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What Dwight Duncan Doesn't Tell You About WBA
Tuesday, 05 October 2010

What Dwight Duncan and his supporters don’t tell you about

Wind-up-by-Annuity (WBA) and the Ontario Pension Benefit Guarantee Fund (PBGF)

Note 1: The NRPC played a major role in getting the Ontario government to meet its obligations to Nortel pensioners under the PBGF. This was a major plank in our 2009 program. After months of saying that no funds were available, the Ontario government finally came through with a commitment in February 2010. Contrary to the assertions of some outsiders, the NRPC would not contemplate any wind-up situation that did not preserve the PBGF benefits.


Note 2: The Nortel Pension Fund currently is worth over $2.5 Billion and our pensions are partially indexed against inflation (CPI)

Pension experts agree that WBA for a huge pension plan like Nortel's is a really bad idea. It will lock-in our losses at a time of depressed market prices and give any future investment gains to the insurance industry. Prices for annuities will go up immediately as demand will greatly exceed supply. WBA will also likely lead to loss of our pension indexing as explained below. Please note the similarity of Recommendation 5-2 from the Ontario Expert Commission on Pensions to the Financial Sponsorship Model proposed by the NRPC as an alternative to WBA.

The following are excerpts from reports available on the internet and on the NRPC web site regarding the pitfalls of WBA:

Ontario Expert Commission on Pensions : Harry Arthurs: Commissioner, November 2008

".........upward pressures on solvency valuations attributable to annuity costs make it cheaper to simply keep plans open and in operation than to annuitize benefits and close them."
"........ Several suggestions were advanced for avoiding or reducing the cost of annuities . These included creating a publicly funded non-profit annuity pool for pensions; removing the requirement of annuitization on wind-up and allowing for lump sums to be paid and invested as the active or retired member wishes; and allowing a private or public agency to handle stranded pensions, thus obviating the need for them to be annuitized and, presumably, reducing both the demand for annuities and their price."

"..........Recommendation 5-2 - .................... .establish an Ontario Pension Agency to receive, pool, administer, invest and disburse stranded pensions in an efficient manner ........."

"........the OPA could be established as an arm's-length Crown corporation, or operated under franchise by one or more private firms based in the pension industry or, indeed, through some form of public-private partnership - but there should be no long-term reliance on government funding."

Educational Note from the Canadian Institute of Actuaries (CIA) , April,2010

"......due to capacity constraints within the Canadian group annuity market, it is possible that large plans would not be able to purchase annuities upon plan wind-up . While the capacity of the group annuity market is not clearly known, the PPFRC believes groups representing non-indexed annuity liabilities exceeding approximately $500 million may have difficulty in effecting a purchase .........

the availability of CPI indexed annuities of any size may be severely limited."

Professor Norma Nielsen , Haskayne School of Business, Univ. of Calgary, July 2010

"..........A series of mergers has left Canada with only three large companies available to provide annuities. Though no study has been identified on the subject, it is possible this market has become an oligopoly where the cost for annuities is higher than might be observed under fully competitive market conditions. "



PBGF Pitfalls: Common perceptions about the PBGF and how it works are often wrong. While it is undoubtedly a benefit for former employees with pensionable service in Ontario it has some serious side-effects.

