CHAPTER THREE
ISSUES
A mixed response
3.1 The introduction of the RSA legislation has provoked a mixed response
among those organisations who contributed to the inquiry. Potential RSA
providers have a number of concerns about aspects of the legislation.
However, a number of submitters to the Committee did welcome the concept
of a simple, flexible and portable superannuation account. For example,
the Credit Union Services Corporation (Australia) Ltd (CUSCAL) welcomed
the initiative, advising the Committee that:
They will provide a capital guaranteed product that is simple
to operate, convenient to access, highly portable and with low or no
fees. They will be a safe and secure savings mechanism for people who
are unsure or uncomfortable about other more complex savings arrangements.
[1]
3.2 It should be noted that CUSCAL has long sought a "on balance
sheet" superannuation product and made several submissions to this
Committee to that effect during 1994/95.
3.3 The Association of Permanent Building Societies (APBS) cast a significant
level of doubt on whether its members would be willing to offer RSA accounts.
While supporting the concept of a simple, deposit based retirement account,
the APBS expressed concern at the Government's approach as requiring RSAs
to have too many characteristics of superannuation products. The Association
advised the Committee that the viability of small accounts in ordinary
savings accounts is already causing problems for deposit taking institutions
and expressed disappointment that "more complex and special attention
will be required for small RSA accounts".
3.4 It should be noted that the Australian Bankers' Association (ABA)
assessed RSAs cautiously, expressing the view that its members had a range
of concerns about the nature of the product. The Chief Executive of the
ABA, Mr Mark Addis, told the Committee that the ABA was "anxiously
awaiting the regulations that will accompany the legislation." He
expressed the view that it was difficult to assess what sort of product
could be developed until these regulations became available. [2]
3.5 The Association of Superannuation Funds of Australia (ASFA), questioned
the need for RSAs, arguing that the existing superannuation system already
met the needs of most individuals.
3.6 The Australian Council of Trade Unions (ACTU) expressed a number
of fundamental concerns regarding RSAs, although noting that this did
not mean that the ACTU opposed the RSA concept. In arguing the case before
the Committee, Ms Elana Rubin, Senior Industrial Officer for the ACTU
noted that prior to the introduction of the trustee system in superannuation,
financial institutions operated for the benefit of their shareholders
rather than policy holders. She highlighted the competing interests of
shareholders as compared to members, emphasising that the trustee system
has played, and continues to play, a significant role in reforming that
system. The ACTU's concerns centred around the issue of "choice"
in the superannuation system and potential implications of allowing employers
to open RSAs for their employees without their consent.
3.7 The Council of Small Business Organisations of Australia, represented
by Mr Rob Bastian, supported the concept of passbook superannuation. To
the extent that RSAs meet this simple, flexible and fully portable requirement,
COSBOA was broadly supportive of the introduction of RSAs. He did advise
the Committee that he favoured bank operated superannuation vehicles over
superannuation funds, because of what he considered to be a relative inaccessibility
of superannuation monies to the small business capital market:
We do believe very strongly that the lenders are far more capable
of managing large amounts of money back to the marketplace than are
the much more conservatively managed superannuation funds. So, our preference
would be to accentuate the money in the banks as best we can. [3]
3.8 It should be noted that this conclusion was premised on the assumption
that the increased loan book available to banks as a result of RSAs would
provide small businesses with increased opportunities to access cheap
funds. The extent to which this will occur cannot be determined and the
Opposition members of the Committee note with some concern the degree
to which COSBOA based their support for passbook superannuation on this
access issue.
3.9 Mr Bastian also indicated that he supported a general simplification
of superannuation:
...superannuation is found by the smaller employers to be fairly
confusing...anything we can do to stabilise it and make it simpler would
obviously be welcomed by the sector.
3.10 Mr Bastian also annunciated a significant degree of concern regarding
the possible disclosure that may become applicable to employers who open
accounts on behalf of employees. Mr Bastian suggested that his membership
would be less than supportive, if they were required to disclose all relevant
documentation regarding RSAs to employees. He said:
My instinct is that if in such a circumstance you can institute
the matter of choice on the employee's part and remove the matter of
compulsion by the state on the employer, then my sector would respond
joyfully." He went on to say, " But if the state then comes
to the employer and says this is what you've got to do and there heaps
of it, and if you don't get it right, we'll penalise you... then we
would oppose that. [4]
3.11 He was very supportive of establishing a nexus between the RSA provider
and the superannuant, as opposed to between the employer and the RSA provider.
