Can and should central banks have a social responsibility (‘central banks’ social responsibility’—CBSR) to play a role in social issues, such as economic inequality? This article provides a conceptual account and analysis of the benefits and challenges associated with CBSR. After showing that CBSR is gaining momentum through the pull of influential actors including central banks themselves, policy-makers, and public opinion, I discuss two types of CBSR the European Central Bank (ECB) could engage in. The moderate approach involves action based on the primary mandate, whereas use of the secondary mandate would present an enlarged version of CBSR. While action based on the primary mandate is both legally possible and desirable, the ‘powered’ version of CBSR comes with significant legal hurdles. Absent clear prioritization by the Union’s political institutions of certain economic policies and objectives, selection and prioritization by the ECB of one or more policies would risk opening the floodgates to policy-making. The enlarged version of CBSR is also undesirable, as it would make the scrutiny of the ECB’s activity more challenging for the European Parliament, negatively alter the public trust the ECB enjoys, and heighten the risk of friction within the European System of Central Banks.
{"title":"A Study on Central Banks and Social Responsibility: the Case of the ESCB","authors":"Raffaele Felicetti","doi":"10.1093/jfr/fjad010","DOIUrl":"https://doi.org/10.1093/jfr/fjad010","url":null,"abstract":"Can and should central banks have a social responsibility (‘central banks’ social responsibility’—CBSR) to play a role in social issues, such as economic inequality? This article provides a conceptual account and analysis of the benefits and challenges associated with CBSR. After showing that CBSR is gaining momentum through the pull of influential actors including central banks themselves, policy-makers, and public opinion, I discuss two types of CBSR the European Central Bank (ECB) could engage in. The moderate approach involves action based on the primary mandate, whereas use of the secondary mandate would present an enlarged version of CBSR. While action based on the primary mandate is both legally possible and desirable, the ‘powered’ version of CBSR comes with significant legal hurdles. Absent clear prioritization by the Union’s political institutions of certain economic policies and objectives, selection and prioritization by the ECB of one or more policies would risk opening the floodgates to policy-making. The enlarged version of CBSR is also undesirable, as it would make the scrutiny of the ECB’s activity more challenging for the European Parliament, negatively alter the public trust the ECB enjoys, and heighten the risk of friction within the European System of Central Banks.","PeriodicalId":42830,"journal":{"name":"Journal of Financial Regulation","volume":null,"pages":null},"PeriodicalIF":2.6,"publicationDate":"2023-11-23","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"138543514","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Abstract Scholars and policy makers have long debated whether securities firms should be allowed to bundle the cost of execution services with the cost of research. Investor advocates condemn the practice whereas industry representatives defend it. In 2018, as part of the Markets in Financial Instruments Directive II (MiFID II) legislative regime, the EU forced the unbundling of commission charges, diverging from US legal standards which still allow ‘soft dollar’ payments for research. The EU’s unbundling regime has challenged global financial services firms, which must now comply with conflicting rules across national boundaries. For more than five years, the US Securities and Exchange Commission provided temporary no-action relief to facilitate compliance with MiFID II, but that relief expired in July 2023, presenting an opportunity to reconsider the impact of MiFID II’s unbundling regime and its implications for US regulators and investors. While this article takes a critical view of soft dollar practices, the story of MiFID II presents contested issues of policy analysis as the agency costs inherent in bundled commissions could be offset by the public benefits of additional research. Unbundling also offers a noteworthy example of an innovation in capital markets regulation flowing from Europe to the United States rather than the other way around.
