Tag: Budget

Introduction
Five months after the passage of the largest budget ever, Minister of Finance Dr Ashni Singh has gone back to the National Assembly for an additional $6.3 billion for spending this year. Some sketchy information for this sum is contained in Financial Papers Nos 1 and 2, the first being a Supplementary Provision to replenish the Contingencies Fund to the tune of $1,978 million and the second a Supplementary Provision of $4.3 billion for additional spending. Today’s column looks at the information and questions whether they meet the statutory requirements governing such additional expenditure.

The law relating to such spending and approvals is contained in the constitution and in the Fiscal Management and Accountability Act 2003 (FMAA). There are two types of supplementary provisions permissible under the Act: those that come before the spending takes place and those that come after such spending and in which case would have been spent out of advances from the Contingencies Fund. If the nature of the expenditure does not qualify it for payment out of the Contingencies Fund, then any such payment would be unlawful, constitute an indictable offence and carry a maximum penalty of two million dollars and imprisonment of three years.

Law’s weakness
The weakness in the law is that the offence can only be committed by an “official,” which by definition does not include a minister. In other words, for purposes of the FMAA a minister seems to enjoy some form of immunity and any action may have to be brought for misfeasance in public office. The self-accounting ministries are like laws unto themselves and while by law the Permanent Secretary is the accounting officer, there is only one power in the ministry and that is the minister(s).

The general rule is that only a supplementary appropriation Bill can finally authorise an allocation for expenditure. The Act requires that on the introduction of a supplementary appropriation bill, the minister is required to present to the National Assembly the reasons for the proposed variations and “a supplementary document describing the impact that the variations, if approved, will have on the financial plan outlined in the national budget.” Papers Nos. 1 and 2 presented to the National Assembly do not seem to meet these requirements.

Contingencies Fund
The Contingencies Fund is a special fund for special purposes and is described as a sub-fund of the Consolidated Fund. Article 220 of the constitution permits the establishment of a Contingencies Fund by paying into it from the Consolidated Fund a specific amount, the quantum of which is determined and, therefore, limited by law in respect of any year. The article goes on to authorise the minister responsible for finance to make advances from that fund, if he is satisfied that there is an urgent need for expenditure for which no other provision exists.

The Contingencies Fund is limited to two per cent of the estimated annual expenditure of the previous financial year or such greater sum as the National Assembly may approve. It is fixed for each year, either by way of the formula or an Act of Parliament and the minister cannot increase it without parliamentary authority. Advances from the Contingencies Fund must be cleared by a supplementary estimate laid before the National Assembly as soon as practicable, thus replacing the amount so advanced. Section 41 of the FMAA gives effect to Article 220 by providing the detailed procedures.

The overriding test for an advance from the Contingen-cies Fund is threefold: urgent, unavoidable and unforeseen. Further, the Minister can use this fund only where no or inadequate sums had previously been appropriated, or where reallocation under the FMAA is not possible, or finally, where delay would cause injury to the public interest. He cannot use the fund because he failed to budget properly, or because some budget agency was careless.

The Minister must report at the next sitting of the National Assembly all advances made out of the Contingencies Fund, specifying (a) the amounts advanced; (b) to whom the amounts were paid; and (c) the purpose of the advances.

Paper No 1: Spending from the Contingencies Fund
The following were the principal payments reportedly made out of the contingencies fund and for which replenishment was approved:

1. Provision for Japan’s earthquake recovery – $20M.

2. Payments to Linden municipality workers for the years 1999 to 2010 – $27.3M. After a period of eleven years this payment became urgent, unavoidable and unforeseen, in an election year.

3. $36 million for payments by the Ministry of Agriculture to farmers and households in Regions 2, 3, 4, 5 and 6 who were affected by the La Nina weather conditions. The sums were for the following organisations identified only by their acronyms: NAREI – $14M, GLDA – $6M, GMC – $5.9M and MMA – $10M. Like 2, this may also have an election element in it.

4. A further $10M appears to have been paid out to the same groups for the same purpose but under a Drainage and Irrigation Support project.

5. The Ministry of Agriculture again was allocated an additional $500M for consultancy services, drainage and irrigation works and procurement of four excavators for the Aurora land development project. In the absence of a project document and considerably greater details, it would be difficult to assess whether this sum is reasonable. What is equally troubling is that the sum would already have been spent and it should therefore have been subject to the strictest controls. Surely details should have included particulars on the tenders and each cost element should have been identified.

