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The regulation of derivatives
Be wary when you hear talk of "derivatives" without further qualification. They fall into three quite distinct categories: exchange-traded, over the counter (OTC), and swaps. Here is the best overall paper I know on that division. Wikipedia is useful as well.
I'll cover swaps in a separate post soon, so for now let's set those aside.
Exchange-traded derivatives include the instruments traded at the Chicago Mercantile Exchange and The New York Stock Exchange. Their regulation has overall gone well and no one serious has alleged that they are responsible for our current financial problems. That said, a single regulator is preferable to our current dual SEC-CFTC structure.
Most but not all OTC derivatives are interest rate derivatives. Equity derivatives fit this category as well and so do credit default swaps (even though they are called "swaps" they do not here fit into the swaps category).
These instruments are OTC because no clearinghouse in the middle guarantees the deal. That means more credit risk and that no single middleman is tracking net positions on a more or less real time basis. Ideally we would like to make OTC derivatives more like exchange-traded derivatives and we should consider regulation toward that end. (Do note that private swaps regulators have already done quite a bit to clear up the issue of hanging and unconfirmed transactions.) At the margin the social benefits of such homogenization are higher than what the private swaps regulators will bring on their own accord. In essence homogenization and trading through a clearinghouse limits the leverage issue to a single, easily-regulated institution and therefore it limits the problem of counterparty risk.
The cost of such additional regulation will be higher transactions costs for the trades themselves and also greater contract homogeneity, which is a requirement for exchange trading, netting, and clearing. We need to make this move wisely and carefully, otherwise OTC derivatives could move to even wilder and less well regulated markets. Simply trying to shut down the OTC markets, even if that were the economically ideal vision (unlikely), would in terms of risk prove counterproductive. But the strong market positions of New York and London do make some effective regulatory action possible for OTC derivatives, especially if done in concert.
The lack of sufficient offset and netting and the inefficient spread of counterparty risk across a large number of institutions is an important issue behind current crises and it does not receive enough attention in most blogosphere discussions.
How about Europe? The 2006 Markets in Financial Instruments Directive extends traditional European financial regulation to OTC derivatives. Here is one source: "MiFID expands the definitions of financial instruments to include other frequently-traded instruments, including contracts for difference (CFDs) and other types of derivatives such as credit, commodity, weather and freight derivatives." Here is one overview of MiFID.
Implementation and enforcement is on a country-by-country basis and of course the UK is the big player. Read pp.27-29 in the very first link above and you'll see that overall the UK has a looser regulatory approach than does the United States, though not on every single matter. For instance the UK is stricter on regulating hedge funds in OTC derivatives markets.
The more important point is that no country uses regulation of the derivatives market as its major line of defense against financial crises. Rather countries regulate their financial institutions, their risk, their leverage, and their accounting directly, of course with more or less success. Regulating the derivatives market, as opposed to regulating the institutions, and their possible participation in those markets, simply isn't a very effective instrument.
To sum up: a) we should regulate OTC derivatives more, b) those regulations should aim toward establishing netting and well-capitalized clearinghouses, not micro-management of those markets, which would prove both impossible and counterproductive, and c) regulating OTC derivatives is only a weak substitute for regulating the institutions which trade in them.
The U.S. passed the Commodity Futures Modernization Act of 2000, which, among other things, limited the ability of the federal government to regulate OTC derivatives. I'll cover that Act in a separate post and yes I do think it should be amended. But I'll start by saying that most blogosphere critics of the act simply do not know or understand much of the above.
Posted by Tyler Cowen on September 22, 2008 at 06:14 AM in Economics | Permalink
Comments
Tyler, you do not seem to have even a minimal grasp of the logic at work here. Derivatives rest on a contradiction : they primarily exist because the underlying instruments are untradable, mostly because of regulatory or accounting reasons - yet, for them to be hedgeable, the underlying needs to be not only actively tradable but actively traded. The usual problem is thus not getting margin calls or adequate collateral from market participants, but finding patsies from outside the financial system that will bear the risk without hedging, and all the more so if the underlying is illiquid. Or, in other words, the nucleus is usually safe, whether derivatives are exchange-traded or OTC, but problems arise when external participants accumulate too much risk, like the AIGs of this world, or withdraw funding. So better derivatives primarily means better, more liquid, underlying instruments. Full stop.