{"title":"‘Nobody Is Proud of Soft Dollars’: the Impact of MiFID II on US Financial Markets","authors":"Howell E Jackson, Jeffery Y Zhang","doi":"10.1093/jfr/fjad007","DOIUrl":"https://doi.org/10.1093/jfr/fjad007","url":null,"abstract":"Abstract Scholars and policy makers have long debated whether securities firms should be allowed to bundle the cost of execution services with the cost of research. Investor advocates condemn the practice whereas industry representatives defend it. In 2018, as part of the Markets in Financial Instruments Directive II (MiFID II) legislative regime, the EU forced the unbundling of commission charges, diverging from US legal standards which still allow ‘soft dollar’ payments for research. The EU’s unbundling regime has challenged global financial services firms, which must now comply with conflicting rules across national boundaries. For more than five years, the US Securities and Exchange Commission provided temporary no-action relief to facilitate compliance with MiFID II, but that relief expired in July 2023, presenting an opportunity to reconsider the impact of MiFID II’s unbundling regime and its implications for US regulators and investors. While this article takes a critical view of soft dollar practices, the story of MiFID II presents contested issues of policy analysis as the agency costs inherent in bundled commissions could be offset by the public benefits of additional research. Unbundling also offers a noteworthy example of an innovation in capital markets regulation flowing from Europe to the United States rather than the other way around.","PeriodicalId":42830,"journal":{"name":"Journal of Financial Regulation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-10-19","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135730280","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Michael Bradley, Irving Arturo De Lira Salvatierra, Mitu Gulati, Ugo Panizza
ABSTRACT In this article, we examine the relations between risk, the choice of foreign or local contract terms (parameters), and maturity in the sovereign debt market. Our primary finding is that the maturities of bonds that carry a meaningful degree of risk are greater when the bonds are written under foreign parameters. This finding is consistent with the Credible Commitment Theory. Relinquishing certain key contractual parameters (governing law, jurisdiction, currency, listing) precludes the issuing sovereign from taking actions that would diminish the wealth of its bondholders after the bonds have been issued. Correspondingly, the yield on lower-grade bonds, written under foreign parameters, is less than the yield on bonds written under local parameters. Investors are willing to pay a premium for lower-grade bonds if they are written in foreign parameters. Finally, we find a positive relation between maturity and S&P ratings for the subsample of lower-grade bonds. However, we find no such relation for the subset of high-grade bonds.
{"title":"Risk, Contract Terms, and Maturity in the Sovereign Debt Market","authors":"Michael Bradley, Irving Arturo De Lira Salvatierra, Mitu Gulati, Ugo Panizza","doi":"10.1093/jfr/fjad009","DOIUrl":"https://doi.org/10.1093/jfr/fjad009","url":null,"abstract":"ABSTRACT In this article, we examine the relations between risk, the choice of foreign or local contract terms (parameters), and maturity in the sovereign debt market. Our primary finding is that the maturities of bonds that carry a meaningful degree of risk are greater when the bonds are written under foreign parameters. This finding is consistent with the Credible Commitment Theory. Relinquishing certain key contractual parameters (governing law, jurisdiction, currency, listing) precludes the issuing sovereign from taking actions that would diminish the wealth of its bondholders after the bonds have been issued. Correspondingly, the yield on lower-grade bonds, written under foreign parameters, is less than the yield on bonds written under local parameters. Investors are willing to pay a premium for lower-grade bonds if they are written in foreign parameters. Finally, we find a positive relation between maturity and S&P ratings for the subsample of lower-grade bonds. However, we find no such relation for the subset of high-grade bonds.","PeriodicalId":42830,"journal":{"name":"Journal of Financial Regulation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-09-05","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135320243","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Abstract Modern data and information technologies are having a profound impact on financial services and opening new frontiers in regulation. This article explores the opportunities for using modern tools of data access and sharing to embed regulatory objectives within the management and decision-making processes of financial firms. This can enhance oversight of prudential and conduct risks as well as substantially lowering compliance costs. It can also help address the information imbalances that limit the effectiveness of older approaches in which the firm is a ‘black box’ that can only be externally supervised. The central challenge is establishing an appropriate governance of data in regulated firms to ensure the achievement of both regulatory and business objectives. Such an approach can be viewed as a further and more radical development of established ‘new governance’ techniques of financial regulation.