6. Other major sums include (a) $522M for rehabilitation of roads in Georgetown and Linden, (b) improvement of water supply in hinterland communities – $252M and (c) $280M to the Ministry of Education for computers in school laboratories.

Usage and abusage
Two things are clear from this. The contingencies fund continues to be used and abused in the most unlawful manner with practically no regard being paid to basic principles of financial management. It is not without some irony that it is the serial violators of the precepts of proper financial management and controls who continue to be provided with increasing sums of money to be spent without regard for the interest of the country’s taxpayers. While the Report of the Auditor General often makes adverse comments on the use of the Fund, it never deals with some of the most troubling questions that the public would wish to see answered. Hopefully the Public Accounts Committee will at some time insist that these be addressed.

GPL, losses and Amaila
Three billion, nine hundred million dollars has been requested and approved as a provision for a 15.6 megawatt plant at Kingston under the Electrification Programme. This is in addition to the sum of two billion eight hundred million voted under this programme in the 2011 budget, bringing the total to $6.7 billion. Guyanese have recently had to face blackouts with some frequency and severity and while the situation appears to have improved recently there are far too many reports of the losses sustained by consumers due to the poor quality of electricity.

The request for additional funds suggests that the state-owned Guyana Power and Light continues to rely on public funds for its capital programme, despite the high tariffs that consumers continue to bear. The company will remain tied to the national budget until it can curtail the theft of electricity which results in “line losses” of more than thirty per cent. While the company has been successful against many small consumers it has signally failed against the bigger thieves, among them businesses and persons who by no stretch of the imagination can be considered poor and therefore unable to afford. It is okay to go after persons in Sophia and Albouystown, but the theft by one business can cause more losses than fifty to one hundred households. Clearly more focus should be given to those groups in a way that does not allow the persons and their clever lawyers to free them to ‘Go and thieve some more.’

The other issue for GPL is of course how all the billions that are being pumped into the company fit into the longer term plans for electricity with Amaila hydro scheduled to come on stream in four to five years. This is not an idle comment since capital costs carry with them depreciation, and the fear must be that if and when the hydro is realised consumers will have to bear the depreciation costs not for one but two plants.

Public Works
The Ministry of Public Works and Communications gets another $400 million for Highway Improvement on the East Coast Demerara, on top of the $100 million voted earlier to make a four lane from Better Hope to Golden Grove. Now do we have any idea how much the whole project is going to cost and whether we are engaged in highway quality or highway robbery with the eye on the elections?

Conclusion
It is a safe bet that this is not the last supplementary we will see this year. It is after all, elections year, and the traditional splurge will be on – Norway or not. Opposition MPs and others need to do much more to protect us from the reckless spending by the government for which electoral defeat will be more than a political loss

Beneficiaries of hundreds of millions in Sports and Arts Development Fund uncertain.

Introduction
Today’s column continues a review of the 2011 budgetary allocations by the National Assembly to some of the principal ministries of government by looking at the Ministry of Culture, Youth and Sport, a ministry with which the Guyana Tennis Association of which I have been President for about eighteen months has had a long and unsatisfactory relationship.

As the table below shows, the total to be spent by this ministry in 2011 is $2.055 billion, 28% over 2010 and a 73% increase over 2009. If one wants to see how strange this government’s priorities are, one has only to compare this ministry’s budget with that of the combined campuses of the University of Guyana which in 2011 were allocated $582 million in 2009 and $657 million in 2010. Indeed, in 2011, the National Assembly voted more for sports in 2011 than the total allocation to the University of Guyana for any of the past three years! And as we shall see later, the financial management in this ministry is serious enough to invite charges being brought under the Fiscal Management and Accountability Act against those officials responsible for the reckless disregard of the requirement of that Act and ordinary standards of accounting and accountability.

[table to be inserted]

All figures are in millions of Guyana dollars. Source: Estimates 2011

Resource allocation
Despite the name of the ministry, sport seems always to get the highest allocation and for 2011 is allocated $964 million or 47% of the ministry’s allocation, with culture receiving 23% and youth 22%, and the administrative costs of running the ministry taking up the remaining 8%. Of the total, capital expenditure accounts for 40% while recurrent costs account for the remaining 60%.