Posted by: Henri Tournyol du Clos at Sep 22, 2008 7:45:25 AM
Henri, let me make it a little simpler: counterparty risk from OTC derivatives has been a *huge* issue of late. Clearinghouses cover that risk. It is true that such counterparty risk is not the "usual" problem but it can be a big problem when it really matters. Like right now. Citing the "paradox of derivatives," which is indeed interesting, doesn't change any of that.
Posted by: Tyler Cowen at Sep 22, 2008 7:56:15 AM
OK, let me make it a little more complicated then. Counterparty risk from OTC derivatives INSIDE the market has NOT been a huge issue - never has been, really. ISDA rules are quite straightforward. If a bank goes bust, deals are just canceled and the residual amount is transferred to the legal department. Everyone can live with that. The burden is transferred from the agent (trading floor) to the principal (the shareholders). Risk, in fact, globally goes down.
The problem all along, as it has always been, is a liquidity problem. Because risk cannot be hedged properly by market professionals, it needs to be taken over by a succession of outsiders. If outsiders are not willing to play anymore or go bust, then risk concentrates again inside the market, where it cannot be hedged and goes nuclear.
So derivatives are only as safe as their underlying is liquid and delta-hedgeable. OK?
Posted by: Henri Tournyol du Clos at Sep 22, 2008 8:20:20 AM
Let me rephrase that so as to make it crystal-clear : the real policy issue here is not derivatives and their eventual counterparty risk, but the low tradability and lack of standardization of much of the credit markets. Derivatives regulation is just a side issue.
Posted by: Henri Tournyol du Clos at Sep 22, 2008 8:48:09 AM
Henri, on your last, that is very similar to what I am saying: regulating the banks and other financial institutions is the main issue, not regulating the derivatives. That said, there is still I think an extra social benefit from clearinghouses and yes that comes at the cost of taxing heterogeneity. You're right to say that a major issue hasn't arisen *yet*, that is in part because there have been various (costly) interventions. I'm hardly the only one with a residual worry about derivatives markets and this is not some hypothesis which I simply concocted in my head.
Posted by: Tyler Cowen at Sep 22, 2008 8:55:23 AM
"The cost of such additional regulation will be higher transactions costs for the trades themselves and also greater contract homogeneity"
An inaccurate statement. Transaction costs will go down if the trades were regulated and therefore standarized, probably by a significant percentage. In every other market, once it was regulated, the costs were driven down dramatically. The associtated profits go down dramatically as well. These higher transaction costs and profits were the reason banks pushed and push so hard to avoid putting IRS on an exchange. Profit centers within the banks are the reason that some products are not traded on the exchagne and have been ignored by the regulators.
This is not a trivial point, and is one of the main reasons why more regulation would be good for most participants in the market and why proper regulation makes it cheaper to trade, not more expensive. This lack of regulation in the plain vanilla space makes the more complex derivatives even less transparent as they are twice removed from the regulators eye, not just once.
Posted by: mickslam at Sep 22, 2008 10:02:06 AM
What about those OTC products that cannot be standardised into an exchange-traded equivalent? If they could already, then they probably would have been - as the buyer would generally pay a premium for the price transparancy & liquidity that an exchange provides. Yet many market participants currently engage in both exchange-traded &/or OTC instruments.
I believe a simpler approach would be to reduce or remove any positive value attributable to OTC derivatives when banks report their Risk Weighted Assets - whilst also requiring full reporting of derivatives liablities *on* their balance sheet.
Posted by: nick at Sep 22, 2008 10:28:42 AM
Tyler,
1 - Sure, a clearing house is still a slight, marginal improvement, but certainly not a huge one as it used to be in the old days before computers : we now have on time risk monitoring and cash transfers. We can grab collateral in no time.
2 - THE problem with all credit instruments is that they are fundamentally non-fungible. So the only way to make them efficiently tradable is to work on their standardization and enhancing their intrinsic tradability. Using derivatives as a proxy does not work. Well, it does, but it is only a fair-weather solution. Once every few years all Hell breaks loose (1987, 1998, 2007/2008, etc) and the cost can then be enormous.
Posted by: Henri Tournyol du Clos at Sep 22, 2008 10:43:54 AM
i have an undergrad elec eng degree and an mba and have worked in wholesale
institutional trading for 14yrs, and while i can understand these posts, i
expect that the layman/politicians would be as likely to understand them as
they would a discussion of various aspects of clutch design for a transmission
in their car - this is part of the mainstreet/wallstreet divide - literacy
and numeracy - unsettling............
