Statement by Bank of Russia Governor Elvira Nabiullina at the 24th International Banking Congress on 4 June 2015

 

Good afternoon, dear colleagues!

I am delighted to welcome you at the International Banking Congress and would like to give a brief overview of the macroeconomic conditions that affect the banking sector, financial markets and the national economy. And of course I will dwell on the issues of banking regulation and supervision in my speech. Let me start with the monetary policy.

We are going through a period of adjustment of the economy and the financial system to the new economic environment. The last year was a challenging one: we have lived through several shocks.

Earlier this year we faced soaring inflation and were actually sliding into recession. Stagflation posed a real threat. The current indicators exceeded economists’ expectations expressed in the moments of the highest tension last year. However, I consider it premature to say that all crisis phenomena are over.

Though risks have been alleviated they essentially persist and we must realise it. They are determined by many-year structural economic restrictions supplemented with recurring recession factors conditioned by drastic changes in the external conditions.

Currently, the financial system and the balance of payments have almost adjusted to the new conditions, though it is true for the economy as a whole.

External conditions remain rather unfavourable. Of course, oil prices have increased, but even stabilised at the current level they still remain half as low again as the five-year average. Besides, prices for other traditional Russian exports also decline, therefore it should not be expected that exports would save our economy. The economy will further receive from exports at least US$150-170 billion per year less as compared with the usual level and simultaneously redeem external debts.

Economic adjustment and recovery will take time, and the result we will finally obtain will depend on changes both in the external conditions and the pace of structural reforms.

A positive scenario is the one where the structure of the economy develops towards higher share of manufacturing industries and services with considerably higher productivity of labour.

A negative scenario is the one where stable oil prices enable us to relax and enjoy 1-2% growth in the old structure of the economy with low productivity.

I should say that both scenarios can occur.

We develop the monetary policy, banking and financial sector regulation in order to create conditions for and increase likelihood of the positive scenario. I would like to emphasise that our policy aimed at reducing inflation and cutting interest rates will be ineffective unless it is supported by the respective improvement of business environment and establishment of conditions for private investments.

I believe that economic realignment should be based on non-inflationary development as inflation would result in nominal rather than real growth, disruption of long-term growth for the sake of short-term effects.

Now I would like to touch upon the effects of the measures we took in the extraordinary situation last year.

I should say that we managed to quickly neutralise many financial stability risks. We managed to contain depreciation expectations, avoid bank runs and growing mutual mistrust among market participants.

The volatility of market indicators went down and interest spreads shrank. Bank deposit inflow resumed.

The Bank of Russia introduced new instruments such as FX refinancing enabling more flexible and smooth external debt repayments amid restrictions in the international markets. Due to the current market situation the demand for additional funding through these instruments is low and therefore we have limited their application.

According to our estimates, during the rest of the year debt repayments will amount to about US$40 billion, net of intergroup payments of large companies. This is approximately twice as low as last year external debt redemption rate. We believe that our economy will accommodate such payments relatively easily.

Following considerable spike early this year due to the impact of powerful though temporary factors, primarily ruble depreciation, inflation has started to slow down rapidly in the recent months due to the measures implemented.

Currently, the monthly and weekly inflation rates returned to those we observed in the past few years (in particular, the weekly inflation rate went down from 0.5-0.9% in early 2015 to 0.1% in May).

We can see the key rate we introduced 18 months ago gains in importance for determining the stance of our monetary policy. It has also become a benchmark for the interest rates in the money market.

We also expect more rapid response or higher sensitivity to our decisions from commercial bank rates. Thus, the practical efficiency of our decisions will be improved. The FX channel of inflation influence still remains very important, but the interest rate channel gains in importance even more.

Should there be no new considerable external shocks, the inflation will drift down in line with our forecasts. We still have the inflation target of 4% for the medium term.

This inflation forecast and lower inflation expectations enable us to reduce the key rate. Yet, the pace of the key rate reduction takes account of risks we see in the next months.

These risks include mainly the normalisation of the US monetary policy. Dollar appreciation will result in capital outflow from emerging markets and the pressure on their currencies, including the ruble.

The second risk is the oil price dynamics. Our baseline scenario provides for oil prices at the level of US$60-65 per barrel, but oil prices are currently very volatile and hard to predict. Besides, it should be taken into account that oil price is a financial asset that can be impacted by dollar appreciation.