As he stated, the first premise that must be foremost is the fact that
superannuation is in fact employees retirement incomes.
Issues canvassed in this report
3.12 Submissions and evidence received by the Committee during the inquiry
identified a number of broad issues associated with RSAs. These included:
- Who can offer a RSA?;
- Choice;
- Nature of the Capital Guarantee;
- Incentives to employers;
- Regulatory regime; and
- Disclosure standards.
3.13 These issues are examined in the following paragraphs of this chapter
of the report.
3.14 The Committee also took evidence about a range of more technical
issues associated with the operation of RSAs. Chapter 4 deals with these
issues.
Who can offer RSAs?
3.15 Under the provisions of the Retirement Savings Accounts Bill 1996,
banks, building societies, credit unions, life insurance companies, friendly
societies (see para 1.6) and prescribed financial institutions can market
RSAs. Several witnesses and submitters argued that existing superannuation
trustees should also be able to offer RSAs, including the right to use
the term "RSA" as a product description.
3.16 The Investment Funds of Australia (IFA), for example, argued essentially,
there was no difference between an RSA and a cash based superannuation
fund. Accordingly, the IFA submitted that superannuation fund trustees
should "have access to the simpler and cheaper structure that is
being proposed for RSAs." The IFA contended that this was "an
important issue of competitive neutrality". [5]
3.17 Similarly, the Association of Superannuation Funds of Australia
(ASFA) submitted that all providers of RSAs and RSA equivalent products,
including those operating within trust structures should be able to use
the single identifying term 'RSA'. ASFA argued that to do otherwise would
confuse consumers and provide RSA institutions with an unfair competitive
advantage.
3.18 The Committee sought clarification of this issue from the Insurance
and Superannuation Commission (ISC). Dr Darryl Roberts, First Assistant
Commissioner, Policy, Legal and Actuarial Division, ISC, advised the Committee
that this issue "is likely to be in the regulations" and that
the term "RSA" could be used by "lookalikes" that
met the requirements:
The Government has indicated that there should be an opportunity
for traditional public offer funds that provide broadly equivalent products
to qualify for the lighter disclosure...
Our current understanding is that the term [RSA] could be used
by RSAs that are covered by the legislation and by lookalikes that met
the requirements. We would expect other products not to use that term.
[6]
3.19 Opposition members of the Committee note that the Coalition parties
explicitly stated in their March 1996 Election Campaign statement that
superannuation funds would be allowed to offer individual superannuation,
RSAs. Opposition members also note that the leaked Cabinet Submission
regarding RSAs notes in its opening paragraph, " The Government announced
its commitment to allow banks, building societies, credit unions, life
insurance companies (life office), complying superannuation funds and
other financial intermediaries to offer Retirement Savings Accounts (RSAs).."(emphasis
added). [7]
3.20 Opposition members of the Committee therefore believe that in the
interests of providing real choice, a level playing field and competitive
neutrality, it is imperative that Government move to amend the legislation
in order to allow complying superannuation funds to offer RSAs.
Choice
3.21 Clause 51 of the RSA Bill permits an employer to open an RSA without
the consent of an employee.
3.22 This issue was one of the most canvassed issues during the course
of the Committee's examination of the RSA bills. The ability of an employer
to open an RSA account on behalf of an employee raises a number of issues
regarding the efficacy of the provision of choice to consumers.
3.23 In addition to this, the ability of an employer to open an account
on behalf of an employee raises privacy concerns. For example, at present
the RSA bill does not require any physical proof of the existence of the
proposed RSA holder nor any proof of the relationship between the proposed
RSA holder and the employer.
3.24 ASFA suggested that there may be instances where a partner may request
his or her employer to open an RSA on behalf of their partners, in order
to access the announced 18 per cent superannuation tax rebate. [8]
3.25 ASFA indicated a number of concerns regarding the provision of consent
on behalf of the spouse whose name may used to open the RSA. [9]
Given the current absence of a 100 point identity test, which is standard
procedure when opening a deposit account, there is nothing to prohibit
this kind of behaviour.