Posted by: franko at Sep 22, 2008 10:46:21 AM
i have an undergrad elec eng degree and an mba and have worked in wholesale institutional trading for 14yrs, and while i can understand these posts, i expect that the layman/politicians would be as likely to understand them as they would a discussion of various aspects of clutch design for a transmission in their car - this is part of the mainstreet/wallstreet divide - literacy and numeracy - unsettling..
This is why those who attempt to make this a partisan issue are idiots. Congress is filled with a bunch of innumerate poseurs who nonetheless need to make sure that this mess gets a LOT of scrutiny. But I am not hopeful....
Posted by: at Sep 22, 2008 11:02:36 AM
guys look we all thought free-markets were good, but everyone has to now admit we need the governemnt to get more involved in our lives. Look how bad this expiriment with free markets turned out. We need to finally give the Federal Reserve and some real authority. Exclusive rights to creating infinite money out of thin air is just not enough power.
Posted by: Paulson at Sep 22, 2008 11:09:21 AM
"Sure, a clearing house is still a slight, marginal improvement, but certainly not a huge one as it used to be in the old days before computers : we now have on time risk monitoring and cash transfers. We can grab collateral in no time."
This is not true. Clearinghouses are huge improvements for the reason that some people are able to monitor the size of positions held by individual members.
Most OTC and cash side people don't understand the role or the power of a clearinghouse. It is hugely useful to the market.
1. Credit only has to be investigated once, rather than for every new counterparty
2. Credit doesn't have to be constantly monitored - only the positions need to be monitored
3. The standardization required to have a clearinghouse results in dramatically lower costs for trading for most participants.
4. Clearinghouses must give a price to the risky products that can be widely agreed upon every day. There is no holding a position at one firm at X and another firm at Y.
There are many more good reasons. This is just a few off the top of my head. For most widely traded derivatives, clearinghouses are far, far superior to OTC clearing.
Posted by: mickslam at Sep 22, 2008 11:17:55 AM
"The more important point is that no country uses regulation of the derivatives market as its major line of defense against financial crises. "
This is part of the reason why we are spending at least $700B. Derivatives regulation should be a first line of defense. Leveraged products = high risk products. Anytime leverage is allowed, you can lose more than you can pay. In general, any product where you can lose more than you can pay should have some oversight.
Posted by: mickslam at Sep 22, 2008 11:21:12 AM
The issue of clearing of OTC derivatives is a thorny one, and one that I've written on. I should first note that there are some derivatives traded OTC that are cleared (mostly vanilla interest rate swaps), so "OTC" is not necessarily synonymous with "no clearing," although "exchange traded" is synonymous with "cleared." The relevant issue is which instruments are cleared, and which are not.
It should also be noted that there are different types of clearing arrangements that could be implemented. Prior to 1925, and the establishment of the Board of Trade Clearing Corporation, the Chicago Board of Trade had a Clearing Department, but this department did not mutualize default/performance risk in any way. It merely netted all positions; calculated net owes and pays; facilitated the flow of margin payments from losers to winners; and calculated who owed whom what in the event of a default.
Mutualization of default/performance risk requires the formation of a central counterparty--CCP. Most of the discussions of OTC clearing today envision the creation of a CCP, although the creation of a netting facility might be a reasonable intermediate step.
The key outstanding question implicit in Tyler's original post is: Why haven't OTC market participants created a CCP already? Tyler's answer is, effectively, that there are externalities, and that OTC dealers do not take into account the social benefits of more extensive sharing of performance risks.
There is something to this answer. There are extensive externalities across contracting parties. When a derivatives counterparty subsequently increases its market risk exposure, for instance, that raises the expected default losses of all its pre-existing trading partners. Increasing market risk exposure increases the likelihood of a big loss that would jeopardize the institution's ability to make good on its promises to those other counterparties.
There are other factors at work. One that I suggest in my clearing paper linked above is that centralized clearing levels the creditworthiness playing field, and thereby increases the competition that well-capitalized institutions (e.g., AIG before its failure'-) face in serving as OTC dealers. These big players may resist formation of a CCP that erodes their competitive advantage (a good credit rating).
