Page: 6588
Mr GERARD MARTIN (Bathurst) [3.42 p.m.]: I move:
That this House urges the Australian Banking Association, in its submission to the Joint Standing Committee on Corporations and Financial Services, to formally reject a plan to increase rural automatic teller machine fees up to $10 a transaction.
This matter has been brought to the attention of Country Labor in recent weeks and for the second time we raise it in this House. We seek bipartisan support from the Opposition on this matter because we expect that there would be a common interest in ensuring that people in rural areas are not discriminated against. The committee seems to have based its determination on the fact that perhaps people in the country should pay higher automatic teller machine fees because of the number of transactions. Obviously an automatic teller machine in Pitt Street or Macquarie Street in the city will be used more than a machine in a small place such as Trangie, where it might be in a post office, an agency—the Federal Government has closed down all those post offices in the bush—or a club. It is obvious that machines in such places will not have the same number of transactions, and some bean counter could work out, on a cost-effective basis, that it costs more.
The reality is that this is a universal service provided by all banks across the State, and the fees should be exactly the same. At the moment fees average about $1.30 per transaction. Under the committee's recommendation the worst scenario could be that fees would increase to around $10, as has happened overseas in places such as Canada. That is obviously unacceptable; Country Labor will not accept it. In its submission to the Joint Standing Committee on Corporations and Financial Services the Australian Banking Association [ABA]—the umbrella organisation for banks—should spell out clearly that banks do not want any part of this increase.
I know that the Commonwealth Bank is concerned about the fees, and will not impose a discriminatory charge. I challenge the other banks, and the ABA, to follow that lead. This is all about fairness; it is about ensuring that people in regional areas are not discriminated against. I know from having spoken to people in the Commonwealth Bank that it has such a policy, although I have not seen it publicised. At least one other bank probably has a similar policy, and they should be applauded for it.
Following deregulation of the banking industry in recent years the banks, quite rightly, have been criticised for withdrawing services, particularly in country and regional areas. We have all had experiences relating to the closure of bank branches. When I was Mayor of Lithgow, and subsequently, I received telephone calls from regional managers of banks in Rylstone and other places in my electorate who wanted to talk to me about how the bank was rationalising services. Before they arrived I knew it was all about which branch they were going to close. The messengers from the banks were always very polite, but that was their bottom line. For that reason I always had a feeling of impending doom when bank managers came to visit.
There has been a gradual erosion of banking services for people in regional and rural New South Wales. The one thing people can rely on is the good old automatic teller machine [ATM], which has become so much a part of our lives in recent years. In many cases it has become the banking facility in post office branches, agencies and clubs, and is the only access to banks for some people. The honourable member for Willoughby has probably gone to ring her mates at the Commonwealth Bank to check the veracity of what I am saying.
Banks have increased their fees on just about every transaction customers make, but we want to draw the line at automatic teller machine fees. We seek bipartisan support on this extremely important issue. It is something on which the Federal Treasurer and the Prime Minister could take the lead. They need some issues at the moment as they are a bit nervous about what might happen in the Federal seat in a few months time. They could certainly impress people in rural areas if they said, "We will not accept a situation where people in the regions have to pay more for the same service". Some people might say this is cross-subsidisation. If it is, well and good. But I am sure the honourable member for Murray-Darling would agree with me that there are plenty of reasons for having cross-subsidisation for services to country and regional areas.
Experience in other countries has shown that when differential fees have been allowed people in rural and regional areas are hit with significant price increases. There is already evidence of that. Some experts who gave evidence to the committee believe that the cost of using a foreign ATM in rural Australia could rise to between $5 and up to $10 per transaction. If a person wants to withdraw $50 from an ATM for a night out—that would be enough for us Labor Party members, but members on the other side of the House would probably need $500 for a night out—having to pay anywhere between $5 and $10 would make it a prohibitively expensive transaction.
The Joint Standing Committee on Corporations and Financial Services called its inquiry into the level of banking and financial services in regional, rural and remote Australia "Money Matters in the Bush". Indeed it does. It matters to people that they should have affordable services from the banks. We should send a direct message to the banks that people in these areas should not be financially penalised for what has become an everyday necessity—access to their ATM.