The ministry employs a total of 359 staff of which 207 are contract employees, up from 159 three years ago and from 197 one year ago. The number of contract employees in each of the four functional areas is culture 62; administration 40; youth 92 and sport 13. As this series has shown this is one of the areas – procurement being another – that offers opportunities for the most unsatisfactory spending and for politicized decision-making by government departments. The average salary paid to each contract employee is approximately $1.2 million per year, significantly more than double the minimum wage.

The mysterious Sports and Arts Development Fund
The Estimates show that for the administration budget, wages and salaries paid to all employees, including those on contract, are $80 million or 52% with utilities accounting for $22 million or 14%. For Culture, wages and salaries cost in 2011 are $110 million or 25%; security $42 million or 10%; national and other events $72 million or 16% and Subsidies and Contributions to local organizations $133 million. And here is where there is a huge problem. Page 387 of the Estimates reveals that $100 million of this $133 million goes to a Sports and Art Development Fund of which no account is ever given. Since 2007, some half a billion dollars has been voted for this Fund but with no systems and procedures in place to ensure proper accountability. Despite questions raised in the 2010 budget debate by AFC MP Mr David Patterson about this Fund which was announced with much fanfare in 2007, the Fund appears to have escaped the attention of the Audit Office which never seems to have eyes for some really serious spending. When MP Sheila Holder of the AFC asked for details last year, Dr Frank Anthony dismissively said that “reports are not available.” Simple, isn’t it?

In the Youth budget, $155 million (37%) is spent on wages and salaries; $22 million on maintenance of buildings; $32 million on utilities; $42 million on “Other”; $12.5 million on training; and $9.7 million as subsidies and contributions of which $5 million is for the President’s award which inexplicably is listed as an International Organisation!

For sport, the current annual operating expenditure is $217 million with the major categories of expenditure being wages and salaries and materials and supplies each of $12 million; maintenance of buildings $10 million, utilities $17.9 million and subsidies and contributions to local organsiations of $120 million, the entire sum of which is paid to the National Sports Commission (NSC). The budget of the NSC shows that it is also to receive a capital grant of $530 million from the central government giving it a total of $650 million. This total is then allocated to capital expenditure of $530 million and current expenditure of $120 million, the full sum received as a subvention.

The pool
It is evident from the table that capital expenditure is relatively insignificant for all the functional areas with Administration’s capital budget being the equivalent of 3.7% of its current budget; Culture 10%; Youth 6.3% and Sport 344%! And this introduces the swimming pool saga, a project that first arose in 2007 and that is taking twice as long to complete as was planned. But the expenditure is also hazy and defies scrutiny. In the 2009 capital estimates, a total project cost of $405 million was stated for the construction of a swimming pool, rehabilitation of roof and electrical system at Cliff Anderson Sports Hall, lighting fixtures and rehabilitation of National Gymnasium, lockers for Colgrain Pool and purchase of sports gear and equipment. In the 2011 estimates, with the only significant additional work being the Athletic Track, the cost has gone up to $1.5 billion! This is clearly outrageous but again, more questions than answers.

National Sports Commission
There is an unhealthy and incestuous relationship between the ministry and the National Sports Commission where the financial lines are crossed with the ministry continuing to expend amounts voted as subvention and capital provision for the NSC. The NSC is a statutory entity created by Act 23 of 1993 and should have not less than six nor more than eleven members. The commission has been defunct for several years but PPP/C MP Mr Neil Kumar operates it like a one-man show in association with the Minister, Dr Frank Anthony. From time to time and at public events the former NSC Chairman Mr Conrad Plummer is called out to act in that role, but yet no effort is being made by the Minister to (re)constitute the commission as required by law.

Up to the time of the last audit report, the NSC had not had an audit since 2004, nor had the Minister presented to the National Assembly the annual report required under section 80 of the Fiscal Management and Accountability Act 2003. Despite these serious lapses that could constitute misfeasance in public office, the National Assembly continues to award this unlawfully-operating entity vast sums of money annually. It begins to sound as though the National Assembly either could not care or does not understand the implications of its vote when it allocates money to this and similarly placed entities.