The foregoing factors suggest that some regulation forcing the establishment of a CCP could improve welfare. There is another factor, however, that deserves further consideration, and which at the very least suggests that caution is warranted in the design of a CCP arrangement for more exotic products.
It is well known that information asymmetries impede risk sharing. Private information leads to moral hazard and adverse selection problems that make it inefficiently costly to share all risks.
My clearing paper argues that these problems are likely to be more acute, the more complex, exotic, and new the financial instrument; and the less liquid and transparent the market for it. Dealers in exotic instruments invest in special valuation expertise that allows them to value these instruments more accurately, and appraise their risks more exactly. Moreover, these dealers have private information on their counterparties and how the derivatives that they trade with them affect their counterparties' likelihood of default. Finally, and perhaps most importantly, these dealers have better information on how the instruments they trade and the positions they take affect their own likelihood of default.
Private information advantages are more likely to be pronounced with newer, more exotic, and less heavily traded instruments. This does not mean that even the most sophisticated dealer with the "best" model is immune to a blow-up. Far from it. But the one eyed man is king in the land of the blind. It is the disparity of information that impedes the sharing of performance risk. These disparities are more likely to be acute with more exotic instruments.
In a nutshell, the costs of risk sharing are substantially greater with more exotic instruments than their "vanilla" cousins. One would expect, therefore, that even absent externalities and strategic behavior that mutualization of default risk is more likely, the more widely traded and understood is the product. This is generally a good characterization of what we observe in practice.
There have been proposals to create a CCP for some credit derivatives. At present, the initiative of the Clearing Corporation Formerly Known as BOTCC is hanging fire. Even that initiative is likely to be limited in the near term to credit index products--the most vanilla, standardized, heavily traded, and transparent part of the CD space.
In brief, creation of a CCP must confront daunting obstacles. The more exotic the product, the more daunting the obstacles. Forcing creation of a CCP for more exotic products could create moral hazard and adverse selection problems that are as bad--or worse--than the disease that the CCP is intended to cure.
At root, then, the issue becomes one of regulating innovation and product diversity. If clearing becomes a requirement for trading an instrument (e.g., regulated entities such as banks can only trade centrally cleared instruments), innovation and product diversity will necessarily be sharply constrained. Thus, in essence, the debate over OTC clearing folds into the debate on whether there is excessive innovation in derivatives markets (where innovation can be "excessive" due to (a) the externality problems discussed above, and (b) the rent seeking and regulatory arbitrage nature of some derivatives innovations).
Re the blogosphere's overlooking of the subject, I would have to concur, though I have attempted to counter that trend in this post on my Streetwise Professor blog.
I can't say that I have the answers to these complex questions (e.g., what is the efficient level of innovation in derivatives?). I would merely argue that clearing should not be invoked as a deus ex machina that will dramatically improve efficiency. The adoption of clearing is endogenous, of course, and the failure of the industry to implement it for numerous products therefore raises serious questions. There are serious arguments to be made that this is a market failure reflecting externalities and strategic behavior. But there are also arguments to be made that (a) the costs of sharing performance risk on newer, innovative, and more exotic products are prohibitively high, and (b) the benefits of innovation that creates products that are not suitable for clearing are larger than the systemic risk costs that these products engender. At the very least, I hope that by pointing out these issues I have helped frame the trade-offs in a way that advances the debate and analysis.
Posted by: Craig Pirrong at Sep 22, 2008 12:11:55 PM
How big did this market become? Here's business correspondent Bob Moon and host Kai Ryssdal on American Public Media's Marketplace from back in the spring.
BOB MOON: OK, I'm about to unload some numbers on you here, so I'll speak slowly so you can follow this.
The value of the entire U.S. Treasuries market: $4.5 trillion.
The value of the entire mortgage market: $7 trillion.
The size of the U.S. stock market: $22 trillion.
OK, you ready?
The size of the credit default swap market last year: $45 trillion.
KAI RYSSDAL: That's a lot of money, Bob.
As in three times the whole US gross domestic product, Bob. And the truth is that Moon probably underestimated. The unregulated and poorly reported credit default swaps may have actually passed $70 trillion last year, or about $5 trillion more than the GDP of the entire world. http://www.dailykos.com/story/2008/9/21/9322/74248/245/602838
What a wonderful shell game it was.