  1. 1.The PBGF offers compensation for some lost pension income but only to some Nortel pensioners . The compensation is portrayed to be a top-up to restore the first $1000 per month ($12,000 per year) of your uncut pension ( but see 3, 4 & 5 below ). This top-up applies ONLY if you have recorded service in an Ontario-based Nortel workplace. Service elsewhere does not count. Nortel pensioners who never worked in Ontario will be excluded .
  2. 2.To qualify for the full PBGF benefit you need to have earned at least $1000 per month of your pension in Ontario ,  as described in 1. above. If you earned under $1000 per month of pension in Ontario, your benefit is limited to the value of your pension. e.g. If you earned $1000 per month of your pension in Ontario, and it is cut to $650 after wind up, it would be restored to $1000 by the PBGF . If you had earned only $800 per month of your pension in Ontario, that would be the maximum that would be restored. But in both cases see sections 3, 4 & 5 below.
  3. 3.The Ontario government and the PBGF seem not to recognize the existence of pensions that are indexed to inflation, like Nortel's. Instead they recalculate them as if there were no indexing. One motivation for this may be the short supply of indexed annuities in Canada or it may be done simply to reduce the costs of the PBGF, or both. The result is likely to be very harmful to Nortel pensioners. e.g. If your original indexed pension is $1000 per month, after-wind up it might have become $650. If the PBGF removes our indexing protection you may get around $720 and the PBGF would top that up to $1000 (Example for illustration only). But the penalty is that we will be forced by the government to trade our indexed pension for higher pensions upfront. Pensioners with longer life-expectancy will be the most vulnerable to inflation, but if the CPI increases rapidly in the near future everyone will suffer.
  4. 4.The Ontario government is claiming a priority standing in the bankruptcy court (ahead of employee and pensioner claimants) for any money the PBGF spends to top-up our pensions. If it succeeds, some or all of the amount of our PBGF benefits will effectively be clawed-back out of the eventual settlement of our claim for the pension deficit. Under these circumstances the PBGF contribution to our pensions is more like a loan than a "guarantee", and it has a very harmful side-effect if it should require removing indexing to inflation from all our pensions.
  5. 5.The PBGF does not compensate all "deferred" pensioners the same. Suppose someone works at a company long enough to qualify for a pension but then terminates and moves on to work elsewhere. The person may choose to become a deferred pensioner, eligible at retirement age to receive the earned pension from the original employer. If the employer is bankrupt, and if PBGF qualifying conditions are met e.g. for terminations after 1986, that the former employee's age on termination plus years of service add up to 60 , the reduced pension will be fully topped up per sections 1 & 2 above. For post-1986 terminations there is a sliding scale that reduces the top up to zero for a total below 50. For more information please go to the Morneau Sobeco web site reference below and select item 10.

*https://www.pensionwindups.morneausobeco.com/en/windup_faqs.asp

The bottom line is that the PBGF only helps those pensioners who worked in Ontario, and even then not as much as portrayed. It certainly does not come close to remedying the injustices caused by Canada's bankruptcy system. The removal of pension indexing is potentially very harmful , especially for pensioners with long life-expectancy. For the benefit of all Nortel pensioners, wherever they worked, it is very important to maximize our pensions, to keep pension indexing in place and NOT to submit to Wind-up-by-Annuity.

Last Updated ( Wednesday, 06 October 2010 )
URGENT! CONTACT YOUR MPP TODAY TO STOP WIND-UP-BY-ANNUITY!
Thursday, 30 September 2010

On September 21, 2010, the NRPC received a letter from Ontario Finance Minister Dwight Duncan stating that he was rejecting the Financial Sponsorship Model (FSM), our proposal to avoid wind-up-by-annuity of the Nortel Defined Benefit Pension Plans. In our opinion, his reasons were based on misinformation and were highly premature. In particular, we feel that without reviewing the proposals from 13 potential financial sponsors (due on September 27), it was impossible for him to have made a fair comparison of the alternatives and a reasonable assessment of the benefits to pensioners and the Ontario taxpayer. A regrettable consequence of Mr. Duncan’s letter was that several potential sponsors chose to reconsider proceeding with their bids because of his stated objections.

Representatives from NRPC met with Premier McGuinty and Mr. Duncan after a demonstration in Ottawa on September 23 and obtained a commitment from the Premier to review the situation. We also responded to Mr. Duncan by letter on September 27, explaining our disappointment with his letter and asking for specific actions that would allow the FSM concept to be properly evaluated based on sponsor proposals.

We made four major requests to Mr. Duncan, as follows:
1.  that you get an immediate update from your staff on what wind-up-by-annuity will mean to all Nortel pensioners.
2.  that you communicate with the parties currently involved in responding to the FSM RFP to indicate that they should complete the process and that their proposals will be reviewed for consideration as an alternative wind up process.
3.  that you and your staff review all of the responses to the FSM with our legal representatives, actuaries and pension experts.
4.  that the new Administrator, Morneau Sobeco, be fully aware of this process.

Go to News / FSM to see also the Appendix that we sent with our letter to Mr. Duncan, addressing his 10 stated objections to the FSM proposal.

If you live in Ontario, please use this information to contact your local MPP (face to face, by telephone,by mail or email) and ask him or her to ensure that the NRPC proposals get a fair hearing!  If you live outside of Ontario, please get your friends and relatives in Ontario to contact their MPPs with this concern and then contact Duncan and McGuinty yourself directly since you have a lot to gain from the FSM proposal.  If you send a letter or email, copy Michael Ignatieff as well so he understands how the Ontario Liberals are impacting the federal picture.