Another traditional risk is crop yield and food prices, as well as possible revision of administered price and tariff growth rates and indexation-related secondary effects.

However, despite these risks and proinflation factors, in the recent months we estimated risks of economy cooling to be higher and it enabled us to smoothly lower the key rate.

More dramatic reduction in interest rates we are sometimes called upon is risky as inflation expectations are high. In these circumstances, too rapid rate reduction may result in a new wave of instability in the FX market and inflation surge.

Currently, the inflation expectations, though lower compared with the maximum values, are persistently high both against the previous years and the expected level acceptable with regard to our medium-term inflation target.

Bringing down inflation expectations is a paramount objective of the monetary policy in the short term. We must create sustainable expectations that inflation will be in line with the set targets.

Our country has already gone through the periods when inflation went down to 5-6% but inflation expectation remained at a higher level. This predetermined the behaviour of households and businesses ultimately resulting in a new inflation growth, but failing to ensure sustainably low inflation. And we know that the higher are inflation expectations, the higher are the interest rates at which people are prepared to deposit their savings in the financial system and ultimately in investments, and the shorter are maturities. Therefore it is hard to expect investment-oriented growth and long money amid high inflation. That is why I give a lot of attention to inflation reduction – because it is the basis for investment-oriented growth our country needs.

Now I would like to say a couple of words about short-term financial stability objectives.

Developments of the past two years not only in Russia, but in other countries as well, have confirmed that the level of confidence in the national currency and the potential for mitigating global risks and global shocks depend on the adequacy of gold and foreign currency reserves. This is the case. Even under inflation targeting and the floating exchange rate the value of reserves does matter.

Our latest experience made us rethink our understanding of the comfortable level of foreign currency reserve adequacy.

According to all international standards we have sufficient reserves. Our reserves cover for over three-month imports, short-term debt, and 20% of the money supply. Currently, internationally it is recommended to use aggregate indices derived from a combination of differently weighted ratios rather than individual adequacy ratios. For Russia this index amounts to about US$188 billion. The current level of reserves is about twice as high. Already twice as high. However, we believe that due to the Russian specifics and the situation we should also take into account the necessity to meet the demand resulting from restricted access to the markets and capital outflow for a longer term than assumed by standard approaches to reserve adequacy. Therefore, one of our priorities is to build up the reserves in several years. In the optimal case, the reserves should be sufficient to cover for significant capital outflow for two to three years. Therefore, we currently estimate reserves in the amount of US$500 billion as a very comfortable level sufficient for long-term turbulence. This is a habitual level for us.

Nevertheless, we believe that reserve build-up should be incremental and should not contradict the main objective of the monetary policy that is inflation reduction to 4% in the medium term. Our estimates show that this is possible if the process of reserve accumulation is protracted over several years; it may be uneven and will depend on the situation with the balance of payments, the level of volatility of global markets and price stability risks. We have already started to replenish our gold and foreign currency reserves. There have been many questions regarding this issue that is why I explain the logic behind our actions.

By the way, many people interpret out activity aimed at replenishing international reserves as an attempt to maintain certain ruble exchange rate in order to sustain both budget revenues and the potential for exports and import substitution, and criticise us for abandoning the principles of inflation targeting and the floating exchange rate. I would like to say that this is not the case even in theory. In practice, such countries as New Zealand, Chile, Israel, Mexico and others that adhere to inflation targeting, at some point in time conducted policy of building up their reserves; so there is no inconsistency here.

Though I completely realise the importance of budget revenues and competitiveness of the domestic economy, I should say that artificial repression of ruble appreciation is as hazardous for the economy as artificial curbing of its depreciation.

If artificial depreciation curbing is fraught with dramatic depreciation as reserves are not unlimited. In case of a protracted contraction of strengthening, negative impacts will manifest themselves as financial bubbles, further inflation growth and dollarisation of the economy.

The transition to the floating exchange rate was a deliberate step that was well prepared. Besides, it was a timely transition towards a floating exchange rate that allowed us to mitigate the shocks of the last year and we do not intend to abandon this policy.

But we realise that we are at the beginning of introduction of a new regime. It will require serious adjustments in the behaviour of all the economic agents. It is not only about changes in the policy of the Central Bank, but also about changes in the behaviour of economic agents. Therefore, as we have previously noticed, at this stage we may intervene in the foreign exchange market more frequently to prevent financial stability risks.

