, but both Bill Black (who I interviewed just now) and I see this as a desperate (or at the very best, remarkably inept) move by Bank of America’s management.

The short form via Bloomberg:

Bank of America Corp. (BAC), hit by a credit downgrade last month, has moved derivatives from its Merrill Lynch unit to a subsidiary flush with insured deposits, according to people with direct knowledge of the situation…

Bank of America’s holding company — the parent of both the retail bank and the Merrill Lynch securities unit — held almost $75 trillion of derivatives at the end of June, according to data compiled by the OCC. About $53 trillion, or 71 percent, were within Bank of America NA, according to the data, which represent the notional values of the trades.

That compares with JPMorgan’s deposit-taking entity, JPMorgan Chase Bank NA, which contained 99 percent of the New York-based firm’s $79 trillion of notional derivatives, the OCC data show.

Now you would expect this move to be driven by adverse selection, that it, that BofA would move its WORST derivatives, that is, the ones that were riskiest or otherwise had high collateral posting requirements, to the sub. Bill Black confirmed that even though the details were sketchy, this is precisely what took place.

Part of BofA’s problems, well, actually a very large part of it’s problems stem from the loose and possibly illegal banking practices at Countrywide Mortgage which it took over in 2008.  Yves updates us on this here.

Bottom-line on all this:  expect more big bank bailouts of some kind in coming months.  It might only be big Euro banks.  It might only involve Bank of America.  But there’s significant,if less than probable, chance that we’ll have to see another round of bank bailouts.

Too Big to Fail Should Be Too Big to Exist

Against Monopoly has a great graphic that shows a big part of the problem with our financial sector and our economy.

How the Too Big to Fail Banks Got  So Big

How the Too Big To Fail Banks Got So Big

The four banks shown above are the four largest banks in the U.S.: JP Morgan Chase, Citi, BofA, and Wells Fargo.  Together they dominate the financial industry. If you add in Goldman Sachs and Morgan Stanley, the domination is near complete.  They all received large bailouts in the 2008-09 crisis.  Today they are much larger than when we entered the crisis. As the graph shows, none of these banks grew so large by “natural” or “organic” means.  They didn’t grow because they offered better or more efficient services to customers.  They didn’t “win in the marketplace” by competing better.  They simply bought the competition.  It’s domination by merger.  The U.S. banking system which at one time was very competitive and decentralized with literally thousands of very competitive banks is now dominated by a few.  We call it oligopoly on the way to monopoly.

When very, very large banks get too big, they become “Too Big To Fail”.  That means, if the banks were allowed to fail because of bad decisions, bad management, or bad investments, it would set off a domino effect throughout the economy and financial system.  That would punish all of us and not just the bank’s owners.  This, of course, is what happened in 2008 when Lehman Brothers was allowed to fail.  It set off a financial panic where banks wouldn’t / couldn’t loan to each other (or anyone else).  Result:  big bailouts of big banks.

But it doesn’t have to be this way.  Yes, once we have a “too big to fail” bank and it fails, then there’s pretty much no choice but to bail them out.  There are choices about the structure of the bailout. We could have set up the bailouts in a way that the economy wins and the failed managers and bank owners suffered.  We didn’t.  The Federal Reserve, the Bush administration, and then the Obama administration made it a priority to keep the bank managers and bank owners whole.  The economy has suffered from a slow recovery partly as a result.

But bailouts shouldn’t be necessary because we shouldn’t allow the banks to become this big in the first place.  Again, we have a choice.  We could have prevented some or all of these mergers.  The laws are on the books to do it.  Washington, following the failed anti- antitrust philosophy of the Chicago school since the 1980’s simply doesn’t challenge many mergers these days.  It’s bad for campaign contributions.  Besides we’re supposed to believe that a market fairy will make it all right.  Instead of challenging and stopping some of these mergers, both the government and The Federal Reserve have actually facilitated and acted as match-maker for many of the mergers.  In March 2008, when Bear Stearns failed, The Federal Reserve offered a deal to JP Morgan Chase.  If Chase would buy Bear Stearns, The Fed would reimburse Chase for any losses over a set amount.  Heads Chase wins. Tails Chase wins.  Nice deal.

We have other choices as well.  In other industries historically when the private competition in the market led to monopoly or near-monopoly outcomes, the government chose to regulate the industry as a public utility.  We did it in the 1920’s and 1930’s with the electrical industry.  Your local electrical company wasn’t always a regulated utility.  At one time it was ravenous and rapacious private monopoly just like these banks are becoming.  When Standard Oil became a monopoly over a hundred years ago, we sued and broke it up into a bunch of other companies.

This complicity in allowing the big banks to become Too Big To Fail is among the types of policies that the protesters of #OccupyWallStreet want changed.  Me, too.