Banks have been part of the history of the bush since 1817. Indeed, the Bank of New South Wales, which is now Westpac, was the first bank in Australia. For many years banks have been fundamental to the services provided in rural and regional Australia. Although in recent times we have been disappointed with the rationalisation carried out by banks with respect to branch closures and reduction in the number of employees and services, people in rural and regional areas should receive the same level of service as those in the city and should not be discriminated against.
Mr Thomas George: You are picking on the honourable member for Willoughby.
Mr GERARD MARTIN: The honourable member for Willoughby will need considerable ammunition because we have heaps on her. In fact, she should declare an interest in this matter. The honourable member for Lismore, the honourable member for Murrumbidgee and others who occasionally visit the South Coast would agree with the essence of my comments.
Mr Peter Black: The member for Clarence does.
Mr GERARD MARTIN: I know that the honourable member for Clarence would agree. I am not sure whether we discussed it in the gym this morning, but if we did, we would have reached agreement on it. I ask honourable members opposite to put aside their bias and use their influence with John Anderson. He needs a few runs on the board at the moment because he has had some bad luck with air safety regulations—
Mr Peter Black: And sugar.
Mr GERARD MARTIN: I did not like to sour the debate by using the word "sugar", but I will talk about that later. Surely it should not be too painful for the Opposition to vote on this motion, and I am happy to accept a vote on the voices. Let us obtain a commitment from both sides of Parliament to defend people in country and regional areas. I am confident that the ABA will do the right thing because its submission will be crucial. However, we as a Parliament must send the right message: We do not want discriminatory ATM fees in rural and regional Australia. I commend the motion to the House and I expect it to receive unanimous support.
Mr ADRIAN PICCOLI (Murrumbidgee) [3.52 p.m.]: That was an interesting contribution by the honourable member for Bathurst, who is described in three words by Labor Party members and people in his electorate: lazy, lazy and lazy! So far as I am aware there is no such organisation as the Australian Banking Association; it is the Australian Bankers Association. Therefore, I move:
That the motion be amended by deleting the words "Australian Banking Association" and inserting instead "Australian Bankers Association".
Although it may appear to be a minor amendment, the motion should be worded correctly. The honourable member for Bathurst fails to grasp the importance of detail; he had only to refer to the telephone directory to get the name right. I hope that Government members support my amendment to correct the motion. People in country New South Wales regard banking regulation and services as very serious. That is why we were so disgusted back in the late 1980s when Labor deregulated the banking industry and sold the Commonwealth Bank. I was only 18 at the time but I still remember when Darlington Point had a Commonwealth Bank branch.
Many Commonwealth Bank branches were located across country New South Wales, but Labor—that great socialist party, which believes in public assets—flogged off the Commonwealth Bank to pay for services in country New South Wales. Labor then racked up another $60 billion or $70 billion of debt. It also privatised Qantas and everything else possible during its 13 years in government. I assume that the honourable member for Bathurst was a Labor member at the time and I know that the honourable member for Murray-Darling was a party member.
Mr Peter Black: Which party?
Mr ADRIAN PICCOLI: The Communist Party, I believe. Those members did not comment on the actions of the Labor Party at that time, and they shrink into their seats when reminded how the Labor Party privatised the Commonwealth Bank. In an attempt to increase the value of shares for its shareholders, the Commonwealth Bank had to close branches in country New South Wales. One can trace the devastation of country banking services back to when Labor was in government for 13 years at the Federal level, so God help country New South Wales if Labor is returned federally. We will return to the dark days experienced under the Labor administration of Paul Keating and Bob Hawke. I hope and pray that Labor is not re-elected for some time.
I remind honourable members that interest rates reached 17 per cent when Paul Keating and Bob Hawke were in office. People in the gallery probably had home loans on which they were paying 17 per cent interest, but the poor people who had a business loan, a farm loan or an overdraft were paying interest of 21 per cent or even 25 per cent. At the time it was like an auction; they could not go high enough quickly enough. We will return to those dark days if Labor is elected federally. Honourable members opposite often raise Federal issues in this Parliament. However, today they do not ask for action by the Federal Government; they want an organisation to provide a submission. Where is a submission from the honourable member for Bathurst, the honourable member for Murray-Darling or the other no-hopers they roll out to whinge in this Parliament? Where are the submissions to this inquiry from so-called Country Labor members? I return to those three words that so clearly and correctly categorise the member for Bathurst—lazy, lazy, lazy!