If you are sending a letter or email, please don't just forward the message above.  There is no problem in cutting and pasting portions but please personalize it in your own words.  Politicians hate getting form letters even more than you do.  Feel free to include the Appendix as an attachment to your letter.

Last Updated ( Wednesday, 20 October 2010 )
Appendix to Letter to Finance Minister Duncan on September 27, 2010
Thursday, 30 September 2010

1. Potential increased risk assumed by pensioners through a high degree of exposure to the equity markets:

Under FSM, the pension funds would be invested according to accepted practice for pension funds. The sponsor assumes the risk below an agreed minimum level. There would be no difference in market risk compared to any other ongoing pension fund. The requirements for the financial institution would be to use prudent investments given current market conditions over time. Everyone knows that market conditions go through positive and negative periods. FSM allows the fund to recover during good times and to maintain value during difficult times by using prudent investments. Annuities, on the other hand, lock in current market losses permanently. Contrary to Ministry of Finance (MoF) assertions, with annuities the downside risk is built-in up front.

2. The lack of a detailed offer and term sheet from a financial institution willing to undertake the financial sponsorship and provide retirement security for pension plan members:

As the MoF knows, NRPC expects detailed proposals on FSM from potential sponsors by September 27, 2010. It will be pleased to share these responses with Ministry pension experts and appropriate third parties. While your statements on September 15 may have discouraged some bidders, many are continuing to prepare their proposals, because they believe in the FSM concept. We ask that you send a private communication to all of the13 institutions that were in the process of responding to let them know that your Government is interested in reviewing their proposals fairly as an alternative to the existing pension wind-up process.

3. Additional risk to the PBGF and Ontario taxpayers if the FSM fails:

The criteria used to select the financial sponsor will ensure that the guarantee of minimum income for the pensioners, and the accompanying collateral, will be at least as favourable and as reliable as what could be provided by Canadian annuity providers under current PBA regulations.

4. The proposal assumed that the PBGF grant money would be available to the new fund but the government made the grant for the purposes of the PBGF. The new fund would not be able to access the money from the PBGF:

The FSM is simply an alternative way for the Administrator to wind up the Nortel pension plans. Under FSM, the sponsor does not take over the PBGF contributions. The Administrator would be responsible for ensuring that the contributions are used, as intended, to top-up the pensions of qualified retirees, according to the extent of their losses. We have seen no evidence to indicate that the PBGF grant is tied to a particular wind-up process such as annuity purchase, or why the Administrator would not be able to access the PBGF funds for an FSM wind up. Over the lifetime of the pension plans, the returns from the FSM investments are expected to reduce the need for PBGF contributions by at least $100M compared to wind-up-by-annuity, which is surely a benefit to Ontario taxpayers.

5. Because the company would no longer be funding the pension plan, the fund would, barring federal legislative change, lose its tax exempt status under the federal Income Tax Act, exposing the fund to significant income tax liabilities and undermining the security of future pension payments:

Our court-appointed lawyers, Koskie Minsky LLP advised NRPC and MoF in August that "we see nothing in the Income Tax Act that precludes the settling of pension plan obligations in a manner other than the purchase of annuities".
Furthermore, the Federal Minister of Finance, Jim Flaherty, on September 22 wrote to Norm Sterling MPP, in response to his question regarding FSM, advising that "If the Ontario government decided to pursue such an initiative and approached the federal government with a detailed proposal, which they have not yet done, the Government of Canada would naturally be willing to support Nortel pensioners and the province of Ontario through expedient implementation of all reasonable proposed policy measures".

6. Other provinces where Nortel pensioners live would also have to agree to the FSM model:

FSM provides for other provincial pension bodies to opt out of FSM and conduct their own wind-up processes. Each province will have to decide to follow FSM or not. Each will need to assess the value of FSM on its own merits. In addition, should any province decide to do so, they may leave the funds with Ontario to administer on their behalf. Initial responses to our queries to other provincial Finance Ministers is that they are receptive to viewing the results of our RFP process. It should be noted that it is not where pensioners now reside that determines provincial responsibility, but where the pensioner retired.