The Fed’s New “Twist” – Not Likely To Help

Late Wednesday The Federal Reserve announced a new program to try to stimulate  the economy so that maybe somebody, somewhere could get a new job, or maybe it’s so that critics would shut-up about employment.  It’s always hard to tell what The Fed’s real objectives are.  I don’t have time to explain now why it’s not likely to do much. But I didn’t want it to go unnoticed, so I’ll give you Stephanie Kelton from neweconomicperpectives, the UM Kansas City MMT people:

Ben Kenobi Launches Operation Twist: Will it Save the Republic?

The Federal Open Market Committee (FOMC) just announced that it’s going to begin another round of asset buying, this time offsetting its purchases of longer-dated securities with sales of shorter term holdings. The goal? Flatten the yield curve. The hope? Engineer a recovery by helping homeowners refinance at lower rates and making broader financial conditions more attractive to would-be-borrowers.

At this point, it looks like Obi-Ben Kenobi realizes that Congress isn’t going to lend a hand with the recovery. Indeed, as a scholar of the Great Depression, he’s probably deeply concerned by the “Go Big” mantra that is now drawing support from people like Alice Rivlin, former Vice Chair of the Federal Reserve.  And so it is Ben, and Ben alone, who must fight to prevent the double-dip. It is as if he’s responding to the public’s desperate cry, “Help me Obi-Ben Kenobi. You’re my only hope.” Will it work?  Not a chance, but that conversation is taking place over at Pragmatic Capitalism, so drop in and find out why.  Below is a description, taken from the full FRB press release, that describes just what the Fed is going to do.  May the force be with us all.

“To support a stronger economic recovery and to help ensure that inflation, over time, is at levels consistent with the dual mandate, the Committee decided today to extend the average maturity of its holdings of securities. The Committee intends to purchase, by the end of June 2012, $400 billion of Treasury securities with remaining maturities of 6 years to 30 years and to sell an equal amount of Treasury securities with remaining maturities of 3 years or less. This program should put downward pressure on longer-term interest rates and help make broader financial conditions more accommodative. The Committee will regularly review the size and composition of its securities holdings and is prepared to adjust those holdings as appropriate.

To help support conditions in mortgage markets, the Committee will now reinvest principal payments from its holdings of agency debt and agency mortgage-backed securities in agency mortgage-backed securities. In addition, the Committee will maintain its existing policy of rolling over maturing Treasury securities at auction.”

Yep, This Is What A Liquidity Trap Looks Like

People, businesses, and banks simply aren’t investing in the sense of putting financial wealth to work in productive purposes with the intent to produce goods and thereby produce profits.  Instead, folks, the ones who have financial wealth that is, are just sitting on cash.  They’re putting it in the bank at record low interest rates. The banks don’t want the extra deposits and are trying to discourage it.  Meanwhile the banks are just turning around and putting the money on deposit at The Federal Reserve where it sits idle. This is called a liquidity trap.

Calculated Risk directs us to this report:

From Scott Reckard at the LA Times: Bank deposits soar despite rock-bottom interest rates

Americans are pumping money into bank accounts at a blistering pace this year, sending deposits to record levels near $10 trillion …

In the last three months, accounts at U.S. commercial banks have increased $429 billion, or 10%, almost double the increase for all of last year.

The large amount of cash only adds to expenses such as paying for deposit insurance premiums. … [banks] have slashed interest payments to discourage customers. Wells Fargo & Co. … halved its payments on one-year certificates of deposits to 0.1%; Citigroup … dropped its payment to a paltry 0.3%.

[Some banks are] stashing it in a safe but unrewarding place: Federal Reserve banks, which are paying them an interest rate of just 0.25% to tend the funds. Such deposits rose to more than $1.6 trillion at the end of August from about $1 trillion a year earlier, according to the Fed.

So why is this really significant?  Simple. Neo-classical/neo-liberal macro theories, the theories that conservatives have been relying on, basically say this can’t happen. It’s irrational and according to those models, people and firms never act irrationally.  So who or what theories say a liquidity trap is possible?  Keynesian theory.  Yes, the whole idea of a liquidity trap in which macro circumstances are such that firms and households would rather hold cash than put it to some productive investment purpose comes from Keynes.

A liquidity trap is also significant because it means that monetary policy, the raising/lowering of interest rates and the purchase/sale of bonds by the central bank, isn’t very effective in a liquidity trap. The Federal Reserve can make funds available for investment, but it can’t force banks to lend or firms to invest or households to spend.  Monetary policy in times of a liquidity trap has been likened to pushing on a string.  The string doesn’t really move much.  Again, neo-classical models don’t allow for the possibility of a liquidity trap.  Indeed they start with assumptions that pretty much exclude the possibility of there ever being one.  Models and theories that start with the assumption that “A” can never happen aren’t of any use in trying solve “A” when it really does show up.

