ESFS 3.0 - Evropský fond finanční stability (EFSF, dokument v AJ)

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Europe Special Report

ECB SMP and EFSF 3.0N O M U R A G L O B A L E C O N O M I C S N O M U R A I N T E R N A T I O N A L P L C

EFSF 3.0 and the fate of the ECBs SMP

One key area of market uncertainty is the ECB's stated intention to suspend its SMP

programme when the EFSF 2.0 is up and running, which could be later this month.

But the EFSF 2.0 is unable to execute this mandate.

However, we believe that an awareness of the structural limitations of EFSF 2.0 will

mean that the ECB will maintain its SMP programme, we assume at a similar scale to

that seen over the past six months albeit with the purchases remaining conditional on

fiscal rectitude among recipient countries.

If we are correct, this would remove one key area of market uncertainty, but many will

remain since we assume that SMP purchases will remain focused on providing the

minimum liquidity support necessary to ensure that key non-core countries maintain

market access.

We have framed the euro-area crisis in terms of governments and the market searching

for a steady state solution, defined as a situation where the market no longer fears the

incremental solvency risk of holding the debt of a euro-area sovereign. In our view, there

are three, often related, paths towards a steady state solution:

1. Fiscal union and/or the issuance of Eurobonds with a joint and several

liability structure. The likelihood of this option has been significantly reduced

following last month's German Constitutional Court ruling against unbounded

liabilities accruing to Germany as a result of its involvement in Euro-area

bailouts.

2. Monetisation of non-core debt via an aggressive expansion of the ECB's

balance sheet. This option runs the risk of merely providing a large window of

market calm after which underlying solvency concerns would remain.

Nonetheless, it would allow the ECB's unbounded balance sheet to be brought

to bear on the crisis which could be sufficient to assuage default risks for a long

period of time. (While the ECB would only buy bonds on the secondary market,

this should spur demand for primary debt since the bonds could be sold to theECB, limiting their downside). However, our view remains that the ECB is

reluctant to increase the credit risk on its balance sheet at this time.

3. Default by selected countries and the potential for some Euro-area

members to leave the euro. This is naturally a market-unfriendly outcome and

one that could result in multi-year economic and market disruptions before a

steady state were reached.

We recently analysed many of the latest policy proposals for addressing the euro-area

crisis that work within this framework (EFSF 2.0, 3.0 and beyond, 29 September), most

notably policies which involve increasing the amount of financial resources brought to

bear in the crisis by altering the structure of and/or leveraging the EFSF. Now we revisit

this analysis, and highlight the implications for the ECB's securities markets programme

(SMP) from some of the proposed changes to the EFSF.

10 October 2011

Jens Sondergaard

+44 (0) 20 710 21969

[email protected]

Desmond Supple

+44 (0) 20 710 22125

[email protected]
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Nomura Global Economics 2 10 October 2011

The planned ending of the ECB's SMP a key area of marketrisk

Since the bond-buying began, its effectiveness has been limited by the markets

awareness that the ECBs commitment to the SMP has been ambiguous. First, the ECB

has repeatedly said that the SMP is intended to be temporary. Second, the governing

council remains heavily divided on the issue and the critical voices are well known (Jens

Weidmann, Juergen Stark, Yves Mersch, Klaas Knot). A divided governing council

makes the bond market interventions less effective.

The ECB is clearly not comfortable with the SMP

Four main concerns explain the ECBs unease regarding the SMP:

1. The ECB bond purchases may be violating the Treaty of the European Union,

Article 21.1 which prohibits the ECB from directly buying bonds from EU

governments, i.e. the ECB cannot bail out governments in financial distress.

There may be a legal loophole in that the ECB is buying bonds in the secondary

markets (i.e. from financial institutions), but the intention of the treaty is clear:

the central bank should not facilitate the deficit financing of the euro-area

governments.

2. Second, the ECB bond-buying has implicitly been conditional on thegovernments adopting the right policy mix of fiscal austerity and structural

reform. The ECB SMP is a quid pro quo: governments take steps to ensure that

their public debt is sustainable; the ECB intervenes to correct the mispricing of

bonds in the markets. If governments do not do their job, the ECB can (and has)

stepped back from its intervention. This is a dangerous area for a central bank.