3.26 Representatives of the ISC explained that under section 51, the
employer may fill out an RSA application form with the employees' details
and lodge that form with an RSA provider. The RSA provider will then open
the account and send the relevant disclosure documentation to the employee.
On receipt of this documentation, a "cooling off" period applies
and the employee has 14 days in which to decide whether to retain funds
in the RSA or transfer them to another fund. [10]
3.27 Several contributors to the inquiry expressed concern about this
provision. They argued that over the longer term, savings held in RSAs
would earn interest at a lower rate than is likely to be achieved in a
conventional superannuation fund. Accordingly, the question of employee
choice about whether the employer contributed to an RSA or a superannuation
fund is important, as an employee whose superannuation savings are in
a RSA might be financially disadvantaged in the longer term.
3.28 The majority of submissions received by the Committee questioned
adequacy of the "14 day cooling off period", arguing that employees
were often in a weak position in respect to the balance of power in negotiations
with employees:
...the industrial reality is that if an employer opens up an
RSA, each individual employee will have the onus of putting up their
hand and saying "I don't like the choice you made for me"
and in the workplace that will not happen, no matter how much the employee
wants to change that arrangement... [11]
3.29 The Australian Institute of Superannuation Trustees (AIST) raised
similar concerns. AIST contended that it was essential that employee choice
was built into the legislation. Dr Diana Olsberg told the Committee that:
It is very difficult, particularly for low income workers who
have very marginal power compared to the employer to actually defy the
choice the employer has made... [12]
3.30 The AIST argued that the issue of choice was compounded by other
factors, such as any commercial arrangement that may exist between an
employer and an RSA provider. This relationship might influence the nature
of the choice that the employer might make for the employee. This point
was supported by the ACTU, the Community and Public Sector Union, the
Transport Workers Union, the Australian Consumers Association and a number
of others.
3.31 Dr Darryl Roberts of the ISC advised the Committee that the Section
51 provision directly mirrors section 153 of the SIS Act, under which
an employer can apply to make contributions to a public offer superannuation
fund without the consent of an employee. He stated that under both SIS
and the RSA Bills, employers can fill out a single application form for
multiple employees.
3.32 Dr Roberts pointed out that the RSA legislation does not make any
change in relation to the freedom of employers to choose a fund for Superannuation
Guarantee contributions. Neither does the legislation disrupt any existing
industrial framework. Dr Roberts confirmed that following amendments to
the Superannuation Guarantee Act, employers could make SG contributions
to RSAs as well as regulated superannuation funds. However, this does
not mean that employers have an automatic right to shift their SG payments
to RSAs:
...consistent with existing industrial relations agreements,
if employers are subject to an industrial agreement or award which does
not include a reference to RSAs then the employer will presumably not
be able to use RSAs to fulfil their SG obligations. [13]
3.33 The ISC argued that the legislation incorporates two important protections
for employees whose employers open RSAs on their behalf:
- a `free look period', under which employees can elect to transfer
the balance of the account to another RSA or fund within 14 days of
receiving the disclosure documentation from the RSA provider; and
- the employee can request that the RSA account balance be transferred
at any time to another fund.
3.34 Opposition members of the Committee however are inclined to question
the soundness of the ISC arguments. Whilst section 153 of the SIS Act
does provide for a sponsor employer entity to lodge an application form
on behalf of an employee, it does not provide for an employer to unilaterally
transfer superannuation monies from one fund to another without some indication
of employee consent. The Opposition members' understanding of section
51 of the RSA Bill is that an employer is granted such a right.
3.35 Opposition members also note that section 153 of the SIS Act does
not allow an employer to open a number of superannuation accounts for
a number of employees with only one form. Opposition members' understanding
of section 51 of the RSA Bill is that an employer need only provide to
an RSA provider one application form, even if the employer is opening
a number of employee accounts.
3.36 The Opposition members of the Committee also note that an employer
under section 153 of the SIS Act must comply with industrial awards. Employers,
must therefore comply with rulings of the Industrial Relations Commission.
The Industrial Relations Commission has made a number of rulings regarding
the ability of an employer to choose and open an RSA on behalf of an employee.