7. Assumes that future market returns and interest rate changes would be favourable to continuing Nortel plans:

See comments in 1. and 3. above. There will be no additional risk to pensioners under FSM but there will be potential for gains if economic conditions improve. Under wind-up-by-annuity only the annuity providers i.e. the insurance industry, stand to gain in an improving economy. Pensioner losses are locked in. We believe the intent of the Pension Benefit Act is to protect the interests of pensioners, not insurers.

8. Opposition from some Nortel pensioners and former employees, particularly those on long-term disability and with lower incomes:

NRPC would like to see the source and quantification of the MoF's information on this topic since it is completely different from its own. NRPC is not aware of any significant number of pensioners or deferred pensioners who oppose FSM. There has been extensive communication with pensioners through a webinar, web site postings, bulk e-mails and a mailed-out newsletter. Lower income pensioners are aware that, even if they qualify for top-up payments from the PBGF, wind-up-by-annuity carries significant long-term penalties in terms of lost pension indexation and vulnerability to inflation.
Based on your comments in the Legislature about post wind-up pension levels, we wonder if the MoF is aware of the significant number of Nortel pensioners who do not qualify for payments from the PBGF. NRPC data puts the number at 43% of the retiree population. A large number of these pensioners also have low incomes and will see their pensions cut by over 35% (and possibly much more) under wind-up-by-annuity. They fully support the FSM initiative as do the vast majority of others who are in full possession of the facts about wind-up-by annuity. They also know that the MoF intends to claim priority in the bankruptcy process so that its PBGF payments will be recovered in whole or in part from funds that would otherwise go to creditors like themselves.
Please note that the approximately 400 Nortel employees who are on Long Term Disability Status (LTD) are current employees. They are not yet pensioners and may never opt for pensioner status. Nonetheless the majority are supporting the FSM concept through their legal representative, Sue Kennedy. A small group of dissenting LTDs (estimated to be 37) are expressing opposition to FSM and have apparently been mistaken by MoF as representing the majority viewpoint. This is erroneous.
NRPC also believes the dissenting LTDs have been given inaccurate information about FSM and the PBGF and about their rights should they eventually choose to become pensioners.

9. Follows a UK model whose credibility has been called into serious question

NRPC has studied the situation in the UK and also similar proposals in the USA. With our financial advisors, we have examined information on the UK buyout system and spoken at length with an expert actuary involved in the process.
In addition to dealing with pension plans of insolvent companies, the UK system is being used increasingly to consolidate and continue active pension plans that solvent employers wish to give up. One of the earlier buyouts apparently was a scam and should not be held up by the MoF as an example of what has happened to the others. This is highly misleading. The other plans have all enjoyed modest growth, even in tough economic times. Based on direct discussions with the British administrators of the buy-out plans, the system is now working well.
In both the UK and the USA, there is less need for a concept like FSM because of the existence of proper pension guarantee funds. We think it appropriate to point out that in dealing with stranded pension plans like Nortel's, the UK provides a Pension Protection Fund that puts the PBGF to shame. Nortel's UK pensioners can receive up to £28,000 sterling or approximately CAD$45,000! The US also has a national Pension Guarantee Fund that provides protection up to $54,000/annum.
Simply put, FSM is necessary because Ontario's wind-up-by-annuity system is damaging to pensioners with large under-financed pension plans and the PBGF contribution ceiling has not changed since 1980!

10. Would set an uncomfortable precedent for other pension plans in similar situations:

While the prospect of change may be uncomfortable to the MoF, we are quite sure that pensioners and citizens of Ontario would welcome an updating of the outdated pension regulations. Ontario's pension system is thirty years old and inflation, together with changes in the external financial markets, has made it obsolete. Nortel's bankruptcy is revealing the weaknesses of the status quo. Employers have been allowed by regulators like the Financial Services Commission of Ontario (FSCO) to under-finance pension plans, while ignoring their very modest obligations to the PBGF. When disaster strikes, as it did for Nortel workers across the whole of Canada, wind-up-by-annuity will stretch the annuity market past the breaking-point and deprive pensioners of a significant portion of the deferred wages they earned over a lifetime in the workforce. In addition, the PBGF limits have not been changed in 30 years. Had they kept pace, the maximum would now be $3000/mo not $1000/mo.
Initiatives like FSM are vital since the Ministry of Finance and its regulatory bodies such as FSCO, are not taking responsibility or action to remedy the serious flaws in the pension system. The Pension Benefits Act was intended to protect pensioners. Now it is being used to exploit them for the benefit of employers and the insurance industry. Under current rules pensioners are forced to buy expensive annuities out of their own pension funds, further reducing their pension income. Other rules force them to forego any indexation their plan currently provides. This is a major injustice.