Bond purchases essentially become a stick and carrot tool where the ECB

takes a direct role in affecting fiscal policy across the euro area. It is hard to see

how central bank independence is preserved and how the ECB can separate

fiscal from monetary policy concerns.

3. We think ECB policymakers are worried about credit risk. A substantial

commitment to further SMP entails a substantial balance sheet expansion. But

policymakers worry that such a balance sheet expansion would increase the

financial risks to their balance sheet. In other words: leveraging up the balance

sheet exposes the ECB to potential capital losses. Policymakers may worry that

any significant capital losses would make the ECB technically insolvent. The

governing council does not have the right to ask for an increase in the ECBs

capital base. That is the responsibility of the European Council. Of course, there

is no theoretical problem with a central bank being insolvent if there is sufficient

confidence that policymakers will not implement an overly loose monetary policy

as they seek to accumulate profits by printing money (seigniorage) and riding

the yield curve. In the current context in Europe, we doubt many investors would

be alarmed if such a scenario emerged. Nonetheless, central banks remain

strongly opposed to depleting their capital.

4. The ECB is concerned about the possible inflationary impacts of a large-scale

SMP intervention. Can the ECB sterilise the inflationary impulse from a large

balance sheet expansion? If not, then SMP could conflict with the price stability

mandate, depending on the economic outlook for the euro area.

The ECBs appetite for its SMP has also related to its own agenda regarding economic

governance in the euro area. It has explicitly talked about the need for closer economic

and in particular fiscal integration within the euro area, and is aware that market pressure

is pushing policymakers down this path. Without this market pressure, the ECB fears that

the momentum towards the ever closer union will falter. An unconditional commitment

to SMP removes market pressure and would imply a lost opportunity to substantially

improve the foundations of European Monetary Union. However, the balancing act for the

ECB is providing an SMP which is viewed as sufficiently conditional on fiscal

consolidation in recipient countries and a partial solution to a countys funding pressures,

The ECBs commitment to

the SMP has been

ambiguous


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but on the other hand providing sufficient liquidity to ensure that key countries, such as

Italy or Spain, do not lose market access. If they were to do so, the survival of the euro

area would become more uncertain. So, the SMP needs to provide a minimum backstop

until a sustained solution is found.

ECB is scheduled to pass the SMP baton to the EFSF 2.0,which is unable to grasp it

Given the ECBs obvious restraint in terms of its SMP intervention, the scheme has had a

success proportionate to the modest scale of its ambition. It has played an important rolein helping to maintain market access for countries such as Italy and Spain since it has

limited the rise in yields, but the scheme has clearly not been large enough to transform

market sentiment towards the semi-core countries since it is not a solution to the debt

crisis. While maintaining the current SMP is not a substitute for a credible and broad-

based EU policy response to the crisis, were the ECB to halt its programme the risks of

Italy and Spain losing market access would increase significantly. In this respect, the

outlook for the ECBs SMP is a crucial area of market risk.

Unfortunately, there are question marks about the longevity of the SMP. As we wrote

recently (Asymmetric market risks in Europe, 6 September 2011), the ECB currently

plans to halt its SMP and to hand over responsibility for secondary market bond-buying to

the EFSF once Euro-area parliaments approve planned changes to its structure. This is aconcern because the proposed new structure of the EFSF (EFSF 2.0) is ill-suited to the

task of taking up the baton of the ECBs bond buying program in our view. At 440bn in

usable/investible resources, 147bn of which have already been allocated to bailout

programmes, we think it is too small to comprise a significant buttress against market

weakness in non-core debt. Moreover, the EFSF lacks the ECBs flexibility since it would

need to pre-fund its interventions, and there is uncertainty about how the EFSF would

choose which bonds to buy.

Does the EFSF 3.0 option change our view of the ECB's SMP?

When looking at the many and varied options for EFSF 3.0, below we divide them into

two broad categories: (1) options which by definition address the issue of the SMP by

making this scheme a central component of the new EFSF; and (2) options such as

leverage-based options which require a separate view on whether or not we expect the

SMP to be maintained and in what size.

Category 1 The ECB indemnity option

In EFSF 2.0, 3.0 and beyond (29 September 2011), we noted that of the proposed

changes to the EFSF, one of the most appealing could be to transform the EFSF into a

mechanism for indemnifying the ECB against losses from its bond holdings. The benefits

of this approach would be threefold:

More efficient use of EFSF capital. This scenario would not need the EFSF to

issue AAA debt for the purpose of its indemnification operations. Hence the full

value of guarantees726bn could be utilised rather than the 440bn when

these assets are over-collateralised to form440bn of investible funds.