Why do people seek money instead of useful investment in a liquidity trap?  Simple. There are two reasons why firms and people would seek to hold financial wealth as money instead of useful, profitable investments.

  • First, profitable investments require a growing economy and expectations of a growing economy.  If firms and people have no confidence that the economy will grow or that any growth will last, then they don’t invest. No need to expand capacity at the business if you won’t need the extra capacity.
  • Second, if you expect the economy to get worse and/or have deflation happen, then it makes enormous sense to be cash instead of things.  Cash actually is profitable and gains in real purchasing power when deflation happens.  So I would interpret from the above data that people, banks, and firms are expecting more deflation and not expecting inflation.

What to do in a liquidity trap?  Theoretically (and Krugman/Delong push this idea)  you could have the central bank (Federal Reserve) make some sort of commitment to higher future inflation.  But that’s in theory only.  It’s not been proven.  What’s experience say?  We have a choice.  Suffer through it, experience a prolonged depression that could easily last a generation, and make do with lower living standards for the vast majority but see the really wealthy become even more wealthy.  This is the story of the Long Depression in the late 1800’s.   Or, we could turn to aggressive fiscal policy. Keynesian style spending for job creation.  That’s been proven.  It worked in the 1930’s until it was abandoned in 1937, it worked in 1939-1940 with the start of WWII (not my choice of spending priorities), and it worked quite well in the 1950’s through the 1970’s in achieving a higher average annual growth rate in GDP than has been achieved since.

Unfortunately, too many economists, and the politicians that follow them, are so married to their ideologically-based models that they persist in the theory even when the facts contradict it.

Founding Fathers Would Have Opposed A Balanced Budget Amendment – The Purpose of National Government Was to Borrow

Both official Washington and the chattering political classes have spent most of the past 12 months debating how to cut the government budget, reduce deficits, and limit debt.  Key groups, and perhaps the most vocal and strident groups in the debate, have been the self-described “constitutional conservatives” and Tea Party types. They have staked out the position that government deficits, debt, and indeed any taxation except the most minimal taxation is un-American and antithetical to “first principles” of the Founding Fathers.  They maintain a myth that the U.S. Constitution was created to limit the U.S. government’s ability to tax or run a deficit.  Unfortunately for them, history and the constitution itself tell a different tale.

Historian William Hogeland punctures the myth that the Founding Fathers would have agreed with today’s Tea Party types using an historian’s favorite tools – the facts. The following originally appeared at New Deal 2.0. Besides the applicability to today’s debates, it makes fascinating reading about the historical situation that led to the Constitution after the Revolution.  (emphasis below in bold are mine)

Why Debt Ceilings and Balanced-Budget Requirements Violate the Original Intent of the Constitution

So-called “constitutional conservatives” ignore the realpolitik of our nation’s origins.

In a critical and entertaining portrait of the anti-tax activist Grover Norquist, the New York Times columnist Frank Bruni presented Norquist as an absolutist obsessed with forcing modern political life to conform to ideas that Norquist associates with the American founders’ first principles.  Of course, Norquist is by no means alone in taking that position. That the Constitution came into existence to keep taxes low, the federal government small, and national debt at zero is an article of faith among many who, like Michele Bachmann, have taken to calling themselves “constitutional conservatives.” And faith is required to believe it, as the Norquist interview shows. To make his supposedly constitutional argument, Norquist cites the first amendment on freedom of religion and the second on the right to keep and bear arms, and then goes on to cite absolutely nothing, in either the articles or the amendments, that so much as hints at a constitutional requirement to balance the federal budget, avoid debt, tax no more than people like Norquist deem appropriate, and keep government small.

He can’t cite anything to that effect because while balancing budgets, restraining borrowing, and keeping taxes low and government small might be good goals, depending on what you mean by them, it is impossible to locate in the founding national law any requirement to accomplish them. Indeed, the reality of founding history leads to the reverse conclusion.

The Constitution came about precisely to enable a newly large government — a national one — to tax all Americans for the specific purpose of funding a large public debt. Neither Alexander Hamilton nor his mentor the financier Robert Morris made any bones about that purpose; James Madison was among their closest allies; and Edmund Randolph of Virginia opened the Constitutional Convention by charging the delegates to redress the country’s failure to fund — not pay off, fund — the public debt, by creating a national government.