The House has already heard from the honourable member for Bathurst the negative side to the suggested reforms. I would suggest that competition in the provision of ATM services from private operators would remove a tier of bureaucratic administration in the form of interchange fees that banks charge and could drive down the cost of using an ATM. The whole point of the inquiry is to examine the consequences of various reforms. The honourable member for Bathurst left his office for a brief period to participate in a television interview in which he referred to a $10 fee for an ATM transaction. If he thinks he must scaremonger country New South Wales in order to get re-elected, good luck to him but bad luck for the rest of the community. Other people, who had obviously been influenced by the honourable member for Bathurst, were interviewed also.
In some communities where there are no ATMs, because there is no bank presence, other non-banking organisations will be able to install them. I am sure that all responsible and sensible members of Parliament would agree that that is a good thing. If that is the potential outcome of such reforms, that is good. Indeed, banks and other organisations may also charge different fees. As a consumer I will find out which financial institution charges the lowest fees and I will use the ATMs belonging to that financial institution. The point of competition is that it enables consumers to choose the right option, particularly the cheapest option. Two possible positive outcomes could be a reduction in fees and an increase in the availability of ATM machines.
I welcome this inquiry because of the possible benefits that can accrue to country New South Wales, which is important. We do not need the continuous negative carping from the honourable member for Bathurst and the honourable member for Murray-Darling, who will speak next in the debate. Listen to the honourable member for Bathurst now! He is outspoken in Parliament when the Premier is not here. During question time today a question was asked about council amalgamations. The honourable member for Bathurst talks big in public but, according to the Premier, he has not raised council amalgamations in caucus. Today the Premier said that the issue of council amalgamations had not been raised with him.
Miss Cherie Burton: Point of order—
Mr ADRIAN PICCOLI: The honourable member for Bathurst goes out and tells the union that he is doing so much—
Miss Cherie Burton: Sit down!
Mr ACTING-SPEAKER (Mr John Mills): Order! The Parliamentary Secretary will address all her remarks through the Chair or I will not hear the point of order.
Miss Cherie Burton: The point is relevance. The motion is about banking in country New South Wales. It has nothing to do with amalgamations.
Mr ACTING-SPEAKER (Mr John Mills): Order! I do not uphold the point of order. The remarks of the honourable member for Murrumbidgee are relevant.
Mr ADRIAN PICCOLI: I was responding to an interjection from the honourable member for Bathurst, who has been telling unions in public and the Premier in caucus that in no way will he accept forced amalgamations. The reality, according to the Premier in question time today—it is in Hansard—is that the honourable member has said absolutely nothing about it.
Mr PETER BLACK (Murray-Darling) [4.02 p.m.]: This is very much a Country Labor issue. I am surprised that The Nationals would send in the honourable member for Murrumbidgee on this matter. Let us face it: In the past few weeks we have seen the annual outbreak of bad manners time and again. The honourable member for Murrumbidgee is leaving the Chamber. Clearly, the annual outbreak of bad manners has been extended; it looks like it will continue for 10 months. Let us hope that it does not continue for 12 months. The first time I was alerted to this issue goes back to a headline in the Australian of 4 March 2003, which stated:
Banks to scrap ATM charge
I thought "This is good." On 5 March the Daily Telegraph stated:
New idea on ATM fees—be up front
But the Australian Consumers Association added a sour note. The article stated:
Consumers know how much they pay and they're very unhappy.
A headline in the Australian Financial Review of 5 March stated:
ATM shake-up plan sparks fears of fee increases
People in the bush started to worry when they saw the headline in the Sydney Morning Herald of 16 January 2004, which stated:
Banks have green light to raise ATM fees in the bush
Then a headline in the Daily Telegraph of 17 January 2004 stated:
ATM fees furore in the bush
Charges may rise $12
I am pleased that the matter has been raised with the Australian Bankers Association, which I understand is run by a chap called Ding Dong Bell. I do not know his first name but I understand that his staff refer to him as Ding Dong Bell.
Ms Gladys Berejiklian: Treat him with a bit of respect.
Mr PETER BLACK: If his staff refer to him as Ding Dong Bell, that is fine with me. What I have to say is this: Treat the banks with respect? I was brought up on a song called The Banks Are Made of Marble:
But the banks are made of marble,
With a guard at every door,
And the vaults are stuffed with silver
That the miners sweated for.