When the question of the failure to have audited financial statements came up in the 2007 Audit Office Report, the ministry assured the Audit Office that the “National Sports Commission was pursuing the preparation of all outstanding financial statements.” Years later, very little appears to have changed. But once again the Audit Office has to share responsibility for the increasing disregard which this ministry and the National Sports Commission show for the law and for accountability. Another body under this ministry with a similar disregard for the law, accounting and accountability is the National Trust, a separate and legal entity created by Act 20:03 of the Laws of Guyana, and which would therefore be subject to separate financial reporting and audit. The National Trust is similarly deficient in respect of submission of financial statements for audit as required by law but there is no evidence that the ministry has taken steps to ensure compliance in this regard.

When the Audit Office reported on unexpended amounts totaling $55.5 million transferred into an Endowment Fund (?) instead of being refunded into the Consolidated Fund, the glib retort of the Head of the Budget Agency, ie, the Permanent Secretary was that “it was impractical to refund the amount of $152.398M to the Consolidated Fund at that stage, as the ministry was committed to pay the amount for the stadium lights. He also indicated that he [emphasis mine] gave permission for the sum to be deposited into the Projects Account.” This person had no problem or hesitation in admitting that he knowingly broke the law!

Procurement
As with all other procurement agencies, this ministry routinely breaches the Procurement Act in which capital works are awarded in a piecemeal manner to avoid adjudication at the level of the National Procurement and Tender Administration Board (NPTAB). As the audit report noted, these were undoubtedly obvious breaches of the Procurement Act 2003.

In 2008, the Ministerial Tender Board awarded one contract under the capital subhead National School of Dance in the sum of $0.382M on April 17, 2008 and yet the contract was signed on April 1, 2008, two full weeks before the decision by the Board. Then in 2009, eighteen transactions totalling $2.016M were undertaken for the acquisition of materials for the rehabilitation of the NOC Guest House. Of these, eleven totalling $1.278M were related to one supplier. According to the Audit Office report, the treatment of the transactions was clearly in breach of Section 14 of the Procurement Act (2003), as it relates to contract splitting.

Funny
But perhaps the most laughable response to come from the ministry to audit queries was in relation to non-compliance with the procedures for the payment of fuel. The ministry explained that the acquisition of fuel is based on a traditional and inherited policy from the Guyana National Service, involving Guyoil!

Despite these significant weaknesses and the fact that the ministry has so far failed to account for World Cup 2007 money, it remains one of the major beneficiaries of lottery money, which is another story. It is easy to conclude that this ministry is infected by a cavalier, sporting attitude more associated with West Indian cricket than with financial management.

Introduction
Today’s column resumes the review of the 2011 budgetary allocations to the principal ministries of government. Two of the ministries covered so far were the Ministry of Education on February 27 and the Ministry of Education on March 6. Today we turn our attention to the Ministry of Finance which in 2011 was allocated $18.3 B on the recurrent budget and $17.4 B on the capital budget, making a total of $35.7 B.

A summary of the expenditure as contained in the 2011 Estimates is as follows.
As a percentage of the national budget, the Ministry of Finance accounts for 18.4% of the recurrent budget and 28.0% of the capital budget. This makes it the single largest spending ministry in the government, and it is perhaps surprising that its capital budget is bigger than that of the Ministry of Public Works and Communication.

What is also significant is the increase over 2010 – a massive 64.3% increase with the bulk of it on the capital side. This is largely due to the proposed spending on LCDS projects including equity spending on the Amaila Falls Hydro-electricity project.

The Ministry
Like the Ministry of Health, this ministry has two ministers, with the junior minister Ms Jennifer Webster playing a more low-key, back-room role while the senior minister Dr Ashni Singh, brought in after the 2006 general elections as a technocrat is increasingly copying the style and language of his mentor, President Bharrat Jagdeo. That style has not endeared him to the diplomatic and multilateral financial community, and many observers think that that may be responsible for the closing of the development agencies DFID and USAID as well as the relocation of the office of the head of the World Bank mission in Guyana.

The World Bank office came in for a scathing attack by Dr Singh who accused the bank’s staff here of having “one of the largest appetites for publicity and self-promotion” and seeking to increase their “creature comforts” by relocating to “a grand former colonial residence opposite one of the city’s most fashionable cafés.” Coming in for his tongue-lashing was the Economic Intelligence Unit which had dared to question the final outturn for 2009 after the economy had performed poorly in the first three quarters. It was a case of how dare they question him.