SMP uncertainty is removed. Under this scenario, the SMP becomes a central

element of the EUs EFSF-related plans for addressing the euro-area crisis. This

option also addresses (depending on the scale of the indemnity provision) the

ECB's concerns about the credit risk implicit in its SMP.

Bank recapitalisation. The plan also allows for EFSF funds to be allocated to

additional uses, such as bank recapitalisation, and hence for the policy

response to comprise a more comprehensive package of measures.

We explore this option first as it would allow us to quantify the potential impact on the

SMP.

SMP has helped limit the

rise in yields, but is nosubstitute for a credible

solution

EFSF funds can be used

to indemnify the ECB for

its bond purchases
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The potential size of the SMP under an ECB indemnity optionscenario

Under the ECB indemnity option, we can calculate based on some assumptions the

potential size of the SMP. We assume that from the 726bn in guarantees, we need to

subtract two amounts. First, we need to remove the 147bn in funds which will be

committed to the various bailout measures for Greece, Ireland and Portugal. This figure

includes EFSF commitments to the second Greek aid package included in the 21 July

private sector Involvement (PSI) deal. While it looks increasingly as if the PSI deal will

need to be renegotiated, for simplicity we assume that the EFSFs involvement in PSI 2.0will be the same as its role in PSI 1.0. Second, 200bn in funds has been allocated to

fund a recapitalisation of euro-area banks.

This leaves a 379bn pool of EFSF funds which would be available to indemnify the

EFSF against losses on its SMP. Of these funds, we would assume that the ECBs

existing160.5bn bond purchases would need to be indemnified against losses.

Full indemnity of the ECBs SMP 218bn. After removing the various items

above, a full indemnity operation for the ECB would allow for additional bond

purchases of218bn. This would represent a 76.3% expansion of the SMP, but

in value terms could be underwhelming since, if the SMP purchases were to

persist at the pace seen in September, the expansion would provide only

around seven months additional resources. Of course, EFSF funds can be

expanded without parliamentary approval, but a full indemnity option would

require clarity on whether the ECB would continue with its SMP after its full

indemnity had been fully utilised.

If the EFSF were to seek to leverage its resources by providing a partial, first loss

indemnity for the ECBs bond-buying programme, then the SMP could expand further.

Some indicative numbers are below.

50% indemnity of the ECBs SMP 598bn. If the EFSF were to provide a

50% loss guarantee, then it would be able to indemnify the ECB against 758bn

in bond purchases. After subtracting the existing SMP, this would result in

additional buying power to the tune of 598bn. This would allow for Septembersrapid pace of bond purchases to be maintained for nearly 19 months, but the

larger the pool of resources that are committed to the SMP the more credible

the ECBs actions become and the less potential there is for them actually being

required.

25% indemnity of the ECBs SMP 1,356bn. If the EFSF provides a 25%

first loss guarantee to the SMP then the available pool of resources increases to

1,516bn which would allow for fresh SMP purchases of 1,355bn. This would

allow for Septembers pace of bond purchases to be maintained for 43 months,

and would represent a sizable policy response to the crisis.

Were the EU to announce that the EFSF were to provide a 25% first loss indemnity to the

ECB and that200bn of funds would be allocated to fund euro-area bank recapitalisation

(with larger countries such as Germany and France potentially funding their own

recapitalisations), then this could significantly alter market sentiment. This package may

not be sufficient to deliver a steady state solution and at the end of the ECB purchases

Euro-area countries would need to have addressed their solvency concerns. However,

the package does provide a significant window of opportunity.

The key question, is whether the ECB would accept a mere 25% first loss guarantee or

would it require a larger if not full indemnity? Given that this proposal would increase

many of the ECBs concerns regarding the SMP noted above (in particular, concerns

about the capacity to sterilise such a large balance sheet expansion, concerns about

central bank independence, and the fact that a partial guarantee would still entail a

potential credit loss), we feel that it is unlikely that the ECB be willing to accept such a

low first loss provision at this stage of the crisis..