Beginning during the War of Independence, and continuing throughout the 1780s, American nationalists committed themselves to a small class of upscale high financiers (largely identical with the American nationalists), who had bought bonds from the confederation Congress in hopes of earning regular, tax-free, 6% interest payments — not in the Congress’s crashing paper currency but in hard, cold metal or its equivalent, stable bills of exchange. Morris, Hamilton, Madison, and others believed that swelling the debt to immense proportions would make a coherent nation out of thirteen squabbling states and make that nation a player on the world economic stage. Their plan to do so depended partly on making military-officer pay a pension, thus turning the entire officer class into public bondholders — and giving Congress new power to tax all Americans to support that debt.

Hamilton is often reflexively presented as finding inventive ways to pay down the national debt. His real accomplishments were of course “funding and assumption” — absorbing the states’ war debts in the federal one and funding that huge obligation via nationally collected and nationally enforced taxes.

Hence the all-important provisions of the Constitution giving Congress very broad powers to tax and acquire debt. To 18th-century American nationalists across the political spectrum — to our founders and framers, that is, from Hamilton to Madison, from Morris to Randolph, from the financiers to the planters — national taxing and borrowing were ineluctably connected to the very purpose of national government.

Nobody has to like it. But the original intent of the Constitution involved sustaining and managing public debt via taxation.

Both the articles and the amendments do, of course, limit government and restrict its power. But no ratified amendment has ever qualified Congress’s power of the purse, which in the minds of the framers explicitly involved the power to take on debt and fund it. In their tweets and blogs, “constitutional conservatives” have been promoting a balanced-budget amendment with reference to the tired notion that since households and small businesses must balance their budgets (as if!), government must too. They link that economically useless prescription to the widespread fantasy that our Constitution was written, amended, and ratified for just such a purpose. The framers saw it just the other way.

But really everybody, not just “constitutional conservatives,” buys into the fantasy now. History is rarely helpful politically. It’s hard to imagine liberals bringing to debt-ceiling and balanced-budget debates the painful realpolitik of our national origins, which show the Constitution existing, originally, to finance the investing class and yoke that class’s interest (in every sense) to national power. Thus the Times gives the Bruni piece a headline referring to Norquist’s “dangerous purity” — as if the danger in Norquist’s approach lies in a too-rigid insistence on basic principle. There’s nothing purist about Norquist. Whether his ideas may be proven right or proven wrong, they are anything but originalist. Like those of Bachmann and the rest of the anti-tax right, Norquist’s principles are novel, innovative, and weirdly postmodern, extra-constitutional at best.

Stark realism about the actual founding purposes of the Constitution will always have limited use in political debate. But it would be nice, at least — though unlikely — if we would argue these issues on their merits, and leave the Constitution alone.

William Hogeland is the author of the narrative histories Declaration and The Whiskey Rebellion and a collection of essays, Inventing American History. He has spoken on unexpected connections between history and politics at the National Archives, the Kansas City Public Library, and various corporate and organization events. He blogs at http://www.williamhogeland.com.

Why the Whole Idea of “Rating” Government Bonds is Absurd

James Kwak at Baseline Scenario offers a great analogy and explanation for why the whole concept of a private rating agency such as Standard and Poor’s putting a credit rating on government bonds is absurd.  It adds no new information.  Now if S&P wants to rate the Greater Podunk Water Authority bonds or some such, that provides a service.  But they add nothing at the national level. James says:

Still, I think the whole thing is preposterous. S&P downgrading the United States is like Consumer Reports downgrading Coca-Cola. Consumer Reports is a great institution. For example, if you want to know how reliable a 2007 Ford Explorer is going to be, they have done more research than anyone to figure out the reliability history of every single vehicle. Those ratings are a real public service, since they add information to the world. But when it comes to Coke and Pepsi, everyone has an opinion already, and no one cares which one, according to Consumer Reports, “really” tastes better. When S&P rated some tranche of a CDO AAA back in 2006, it meant that some poor analyst had run some model fed to her by an investment bank and made sure that the rows and columns added up correctly, and the default probability percentage at the end was below some threshold. It might have been crappy information, but it was new information. When S&P rates long-term Treasuries AA+, it means . . . nothing. And if any serious buy-side investor were tempted to take S&P’s rating into account, she would be deterred by the fact that the analysis that produced the rating included a $2 trillion arithmetic error.

When it comes to sovereign debt issued by major countries, investors already use their own judgment instead of following credit ratings. These are the current ten-year yields for fifteen countries that had AAA ratings on Friday:

  • Switzerland: 1.17
  • Singapore: 1.79
  • Germany: 2.34
  • Sweden: 2.34
  • United States: 2.56
  • Denmark: 2.58
  • Canada: 2.63
  • Norway: 2.63
  • United Kingdom: 2.68
  • Netherlands: 2.77
  • Finland: 2.90
  • Austria: 2.97
  • France: 3.14
  • New Zealand: 4.50
  • Australia: 4.64