It is a great song. I suggest that members opposite find out what Australians have traditionally thought about banks. Let us get back to Ding Dong Bell. In 1999, when I last was on the executive of the Local Government and Shires Associations, we did a survey from 1990 to 1999 across Australia. The survey showed that the banks had closed 1,100 branches and in the last decade—I know there is an overlap—750 bank branches were closed. I was horrified when the Commonwealth Bank was sold off, because I knew what would happen. First, I was horrified when it was sold off—I do not back off from that. When the bank was sold it closed branches in country areas, including Ivanhoe. Incidentally, Ivanhoe had a temperature of 48.5 degrees two weeks ago; it was so hot they had to turn off the heaters in the gaol. Importantly, the people in gaol do not have a bank branch in Ivanhoe. The nearest bank is located in Hillston. The honourable member for Murrumbidgee referred to rail branch lines. Rail branch lines! Silo workers in many bush communities cannot go to a bank to cash their cheques.
Mr Thomas George: Point of order—
Mr ACTING-SPEAKER (Mr John Mills): Order! If the point of order relates to relevance I will rule against it. I am listening to every word the honourable member for Murray-Darling says.
Mr Thomas George: It is one of relevance. The honourable member for Murray-Darling should be brought back to the subject.
Mr ACTING-SPEAKER (Mr John Mills): Order! The remarks of the honourable member for Murray-Darling are entirely relevant to the motion.
Mr PETER BLACK: I will return to the subject of Ivanhoe. The closure of the Commonwealth Bank branch in Ivanhoe saved a lot of marriages. The bank did a special deal with the IDU. When the sheds closed at Ivanhoe the men were paid with two cheques because the Ivanhoe RSL could not cash big cheques. So for the first time in their lives the chaps were going home and handing over the big cheque to their wives, who thought it was marvellous. However, the wives did not hear about the small cheques. The banks closed branches in Wentworth and Wilcannia. They do not care about isolated communities; they do not care about workers who want to cash cheques; and they do not care about pensioners who want to cash cheques. The banks have never cared about the bush. They have always been made of marble. [Time expired.]
Mr GREG APLIN (Albury) [4.07 p.m.]: Let us cast our minds back to when a similar motion to this was moved last week. It was on a day when the Government was under fire, and the motion was obviously a diversion. However, it failed to move forward, and it is based on spurious grounds, to say the least. There is absolutely no evidence of this $10 fee; it is an invented figure that exists in the minds of members opposite. It is a scaremongering tactic, like so many others we have heard raised in this House. The Joint Standing Committee on Corporations and Financial Services report on the ATM fee structure stemmed from the committee's original report entitled "Money Matters in the Bush".
On 25 July 2002 the chairman of the committee announced that it had agreed to inquire into the level of banking and financial services available to Australians living in rural, regional and remote areas. In October 2003 the committee resolved to conduct, as part of its broader inquiry into banking and financial services in country areas, an inquiry into proposals to reform the foreign ATM fee structure and its likely effect in country areas. Recommendation 1 of the report stated:
The Committee recommends that the ATM Industry Steering Group include in its considerations on the reform of ATM interchange fee arrangements the special circumstances of fees and charges associated with the use of foreign ATMs in rural, regional and remote Australia.
Recommendation 1 continues:
The focus of the group would be on building into any proposed reform of the ATM fee structure, safeguards that would ensure that people living in country towns and remote communities do not incur significantly higher fees or charges for using a foreign ATM and that an unreasonable or unwarranted differential in fees and charges between those in rural and remote areas and those in metropolitan areas does not develop.
Recommendation 4 states:
The Committee recommends that should a direct charging regime be introduced both the RBA and the ACCC closely monitor shifts in fees and charges for foreign ATM services and report publicly on developments in fees charged.
The Committee recommends further that should a direct charging regime be introduced the RBA produce statistics to show the fees for ATM services in rural, regional and remote Australia and the fees in metropolitan areas.
In addition, the Committee recommends that the statistics include as a separate category fees charged for obtaining an account statement.