His shutting out of critical views by draconian legislation on the New Building Society, his refusal to approve proposals by micro-projects for EU funding and his refusal to canvass views prior to his annual budgets all demonstrate an intolerance for opposing views that is inconsistent with a true technocrat.

Staffing
This is another of those ministries where the percentage which the number of contract employees bears to the total number of employees exceeds 40%. It is in fact 43.4% but it accounts for 72% of the total wages and salaries of that ministry. If one excludes the junior staff who according to Labour Minister Manzoor Nadir, were recently shifted to the category of contract employees, the share of the wages budget that is paid to contract employees is huge, very huge.

In the current budget of the Ministry’s Administration, three line items account for 94.06 % of the total as follows:
$B
Revision of wages and salaries 3.5
Electricity charges 2.5
Subsidies and contributions to local organisations 6.3
12.3

In the Government Accounting Administration two line items – statutory pensions and gratuities ($2.2B) and Pension Increase ($2.1B) – account for 82.4% of this programme’s activity.

Subsidies and contributions
The entities in receipt of the largest contributions were the Guyana Revenue Authority ($3.1B) and LINMINE for community power ($2.2B). It is of some interest that notwithstanding a decision of the court, the GRA is treated for the purposes of its expenditure as a separate entity while its entire income goes into the Consolidated Fund.

Other significant subsidies and contributions were made to organizations, some of which are of doubtful legal status, while that of their audits is even less clear. The principal ones are:

$M
Customs Anti-Narcotics Unit 99.2
Ethnic Relations Commission 89.1
Kwakwani Utilities Inc. 253.5
State Planning Secretariat 130.1
Statistical Bureau 172.0
Total 743.9

Capital programme
Under the capital programme are such hazy projects as:

$M
Road Support Project 150
Basic Needs Trust Fund 650
LCDS Projects 14,350
Student Loan 450
Poverty 717
GuySuCo 440
Total 16,607

The projects earmarked for funding under the LCDS programme are “Amaila Falls equity” which can surely mean anything and everything, Amerindian Development Fund and Land Titling, and Fibre Optic Cable.

Conclusion
But for the interventionist style of the President, this would easily be the most important ministry in the government. In addition to his several functions and duties under the Fiscal Management and Accountability Act 2003 which he sometimes conveniently ignores, Dr Singh is also the subject minister responsible for the Bank of Guyana, the Guyana Revenue Authority, the Bureau of Statistics, the National Insurance Scheme (NIS) and the Office of the Commissioner of Insurance. Under the Bureau of Statistics Act, 1991 unless he appoints a chairman of the bureau he is automatically the chairman, making him the scorekeeper of his own performance. And as subject minister, he seemed blissfully uninformed about the failure of the Office of the Commissioner of Insurance which allowed Clico Guyana to conduct its affairs in the most reckless manner and caused the NIS to have a yet-to-be filled hole of $6 billion.

Even though the major bungling and the public pronouncements on the tax concessions to the Ramroop group by Mr Jagdeo took the spotlight off Dr Singh, he was in fact at the centre of the fiasco, having had to look at it from three different perspectives. To his further discredit, Dr Singh also chairs the board of NICIL, the state-owned company that simply refuses to conduct its affairs in accordance with the law.

The Minister regularly publishes the mid-year report with misleading dates. He was cited by an opposition MP in the $4B transaction with GuySuCo in which his colleague in the Ministry of Housing was found to have a prima facie case made against him for misleading the National Assembly. There can be no doubt that Dr Singh would have known and went along with the transaction. But if there is a single issue for which this Minister will always be remembered is that while he served as Senior Minister of Finance, his spouse was effectively the Auditor General. That is an extremely convenient arrangement, but one over which few would be prepared to risk their reputations, and which will overshadow Dr Singh’s tenure as Minister during which he reported growth in each year.

Next week I will review the annual report of the Guyana Bank for Trade and Industry Limited which has published a notice of its AGM.

Introduction
An appendix to the budget speech includes some very useful indications about the health of the nation. Here are some of those statistics:

These data tell a mixed story with some interesting variations. For example while the number of deaths per 1,000 of the population for infants (under 1 year) has declined significantly since 2006, the same measure for the under fives has remained almost constant. The percentage of the population that is severely malnourished has halved over the same period indicating a fall in the number from 3,043 persons to 1,556 persons. At the same time the number of persons who are moderately malnourished has fallen from 44,881 to 42,785, although it increased in 2010 when the economy reported favourable growth.