With EFSF indemnity, the

ECB could expand the

SMP up to 1.4trn


5/11


However, one practical problem with the proposals above is that parliamentary approval

is required for the suggested changes to the EFSF. That would likely take at least three

months, meaning that there may be an interim period when the SMP continues in its

current form.

Adverse implications of the indemnity options correlation riskand reconfigured EFSF

It is important to note two additional implications of the indemnity options. First, by

utilising the full 726bn in EFSF guarantees, a clear correlation risk would exist sincecountries that would be the target of the SMP would be large contributors to the

guarantee structure. Italy currently accounts for 19.2% of the EFSFs maximum

guarantee commitments. Were Italy to step out, unless other countries increased their

commitments, then the available pool of resources would need to decline. This would not

be a problem with proposals that utilise the EFSFs 440bn structure, since there rely on

over-collateralisation of AAA countries and hence do not contain this correction risk.

Secondly, the indemnity option could require a restructuring of the EFSF structure. Part

of the EFSFs operations could largely continue unaffected, notably the debt that is

issued to fund participation in Troika bailout packages and, potentially in the future, bank

recapitalisations. However, the EFSFs indemnity of the ECB could be structurally

problematic. The EFSF would issue debt which would be transferred, not lent, to the ECB.This would leave the EFSF with a liability but without an asset with which to service or

repay its debt. EFSF liabilities would be paid by the guarantors, but this option seems

inefficient to us. It would be more efficient if governments were to issue debt in their own

name to finance the ECBs indemnity commitments, and given the statutory requirements

for the ECB to be recapitalised a similar arrangement already exists. This could entail

part of the EFSF becoming a mechanism for co-ordinating the transfer of callable

capital/callable indemnity funds to the ECB.

These downsides may not necessarily be constraints against the indemnity option, but

they are important in our view.

Category 2 - Non indemnity and leverage scenarios

Options outside of the ECB indemnity proposal require a view on whether the SMP will

continue and in what size. One can argue that if the EU could implement one of the

proposals which entail leveraging the EFSF into a 2-3trn pool of usable/investible

resources, then the scale of the policy response would be so large that the need for SMP

buying would be removed. This is true, but as we have argued we doubt that there is a

viable leverage option that could generate such a large pool of investible resources.

There are three most likely paths to leverage, all of which we think are flawed:

EFSF turns into a bank and levers its capital base via repos with the ECB .

The obvious hurdle to this solution is whether the ECB would be willing to allow

a rapid expansion of its balance sheet and expansion of credit risk on its

portfolio. This reticence has thus far limited the scale of its SMP programme.

Indeed, in his final press conference, ECB President Trichet implied that the

Bank was not supportive of being the mechanism through which the EFSF is

levered.

EFSF turns into a bank and undertakes repo financing with the market

albeit with guarantees from Euro-areagovernments against counterparty

losses on repo. This option could limit the amount of leverage that the EFSF

could undertake since increasing the guarantees would incur a contingent

liability which would raise concerns about the stability of the AAA ratings of

selected sovereigns in Europe.

EFSF turns into a bank and utilises repo financing with the market withoutgovernment guarantees. Under this scenario we struggle to see the EFSF

leveraging itself more than 2x, which would result in a set of usable resources

that fell considerably short of the recent 2-3trn headlines. The EFSF could

EFSF 3.0 will require at

least three months of

parliamentary approvals


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finance non-core debt on relatively generous repo terms (limited collateral

haircuts) up to the point where its purchases would match its available

resources. Without additional guarantees, if the EFSF were to lever its balance

sheet, its perceived credit worthiness would increasingly be defined by the

quality of its assets (non-core debt) rather than its capital base, meaning

steadily increasing collateral haircuts would likely be used to address this

counterpart credit risk. At 2x leverage, repo counterparties would see that a

50% loss on the EFSFs debt holdings (under an extreme scenario) would

generate a 25% recovery rate. Beyond this level (and potentially even before

this point), the cost of repo financing could be prohibitive.

If we assume that the ECB repo financing is not a viable policy option at this stage, then

the leverage option would not be large enough to render the SMP redundant. Hence, we

need to know the likely fate of the SMP when the EFSF 2.0 is up and running, we

presume, later this month.