Another issue I would like to focus on with regard to the monetary policy is the role of various refinancing instruments that we use and that we have begun to use more actively in the challenging environment, and their impact on the monetary policy. Currently we have several instruments to refinance loans to small businesses, export loans, and investment project loans (the so-called project financing). In all the cases special purpose instruments were introduced in the sectors where market failures are common.

However, the scope of these instruments does not contradict monetary policy goals and objectives, therefore, despite the requests we are not going to expand the use of these instruments because this may undermine the monetary policy efficiency.

We are currently harmonising conditions for use of these instruments making them more standardised. Besides, as we allocate resources on favourable terms, they should meet the objectives they are aimed at. Recently we have created a mechanism for refinancing loans to small businesses provided not only through a special purpose bank – MSP-Bank – but also by other banks in cases loans are guaranteed by the Credit Guaranty Agency. Moreover, in case of MSP-Bank we started to refinance loans to microfinance organisations.

We believe that refinancing of project financing has not yet met all the expectations. We introduced this instrument more than a year ago, but its real effect is minimal, therefore we are not intending to expand its application. We will consider other possible responses to market failures resulting from the lack of long-term liabilities in the banking system.

Now I would like to comment on another issue. Currently there are a lot of appeals for the Central Bank for funding, e.g., additional capitalisation costs, investments in various investment projects, i.e. to finance quasi-fiscal functions. We consider it unacceptable, as the main objective of the Central Bank is to ensure price stability, macroeconomic and financial stability and thus conditions for sustainable economic growth.

Now let’s consider the situation in the banking sector.

Russian banking sector is at the medium level of development. As a result of the intensive growth in banking assets in previous years, in 2014, the assets amounted to 108% of the GDP as of the beginning of this year. It exceeds the indicator of 90% built into the Banking Sector Development Strategy for 2016. By early May the value of banking sector assets had exceeded 72 trillion rubles.

Despite challenging external conditions and slower economic growth, the overall banking sector demonstrates resistance to financial shocks. The stress-test proves that allowing for the additional capitalisation measures the adequacy of the total capital of the banking sector will exceed the regulatory minimum of 10% even in case of severe scenarios such as oil price fall to US$40 per barrel. Additional capitalisation is required to increase the banking sector dynamics in lending to the real economy and to reach the operating margin more rapidly.

The banking sector grew rapidly for most of the last year. The situation in 2015 differs considerably from that of the last year, but we still expect a moderate growth in the main parameters of the banking activity this year.

Foreign currency revaluation had a considerable impact on the banking sector dynamics in 2014 and early this year: when the national currency depreciated the nominal indicators of banks rose, and when the ruble appreciated, they fell.

The data on the slide is rather reassuring; it is important, however, what is behind those figures. The situation in banks is a mirror reflecting the economic developments.

Unfortunately, economic slowdown unavoidably leads to slower lending and the growth of problem assets. Lending slowed down both in corporate (to lesser extent) and retail segments in January-April 2015.

The retail portfolio is shrinking mainly due to the depreciation of unsecured consumer loans after several years of the boom. This is an expected slowdown, but it happens faster than we have predicted due to the combination of two trends both on the supply-side due to the lower lending stimuli and our measures to cool down this segment, and on the demand-side due to the decline in real household income that started several months ago. In our view, this segment of lending will be getting back to normal when the pace of its change correlates with the dynamics of the nominal income of households.

These dynamics normalise rather quickly, therefore the Bank of Russia gives special attention to banks of the retail sector. Some of these banks require additional capitalisation by their owners. We can see that some credit institutions already received it last year. At the same time, managers have to adjust business models of their banks on the basis of more conservative risk assessment in this segment.

Mortgage lending remains the high-quality element of the entire lending system with the lowest share of problem loans and this share has not been growing in the recent months. Following the drop in the first few months of the year, mortgage lending is recovering bolstered by the government support programme. In April, we already saw a slight monthly increase in the mortgage loan portfolio. According to our estimates, mortgage lending will decline less than in 2008-2009; we expect its incremental recovery in the next months.

Improvements are also seen in lending to non-financial organisations. As usual, small and medium-sized enterprises faced the most challenging conditions. And the situation will not change considerably without government support measures.