Posted by: lxm at Sep 22, 2008 12:24:04 PM
Years ago I was part of an effort to create a clearinghouse for the energy market. They are hugely beneficial - netting the overall market exposure by upwards of 99%.
An important point though is that the market itself needs to agree on standardized products. But EVERY market eventually goes through this process. Products typically start out as custom/complex OTC products, and then migrate into more-fungible, more-vanilla instruments. CDS products simply need to do this same evolution.
If the gov't, or some consortium, were to become a market maker in a simple, standard CDS-like security intrument, then it would be pretty straightforward to move these products onto an existing clearinghouse.
Posted by: kis at Sep 22, 2008 12:49:56 PM
lxm, but that is mostly due to the situation which makes it cheaper to create an offsetting position rather than go back to the original counterparty and undo the transaction. If you buy something and sell the same thing you're not exposed to the price change any longer, but if they were contracts you still have 2x the notional value created. The standardized clearinghouse settled contracts everyone else is speaking about, would go a long way to cutting that size down substantially.
Posted by: nelsonal at Sep 22, 2008 1:06:43 PM
//But I'll start by saying that most blogosphere critics of the act simply do not know or understand much of the above.//
Ah yes, so true. I understand hardly a word...
Posted by: joe at Sep 22, 2008 2:39:32 PM
I believe two apparently inconsistent beliefs on this:
1) MBS are worth much less than holders originally thought, but they should still have quite a bit of real value.
2) There is very little liquidity in the MBS market; lot's of sellers but very few buyers. It’s very difficult if even possible for banks to liquidate their MBS positions right now.
These two don't really fit. If MBS clearly retain a lot of value, then somebody... healthy banks, hedge funds etc. should be eagerly buying them up. So if number one is right, number two should not be also true. Alternatively, if it really isn’t clear how much value these things have (because we don’t know how much worse the housing market will be, etc.) then maybe number 1) is wrong, which explains number 2).
But maybe there is another possibility. Perhaps there are plenty of buyers, but MBS holders are simply unwilling to lock in the loss at current market clearing prices. Rather then stop the bleeding like a disciplined risk manager, maybe these guys are crossing their fingers, praying for a) miraculous turn around in home prices, or b) some sort of government bailout in which they get cheap financing courtesy of the feds or maybe the feds end up buying MBS at higher prices than the market is willing to buy at. The longer they leave these positions open, the more value is lost if housing prices keep dropping and liquidity keeps drying up. But if the feds pass a huge bail, they’ll look like geniuses for leaving the positions open.
So what I'm saying is that I'd assumed banks weren't selling MBS because they simply couldn't. But maybe the truth is that they choose not to. I suppose that is one form of moral hazard, a case of executive incentives not aligning with shareholder interests, or possibly both.
Posted by: Chris Janak at Sep 22, 2008 5:16:38 PM
Today, the state of New York issued a press release saying that New York will regulate CDSs as an insurance product.
Posted by: Norman Pfyster at Sep 22, 2008 8:20:42 PM
Thank you, Tyler and others, for this discussion -- it's much more informative than the usual newspaper/blog fare. I'm a student - can I ask an ignorant question?
I can see how a clearinghouse can provide uniform, standard information about credit, but how does it "cover" counterparty risk? If one party can't pay its losses, does the clearinghouse step in somehow?
Also (the $20 bill on the sidewalk) why haven't OTC derivatives already been organized in a more transparent market, if the gains are so big?
Posted by: Sarah Constantin at Sep 23, 2008 7:11:01 AM
Good questions, Sarah.
Re how the clearinghouse/CCP operates . . . it's a little more complicated in reality than the textbook description. The cartoon description of the clearinghouse is that it is the buyer to every seller and the seller to every buyer. Through the miracle of "novation" when S sells to B, after clearing, S has a contract to sell to the CCP, and the CCP has a contract to sell to B. In this version, the CCP is in the middle of every contractual chain. If S defaults, B looks to the CCP for performance--not to S.
Now . . . for the reality. A CCP is typically in essence a cooperative, the members of which are large financial intermediaries. These firms are referred to as "clearing members." In the futures markets, everyone who wants to trade futures must have its contracts guaranteed by a clearing member. In the US, clearing members must segregate the accounts of its customers from its own proprietary trading accounts.