3.37 Opposition members of the Committee note the comments of Ms Elana
Rubin, Senior Industrial Officer, ACTU regarding this issue,
" Choice of funds should not rest with the employer - such
a practice denies employees ownership of their superannuation benefits
and is contrary to the Government's stated objective of promoting greater
consumer choice...Employers have no direct interest in ensuring employees'
superannuation contributions are paid into low cost and efficient superannuation
saving vehicles which meet both the retirement needs and employment
patterns of their workforce. Employers have no direct interest in ensuring
that superannuation contributions are placed in a superannuation vehicle
which has an investment programme which meets the risk profile and aspirations
of their employees." [14]
3.38 The Opposition members of the Committee consider that due to the
employees' undeniable ownership of the superannuation contribution, it
is unacceptable that the employer has the ability and legal right under
the RSA bill to direct employees superannuation contributions to their
own choice fund. Opposition members believe if the RSA product is to be
remotely consistent with the policy intentions of the Coalition Government,
the legislation must be amended to ensure that the choice associated with
taking out an RSA is that of the employee's, not the employer's.
3.39 The ISC acknowledged that RSA institutions can require up to 12
months notice for liquidity and administrative reasons, or because of
the terms of the contract. For this reason, it may take up to twelve months
for the balance to be moved to the employees' nominated fund. However,
the ISC maintained that:
These consumer protection measures provide portability and ensure
that employees remain in full control of the RSA once it is opened...
...the RSA regime retains the degree of choice available in the
existing superannuation system, and adds a new product to the market,
and provides for better portability. [15]
3.40 The Opposition members of the Committee consider that for the RSA
to be a fully portable account, RSA providers must be required to roll
over accounts to other funds in a much shorter period of time than the
currently provided for period of twelve months. Opposition members of
the Committee recommend that the RSA bill be amended to require RSA providers
to roll over such monies in 30 days from the time of an employee notifying
the provider of his or her choice.
Nature of the Capital Guarantee
3.41 A number of potential RSA providers questioned the inclusion of
the capital guarantee provisions for RSAs, arguing that deposits in banks,
credit unions and building societies are already capital guaranteed. Mr
Raj Venga, Director, Policy and Compliance, APBS, summarised the view:
...the concept of negative returns simply does not apply to deposits.
There cannot be a negative return, because you are contracting to repay
the amount with or without interest that has been deposited. So it applies
to life insurance company models but certainly not to banks building
societies and credit unions. [16]
3.42 The Committee further explored the meaning of the capital guarantee
that is expected to be an essential feature of this product. Under questioning,
representatives of the ABA acknowledged that while the capital is guaranteed
against negative earnings, situations may arise where a deposit in an
RSA might be eroded by bank fees. Mr Addis told the Committee:
What we are saying is the capital is guaranteed against negative
earnings but admits the possibility that there may be some erosion of
the capital in the unlikely event I would expect, that fees and charges
are greater than positive earnings. [17]
3.43 Opposition members of the Committee note that S38(2)(i) of the RSA
Bill gives reserve powers to the ISC, permitting standards to be prescribed
in relation to "fees that may be charged for the provision of RSAs".
3.44 Opposition members also note that CUSCAL indicated that they did
not believe it would be commercially worthwhile for their institutions
to charge fees. Ms Barbara Livesey, Senior Policy Adviser CUSCAL indicated
that CUSCAL did not expect any of its credit unions to charge fees. She
also indicated that if the Committee were so inclined as to attempt to
recommend the regulation of fees and charges, CUSCAL would be supportive
of a Committee recommendation prohibiting fees and charges rather than
regulating them.
3.45 Ms Livesey also noted the need for consumers to be able to easily
compare fees, charges and interest rates across a wide range of RSA products.
[18]
3.46 Opposition members of the Committee consider that the ISC should
survey the fees and charges applied to RSA accounts to ensure the capital
guaranteed nature of RSAs is not undermined by unreasonable fees and if
necessary, consider the use of its S38 reserve powers. Opposition members
also consider that all fees and charges should be disclosed up front to
the prospective RSA holder. Additionally, Opposition members consider
such monitoring is essential to ensure that the Governments' objectives
for RSAs to be a simple, low cost product are met.
Incentives to employers
3.47 A number of contributors to the inquiry considered that the Government
should prohibit RSA providers from offering incentives or inducements
to employers to use a particular RSA product. For example, a bank might
offer a business a reduced rate of interest on borrowing's if the employer
opens RSA accounts for employees with that bank. Submitters argued that
there were a number of shortcomings associated with such a practice:
- Competition takes place between providers and third parties;
- Competition is not necessarily based on the merits of the product;
- The interests of the RSA holder may be secondary.