{"title":"Data Access Technologies and the ‘New Governance’ Techniques of Financial Regulation","authors":"David McNulty, Andrea Miglionico, Alistair Milne","doi":"10.1093/jfr/fjad008","DOIUrl":"https://doi.org/10.1093/jfr/fjad008","url":null,"abstract":"Abstract Modern data and information technologies are having a profound impact on financial services and opening new frontiers in regulation. This article explores the opportunities for using modern tools of data access and sharing to embed regulatory objectives within the management and decision-making processes of financial firms. This can enhance oversight of prudential and conduct risks as well as substantially lowering compliance costs. It can also help address the information imbalances that limit the effectiveness of older approaches in which the firm is a ‘black box’ that can only be externally supervised. The central challenge is establishing an appropriate governance of data in regulated firms to ensure the achievement of both regulatory and business objectives. Such an approach can be viewed as a further and more radical development of established ‘new governance’ techniques of financial regulation.","PeriodicalId":42830,"journal":{"name":"Journal of Financial Regulation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-09-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"136354411","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Like similar bodies in several other countries, the Systemic Risk Council in Denmark was established in response to the global financial crisis. This article first outlines the Council’s design and performance, and then discusses the need for changes to the Council’s remit, governance, powers, and communication with the public. While the design of systemic risk councils varies a lot across countries, and without a consensus on what constitutes an optimal design of a macroprudential policy framework, the Danish experience contributes to the literature on what works, and what does not, in relation to managing systemic risks.
{"title":"The Systemic Risk Council in Denmark: Assessing Strengths and Weaknesses","authors":"S. Jensen, Thomas Sangill","doi":"10.1093/jfr/fjad006","DOIUrl":"https://doi.org/10.1093/jfr/fjad006","url":null,"abstract":"\u0000 Like similar bodies in several other countries, the Systemic Risk Council in Denmark was established in response to the global financial crisis. This article first outlines the Council’s design and performance, and then discusses the need for changes to the Council’s remit, governance, powers, and communication with the public. While the design of systemic risk councils varies a lot across countries, and without a consensus on what constitutes an optimal design of a macroprudential policy framework, the Danish experience contributes to the literature on what works, and what does not, in relation to managing systemic risks.","PeriodicalId":42830,"journal":{"name":"Journal of Financial Regulation","volume":null,"pages":null},"PeriodicalIF":2.6,"publicationDate":"2023-06-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"46154228","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article explores the use of artificial intelligence software to create financial recommendations. It seeks to define the impacts and outline the benefits of using ChatGPT software in the highly regulated Australian financial sector. ChatGPT was asked to create a financial recommendation, which was evaluated against the relevant regulations and the recommendations of existing professionals and market contributors. The data generated was analysed using Qualtrics analysis techniques. The findings suggest that ChatGPT significantly reduces the time required to carry out creation, input, and editing services for simple financial advice recommendations. However, ChatGPT fails to operate effectively with complex financial advice and requires professional guidance to ensure regulatory adherence. In future, it may be possible to develop ChatGPT as a complementary tool to decrease the time and cost required to create financial recommendations.