Absent a shock-and-awe solution, the SMP should continue afterEFSF 2.0 is implemented

As we noted above, there is currently no credible policy backstop to ensure that the

governments of Spain and Italy continue to have market access. Hopes have been

raised that a comprehensive framework for addressing the euro-area debt crisis can bedelivered at the G20 meeting in Cannes on 3-4 November as was flagged by this

weekends Merkel-Sarkozy summit. Encouragingly, Angela Merkel and Nicholas Sarkozy

appeared to have increased the scope of their ambitions as they implied that a

comprehensive solution would encompass a bank recapitalisation, a "durable" solution

for Greece and some form of policy change probably revolving around the EFSF that

could channel additional fiscal resources to the debt crisis. However, as noted above, we

doubt any shock-and-awe policy announcement will be delivered given our past research

which highlights the numerous constraints on aggressively leveraging the EFSF, moving

towards closer fiscal union and the ECBs reluctance to substantially expand its balance

sheet via the accumulation of greater credit risk.

Moreover, without a comprehensive framework for addressing the debt crisis, we see the

hoped for recapitalisation of the euro-area banking system being only of partial benefit.

The market would have no certainly that it could crystallise the potential capital deficit in

the financial system since it would lack confidence about the accuracy of assumptions

regarding the book value of financial institutions. (In the US in 2009 it was critical that

TARP was combined with a policy of monetary and fiscal reflation which eased the

markets fears about the downside risks to bank asset values, and in Europe a credible

framework for addressing the non-core debt crisis will need to play the role that policy

reflation did in the US.)

Without a credible policy package that can arrest market fears regarding euro-area debt,

we believe the ECB would have no alternative but to maintain its SMP programme.

Indeed, given that the ECB is likely fully aware that the EFSF 2.0 is unable to take over

its stated role of buying euro-area debt, we believe that the Bank may not even pause in

its bond-buying programme once the institution is up and running. Instead, it may carry

on and wait for the EFSF 2.0 to begin its buying programme, which we doubt it will be

able to. (The more bearish alternative, is that the ECB does indeed suspend its SMP and

only resumes buying in the likely, in our view, event of a notable widening in non-core

spreads to Bunds as the EFSF 2.0 proves unable to stabilise markets.)

and a continuation of the past six months implies156bn in SMPover the coming year

It is highly uncertain how many bonds the ECB would need to buy to ensure market

access. As we said earlier (see Special Topic: Q&A on the ECB and the EFSF, 12

August 2011), an optimistic view is that the simple threat of ECB intervention would be

sufficient to keep yields low. And the most pessimistic assumption is that the ECB might

have to be ready to buy the entire outstanding stock of Italian and Spanish liquid debt

Without a credible policy

backstop...

...the ECB will probably

have to maintain its SMP...

...possibly buying156bn

bonds over the coming

year
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(e.g.467bn Bonos for Spain and1.1trn BTB for Italy), but we rule out at this stage any

major expansion of the ECBs balance sheet.

We assume that the SMP bond buying will be similar in scale to that which has prevailed

over the past six months. The scale of buying should be sensitive to prevailing market

conditions, but the bias which has guided ECB bond-buying over the past six months

should persist the SMP should provide the minimum level of liquidity support needed to

ensure that countries which the Bank believes have a liquidity problem will be able to

access the markets. In terms of size, over the past eight weeks the SMP has resulted in

average weekly bond purchases of around 11bn, or roughly 44bn a month, however

over the past six months which encompassed periods of relative market calm

average weekly purchases have measured 3.3bn or roughly 13bn a month (see

Figures 1 and 2).

A sustained continuation of the SMPs pace of the past 8 weeksappears unlikely

Extrapolating the past eight weeks bond purchases over the coming 12 months results in

SMP purchases over this period of around 528bn and means a 26.4% increase in the

size of the ECB's balance sheet. This would represent a notable increase in the pace of

expansion but we view this as a less likely extreme scenario. If there were such a large

and persistent need for ECB intervention then we think increased pressure would bebrought to bear on policymakers to accelerate the search for a steady state solution.

Similarly, since we assume that such a large and sustained increase in SMP would be in

response to adverse market conditions, almost by definition we assume that such a large

scale of buying would not be sufficient to transform market sentiment towards Europe.

Indeed, one danger with a continuation of the SMP is that the market starts to price-in

such a large expansion of bond purchases, which is one reason why our FX strategy

team would view the maintenance of an SMP without a pre-defined limit as negative for

the EUR.