3.48 Representatives of the Australian Banking Association took a different
view. Mr Addis of the ABA told the Committee that as long as they are
not improper, incentives are part of normal business relationships:
I cannot see that it is a conflict of interest. I really wouldn't
want to speculate on the nature of the incentives, or the quantification
of those incentives, but the notion of incentives is part of any business
relationship, part of the negotiation of any relationship. It is part
and parcel of normal business. As long as it is not improper, as long
as people are comfortable with those arrangements, then so be it. [19]
3.49 The Australian Consumers' Association (ACA) drew the Committee's
attention to Section 47(IV) of the Trade Practices Act which prohibits
'Third Line Forcing' and other exclusive dealing in general terms. However,
the ACA and others considered that there is a clear need to clarify the
types of practices that should be prohibited as unreasonable and specify
appropriate penalties. [20]
3.50 Opposition members of the Committee consider that this issue has
the potential to be very damaging. Opposition members recommend that such
a prohibition should be placed in the legislation so as to avoid any such
behaviour.
3.51 The Opposition members take this view especially given the presence
of a due diligence defence within the legislation. The Opposition members
note that the Wallis inquiry is currently studying Part V of the Trade
Practices Act and there is increasing speculation about the possibility
of it being removed in so far as it impacts on the financial services
industry.
3.52 In this uncertain environment, the Opposition members consider it
important that consumers, -RSA holders, are provided with every available
opportunity to protect themselves.
3.53 In keeping with this sentiment, the Opposition members also note
with interest the ACTU's point regarding the level of disclosure that
should occur where the RSA provider and the employer have a business or
commercial relationship.
3.54 The ACTU, AIST and the ACA all noted that in circumstances where
the employer and the RSA provider have a business relationship, the nature
of this business relationship should be disclosed to the employee.
3.55 All three organisations emphatically noted this point should the
situation remain that employers are able to open an account on behalf
of an employee.
Regulatory regime
3.56 A variety of financial and other organisations expressed reservations
about the regulatory regime that will apply to RSA providers.
3.57 The Australian Association of Permanent Building Societies (AAPBS)
expressed disappointment about the regulatory environment that is to apply
to RSA providers. AAPBS considered that the structure imposed under the
RSA legislation was excessively and unnecessarily complex, giving rise
to higher administrative costs and making the product a marginal economic
proposition. Mr James Larkey, the executive director of the APBS, summed
up the society's position:
At this stage we are anything but bullish about the future of
RSAs. We think an opportunity for a low-cost, simple bank deposit product
that would qualify for superannuation savings privileges is probably
being lost. [21]
3.58 ASFA also expressed concern that there will be no clear separation
of responsibilities, for example in complaints resolution, suggesting
that in the longer term, it would be simpler to move towards a singe complaints
regulator.
3.59 Dr Darryl Roberts of the ISC addressed concerns about the dual regulatory
regime at the Committee's first public hearing. Dr Roberts acknowledged
that the ISC is conscious of potential problems that might arise as a
result of adopting a dual regulator approach. He explained the ISC's proposed
approach in the following terms:
Therefore, to avoid the danger of encroaching on the
domain of an RSA provider's traditional prudential supervisor with adverse
consequences, we intend to closely coordinate and cooperate with that
supervisor and to generally take a non-intrusive approach to the regulation
of compliance with the retirement income standards. Essentially, this
means a system of self-assessment whereby the RSA providers themselves
will need to certify in writing that they clearly understand the RSA
requirements, that they have adequate systems in place to meet those
requirements and that they have, in fact, been fully complying with
those requirements. By adopting this self-assessment approach, we hope
to minimise the regulatory overlap and compliance burden which might
otherwise result from not having the prudential supervision and the
functional regulation of a superannuation provider housed in the same
agency under the one roof. [22]
3.60 Dr Roberts emphasised that should this system of self assessment
break down, the ISC would intervene promptly:
For example, we will immediately and intensively investigate
any suspected breaches of the preservation, disclosure or other superannuation
standards brought to our attention by way of market intelligence or
customer complaints. If remedial action by the RSA product provider
is required, we will ensure that it occurs. [23]
Disclosure
3.61 The RSA Bill does not specify disclosure standards. Rather, it enables
the Government to make regulations that will set standards in this area.