Amid deteriorating quality of assets, capital stock and the possibility to cover for losses from current income are important for banks. Early 2015 was characterised by the aggravation of credit and interest rate risks in the banking sector – loan loss provisions increased and net interest income declined; this resulted in a drop in banking profitability. As a result of the first four months of this year, the banking sector had a small loss.

In the next six months, we expect a U-turn of the lending market, improvement in the ratio between interest income and expenses of banks. According to our estimates, the financial result of the banking sector for this year will be considerably lower than that of the previous year, but will still remain positive (about 100 billion rubles, according to estimates). Some experts are more optimistic in their forecasts, but I still remain with the conservatives.

As of 1 May, banking sector capital exceeded 8 trillion rubles. Capital adequacy ratio had rose to 12.9% by early May driven by the government measures to provide banks with additional capital and, of course, by the decision of the Central Bank to temporary ease regulatory requirements. The government support of banks through extending subordinated loans in January-May already reached 310 billion rubles, including OFZs in the amount of 71 billion rubles out of the DIA funds; thus, only 7% out of the declared one trillion rubles were spent for additional capitalisation. But it was the possibility of such support that soothed the market and raised confidence. In the short term, the DIA will consider applications from banks for more than 700 billion rubles.

As for the regulatory requirements, we intend to gradually return to standard regulation by late 2015. And all representatives of the banking community should take it into account to assess the situation and develop their short-term business plans.

Confidence in banks is a paramount condition of banking sector development. The renewed growth of household deposits with banks signals of sustainability of such confidence.

Obviously, confidence can be sustainable only in the banking system where problems are not suppressed, but revealed and solved. Insufficient supervisory response and suppression of signs of financial instability only give an illusion of welfare.

Opposite views are expressed in discussions of the Bank of Russia policy – that we should act more quickly and should not wait for problems to pile up. On the other hand, the rate of withdrawal of weak players is too high and it undermines the confidence in banks and exhausts the DIA.

Let’s start with the issue of withdrawing financially unsound and unconscionable banks from the market.

Over the previous 18 months, our objective was to sort out problems as quickly as financial stability permits. Many obvious problems were solved. Meanwhile, the deterioration of economic conditions inevitably impacts the range of troubled banks. Our main objective is to act proactively. This requires further improvement of supervision. It is clear for us.

An internal challenge to the banking supervision is to bring bank resolution to a new level. If previously (for 18 months) supervision mostly dealt with already reveled issues and had to quickly prove them, formalise the claims and take a decision, now these objectives are supplemented with the necessity to efficiently reveal problems. And this issue becomes of primary importance. Early detection becomes critical for these problems not to become overdue when there is no other solution than licence revocation or bank resolution, which is costly and highly undesirable. The need to create an early response system is not new for the Russian supervision. There were attempts to introduce such system before; however the effectiveness of these efforts is not sufficient.

Therefore, one of the principal challenges for our banking supervision system is to ensure an effective early response. I believe that we have enough capacity to make it happen, but this will require certain restructuring and refocusing of supervision.

One of the elements of this early response framework is cooperation with owners and management of banks in order to remedy the situation. If it is impossible for financial or other reasons, we intend to apply mechanisms that will enable these institutions to find new investors.

Implementation of these approaches is expected to lead to further rehabilitation and market consolidation of the banking sector.

Our performance in 2013-2014 indicates that the root cause of the problems is not really bad financial risk management but really low quality of governance or counterproductive governance when decision-making is not focused on customer service and profits, but rather on enrichment of beneficiaries and top-management. We believe that this comes from the feeling of impunity and the related lack of accountability. Recently, enforcement in the financial sphere has been stepped up. We actively support this positive process and we will do our utmost to ensure that the words ‘bank’ and ‘banker’ evoke only positive connotation.

One of the prerequisites for meeting these challenges is transparency of banking activity. Lack of transparency is a favourite strategy of dishonest businessmen, including bankers, when they conceal risks and problems from the public and from the regulator. This is why additional scrutiny in our supervision activity is focused on transactions bearing no evident economic sense and non-transparent assets, including non-marketable assets, hidden encumbrance, and loans to borrowers not engaged in real activity.

Efforts of the banking supervision are aimed at unmasking such assets, preventing misreporting and concealing real level of assumed risks from the regulator.