On the positive side too is the rapid growth in the number of doctors from 373 to 537. On the other hand the number of nurses in absolute terms has declined from 822 to 786, suggesting that the doctors now have fewer support staff with whom to work. Now that the government has taken a decision to import skills it is not unlikely that it may move to fill the many vacancies at this level in the health system.

Details of expenditure
Agency Details

It is important to note that there is other expenditure to fill in the wider picture. The Georgetown Public Hospital Corporation is a separate agency in the budget and for 2011 has an allocation of $4.14 billion, or 71% of the budget for the substantive ministry. Expressed another way, the GHPC is allocated 42% of the total allocation of these two budget agencies. It is also uncertain whether there is proper accounting for the considerable sums received from various donors for different projects and programmes, with the major one being the HIV and AIDS programmes.

Over the years Guyana has been a major beneficiary of donor funds for our HIV/AIDS programmes which sought to project us as one of the region’s most infected populations. We received hundreds of millions from several sources and particularly from the US. It is unclear whether these have been accounted for in accordance with the Fiscal Management and Accountability Act which would deem the grants public money to be accounted for through the Consolidated Fund.

Capital budget
The ministry’s capital expenditure for the year is projected at $845 million with the lion’s share being $523 million under Regional and Clinical Services. Of this one hundred and fifty million dollars ($150 million) has been allocated for the “provisions [sic] for preparatory studies and designs for a Specialty Hospital”! Is this for real and was this hospital not supposed to be a free deal arising out of the President’s recent doctoral visit to India? Just improving the doctor’s quarters at Skeldon is budgeted to cost $10 million while filing cabinets, a projector, a refrigerator and chairs will cost $3.5 million. Seems that at Health, the mandate is to go for the highest bidder.

This ministry is one of the most politicised ministries with two ministers and a permanent secretary as political appointees. It is also the ministry in which more than half the employees (683 out of 1233) are contract employees with implications for their independence and right to membership of a trade union which in the main would be the Public Service Union that has had a stormy relationship with successive PPP administrations.

Lack of accountability
Now even by the standards of the Audit Office, the ministry and to a lesser extent the GHPC have had serious accounting issues over the years. In 2009 a fire of unknown origin destroyed the main building and with it financial and other records. What the fire revealed was a pattern of non-compliance with requirements to circulate copies of contracts, Tender Board minutes and basic matters like pay changes.

The matter of financing the GHPC is clearly not consistent with the requirements of the Fiscal Management and Accountability Act in that the corporation has been receiving an appropriation rather than a subvention. The explanation given for the whole question of inadequate accounting and improper financing is far from clear, but we are told that the matter has been submitted to Cabinet for consideration. What is clear is that Cabinet has shown no urgency in complying with the statutory requirements.

Similarly, the GHPC, despite annual adverse comments by the Audit Office continues to spend moneys that should properly have gone to the Consolidated Fund, because the Board approved the expenditure.

Both the GHPC and the Ministry of Health continue to buy billions of dollars of drugs with scant regard for proper tender procedures, sometimes advancing hundreds of millions of dollars to the New Pharmaceutical Corporation for drugs received several months later. It is unclear why this lop-sided relationship has been allowed to continue when the transactions with the company cannot even be verified, and again the disrespect or sheer stupidity of the excuses is hard to understand. These transactions are reminiscent of the unlawful tax concessions given to the group of which this company is a key component.

But these are not all. The ministry fails to adhere to the FMAA in relation to unspent balances causing the national accounts to be overstated, and was unable to provide satisfactory evidence to support the purchase of some $20 million of fixed assets.

Conclusion
There seems more than mere financial lawlessness at this ministry of which one of the ministers had once famously said he would not hesitate to break the law in some circumstances. Earlier this week the Minister of Finance made a real show of calling in the police and the Audit Office at his ministry. Seems that the Ministry of Health can do with some real forensic auditing and those responsible be subjected to serious questioning.

Correction
In the Business Page last week, I mistakenly noted that Education’s share of the National Budget has declined from 10.6% in 2007 to 9.4% in 2010. In fact these percentages should have read 17.1% to 15.3%. I sincerely apologize for the error and the inconvenience caused.