In the first instance, if a customer defaults, his clearing member seizes his collateral and has a claim against the defaulter's assets if the collateral is insufficient to cover the default. The clearing member is effectively on the hook for the customer's loss. The clearinghouse will not step in and cover the loss to other traders unless the clearing member of the defaulting customer can't do so.
In this regard, it should be noted that non-defaulting customers of the defaulting clearing member can also lose money in the default. The clearinghouse can seize the collateral of all of the defaulting clearing member's customers to make payments to the other market participants who are owed money. This happened in 1985 with a COMEX brokerage called Volume Investors and in 1998 with a brokerage firm called Griffin Trading Company. Moral: don't think that the clearinghouse makes you immune from somebody else's default.
In the event of a default of a clearing member, the clearinghouse has a variety of sources of funds to make whole those whose contracts are "in the money" and who were expecting to receive payments from the defaulter(s). Most CCPs have a default fund, made up of contributions of capital from clearing members. The CCP can dip into this fund to cover default losses. Moreover, most CCPs can make capital calls on clearing members, forcing them to put in additional funds to cover defaults. Most CCPs also have irrevocable lines of credit with major banks. They can call on these credit lines to obtain the cash needed to make payments to traders expecting payments from defaulting traders. Most exchanges bulked up on these credit lines in the aftermath of the 1987 crash, when the refusal of banks to make short term loans to customers to fund margin calls threatened to force the closure of the CBT and CME clearinghouses. The credit obtained by calling on these lines is a liability of the CCP, and its clearing members.
In sum, there are several tranches of money available to cover a default. The margin monies of the defaulting customer; the capital of the defaulter's FCM; the margin monies of the FCM's other customers; the default fund; the capital of other FCMs. In essence, a clearinghouse creates a complex set of rules that determines how the risks of default are shared among all market participants. Without a CCP, default risks are also allocated, but in the first instance (absent some systemic cascade), default risks are borne by an OTC dealer and its counterparties, with no possibility of sharing these risks among entities that did not have contracts with the defaulter or its counterparty, as is possible under a CCP.
Re your second question on the $20 bill, there is no definitive answer. One possibility is that there are pervasive externalities that are costly to internalize due to collective action problems. A clearing arrangement is a collective, cooperative agreement on how to share default risks. This arrangement has both distributive and efficiency effects, and as other examples (e.g., oil field unitization) have demonstrated, distributive effects and free rider problems can impede the achievement of efficiency enhancing collective action. This would provide the rationale for some government intervention to overcome the collective action problem.
The other (not necessarily mutually exclusive) explanation is that for some products, even those with massive volumes outstanding, there isn't really a $20 bill on the sidewalk--maybe there's only a quarter. That is, the gains from the sharing of default risk are not that large. Why might that be? I tried to outline some of the reasons in my earlier comment. Specifically, when there is substantial private information about the value and risks of some kinds of contracts, moral hazard and adverse selection problems reduce the gains from sharing risk. These costs can be so large as to make it not worth the candle to share the risk. My hypothesis, which is consistent with the pattern of adoption of central clearing in derivatives markets, is that these costs are particularly large for more complex products that are not actively traded.
Hope this helps.
Posted by: Craig Pirrong at Sep 23, 2008 11:19:47 AM
Sarah,
Re: why haven't OTC derivatives already been organized in a more transparent market, if the gains are so big?
Because the people who see the gains from having common clearing are different than the people who are gaining from the current situation.
Banks are not one huge business, they are a collection of independent businesses within one company. The swaps and CDS desks make much more money from having the products be less standardized than they would gain from having them standardized and cleared. Doing a swap with a single counterparty gives that counterparty leverage over your future trading. You cannot just trade with anyone to exit the trade, you must trade with your counterparty on the trade to truly exit. This results in higher overall fees for the end user customers - and higher profit for the desks.
Posted by: mickslam at Sep 23, 2008 2:05:47 PM
Thanks -- that really clarified things.
Posted by: Sarah Constantin at Sep 23, 2008 2:23:46 PM
The otc market is seeing lot of changes and the recent financial crisis has yet again brought the need of revolution in OTC market. I just want to throw the point, will this revolution just lead to merger of exchange and OTC market.
I recently wrote a paper over this.. those who are interested have a look at it here
http://researchunlimited.blogspot.com/
Posted by: Anurag at Oct 6, 2008 1:41:34 PM