The Bank of Russia gives special attention to the situation in the household deposit market and aggressive policy of some banks in this market. This is the case not only in terms of deposit growth and the related interest rates, but mostly of the situations when aggressive policy in the deposit market is combined with low quality and non-transparency of assets in which the bank invests raised funds.

I would like to underscore here that the challenging economic environment is not the reason to ease the supervision. Dishonest and non-transparent banks are the first to experience problems in the current situation. They can fool the regulator, but they cannot fool the economic reality. Lack of high-quality liquid assets precludes such banks from resisting even light shocks, and all concealed problems surface.

Misreported financial insolvency is the leading reason resulting in licence revocation. From the experience of provisional administrations of banks which underwent licence revocation, the negative capital is usually detected in 65% of cases, and the value of assets is usually overreported by 58% on average by the former managers and owners of the banks, whose licences were revoked in the past two years. This is unacceptable.

Last year a provision on the responsibility for misreporting financial data was introduced in the Criminal Code, and currently we have already submitted seven applications to the law-enforcement agencies under this provision.

I will briefly review the statistics of licence revocation. Over two years and six months, we revoked 145 licences, of which 27 licences have been revoked in 2015.

I will repeat once again that licence revocation is a measure of last resort for us. When it is economically feasible we try to apply resolution measures.

Over the past two and a half years, resolution decisions were made for 15 banks, we provided the total of 509 billion rubles on a repayment basis for the resolution purposes. This has enabled banks to ensure their solvency on liabilities totalling 800 billion rubles, including liabilities to depositors in the amount of 500 billion rubles.

Currently there is a debate over how we can increase the resolution efficiency, including the issue of establishing a state-controlled resolution bank and its functioning.

We are against the state monopoly on resolution. This will result in higher resolution costs and additional state control over banks.

Resolution measures should be applied through a special purpose state-controlled bank only in case the market is not willing to participate in this process. Should the market show no interest in resolution, the Rossiysky Capital bank charged with special functions is supposed to be involved. Mostly resolution is expected to be implemented through private investments.

The functions of Rossiysky Capital in cooperation with the DIA are as follows:

- participating in problem bank asset and liability valuation;

- developing proposals for a competitive selection of investors for financial resolution aimed at selecting the most economical variant;

- participating in the transfer of assets and liabilities of problem bank before the bankruptcy proceedings are initiated.

Simultaneously, the Bank of Russia is contemplating the development of market approaches to financial resolution of problem banks through private investments. One such mechanism could involve the provision of marketable Bank of Russia loans to potential investors. These loans could be provided in order to sustain the liquidity of the investor, not the investor’s capital but liquidity. Potential investors may include banks which meet the scope of activity and financial stability requirements enabling these banks to cover for risks associated with the new business through their own capital.

Another actively discussed issue is the condition of the deposit insurance. There are a lot of debates about the adequacy of the deposit insurance fund, the possibility of deposit insurance deductibles, and even a reform of the whole deposit insurance system. I believe that our deposit insurance system functions effectively and does not require any serious restructuring.

I will start with the adequacy of the DIA funds. Despite recent licence revocations resulting in shrinking of funds in the Deposit Insurance Fund, the DIA will have sufficient funds to pay the depositors under any circumstances and, if necessary, the Central Bank will provide a loan. The DIA will redeem these loans when the rates of bank withdrawal from the market will slow down. In fact, the Bank of Russia loan is required only to close the cash flow gaps when expenses temporary exceed income, but according to our estimates, as soon as active work with problem banks is over the fund’s income will exceed its expenses.

More details about deductibles. I should say straight away that the Bank of Russia is against the introduction of deductibles. The deposit insurance system is the major precondition of depositors’ confidence in the banking system, and the economic benefits from deductibles are much less than the reputational losses the banking sector will incur.

Meanwhile, we realise that the problem of the so-called serial depositors – people who place deposits with banks offering the highest interest rates understanding that if the licence is revoked from the bank their deposits will be refunded with high interest. Such problem exists. But we will solve it not at the citizens’ expense but through discouraging banks from unfair competition in the deposit market. We will do it through our regulation and supervision instruments.

The first measure to be taken is to differentiate bank contributions to the deposit insurance fund depending on their deposit policy and it will come into effect in a month from now. One cannot expect citizens to be professional users of bank services, to follow bank reports, ratings, business news, etc. In order to protect non-professional users of these services we established the deposit insurance system.