{"title":"Artificial Intelligence Authoring Financial Recommendations: Comparative Australian Evidence","authors":"Benjamin R. Neilson","doi":"10.1093/jfr/fjad004","DOIUrl":"https://doi.org/10.1093/jfr/fjad004","url":null,"abstract":"\u0000 This article explores the use of artificial intelligence software to create financial recommendations. It seeks to define the impacts and outline the benefits of using ChatGPT software in the highly regulated Australian financial sector. ChatGPT was asked to create a financial recommendation, which was evaluated against the relevant regulations and the recommendations of existing professionals and market contributors. The data generated was analysed using Qualtrics analysis techniques. The findings suggest that ChatGPT significantly reduces the time required to carry out creation, input, and editing services for simple financial advice recommendations. However, ChatGPT fails to operate effectively with complex financial advice and requires professional guidance to ensure regulatory adherence. In future, it may be possible to develop ChatGPT as a complementary tool to decrease the time and cost required to create financial recommendations.","PeriodicalId":42830,"journal":{"name":"Journal of Financial Regulation","volume":null,"pages":null},"PeriodicalIF":2.6,"publicationDate":"2023-05-15","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"46827646","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
{"title":"Correction to: Badges of Misconduct: Consumer Rules to Avoid Abusive Financial Advisers","authors":"","doi":"10.1093/jfr/fjad005","DOIUrl":"https://doi.org/10.1093/jfr/fjad005","url":null,"abstract":"","PeriodicalId":42830,"journal":{"name":"Journal of Financial Regulation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-04-04","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"136186234","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
ABSTRACT There is growing presumption that central banks have a significant role to play in addressing environmental challenges, especially climate change. This article explains, on the basis of both theoretical and empirical evidence, that attempting to use existing central bank tools and powers to tackle climate change will prove inadequate to tackle the issue(s) at hand. From a positivist perspective at least—and contrary to the claims made in the literature—the tools that central banks possess are insufficient to make any meaningful contribution to emissions reductions and prevent global heating. This is because many of the proposals made by academics, regulators, and legislators to expand the central bank toolkit to equip banks to tackle climate change suffer from deep conceptual and practical drawbacks when applied in this domain. These critical weaknesses mean that the policy prescriptions that flow from them will be of limited impact; this would likely be the case even if central banks were to obviate their mandates more explicitly and attempt to use such tools to address climate change directly. In so doing, they waste valuable political and economic capital that might be usefully deployed in tackling climate change. The obstacles to using these tools are not political or legal; they are inherent in their operation.
{"title":"Central Banks and Climate Change: Mission Impossible?","authors":"Jay Cullen","doi":"10.1093/jfr/fjad003","DOIUrl":"https://doi.org/10.1093/jfr/fjad003","url":null,"abstract":"ABSTRACT There is growing presumption that central banks have a significant role to play in addressing environmental challenges, especially climate change. This article explains, on the basis of both theoretical and empirical evidence, that attempting to use existing central bank tools and powers to tackle climate change will prove inadequate to tackle the issue(s) at hand. From a positivist perspective at least—and contrary to the claims made in the literature—the tools that central banks possess are insufficient to make any meaningful contribution to emissions reductions and prevent global heating. This is because many of the proposals made by academics, regulators, and legislators to expand the central bank toolkit to equip banks to tackle climate change suffer from deep conceptual and practical drawbacks when applied in this domain. These critical weaknesses mean that the policy prescriptions that flow from them will be of limited impact; this would likely be the case even if central banks were to obviate their mandates more explicitly and attempt to use such tools to address climate change directly. In so doing, they waste valuable political and economic capital that might be usefully deployed in tackling climate change. The obstacles to using these tools are not political or legal; they are inherent in their operation.","PeriodicalId":42830,"journal":{"name":"Journal of Financial Regulation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-03-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135628901","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Stefan Gissler, Borghan Narajabad, Daniel K Tarullo
Abstract The Federal Home Loan Banks (FHLBs) are the less well-known siblings of Fannie Mae and Freddie Mac. Since these government-sponsored enterprises were created in 1932, changes in housing finance markets have rendered largely irrelevant their original purpose of increasing the availability of mortgages. Yet the level and scope of their activities have increased dramatically in recent decades. These activities have at times both exacerbated risks to financial stability and obstructed the missions of federal financial regulators. Behind these undesirable outcomes lies the public/private hybrid nature of the FHLBs. The private ownership and control of the FHLBs provide an incentive to take advantage of the considerable public privileges from which they benefit—including an explicit line of credit from the United States Government and an implied guarantee of all their debt similar to that enjoyed by Fannie Mae and Freddie Mac before the Global Financial Crisis. This article examines past incidence and future potential for the FHLBs to amplify financial stability risks. It offers a framework for regulatory reform by the Federal Housing Finance Agency to contain these risks and avoid harmful interference with the activities of other federal regulators.