NRPC, September 27, 2010

Last Updated ( Friday, 01 October 2010 )
Response to current Liberal MPP letter to constituents re proposed alternative to pension
Wednesday, 22 September 2010

Smokescreen 1 Potential increased risk assumed by pensioners through a high degree of exposure to the equity markets.

Rebuttal: Under FSM the pension funds would be invested according to accepted practice for pension funds. There would be no difference in market risk compared to any other ongoing pension fund. The requirements for the financial institution would be to use prudent investments given current market conditions over time. Everyone knows that market conditions go through positive and negative periods. FSM allows the fund to recover during good times and to maintain value during difficult times by using prudent investments. The sponsor assumes the risk below an agreed minimum level. Annuities on the other hand lock in current losses permanently. Contrary to Ministry of Finance (MoF) assertions, with annuities the downside risk is built-in up front.

Smokescreen 2 The lack of a comprehensive FSM proposal beyond ahigh-level idea.

Rebuttal: FSM began as a high level idea as all innovations do. However it has already been developed to the point where major financial institutions including Canadian banks, have responded positively to a Request for Statements of Interest from NRPC and have committed high level staff to developing their own bids. Nortel and Ernst & Young (the Monitor in the CCAA proceedings) are actively supporting the FSM proposal process, including provision of a secure data room for bidders to examine the pension fund. The MoF has been kept informed of our interactions with financial institutions and the timeframe in which to expect firm proposals. So far, the MoF has apparently not examined the FSM proposal in detail or taken the time to await the results of its progress through the RFP process, preferring to make premature announcements and cite vague objections.

Smokescreen 3 The lack of a detailed offer and term sheet from a financial Institution willing to undertake the financial sponsorship and provide retirement security for pension plan members.

Rebuttal: As the Ministry of Finance already knows, NRPC expects detailed proposals on FSM from potential sponsors by the end of September. It will be pleased to share these responses with Ministry pension experts. We have had feedback that potential bidders are not discouraged by the Minister of Finance's premature comments on September 15, as they see a need for an alternative for our large pension funds.

Smokescreen 4 FSM creates additional risk to the PBGF and Ontario taxpayers if the FSM fails.

Rebuttal: The criteria used to select the financial sponsor will ensure that the guarantee of minimum income for the pensioners, and accompanying collateral, will be at least as favourable and as reliable as what could be provided by Canadian annuity providers under current PBA regulations. PBGF costs are expected to be reduced by $100M or more.

Smokescreen 5 Because the company would no longer be funding the pension plan, the fund would, barring federal legislative change, lose its tax-exempt status under the federal Income Tax Act, exposing the fund to significant tax liabilities and undermining the security of future pension payments.

Rebuttal: The MoF has yet to clearly define the article under the income tax act that would support this assertion. This appears to be a delaying tactic.
Our legal representatives have reviewed the Income Tax Act (ITA) in this area and stated "...and we see nothing in the ITA that precludes the settling of pension plan obligations in a manner other than the purchase of annuities." It appears that there would not be need for any federal legislation to accommodate the FSM proposal.

Smokescreen 6 Other provinces where Nortel pensioners live would also have to agree to the FSM model. We don't know if any such discussions are taking place.

Rebuttal: FSM provides for other provincial pension bodies to opt out of FSM and conduct their own wind-up processes. Each province will have to decide to follow FSM or not. Each will need to assess the value of FSM on its own merits. In addition, should any province decide to do so, they may leave the funds with Ontario to administer on their behalf. Initial responses from other provincial Finance Ministers is that they are receptive to viewing the results of our RFP process.
It should be noted that it is not where pensioners now reside that determines provincial responsibility, but where the pensioner retired. It appears that the Ministry does not understand this

Smokescreen 7 FSM assumes that future market returns and interest rate changes would be favourable to continuing Nortel plans.