The Australian Bankers Association has stated that banks, building societies and credit unions are currently finalising their ATM proposal, which will be presented to the Australian Competition and Consumer Commission [ACCC] for authorisation. The proposal supports the ACCC and the Reserve Bank of Australia [RBA] recommendation that a direct pricing model be implemented. Once that proposal is lodged, it will be considered by the ACCC. Most importantly, the ACCC must consider the public benefits and detriments of applications before making a determination. The Act requires the ACCC to consider the impact of any proposal on identified consumer groups, including rural and regional consumers.
The inquiry by the Parliamentary Joint Standing Committee on Corporations and Financial Services recommended that interchange fees between banks for foreign ATM transactions be abolished immediately and replaced by direct charging, which would have the effect of reducing foreign ATM transaction fees from approximately $1.50 to 50¢. The Labor members of the committee opposed the introduction of the proposed direct charging regime. They were concerned that direct charging fees would allow ATM owners to charge a different fee for each individual ATM based on differential costs.
The ATM Industry Steering Group stated that under its direct charge model the framework of bilateral interchange fees would be dismantled. The proposed model removes the need for the card issuer to reimburse the ATM owner-operator for providing the service and hence the card issuer to recover the interchange from the cardholders. Rather, an ATM owner-operator would levy a direct charge on all cardholders who use its ATM service. The size of the charge would be determined solely by the owner-operator and debited to the cardholder's account. The fee for providing the service should reflect the cost of providing the service plus a margin for return on investment. In other words, the ATM interchange fee would be set at zero and the components of the foreign fee would be unbundled.
In the time I have available I will refer to some of the major recommendations of the inquiry: the introduction of industry standards for electronic banking in remote Australia, the protection against unreasonable differential rural foreign ATM fees in areas where there is only a foreign ATM, the branch closure protocol to incorporate comprehensive community consultation, and improved consumer protection measures for isolated people. [Time expired.]
Mr STEVE WHAN (Monaro) [4.12 p.m.]: I am pleased to support the motion, which goes to the heart of the provision of basic services for families and businesses in rural and regional New South Wales. While rural families suffer as bank services diminish, the banks continue to post bigger profits. Recently the Commonwealth Bank posted a half-yearly profit of more than $1.2 billion. Our big four banks remain on target to once again break the $10 million barrier and set yet another record profit over the coming year. In 1997 household bank fees were $1.2 billion. By 2002 they were closer to $2.7 billion, an increase of 123 per cent. It is now possible that charges on automatic teller machines [ATMs], particularly for rural and regional Australians, will be increased. Country Labor believes it is time for the Federal Coalition to accept Labor’s policy and reject any suggestion of differential fees for ATMs.
I listened carefully to the contribution by the honourable member for Albury, who spoke about the recommendations made by the committees. I will refer to one such recommendation, which I believe is particularly important. The majority of members on the Joint Standing Committee on Corporations and Financial Services, the Coalition members, recommended that there should be direct charging. They said that they want to protect against an unreasonable or unwarranted differential in fees and charges between rural and remote areas. Who will judge what is unreasonable or unwarranted? According to the Coalition members, if a bank can justify an increase of $10, then it can go ahead and charge that amount.
Mr Greg Aplin: It is called competition.
Mr STEVE WHAN: The honourable member for Albury interjects "It is called competition". Those of us who talk to people in rural communities know that in many areas competition has not delivered a great deal of benefit for rural towns. The honourable member for Murrumbidgee seems to be of the view that deregulation and allowing banks to charge what they want will result in the provision of more services. We have seen evidence of that in a lot of areas! People in rural communities do not believe that they will get the benefit of lower prices if deregulation occurs. In contrast, the Labor members of the committee stood up for rural New South Wales. They stood up for the things that Country Labor stands for and rejected the introduction of direct charging. The report states:
The Labor members of the Committee opposed the introduction of the proposed direct charging regime. They were concerned that direct charging of ATM fees would allow ATM owners to charge a different fee for each individual ATM based on their different costs.
The Labor committee members were absolutely right to take that position because the application of differential fees will result in more expensive services in regional New South Wales. Figures of between $5 and $10 per transaction are commonly bandied about in the community. Such amounts are unacceptable and should be ruled out by the Federal Government and the banks. We understand that banks are in the business of making profits for their shareholders. However, they also perform a community service and have obligations and responsibilities. We want to make sure that they provide a service and that the people of regional New South Wales can access the funds reasonably close to their homes and at a reasonable price.