These regulations were not referred to the Committee and indeed had not
been made available during the Committee's examination of the legislation.
However, the Opposition members of the Committee consider that it is appropriate
to advise the Senate of the nature of concerns about disclosure requirements
that emerged during the inquiry.
3.62 A common theme was that consumers should be provided with adequate
information to make informed choices, including fees and expected returns.
However, excessively detailed material was considered counterproductive
as experience has demonstrated that excessively large amounts of material
is likely to be ignored. Additionally, excessive disclosure requirements
will impose excessive costs on RSA providers.
3.63 For example, the IFA representative, Mr Richard Gilbert advised
the Committee that the prospectus documents required for ordinary, cash
based funds can be as long as 50 pages. He said that the key features
statement should not exceed six pages. [24]
3.64 Other general points raised include that:
- Opinion is mixed about whether the proposed "health warning"
at a balance of $10 000 is adequate. Some support this level, others
argue that there should be also a "health warning" in the
initial disclosure documents;
- Several organisations offered opinions about what should be included
in disclosure documents. Common elements included information about
fees, commissions and charges; the nature of the capital guarantee;
historical and future returns; dispute resolution information; preservation
and access; information about the $10 000 "health warning".
- Commonly, potential RSA providers sought that disclosure rules be
kept "simple and minimal".
3.65 The Opposition members of the Committee consider it appropriate
to offer a number of guiding principles in relation to the area of disclosure.
The Committee is agreement with the Australian Consumers' Association,
Jacques Martin, the ACTU, AIST, ASFA and CUSCAL. In order to ensure free
and effective choice it is imperative that prospective RSA holder receive
all relevant information regarding fees and charges, the rate of return,
the level of risk associated with the product in addition to a health
warning at the time that the RSA holder is contemplating establishing
a RSA.
3.66 The Opposition members also consider it important to ensure that
the RSA holder receives all such information on a regular basis. The Opposition
members are attracted to the cigarette style health warning regarding
the $10,000 proposed limit. The Opposition members also consider it to
be highly desirable if such health warnings could be distributed regularly,
preferably annually to the RSA holder.
3.67 Should employers remain legally capable of opening an RSA on behalf
of an employee, the Committee considers it appropriate that the responsibility
to disclose fees, charges, rates of return and risk profiles as well as
the health warning should also fall to the employer. That is the Committee
considers the burden to be too onerous on RSA providers if they are required
to provide information in the first instance to the employer and then
upon having an account opened for them the RSA provider has to inform
the RSA holder.
3.68 The Committee is of the opinion that the best relationship would
be between the RSA holder and provider. However if the relationship is
to be brokered at the outset, the intermediary, the employer must be liable
for some of the responsibility associated with disclosure.
[Return to Table of Contents]
Footnotes
[1] CUSCAL Submission, p. 1.
[2] Evidence, 21 Feb 1997.
[3] Evidence, 21 Feb 1997.
[4] Evidence, Mr Bastian 21 February.
[5] Submission, p. 2.
[6] Evidence, 25 Feb 1997.
[7] 1996 Cabinet Submission regarding RSAs,
which was leaked to the Opposition and made publicly available via the
internet.
[8] On August 20 1996, the Treasurer announced
that an 18 per cent tax rebate of up to $3000 would be available to spouse
who contributed to the superannuation accounts of a low income or non
working spouse. Treasurer's Budget Press Release titled "Superannuation
Reform".
[9] Evidence, Mr Foxton 21 February.
[10] Evidence, 25 Feb 1997, Dr Roberts,
opening statement.
[11] Evidence, 21 Feb 1997.
[12] Evidence, Ms Elana Rubin, Senior
Industrial Officer of the ACTU, 21 February
[13] Evidence, 25 Feb 1997, Dr Roberts,
opening statement.
[14] ACTU submission p 5 - 6.
[15] Evidence, 25 Feb 1997, Dr Roberts,
opening statement.
[16] Evidence, p. 22.
[17] Evidence, 21 Feb 1997.
[18] Evidence, 25 February.
[19] Evidence, 21 Feb 1997.
[20] Submission, Australian Consumers'
Association, p. 3.
[21] Evidence, p. 17.
[22] Evidence, p. 26.
[23] Evidence, p. 26.
[24] Evidence, p. 5.
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