Rebuttal: See comments in 1. and 4. above. There will be no additional risk to pensioners under FSM but there will be potential for gains if economic conditions improve. Under Wind-up-by-Annuity only annuity providers i.e. the insurance industry, stand to gain in an improving economy. Pensioner losses are locked in. We believe the intent of the Pension Benefit Act is to protect the interests of pensioners, not insurers!

Smokescreen 8 Some Nortel pensioners and former employees, particularly those on long-term disability and with lower incomes, are opposed to the FSM model.

Rebuttal: NRPC would like to see the source and quantification of the Ministry of Finance's information on this topic since it is completely different from its own. NRPC is not aware of any significant number of pensioners or deferred pensioners who oppose FSM. Extensive communication has occurred through a webinar, web site postings and a mailed-out newsletter. Lower income pensioners are aware that, even if they qualify for top-up payments from the Ontario Pension Benefit Fund (OPBGF), wind-up-by-annuity carries significant long-term penalties in terms of lost pension indexation and vulnerability to inflation.
Based on comments made in the Legislature by the Finance Minister, NRPC believes that he is unaware of the significant number of Nortel pensioners who do not qualify for payments from the PBGF. NRPC data puts the number at 43% of the retiree population. A large number of these pensioners also have low incomes and will see their pensions cut by over 35% (and possibly much more) under wind-up-by-annuity. . For Minister Duncan to claim that the vast majority of pensioners will obtain 90% of their pensions under wind-up by annuity is ridiculous
Note that Nortel employees who are on Long Term Disability Status (LTD) are current employees and are not yet pensioners Nonetheless the majority are supporting the FSM concept through their legal representative, Sue Kennedy. A small group of dissenting LTDs (estimated to be 37) are expressing opposition to FSM and have apparently been mistaken as representative of the majority viewpoint. This is erroneous.
NRPC believes the dissenting LTDs have been given inaccurate information about FSM and about their rights should they eventually opt to become pensioners. Also due to their lower age, those LTDs who are not pension eligible will be able to take out their pension as a Commuted Value, thereby avoiding annuities

Smokescreen 9 FSM follows a UK model whose credibility has been called into serious question .

Rebuttal: Again NRPC would like to see the source and quantification of the Ministry's information. NRPC and its financial advisors have examined information on the UK system and spoke at length with an expert actuary involved in the process.
The UK system is apparently being used to consolidate and continue active pension plans that employers wish to give up. One of the earlier buyouts was a scam and is being held up by the MoF as an example of what happens to all plans. This is disingenuous. Other plans have all enjoyed modest growth, even in tough economic times. Based on direct discussions with the British administrators of the buy-out plans, this system is now working well.
We think it appropriate to point out that in dealing with stranded pension plans like Nortel's, the UK provides a Pension Protection Fund that puts the OPBGF to shame. Nortel's UK pensioners can receive up to £28,000 sterling or approximately CAD$45,000! The US also has a national Pension Guarantee Fund which provides protection up to $54,000/annum.

Smokescreen 10 FSM would set a precedent for other pension plans in similar situations.

Rebuttal: Yes, this is exactly what should happen. Ontario's pension system is thirty years old and inflation, coupled with changes in the external financial markets, have made it obsolete. Nortel's bankruptcy has dramatically revealed the weaknesses of the status quo. Employers have been allowed by regulators to under-finance pension plans, while ignoring their very modest obligations to the OPBGF. When disaster strikes, as it did for Nortel workers across the whole of Canada, wind-up-by-annuity will stretch the annuity market past the breaking-point and deprive pensioners of a significant portion of the deferred wages they earned over a lifetime in the workforce. In addition, the PBGF limits have not been changed in 30 years. Had they kept pace the maximum would now be $3000/mo not $1000/mo.
Initiatives like FSM are vital since the Ministry of Finance and its regulatory bodies, such as the Financial Services Commission of Ontario (FSCO) are not taking action to remedy the serious flaws in the pension system. The Pension Benefits Act was intended to protect pensioners. Now it is being used to exploit them for the benefit of employers and the insurance industry. Under current rules the pensioners are forced to buy expensive annuities out of their own pension funds, further reducing their pension income; rules also force them to forego any indexation their plan currently provides. The original intent of the law is not being met; the law must be changed.

Last Updated ( Saturday, 25 September 2010 )
One Page Summary of FSM
Monday, 13 September 2010
Last Updated ( Monday, 13 September 2010 )
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