In recent years ATMs have popped up everywhere around the country. There are now approximately 20,000 ATMs in Australia, compared to 4,400 in 1990. We hear a lot of talk about foreign ATM transactions, that is, when one bank's ATM is used to withdraw money from another bank. In rural and regional New South Wales about 40 per cent of ATM transactions are foreign transactions. The honourable member for Murrumbidgee said that he would make sure he chose the ATM with the lowest fees. In most of the small towns I represent people do not get that choice because there are not multiple ATMs. Indeed, under this new charging regime there will not be multiple ATMs; there will simply be an ATM charging a much higher price.
Currently, banks charge an interchange fee of between $1.50 and $2.00 on a foreign ATM, while the actual cost of providing the service is about 50¢. There is a big difference between the fee charged and the actual cost. Under the philosophy of the Coalition, the banks will be able to justify charging more in New South Wales. Once again, rural residents of New South Wales will be charged more to access services. They deserve to have services provided to them on the same basis as they are provided to people in the cities. [Time expired.]
Mr GERARD MARTIN (Bathurst) [4.18 p.m.], in reply: I thank all members who contributed to this debate. In particular, I thank the honourable member for Murray-Darling for his usual incisive and entertaining address and the honourable member for Monaro for his excellent and considered contribution. Government members were surprised to hear the honourable member for Murrumbidgee lead on behalf of the Opposition. That shows that the Opposition has little regard for this issue. The honourable member for Murrumbidgee accused me of being lazy. It is no secret that the Leader of The Nationals is trolling around The Nationals backbench trying to get someone to replace the honourable member for Murrumbidgee in the shadow ministry. One only has to look at his performance last week to understand why. After five years as a member in this place he could not ask a question properly and was bounced out. The honourable member for Murrumbidgee should do his homework.
The Government accepts that the Opposition is closer than the Labor Party to the top end of town, the bankers. We accept the Opposition's amendment to change "Australian Banking Association" to "Australian Bankers Association". I take responsibility for the oversight; we must get the little bits right.
I am disappointed that the honourable member for Willoughby did not join the debate. She would have had to declare an interest. We have only to go back to her maiden speech, which was effusive about her career in the Commonwealth Bank, to understand that she comes from a long line of people on the other side who see it as their God-given right always to defend the banks, because the banks are always right. The Coalition opposed the Farm Debt Mediation Bill—which was introduced by my predecessor as member for Bathurst, Mick Clough—until right at the end when they had to join us and support it. The opening lines from the responses of the Hon. Duncan Gay and the honourable member for Lachlan show that they are apologists for the banks.
We have an opportunity at the moment because the committee is in full flight. It is making recommendations. We are saying only that there is a possibility in this case that people in rural areas may be discriminated against. The honourable member for Albury is another north shore-ite, the north shore of the Murray. The north shore is well represented here, and that is great. He claimed that the suggestion that the transaction fee could increase to $5 or $10 was preposterous. Ample evidence was given to the committee that that is exactly what has happened, particularly in Canada, when charges were deregulated to allow differential charging. The banks will make hard-nosed business decisions; they will not build in any social commitment.
The Labor Party supports a social contract with the banks so that community interests are considered. It should be written into the charter of the banks. We will not get any support from the other side of the Chamber on that issue. It is important for us to speak out on this issue in a bipartisan manner. It will not hurt the Opposition too much to do that. We are prepared to accept the Opposition amendment. I do not speak to the Australian Bankers Association every day; it is a body foreign to me. But I did have a phone call from a lady from that organisation in the last week. It must have been static in the line that made me think that she said she was from the Australian banking association. Acceptance of the amendment might be the only win that the honourable member for Murrumbidgee ever has in this place.
We want bipartisan support. We want to say in a unified voice to the committee, while it is considering the recommendations, that we would like these people, if they have any influence with their masters in Canberra before they are swept up in front of the Latham juggernaut, to make sure that people in rural and regional New South Wales are not unfairly penalised with ATM charges because of where they live. As the honourable member for Murray-Darling and the honourable member for Monaro so eloquently put it, the banks have discriminated against people in country areas for too long with the wholesale rationalisation of banking services. So let us stand up as one group, support the motion and say to the banks "Hands off" as far as exorbitant ATM charges for people in country areas are concerned. [Time expired.]
Amendment agreed to.
Motion as amended agreed to.