{"title":"Federal Home Loan Banks and Financial Stability","authors":"Stefan Gissler, Borghan Narajabad, Daniel K Tarullo","doi":"10.1093/jfr/fjad002","DOIUrl":"https://doi.org/10.1093/jfr/fjad002","url":null,"abstract":"Abstract The Federal Home Loan Banks (FHLBs) are the less well-known siblings of Fannie Mae and Freddie Mac. Since these government-sponsored enterprises were created in 1932, changes in housing finance markets have rendered largely irrelevant their original purpose of increasing the availability of mortgages. Yet the level and scope of their activities have increased dramatically in recent decades. These activities have at times both exacerbated risks to financial stability and obstructed the missions of federal financial regulators. Behind these undesirable outcomes lies the public/private hybrid nature of the FHLBs. The private ownership and control of the FHLBs provide an incentive to take advantage of the considerable public privileges from which they benefit—including an explicit line of credit from the United States Government and an implied guarantee of all their debt similar to that enjoyed by Fannie Mae and Freddie Mac before the Global Financial Crisis. This article examines past incidence and future potential for the FHLBs to amplify financial stability risks. It offers a framework for regulatory reform by the Federal Housing Finance Agency to contain these risks and avoid harmful interference with the activities of other federal regulators.","PeriodicalId":42830,"journal":{"name":"Journal of Financial Regulation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-03-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"134964737","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Abstract Using post-Brexit regulatory freedom to strengthen the financial sector has been seen as a priority for the UK government under the Conservative Party following the 2017 general election. The laying before Parliament of the Financial Services and Markets Bill (July 2022) marked the start of a multi-year process aiming to transform the regulatory framework. Adding a competitiveness and growth secondary objective to regulatory mandates was an important part of the reform agenda set out in the Bill. This article draws on theory (regulatory competition, regulatory procyclicality, and regulatory design) and recent history (post 2008-crisis regulatory reform) to question the wisdom of reinstating international competitiveness in regulatory mandates in this way. The key concern is that this change risks opening the door to an excessively deregulatory agenda and the undermining of regulatory independence. That the new competitiveness and growth objective will be used to advance deregulatory agenda was already becoming evident during 2022 as the UK debated the adaptation and evolution of EU-derived prudential and capital market laws to suit its new situation. Since the competitiveness and growth objective bandwagon may have become unstoppable, the article directs attention to the role of accountability in protecting regulatory independence. Regulators need to be able to resist pressure to lower standards unduly, and an effective system of accountability can support them in doing so.
{"title":"International Competitiveness and Financial Regulators’ Mandates: Coming Around Again in the UK","authors":"Eilís Ferran","doi":"10.1093/jfr/fjad001","DOIUrl":"https://doi.org/10.1093/jfr/fjad001","url":null,"abstract":"Abstract Using post-Brexit regulatory freedom to strengthen the financial sector has been seen as a priority for the UK government under the Conservative Party following the 2017 general election. The laying before Parliament of the Financial Services and Markets Bill (July 2022) marked the start of a multi-year process aiming to transform the regulatory framework. Adding a competitiveness and growth secondary objective to regulatory mandates was an important part of the reform agenda set out in the Bill. This article draws on theory (regulatory competition, regulatory procyclicality, and regulatory design) and recent history (post 2008-crisis regulatory reform) to question the wisdom of reinstating international competitiveness in regulatory mandates in this way. The key concern is that this change risks opening the door to an excessively deregulatory agenda and the undermining of regulatory independence. That the new competitiveness and growth objective will be used to advance deregulatory agenda was already becoming evident during 2022 as the UK debated the adaptation and evolution of EU-derived prudential and capital market laws to suit its new situation. Since the competitiveness and growth objective bandwagon may have become unstoppable, the article directs attention to the role of accountability in protecting regulatory independence. Regulators need to be able to resist pressure to lower standards unduly, and an effective system of accountability can support them in doing so.","PeriodicalId":42830,"journal":{"name":"Journal of Financial Regulation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-03-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"136275123","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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