It is the regulator who is charged with timely withdrawal of unconscionable banks from the market. Therefore, we are not going to shift our responsibility to the citizens. Our analysis shows that banks participating in the deposit insurance system whose licences have been revoked in 2015, raised deposits at high non-market interest rates in the run-up to the revocation. Therefore, the banking supervision is charged with timely application of strict restrictions in such cases. I urge the banking community to be prepared for them and I believe that our efforts aimed at banking sector resolution will be supported. I am sure that bona fide banks are interested in fair competition just like us.

We hope that the practical implementation of these approaches will address these challenges of bona fide banks.

Now let me turn to tackling dubious transactions and money laundering. The Bank of Russia gives a great deal of attention to that. We efficiently apply restrictive measures and revoke licences.

This year, we have started to apply new powers in this area granted by law, including the powers to revoke licences due to the breach of Bank of Russia regulations on countering money laundering. Meanwhile, the number of banks involved in suspicious transactions gradually decreases.

Nevertheless, the issues of countering money laundering are persistently critical. The supervision in this area will be based on the introduction of a risk-oriented approach. We believe that including bankers in the so called black list for five years preventing recurrences in this area is an efficient measure.

We will also apply our experience in supervision to non-financial organisations; however, it requires legislation amending.

In order to implement our functions of a megaregulator, we started inspecting both credit institutions and non-bank financial organisations. The simultaneousness of these inspections enables us to receive information and respond faster.

As for the banking regulation, to conclude, I would like to touch upon two main issues bankers are concerned about – these are the exit strategy from the crisis-response measures and the timeframe for introducing the Basel standards.

As a result of discussions with the banking community, we decided to gradually abandon regulation easing. We believe the banking system is ready for that. This will happen gradually during the year.

Now some words about the introduction of the internationally recognised standards, primarily Basel II and Basel III. We are sure that the current economic situation is not an excuse to reject or delay the introduction of the Basel standards.

These standards are being introduced in due order. Thus, the minimum capital adequacy ratio has been raised to 6% since the beginning of the year. We are currently collecting data on short-term liquidity indicators, cooperating with banks and will recently come up with the timeframe and the range of banks (these will be the largest banks) this ratio will be applied to. Besides, this year we are going to publish our regulations enabling the largest Russian banks to apply the approach based on the internal ratings upon their validation by the Bank of Russia (the so called IRB-approach).

It is important to say that this year the Russian banking regulation is assessed for compliance with standards of the Basel Committee on Banking Supervision. The regulation of Russian credit institutions is generally based on these standards, though there are some country-specific peculiarities. In some cases they are more conservative, in others – less. We take account of the Russian specifics, but at the same time we believe that the introduction of the Basel standards is a basis for our banks to function within the global financial system.

In the banking regulation we will focus on two issues.

The first one is countering various schemes used to conceal losses or artificially increase the bank capital. In particular, we intend to issue regulations determining signs of credit institutions’ investing their capital in their own capital sources through third parties, i.e. signs of bogus capital formation through non-transparent sources.

The second issue is limiting risks arising from lending to businesses of banks’ owners. These risks have been accumulated by banks for many years and have affected the general structure of the banking sector, when a considerable number of banks serve the interests of financial and industrial groups and deposited funds are used for funding bank owners. Obviously we must scrutinise this trend.

I am not going to focus on the general development of financial markets, because as you know the last year was the year when we worked as a megaregulator; that presumes a lot of work with insurance companies, non-governmental pension funds and microfinance organisations. Our main objective in this area is to create conditions for business development through better regulation, because well-developed financial markets are one of the sources of the economic growth.

In conclusion I would like to say that all of us understand that there are difficult years ahead both for banks and the real sector of the economy. At the beginning of my statement I said that without structural reforms the Russian economy will be unable to demonstrate high growth rates. We have to accept the new economic reality and should not expect to return to the pre-crisis condition. The prospects of the real sector of the economy largely depend on our work, on stability and efficiency of the banking sector.

I would like to wish all of us to succeed in this work. I hope that the congress that has opened today will become a platform for productive debate about the current developments; that you will be able to openly discuss the most acute issues which are numerous, and to work out joint solutions. I wish you luck. Thank you very much for your attention!

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