Alternatively, there could be a continuation of the trend of the past six months. This would

entail an expansion of the SMP programme over the coming year of 156bn or a mere

7.8% increase in the ECB's balance sheet. The reality may prove to be somewhere inbetween these scenarios, in which case the SMP may have a less significant impact on

the size of the ECB's balance sheet than would the provision of the 12-month Long Term

Refinancing Operations.

Our view assumes that: (1) SMP is not inflationary,, and (2) Italy and Spain continue to

deliver on austerity and structural reform programmes. The ECB would likely scale back

its support (but not stop completely) if Spain and Italy did not deliver the required fiscal

policy initiatives. The question then would be whether the rise in yields would push

Spanish and Italian policymakers back towards their programme of fiscal consolidation

We assume a similar scale

of SMP bond-buying to

the past six months

Figure 1. SMP weekly bond-buying amounts Figure 2. SMP total outstanding amount

0

5

10

15

20

25

10-May 02-Aug 25-Oct 17-Jan 11-Apr 04-Jul 26-Sep

, bn

Weekly SMP amounts

0

20

40

60

80

100

120

140

160

180

10-May 02-Aug 25-Oct 17-Jan 11-Apr 04-Jul 26-Sep

, bn

Total amount purchases

Source: ECB and Nomura Global Economics Source: ECB and Nomura Global Economics


8/11


and thereby allow the ECB to step up its support.

An ECB pre-commitment to a future SMP appears unlikely

Indeed, this desire on the part of the ECB to make bond purchases conditional means

that the likelihood of the Bank announcing and pre-committing to a large bond purchase

programme is, in our view, very low. The ECB would not want its flexibility curtailed in this

manner. The new ECB President, Mario Draghi, understands that unconditional help to

Italy given its politics would be the worst possible outcome in terms of moral hazard,

and this is a concept which continues to frame ECB thinking about the financial crisis farmore than it has guided the US Feds policy response.

As for the longevity of the SMP programme, we think this is contingent on external

factors such as whether the EU can develop a plan that will address the markets

concerns about debt sustainability in the euro area. Alternatively, in an extreme scenario

whereby the euro-area crisis results in a deep and lasting recession in Europe and

generates a significant degree of deflation risk, then the potential for the SMP to expand

significantly would grow if, as is possible under this scenario, interest rates approach

their zero bound. But on this score the path to the current SMP might not be so clear

since in order to engineer inflation in the euro area through QE, one would optimally

require the ECB to buy government bonds across the euro area, not just periphery bonds.

So this would involve buying German bunds in very significant amounts.

Conclusion one market risk removed, many remaining

In summary, assuming that the EU does not deliver a policy response that directly

addresses the issue of the SMP by generating a shock-and-awe policy that obviates

the need for ECB buying, or if it sanctions a policy of indemnifying the ECB against credit

losses on its bond purchases then we assume that, even after EFSF 2.0 becomes

effective, the SMP will be maintained.

While the scale of bond purchases should be sensitive to prevailing market conditions,

the general goal of the SMP will remain to provide the minimum level of market support

needed to maintain market access for countries deemed to have a liquidity rather than a

solvency problem. This outcome would be a positive one for the market in that, if we areright, it would address a key area of market risk, namely the question as to what happens

to the euro-area debt market once the EFSF 2.0 becomes operational.

However, as has been seen throughout the life of the SMP, the scale of the programme

will likely remain insufficient to comprise a solution to the debt crisis and risks continuing

to be a mechanism that allows the market to scale back its DV01 exposure to non-core

Europe, without many of these funds being reinvested outside of core bond markets.

Bond-buying continues to

be conditional on Italy

delivering austerity

ECB bond-buying should

continue even after EFSF

2.0 becomes operational


9/11


ANALYST CERTIFICATIONS

We Jens Sondergaard and Desmond Supple, hereby certify (1) that the views expressed in this report accurately reflect our personalviews about any or all of the subject securities or issuers referred to in this report, (2) no part of our compensation was, is or will bedirectly or indirectly related to the specific recommendations or views expressed in this report and (3) no part of our compensation is tiedto any specific investment banking transactions performed by Nomura Securities International, Inc., Nomura International plc or anyother Nomura Group company.

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ESFS 3.0 - Evropský fond finanční stability (EFSF, dokument v AJ)

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